LDCRS FLOW FROM DOUBLE-LINED LANDFILLS
                 AND
        SURFACE IMPOUNDMENTS
                   by

    Rudolph Bonaparte and Beth A. Gross
          GeoSyntec Consultants
          Atlanta, Georgia 30342
         Contract No. 68-CO-0068
              Project Officer

           Mr. Robert E. Landreth
    Risk Reduction Engineering Laboratory
          Cincinnati, Ohio 45268
 RISK REDUCTION ENGINEERING LABORATORY
  OFFICE OF RESEARCH AND DEVELOPMENT
 U.S. ENVIRONMENTAL PROTECTION AGENCY
         CINCINNATI, OHIO 45268

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'*",
4
                                                 DISCLAIMER
               The information in this document has been funded by the U.S. Environmental Protection Agency
          (EPA) under Contract No. 68-CO-0068, Work Assignment No. 35 to Eastern Research Group, Inc. It
          has been subjected to the Agency's peer and  administrative reviews, and it has been approved for
          publication as an EPA document.  Mention of trade names or commercial products does not constitute
          endorsement or recommendation for use.

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                                         FOREWORD
     Today's rapidly developing and changing technologies and industrial products and practices
frequently carry with them the increased generation of materials that, if improperly dealt with, can
threaten both public health and the environment.  The U.S. Environmental Protection  Agency is
charged by Congress with protecting the Nation's land, air, and water resource.  Under a mandate of
national environmental laws, the agency strives to formulate and implement actions  leading to a
compatible balance between human activities and the ability of natural systems to support and nurture
life.  These laws direct the EPA to perform research to define our environmental  problems, measure
the impacts, and search for solutions.                                                 :

     The Risk  Reduction  Engineering  Laboratory  is responsible for planning,  implementing,  and
managing research, development, and demonstration programs to provide an authoritative,!defensible
engineering basis in support of the  policies, programs, and regulations of the EPA with  irespect to
drinking water, wastewater, pesticides, toxic substances, solid and hazardous wastes, and Superf und-
related activities.

     This report provides the field data to support the Agency's recent final rule on liner leak detection
(40 CFR 260, 264, 265, 270, and 271). The data illustrates that waste management facilities can be
constructed with minimal leakage rates provided that quality control and quality assurance programs
are used.
                                                   E. Timothy Oppelt, Director
                                                   Risk Reduction Engineering Laboratory
                                             in

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                                        ABSTRACT

     This report presents field data on the measured flows of liquid from the leakage detection,
collection, and removal systems (LDCRSs) of 28 double-lined landfill facilities and eight double-lined
surface impoundment facilities.  For each facility, information on design and operation is presented,
as is an evaluation of the sources of the measured flow. Potential sources include leakage through the
top liner, precipitation that percolates into the LDCRS during construction, water that infiltrates through
the bottom liner and enters the LDCRS, and consolidation of any clay component of the top liner.  From
the evaluation, conclusions are drawn regarding the frequency of occurrence, sources, and rates of
liquid flows from the LDCRSs of double-liner systems. Conclusions are as follows:

     •   LDCRSs frequently exhibit flows from one or several of the aforementioned sources;
     «   all of the landfill cells constructed with geomembrane top liners appear to have exhibited top
         liner leakage; cells with composite top liners typically exhibited LDCRS flows attributable to
         consolidation water, except for composite liners constructed with geosynthetic-clay liners
         (GCLs) for which there  is little, if any, consolidation water;
     «>   about 60  percent of the surface impoundment ponds constructed with geomembrane top
         liners appear to have exhibited top liner leakage; the lower incidence of top liner leakage for
         ponds than for landfill cells may be attributed to the use of ponding tests and/or leak location
         surveys during construction of the ponds to identify geomembrane defects and allow their
         repair;
     •   flow rates from the LDCRSs of the landfills are generally within the range that would be
         expected, based on currently available methods of analysis for liner system performance;
         flow rates from the LDCRSs of ponds constructed  with geomembrane top liners are lower
         than would be calculated using available analysis methods because the use of ponding tests
         and leak location surveys, followed by geomembrane repair, resulted in fewer geomembrane
         liner defects than assumed in the analysis methods; and
     •   facilities constructed with a rigorous construction quality assurance program typically meet
         EPA recommended action  leakage rates (ALRs) of 1,000 Iphd (100 gpad) for landfills and
         10,000 Iphd (1,000 gpad) for  ponds; however,  flow rates  higher .than these ALRs
         occasionally occur at landfills with composite top liners and ponds that have geomembrane
         top liner defects.
     This report was submitted in fulfillment of Contract No. 68-CO-0068, Work Assignment No. 35,
by GeoSyntec Consultants under the sponsorship of EPA. The report covers work completed through
September 1992.
                                            IV

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                                     CONTENTS
DISCLAIMER	ii
FOREWORD	,. .	Hi
ABSTRACT	iv
FIGURES	vii
TABLES	viii
ACKNOWLEDGEMENTS  	\	ix
1.       INTRODUCTION	1
        1.1    Purpose of the Report	1
        1.2    Organization of the Report	2
        1.3    Definitions	2
               1.3.1     Landfills and Surface Impoundments	 2
               1.3.2     Liner, Lining System, and Double-Liner System	'. .  . 3
               1.3.3     Double-Liner System Components	3

2.       CONCLUSIONS	7

3.       RECOMMENDATIONS	  . 9
        3.1    Introduction	9
        3.2    Available Data	 .	9
        3.3    Data Evaluation	  10

4.       POTENTIAL SOURCES OF LIQUIDS IN LDCRSs  	11
        4.1    Introduction	11
        4.2    Top Liner Leakage	11
        4.3    Construction Water   	14
        4.4    Compression Water   	;	15
        4.5    Consolidation Water	16
        4.6    Infiltration Water	'	18

5.       DATA FROM LDCRSs OF OPERATING UNITS	19
        5.1    Data Collection Methodology	19
        5.2    Description of Operating Units	•	19
        5.3    Measurement of Flow from LDCRSs	41

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                                  CONTENTS (continued)


6.       RESULTS AND DISCUSSION	  43
         6.1     Methodology for Evaluating Measured Flow	  43
         6.2     Review of Data	-.	  44
                6.2.1    Group I Facilities	 . .	  44
                6.2.2    Group II Facilities	  47
                6.2.3    Group III Facilities		  .  49
                6.2.4    Group IV Facilities	  51
         6.3     Interpretation of Data	  53
                6.3.1    Group I and Group II Landfills	  53
                6.3.2    Group III and Group IV Landfills	  55

REFERENCES	  57

APPENDIX A  REGULATORY BACKGROUND		  59
                                           VI

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                                         FIGURES

Number                                                                     Page
  1      Typical double-liner systems for leachate containment in landfills	4
  2      Definitions and terminology for double-liner system components  	6
  3      Potential sources of flow from LDCRSs	12
                                           VII

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                                         TABLES
Number                                                                     Page
  1      Calculated top liner leakage rates due to leakage through holes
         in a geomembrane  	;	  13
  2      General information on double-lined landfills	  20
  3      Details of landfill double-liner systems	  23
  4      Measured flow rates from the LDCRSs of the double-lined landfills  	  26
  5      General information on double-lined surface impoundments  	'. .  . . .  34
  6      Details of surface impoundment double-liner systems  	  35
  7      Measured flow rates from the LDCRSs of the double-lined surface
         impoundments	  36
  8      Characterization of 93 individually monitored cells and ponds	  40
  9      Number of facilities in each group	 .  40
 10      Comparison of measured flow rates at Group I and II landfills	  54
 11      Comparison of measured flow rates at Group III and IV landfills  	  56
                                           VIII

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                                   ACKNOWLEDGEMENTS
         This report was  prepared under the  guidance  of the EPA,  Office  of Research and
Development.  The  EPA Task Manager overseeing preparation of the report was Mr. Robert E.
Landreth.  An earlier version of this report was prepared for the EPA Office of Solid Waste; EPA Task
Managers for the earlier report were Messrs. Alessi D. Otte and William Kline.  The support and
contributions of Messrs. Landreth, Otte, and Kline to this work are appreciated. The authors would
also like to thank Dr. J.P. Giroud of GeoSyntec Consultants for his review of the report,  i
                                            IX

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                                         SECTION 1

                                       INTRODUCTION

 1.1      PURPOSE OF THE REPORT

         Liquid flows have been observed from the leakage detection, collection, and removal systems
 (LDCRSs) of many double-lined landfill and surface impoundment units.  Regulatory authorities and
 others have sometimes assumed that these flows are due solely to leakage through the top liner and
 are, therefore, a cause for concern and action.  The flows, however, can be due to sources other than
 top liner leakage.

         The purpose of this report is to summarize and evaluate field data on the measured flows of
 liquid from the LDCRSs of 28 double-lined  landfills and eight double-lined surface impoundments.  The
 report was originally prepared to provide technical support for EPA's proposed Liner/Leak Detection
 System Rule of 29 May 1987.  In this proposed rule, EPA introduced the concept  of action leakage
 rate (ALR) which was defined as (52 FR 20222) "the rate of leakage from the top liner into the LDCRS
 that triggers interaction between the owner or operator and the Agency to determine the appropriate
 response action for the leakage".  Under the proposed  rule, the facility owner or operator could
 establish an ALR as a value specified by EPA or by developing a site-specific  ALR. The ALR value
 specified by EPA was proposed to be in the range of 5 to 20 gallons/acre/day (gpad). This report was
 initiated to provide technical support to EPA for selection of a specific ALR value.  Interim results of
 the investigation of LDCRS flow rates were presented by Bonaparte and Gross [1990]. In their paper,
 Bonaparte and Gross conclude that while an ALR of 50 Iphd (5 gpad) is too restrictive, an ALR of 200
 Iphd (20 gpad) appears to be reasonable for facilities constructed to present standards with rigorous
 construction quality assurance.  (NOTE:  For simplicity, in this report it is assumed that 1 gpad = 10
 Iphd.  More precisely, however, 1 gpad = 9.3 Iphd.)

         The proposed Liner/Leak  Detection System Rule was finalized on 29 January 1992 (57 FR
 3462). The original ALR concept was not included in the final rule, and the ALR was redefined as (57
 FR 3462) "the maximum design leakage rate that the leak detection system can remove without the
fluid head on the bottom liner exceeding  one foot".  The value  of the ALR in the  final rule is site-
specific.  Additionally, as"stated in  the preamble to the final rule (57 FR 3474),  "the Agency believes
that units meeting the minimum technical requirements would not require action leakage rates below
 100 gpad for landfills and waste piles and  1000 gpad for surface impoundments". These flow rates,

                                             1

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which are referred to as EPA's "recommended action leakage rates" in the preamble to final rule, are
significantly higher (i.e., approximately one to two orders of magnitude higher) than the ALR values
considered under EPA's proposed rule of 29 May 1987.  As will be shown in this report, the facilities
considered in this report typically exhibited LDCRS flows less than the ALR values in the final rule.

1.2      ORGANIZATION OF THE REPORT                                           \      '    •

         The organization of this report is as follows:

         •      conclusions on the analysis and interpretation of the LDCRS flow  rate data are
                presented in Section 2;                                             '

         •      recommendations for future research related to the information presented herein are
                presented in Section 3;                                             '

         •      potential sources of liquid flows from LDCRSs are described in Section 4;

         •      data on  measured flows from  the LDCRSs  of double-lined  landfills and surface
                impoundments are  presented in  Section 5; and

         •      analysis and interpretation of the LDCRS flow rate data is presented in Section 6.
                                                                                  I
         The regulatory developments that led to the final ALR concept are presented in Appendix A
of this report.

1.3      DEFINITIONS                                                             '

1.3.1    Landfills and Surface Impoundments                                        \

         Landfills and surface impoundments are land-based units that contain solid wastes, and liquid
wastes or sludges, respectively.  The goal of the lining  system in these units is to minimize, to the
extent achievable, the migration of hazardous constituents out of the units.              >

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 1.3.2    Liner, Lining System, and Double-Liner System

         A liner is a low-permeability barrier used to impede liquid or gas flow.  As discussed in Giroud
 [1984]  and EPA [1987], no currently available  liner is  totally  impermeable.   Since no liner  is
 impermeable, liquid containment within a landfill or surface impoundment unit can only result from a
 combination of liners and drainage layers performing complementary functions.  Liners impede the flow
 of liquid out of the unit.  Drainage layers collect and convey the liquid towards controlled collection
 points (sumps) where the liquid can be removed from the unit. Combinations of liners and drainage
 layers in the units are called lining systems.

         A double-liner system is a lining system which includes two liners with a leakage detection,
 collection,  and removal system (LDCRS) between  the liners. For landfills, a leachate  collection and
 removal system  (LCRS) is placed above the top liner. For surface impoundments, there is no need or
 regulatory requirement for a LCRS above the top  liner. The majority of double-liner systems being
 constructed today have either geomembrane or composite top and  bottom liners (where a composite
 liner consists of a geomembrane placed directly on  top of a low-permeability soil layer or geosynthetic
 clay liner (GCL))  with a LDCRS between the two liners. Older lining  systems constructed with low-
 permeability soil  liners alone are not considered in  this report.

 1.3.3    Double-Liner System Components

         Figure  1 illustrates typical double-liner systems used to contain leachate in landfills.  Double-
 liner systems used to contain liquid in surface impoundments are similar to those shown in Figure 1,
 except that surface impoundments do not require an LCRS drainage layer above the top liner. (Waste
 piles are a third type of land-based containment unit and are similar to landfills except that they only
 contain  solid wastes temporarily. Waste piles are mentioned briefly in this report for completeness
 since they are  subject to most of the same regulations as landfills.) The  double-liner systems shown
 in Figure 1 incorporate the liner types (i.e., geomembrane liners and composite liners) and the drainage
 materials types (i.e., granular materials, geonets, or other geosynthetics) used to construct landfills,
 waste piles, and surface impoundments. The types  of liners and drainage materials  used in double-liner
 systems significantly influence the frequencies of occurrence, sources, and rates of flow from LDCRSs.
Therefore, different liner and drainage material types will be considered in this report.

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                  SAND LCRS
                DRAINAGE LAYER.
       SAND LDCRS
     DRAINAGE LAYER
PROTECTIVE
COVER SOIL
                                    GEOMEMBRANE
                                      TOP LINER
                                      COMPOSITE
                                       BOTTOM
                                      '  LINER
 GEONET LCRS
DRAINAGE LAYER
                                     COMPOSITE
                                      TOP LINER
                                     COMPOSITE
                                       BOTTOM
                                        LINER
                            GEONET LDCRS
                            DRAINAGE LAYER
Figure 1.  Typical double-liner systems for  leachate containment in landfills.

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 f
                     In this report, the parameters used to describe the design features of double-liner systems
            are (Figure 2):  i = slope gradient (dimensionless); kdt = hydraulic conductivity of the LCRS drainage
            material  (cm/s); Tdt  = thickness of the LCRS drainage  material (m  (ft)); Tflt =  thickness  of the
            geomembrane component of the top liner (mm (mil)); kst =  hydraulic conductivity of the compacted
            low-permeability soil or geosynthetic clay liner (GCL) component of the top liner {cm/s); T3t = thickness
            of the compacted low-permeability soil or GCL component  of the top  liner (m (ft)); k,, = hydraulic
            conductivity of the LDCRS drainage material (cm/s); Tdb = thickness of the LDCRS  drainage material
            (m (ft));  TBb = thickness of the geomembrane component of the bottom liner (mm  (mil));  k.b =
            hydraulic conductivity of the compacted low-permeability soil component of the bottom liner (cm/s);
            and Tsb = thickness of the compacted  low-permeability soil  component of the bottom liner (m (ft)).

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                                                           LCRS DRAINAGE LAYER
                                                           TOP LINER
                                                           LDCRS DRAINAGE LAYER
                                                           BOTTOM LINER
Figure 2.  Definitions  and  terminology  for double-liner system components,
           (Note: k = hydraulic  conductivity;  T = thickness; and    ;
           ± = slope gradient.)                                _     !

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                                        SECTION 2

                                      CONCLUSIONS

         Using the data for landfills and surface impoundments presented in Section 5 of this report,
and the data analysis and interpretation presented in Section 6, the following conclusions are drawn
with respect to LDCRS flows from double-lined waste containment facilities.

         •      LDCRSs frequently exhibit flows that may be due to top liner leakage or other
                sources  such as construction water,  consolidation water, and  infiltration water.
                LDCRS flow  rate data presented in  Tables  4 and 7,  for  landfills and surface
                impoundments, respectively, demonstrate the frequencies of  occurrence and rates
                of flow from these sources.

         •      All  of the landfill cells  reviewed  in  this  report  that were  constructed  with
                geomembrane top liners appear to have exhibited top liner leakage.  Based on the
                available data, the average and maximum flow rates attributable to top liner leakage
                at active cells that had geomembrane top liners and construction quality assurance
                (CQA) programs were less than 1,000 Iphd (100 gpad).  Typically, flow rates from
                these units were less than 200 Iphd (20 gpad).  For cells without  CQA  programs,
                both average and maximum flow rates attributable to top liner leakage were
                frequently  more than 1,000 Iphd (100 gpad).  Maximum flow rates, which often
                occurred shortly after storm events, were typically several times greater than the
                average flow rates.

         •       Only about 60 percent of the surface impoundment ponds  reviewed in this report
                that were constructed with geomembrane top liners appear to have exhibited  top
                liner leakage.  In general, the measured flows from the ponds were less than 300
                Iphd (30 gpad).  The lower incidence of top liner leakage for ponds than for landfill
                cells  may be attributed to the use of  ponding tests and/or leak location surveys
                during construction of the ponds to identify geomembrane defects and allow their
                repair. Additionally, when flows were observed during operation of a pond, defects
                were often located and repaired. Thus, significant LDCRS flows  from ponds were
                often of limited duration (i.e., until the pond was repaired).

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 Facilities having a composite top liner incorporating a layer of clay almost always
 exhibited LDCRS flows due to consolidation water.  Flows attributable to primary
 consolidation of the clay occurred while the facilities were active.  Continuing flows
 after facility closure are potentially attributable to water expelled  during secondary
 compression of the clay layer (secondary compression water). Average measured
 flow rates attributable to consolidation water ranged up to 1,300 Iphd (130 gpad),
 although most rates were less than 300 Iphd  (30 gpad);  average measured flow
 rates potentially attributable to secondary compression water ranged from 30 to 380
 Iphd (3 to 38 gpad).

 Leakage  rate calculations performed  using the method of Giroud and Bonaparte
 [1989a,b] provide a reasonable upper bound on observed flow rates attributable to
 top liner leakage at  landfills with .geomembrane top liners.  However, ;the method
 greatly overpredicts top liner leakage rates at impoundments with geomembrarie top
 liners.  It appears that the primary reason for the overprediction is that |the number
 and/or frequency of geomembrane holes assumed by Giroud and Bonaparte are too
 high for the considered surface impoundments  and period of monitoring. Based on
 the data in this report, the use of ponding tests and leak location surveys, followed
 by geomembrane repair, reduces the frequency and/or size of geomembrane holes
 below the number often assumed for leakage rate calculations  (i.e., :3 to 5 per
 hectare  (1 to 2 per acre)).

 The  calculation  methods  presented  by  Gross  et  al.  [1990]  for! estimating
 consolidation water  and construction water flow rates appear to give, reasonable
 order-of-magnitude estimates of flows attributable to these sources.

 Based on an analysis of the data presented in Tables 4 and 7, facilities with double-
 liner systems constructed with a rigorous CQA program will typically meet the EPA
 recommended action leakage rates of 1,000 Iphd (100 gpad) for landfills and 10,000
                                                                  I
 Iphd (1,000 gpad) for surface impoundments. For landfills with composite top liners,
' flows due to consolidation water may occasionally be greater than 1,000 Iphd (100
 gpad).  For surface impoundments that have defects in the geomembrane top liner,
 flow rates may temporarily be higher than 10,000 Iphd (1,000 gpad).; However,
 repair of the defects will usually decrease flows to below triggering levels (i.e., less
 than 10,000 Iphd (1,000 gpad)).                                    '
                              8

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                                         SECTION 3
                                    RECOMMENDATIONS
3.1      INTRODUCTION

         The information contained in this report is intended to provide a preliminary understanding
of how landfill and surface impoundments are performing with respect to liquid containment and
environmental protection. To increase this understanding, it is recommended that additional studies
be undertaken. The purpose of this section of the report is to present recommendations for future
studies to  expand the information  contained  in this report.  In developing the  recommendations,
emphasis is placed on those studies appearing to have the best potential to provide useful results and
that can be performed with data currently accessible  to EPA.

3.2      AVAILABLE DATA

         As a  starting  point for the  additional studies,  data  should  be  obtained from the waste
management  units described in  this report and other units that have designs meeting,  or at least
reasonably consistent with,  existing EPA regulations. Information should be collected directly from the
owners/operators of the units, as well as from EPA files.  The  data that should be gathered for each
unit include:

         •      type of unit and design details, geographic location,  hydrogeologic setting, waste
                characteristics, key  dates  in the life of the unit (e.g.,  construction, operation,
                closure), and operations and maintenance information;

         •      LCRS monitoring data (liquid quantity and chemical quality);

         •      LDCRS monitoring data (liquid quantity and chemical quality);

         •      unsaturated zone monitoring data  (liquid quantity and chemical quality),  if it exists;

         •      ground-water quality monitoring data;

         •       rainfall monitoring data; and

         •       results of any special evaluations or testing, such as geomembrane coupon testing.

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3.3      DATA EVALUATION

         The available data for landfills, waste piles, and surface impoundments should be collected,
analyzed, interpreted and cataloged. The cataloging effort should be designed to create a permanent
data base, available for interested parties, that can be periodically updated in the future. The analyses
and interpretation of the data should be intended to systematically address the  following questions.

         •      What quantity and chemical quality of leachate is generated in the units, both during
                and after closure?                                                 i

         •      How does the quantity and chemical quality of leachate vary geographically?

         •      What impact is EPA's land disposal restrictions (i.e., 40 CFR 268) having on leachate
                quantity and chemical quality?                                      :

         •      What is the quantity and chemical quality of the liquid flows from the LDCRSs of the
                units?
                                               I                                  i
         •      What are the sources of the liquid flows from the LDCRSs?            '•

         •      What conclusions can be drawn from the available LDCRS data on the performance
                of top liners and, by extrapolation, on the performance of the entire liner system?

         •      What is the risk of the  liquid flows from  the  LDCRS on human health and the
                environment?

         •       Is there any indication from the available data that the LCRSs or LDCRSs are clogged
                or otherwise not functioning adequately?

         •       Is there any indication that units with one type of LCRS or LDCRS rdesign are
                performing better than units with  a different type of design?

         •       Does available ground-water quality monitoring data or other  available imonitoring
                data (such as unsaturated zone monitoring data) provide any indication!of leakage
               from a unit?                                                       :
                                           .10

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                                        SECTION 4
                         POTENTIAL SOURCES OF LIQUIDS IN LDCRSs

 4.1      INTRODUCTION

         To evaluate LDCRS flow data, the potential sources of flow must first be identified. Flow
 can  be due to top liner leakage,  water from  precipitation or other sources that percolates into the
 LDCRS during construction ("construction water"), water expelled from a granular LDCRS  due  to
 compression of the LDCRS ("compression water"), water squeezed out of the clay component of a
 composite top liner as a result of clay consolidation ("consolidation water"), and water that infiltrates
 the bottom liner and enters the  LDCRS  ("infiltration water") [Gross et al., 1990].   Each of these
 potential sources of flow  is depicted in Figure 3 and is described below.

 4.2      TOP LINER LEAKAGE

         All of the top liners considered in this report include geomembranes (i.e., they are either
 geomembrane liners or composite liners). Leakage through liners constructed with  geomembranes
 occurs essentially as a result of flow through defects in the geomembrane.  Occasional small defects
 in geomembranes may result from manufacturing, but are more likely to result from during or after
 geomembrane installation. Equations to calculate steady-state leakage rates through liners constructed
 with geomembranes due to flow through holes were developed in EPA [1987], based on the analytical
 and experimental studies by Faure [1979,  1984], Sherard [1985], Fukuoka [1985, 1986], and  Brown
 et al. [1987].  The equations were later modified by Bonaparte et al. [1989], Giroud and Bonaparte
 [1989a,b],  and Giroud et al. [1989; 1992].  Based  on  these equations, the rate of flow through
 geomembrane holes is dependent on the liquid head on the geomembrane, the hydraulic conductivities
 of the soil layers immediately underlying and overlying the geomembrane, the size and frequency of
 occurrence of holes in the  geomembrane, and, for composite liners, the quality of the contact between
 the geomembrane and underlying  soil layer (which is a function of the quality of construction).

         Table 1 presents the results of calculations using the equations for flow through holes in a
 geomembrane to obtain top liner leakage rates  per unit  area  of liner.  For  the calculations, it was
 assumed that the soil layer underlying the  geomembrane is 0.9 m (3 ft) thick, and the GCL underlying
the geomembrane  is 6 mm (0.25 in.)  thick.  It was further assumed  that the geomembrane was
carefully constructed and had only five small holes per hectare  (2 small holes per acre), with each hole
having an area of 3 x 10~6 m2 (5 x 10~3 in2), and that  good quality contact existed between the
geomembrane and  underlying soil layer or GCL (assumptions consistent with those of Giroud and
Bonaparte [1989a,b]).
                                            11

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    GROUND-WATER TABLE
 Q =  TOTAL FLOW
 Q =  AtB+C+D
 POTENTIAL SOURCE:
 A =  TOP LINER LEAKAGE
 B =  CONSTRUCTION WATER AND COMPRESSION WATER
 C =  CONSOLIDATION WATER
 D =  INFILTRATION WATER
Figure 3.  Potential sources  of  flow from LDCRSs (from Bonaparte arid
           Gross  [1990]).                                           ;
                                    12

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Table 1.      Calculated top liner leakage rates due to leakage through holes in a geomembrane (qT,
             Iphd). (Values obtained using equations from Bonaparte et al. [1989] and Giroud et al.
             [1992],  and the following input parameters:  N = number of geomembrane holes per
             unit area = 5 holes/hectare (2 holes/acre); a =  area of geomembrane hole  = 3 x 10"6
             m2 (5 x 10'3 in2}; kmin = minimum of kdb or kat; and ht =  liquid head on liner.  Good
             o.uality  contact  exists between the geomembrane  and underlying  soil  layer  or
             geosynthetic clay liner (GCL). The thickness of the soil layer is 0.9 m (3 ft), and the
             thickness of the GCL is 6 mm (0.25 in.).)


Conductivity
kmln (cm/s)
io-9
10-8
10'7
10'6
1 0'5
10'4
io-3
TO'2
io-1
1
Liquid Head on Liner, ht (m (ft))

0.03 (0.1)
Soil Layer
-
0.05
0.3
1
8
40
200
400
600
600
GCL
0.01
0.06
-
-
-
-
-
-
-
-
0.3 (1)
Soil Layer
-
0.4
2
10
60
300
1000
1500
2000
2000
GCL
0.2
1
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6300
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                                            13

-------
          From inspection of Table 1, it can be seen that calculated steady-state top liner leakage rates
through composite liners (based on a hydraulic conductivity (kmln) of the clay or GCL component of the
composite liner of 10~7 cm/s or less) range from 0,01 to 90 Iphd (0.001 to 9 gpad). In contrast,
calculated leakage  rates through  geomembrane liners  underlain by drainage materials (with the
hydraulic conductivity of the  drainage material kmin  >  10"2 cm/s)  range from 400 to 6,300 Iphd (40
to 630 gpad).  The calculated leakage rates for geomembrane top liners are about two to five orders
of magnitude greater than those calculated for composite top liners.  A further contrast between
composite liners and geomembrane liners lies in the fact that it can take from several months to many
years for liquid to flow  through the clay component of a composite liner or several daysj to  several
years for liquid to flow through the GCL component of a composite liner, whereas flow through a hole
in a geomembrane liner underlain by a drainage  material occurs almost instantaneously.  It can  also be
observed from Table 1  that  composite  liners  incorporating GCLs are  most effective  at minimizing
leakage when subjected to liquid heads of 0.3  m (1 ft) or less, which are typical for landfills. When
subjected to higher liquid heads, such as those that occur in surface impoundments (e.g., 3 ;m (10 ft)),
the effectiveness of composite liners incorporating GCLs decreases somewhat due to the high hydraulic
gradient across the GCL [Giroud et al., 1992].

4.3       CONSTRUCTION  WATER

         The primary source of construction water in a LDCRS is precipitation that percolates into the
LDCRS prior to placement  of the top liner.  Of this water, some may be retained in the drainage
material by capillary tension, and the rest will flow by gravity from the LDCRS.

         The maximum time required for gravity drainage of construction water from a LDCRS can be
estimated using Darcy's equation, as follows:
                                                      )                         (Equation 1)

where: tc = maximum  time for gravity drainage of construction water (s); Lf = maximum  length of
flow path  (m (ft)); i =  slope gradient (dimensionless); and ndb = porosity of the LDCRS drainage
material (dimensionless).

         The maximum volumetric moisture content of a drainage material due to capillarity Is referred
to as its specific retention,  sr.  The specific retention of a drainage material is dependent on the size
distribution and shape of the material's pores. The specific retention of a geonet drainage layer is zero;
the specific retention of a  coarse gravel is almost  zero.  A medium to coarse sand hasja specific
retention on the order of 0.08 [Linsley et al., 1975].  If the volumetric moisture content, !wv, of the
                                             14

-------
 LDCRS drainage material at the end of construction is less than its specific retention (i.e., if wv < sr),
 there will be no drainage of construction water. If, however, the volumetric moisture content of the
 material at the end of construction is greater than its specific retention (i.e., if wr > sr), water will drain
 from the layer until the volumetric moisture content equals the specific retention (i.e., wr = sr).

          The volume of water per unit area of liner that drains from the LDCRS by gravity  can be
 estimated using the following equation:
                               vc = Tdb (wv - sr) = Tdb (S ndb - s,)                  (Equation 2)

 where: vc = volume  of construction water per unit area of liner that drains from the LDCRS  by  gravity
 (m (ft)); wv = volumetric moisture content of drainage material at end of construction {dimensionless);
 sr = specific retention of drainage material (dimensionless); and S  = degree of saturation of drainage
 material at end of construction (dimensionless)'.

         The average LDCRS flow rate per unit area of  liner, qc  (Iphd (gpad)), due to construction
 water  is given by:
                                          Qc = vc I tc                             (Equation 3)
         Gross et al. [1990] presented the results of calculations to quantify potential construction
water flow rates and durations for a typical landfill cell. The results indicate that the flow rate is
directly proportional to kdb and the duration of flow is inversely proportional to kdb. Thus, with a high-
permeability drainage material, such as a clean gravel or geonet (e.g., kdb > 1 cm/s), the flow rate after
a precipitation event can be large (e.g., 200,000 Iphd (20,000 gpad)) but of very short duration (e.g.,
less than one day).  In contrast, with a lower-permeability drainage material, such as a fine to medium
sand (e.g., kdb =  10~2 cm/s), the rate of flow of construction water will be smaller (e.g., 2,000 Iphd
(200 gpad)), but the duration of flow will be quite long (e.g., more than 100 days). In the latter case,
construction water  may still be draining from a facility well after the start of operation.

4.4      COMPRESSION WATER

         As a LDCRS constructed of a granular material compresses under the weight of the overlying
waste or impounded liquid, the pore volume and porosity of the LDCRS decrease. Simultaneously, the
capillary tension of  water in the pores of the material increases as the soil particles take on a denser
packing.
                                              15

-------
          When a granular LDCRS material retaining water by capillary tension compresses, the volume
                                                                                    !
 of water per unit area of liner that drains from the LDCRS can  be calculated using the following
 equation:

                                 v£ = ev s, Tdb = (Aav I Ec)sr Tdb                    (Equation 4)
 where: VE = volume of water per unit area of liner that drains from the LDCRS by gravity (m (ft));
 ev =  compressive strain of the  LDCRS drainage  material  (dimensionless); Acrv = change1 in vertical
 stress due to placement of waste (kPa (psf)); and E0 = constrained modulus of the drainage material
 (kPa  (psf)).   Equation 4 was derived using the conservative assumption that there  is no increase in
                                                                                    f
 specific retention of the granular material as it compresses under the weight of the  overlying waste.
 Equation 4 can only be  used if the volumetric water content of the material is greater than or equal to
 its specific retention (i.e., wv >: sr).  If the volumetric water content of the material is less than the
 material's specific retention (i.e., wv < sr). Equation 4 is not valid since liquid may not be released as
 a result of compression.

         Calculations in Gross et al. [1990] indicate that the flow rate of compression water from a
                                                                                    i
 granular drainage material initially at its specific retention is small  (e.g., 1 to 20 Iphd (0.1 to 2 gpad))
 and is frequently negligible in comparison to potential flow rates from other sources.     ;

 4.5      CONSOLIDATION WATER                                                  !    .

         Two general categories of low-permeability soil layers must be considered: (i) relatively thick
 (0.5 to 1.5-m (1.5 to 5-ft) thick)  layers of compacted natural clay or bentonite-treated soil; and (ii) thin
 (6-mm (0.25 in.) thick) GCLs. During filling of a landfill or surface impoundment, soil layersiin the first
 category will consolidate and expel water into the adjacent LDCRS drainage layer.  GCLs, however,
 are placed in a dry state and will not contribute additional  liquid to the LDCRS.

         An upper bound of the rate at which water is expelled from a clay layer can be obtained by
assuming the clay layer is initially saturated. With this assumption, the occurrence of consolidation
                                                                                    |
water can be quantified using the classical theory of one-dimensional consolidation [Terzaghi, 1943].
This theory uses the consolidation time factor,  T, defined as:

                                            T = f£                              (Equation  5)
                                                H2
where: T  = consolidation time factor at time t (dimensionless); t = elapsed time since instantaneous
load application (s); H = length of drainage path (m (ft)); and cv = coefficient of consolidation (rn2/s

                                             16

-------
 (ft2/s)).  The theory also establishes a relationship between the consolidation time factor T and the
 degree of consolidation U.     .                                                            .

          Schiffman [1957] modified the classical theory of one-dimensional consolidation to account
 for a constant rate of load application. In his work, Schiffman established a relationship between the
 degree of consolidation  U and the consolidation time factor T.  This relationship was later used by
 Giroud [1983] to determine the maximum rate of consolidation Rmax (defined as dU/dT) for a constant
 rate of load application.  For flow rate calculations, it can be assumed that the rate of filling of a unit
 is constant between t = 0 and  t = tf,  where  t,  is the time required to fill the landfill or surface
 impoundment.  It can also be assumed that the pore water within the clay layer drains to the LDCRS
 drainage layer (i.e., the maximum length of the drainage path for pore water is equal to the thickness
 of the clay layer).

          For most landfill and many surface impoundment applications, the time factor, Tf, at the end
 of filling (obtained using Equation 5 with t = tf) is larger than one. As shown by Giroud [1983], when
 Tf >  1, almost all of the consolidation water has  been expelled  at time t = t, (i.e., at the end of waste
 placement or surface impoundment filling) and Rmax = 1 /Tf.

          Giroud [1983] has established the following equation to calculate the maximum rate of water
 expulsion from a consolidating clay layer subjected to a constant rate of load application:

                                       gs = Aff" **! /?max                          (Equation 6)
                                            Pw 9 I st
 where: qs = maximum flow rate from the LDCRS per unit area of liner due to consolidation water (m/s
 (ft/s)); Aav =  vertical stress due to the weight  of waste (kPa (psf)); pw = density of water (kg/m3
 (lb/ft3)); g = acceleration of  gravity (m/s2 (ft/s2));  and Rmax  = maximum rate of consolidation.  Equation
 6 is conservative because it assumes that the clay is initially saturated. In most cases, clay layers are
 compacted to a degree of saturation between 75 and 90 percent.

         Calculations presented in Gross et al. [1990] suggest that the flow rate due to consolidation
 water may range from 10 to 1,500 Iphd (on the  order  of 1  to 150 gpad).  Higher flow rates are
 associated with  more compressible soils, faster rates  of load application, and larger consolidation
stresses. The calculations also indicate that, for most landfills that receive waste at a steady rate over
one or more years, the end  of primary consolidation will approximately coincide with the end of the
active life of the landfill.
                                              17

-------
         It should be noted that, as described by Bonaparte and Gross [1990], water from secondary
compression of a clay layer may persist after the end of primary consolidation. In general, soils that
exhibit relatively high consolidation, such  as  high plasticity clays, will also exhibit relatively high
secondary  compression.  As a consequence, for some plastic clay materials compacted  wet of
optimum moisture content, water due to secondary compression may be a significant souijce of liquid
flow after the end of a facility's active life. Calculated secondary compression flow rates are in the
range of 10 to 100 Iphd (on the order of 1 to 10 gpad).  These flow rates may persist over the entire
post-closure period of the facility, albeit at a progressively decreasing rate.              ;

4.6      INFILTRATION WATER

         Infiltration water can migrate through defects in the geomembrane component of ithe  bottom
liner into the LDCRS if there is a sustained ground-water table above the base of the bottom  liner or
if the bottom liner is a composite liner with a clay layer that is undergoing consolidation or secondary
compression.  The calculation results given in Table 1 can be used to estimate infiltration rates if it is
assumed that the rate of flow  through the liner is independent of the  direction of flow (i.e., up or
down).  In this case, kmln in Table 1 corresponds to the hydraulic conductivity of the soil immediately
underlying the geomembrane component of the bottom liner. From Table 1, the quantity of infiltration
through composite  bottom liners (i.e., ksb < 10"6 cm/s) constructed with clay layers will be relatively
small and will only occur after water saturates the clay layer.  In contrast, infiltration rates through
                                                                                   i
geomembrane bottom liners underlain by relatively permeable soils can be very large and will occur
quickly.
                                             18

-------
                                          SECTION 5

                          DATA FROM LDCRSs OF OPERATING UNITS

 5.1       DATA COLLECTION METHODOLOGY

          The data  presented  in this  report were  obtained  from engineering drawings,  project
 specifications, operation records, and interviews with facility owners and operators and regulatory
 agencies. With respect to flow data, in most cases only data on LDCRS flow rates were available; data
 on LCRS flow rates and on the chemical  quality of flows from the LDCRS and LCRS were typically not
 available.  Efforts were made to obtain data from operating and  closed landfills and from facilities
 constructed with different types of lining systems (e.g., geomembrane top liners versus composite top
 liners, and sand  LDCRS drainage layers versus geonet LDCRS drainage layers), constructed with and
 without third-party construction quality  assurance (CQA) programs, and located in different climatic
 regions.  For the purpose of this report,  a facility was considered to be closed if it was covered with
 a soil layer or geomembrane. Very little  data were obtained from closed facilities, and approximately
 86 percent of  the  facilities were constructed under  a third-party CQA program.   In addition,
 approximately 96 percent of the landfill  facilities are  located in relatively moist climatic regions.  All
 other things being equal, larger flow rates would be expected from the LDCRSs of operating or closed
 landfills located in relatively moist climatic regions than from operating or closed landfills, respectively,
 located in drier climatic regions, since there is less leachate production in drier climates.  Based on the
 characteristics of the data base, the measured flow rates presented in this report likely represent the
 higher end of the range of flows  that might occur from landfills constructed under third-party CQA
 programs.

 5.2      DESCRIPTION OF OPERATING UNITS

         LDCRS flow rate data have been collected from 28 double-lined landfill facilities (containing
 76 individually monitored landfill cells) and eight double-lined surface impoundment facilities (containing
 17 individually monitored ponds). The  data, along with information on each of the  facilities,  are
 presented in Tables 2 through 7.  These tables  include all of data reported by Bonaparte and Gross
 [1990], as well as additional data that the authors were able to obtain since the preparation of the
cited  reference.   Tables 2 and 3 present general information and double-liner system properties,
respectively, for  the 28 landfill facilities.  Tables 5 and 6 present the same information for the eight
surface impoundment facilities.  It should be noted that the double-liner system properties given in
Tables 3  and 6 were obtained from the previously-listed sources; they are, not measured properties.
                                             19

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          Tables 4 and 7, respectively, present the LDCRS flow rate data for the landfill and surface
 impoundment facilities.  Data are summarised for two different time periods: (i) just after the end of
 construction, when the influence of construction water on the flow rates would be greatest;  and (ii)
 during the active life of the facility. Where possible, flow rates are reported at different time intervals
 during the active life.  The authors found only limited data on flow rates after landfill closure. The data
 corresponding to closed landfill conditions are specially noted in Table 4.

          A characterization of the monitored cells  and ponds is presented in Table 8. It can be seen
 that about 40 percent of the monitored  cells and ponds have geomembrane top liners, while the
 remaining 60 percent have composite top liners. About 40 percent of the monitored cells and ponds
 have sand LDCRSs, while the remaining 60 percent have geonet LDCRSs. (Some of the facilities listed
 in Table 8 as having a geonet LDCRS may actually have a geocomposite LDCRS consisting of a geonet
 with a geotextile bonded to its top surface. However, for the purposes of this report, geocomposite
 LDCRSs are considered functionally equivalent to geonet LDCRSs.) Most of the units are located at
 sites where the ground-water table is below the unit base; however, in a few cases, the relationship
 between  the unit  base and the ground-water table is unknown.  For purposes of this report, it is
 assumed that infiltration of ground water  did not contribute to the LDCRS flows at any of the units.
 For all units,  the  bottom liner included a geomembrane; in most cases, the bottom liner  was a
 composite.  Therefore, for most facilities,  a small amount of the water expelled during consolidation
 of the  soil component  of  the  bottom  liner could infiltrate the LDCRS  through a  hole  in  the
 geomembrane component of the bottom  liner. This small amount  of water is  considered to be
 negligible for the purpose of this report.   Also, for most facilities, the collection efficiency  of  the
 LDCRSs at the monitored facilities should be very high (i.e., very little of the liquid in the LDCRS should
 have migrated into the bottom liner).

          It should be noted that only 13 of the 28 landfill facilities and three of the  eight surface
 impoundment facilities have lining systems that appear to meet the minimum design requirements of
 EPA's final rule of 29 January 1992 (described in Appendix A). The minimum design requirements of
the final rule include the following: (i) a composite bottom liner consisting of a geomembrane and a 0.9
m (3 ft) thick compacted  clay layer with a hydraulic conductivity no greater than 1  x  TO"7 cm/s; (ii) a
minimum  LDCRS bottom slope of 1  percent; (iii) for granular LDCRS drainage media, a minimum
thickness  of 30 cm (12 in.) and a minimum hydraulic conductivity of  1 x 10~2 cm/s for landfills and
1 x 1Q'1 cm/s  for surface impoundments;  and (iv) for synthetic LDCRS drainage media, a minimum
                                            39

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TableS.  Characterization of 93 individually monitored cells and ponds. [Note: Gmb = gebmembrane;
         Cmp = composite; Below = ground-water table below base of facility.]



Cells
Ponds
Cells and
Ponds
Top
Liner
Gmb
25
11
36

Cmp
51
6
57

LDCRS

Sand
32
7
39

Geonet
44
10
54

Ground-Water
Table
Below
74
15
89

Unknown
2
2
: 4

Table 9.  Number of facilities in each group.
Group
No.
I
II
III
IV
Top
Liner
Geomembrane
Geomembrane
Composite
Composite
LDCRS

Geonet
Sand
Geonet
Sand
Number of
Cells and Ponds
13 ;
23
41 ;
16
                                            40

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 hydraulic transmissivity of 3 x 10'5 m2/s for landfills and 3 x 10"4 m2/s for surface impoundments.  The
 main reason that some of the facilities do not meet the requirements of the final rule is that the
 compacted  clay component of the  bottom liner is less than 0.9 m (3 ft) thick or has a hydraulic
 conductivity greater than 1x10"7 cm/s.

         To interpret the data, it is convenient to group the monitored facilities by the type of top liner
 (i.e., geomembrane  versus composite) and type  of LDCRS (i.e., sand versus geonet).  With  this
 grouping, the potential sources of flow for cells and ponds in any group are basically the same (Table
 9).  The flow rate data are interpreted for each group of facilities in Section 6.

 5.3      MEASUREMENT OF FLOW FROM LDCRSs

         Under EPA's final rule of  29 January 1992,  owners and operators of hazardous waste
 landfills and surface  impoundments  are required to monitor the rate of flow from the LDCRS of the
 facilities on a weekly basis during the active  life of the facilities  (including the closure period)  and
 monthly or quarterly during the post-closure period. For the majority of the facilities presented in  this
 report, liquid flows from the LDCRSs of operating units were measured daily or weekly. However, the
 available data were typically weekly or monthly flow volumes, or flow  rates.

         The flow rate data for each facility are given in Table 4 for landfills and Table 7 for surface
 impoundments. Where there is sufficient data to evaluate the temporal variation in flow, both average
 and  maximum flow rates are reported.  Average flow rates are typically reported for one or more
 months. Maximum flow rates are reported as the maximum weekly or monthly flow rate over a given
 time interval, except as noted.  When possible, the maximum flow rates are  based on a maximum
 weekly flow rate. It  is preferable to  report the maximum flow rates based on a weekly time interval,
 as this is the time interval required by EPA for monitoring of LDCRS flow rates at active units.  With
 this information, conclusions can be drawn on the  .maximum LDCRS flow rates that may occur on a
 weekly basis at other land disposal units.

         The techniques for measuring LDCRS flow rates at the  landfill and  surface impoundment
facilities  presented in this  report range from the relatively simple, such as  calculating the flow
quantities based on  changes in  liquid depth in the LDCRS sump,  to  relatively complex, such as
measuring flows using tipping buckets and flumes and recording the flow data  with  automated data-
logging systems.  The different methods used to measure LDCRS flow rates  at the facilities in  the
report were as follows:
                                            41

-------
         •      estimating the volume of liquid pumped from the sump by multiplying the sump area
                by the change in the liquid depth in the sump and dividing volume of liquid by the
                time between liquid depth measurements;

         •      measuring volume indirectly by multiplying the pumping time by the pump capacity
                and dividing by the time since the last pumping event;                !

         •      estimating the  volume of liquid  removed from the LDCRS sump during a certain
                period of time by multiplying the  number of times the pump automatically activated
                by the volume of liquid that is stored in the sump between the "pump on"! and "pump
                off" levels, and dividing  the estimated  volume of liquid by the length of the
                considered time period;

         •      measuring the  flow  rate manually at a  given point in time, using a bucket and
                stopwatch {at gravity flow outlets);                                '

         •      measuring the liquid volume in the LDCRS by opening the drain lines and allowing the
                liquid to flow by gravity into a graduated container and dividing the volume of liquid
                by the time since the last measurement event (at gravity flow outlets);

         •      using flow meters equipped with mechanical accumulators or automatic data-logging
                systems and dividing  the change in flow  volume by the  time since  the last
                measurement event; and

         •      using'tipping buckets and flumes, with automatic flow data acquisition systems (at
                gravjty flow outlets).     >  ;                  :
             •  _.•".-•/>     . •   _   - • -    i    - .    ...    •   •  •.      •    . - t-
        •       '.' ,'•'••••••";•'•". ••'•'•"-.•'•'.'      '/'••'•       x:                      [
        The most common method used to measured LDCRS flow rates at the facilities presented
in this report involved using a flow meter equipped with a mechanical accumulator and dividing the
change in flow volume by the time since the last measurement event.                  :
                                            42

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                                         SECTION 6

                                 RESULTS AND DISCUSSION

 6.1       METHODOLOGY FOR EVALUATING MEASURED FLOW

          In this section  of the report, the sources of flow from the LDCRSs of operating facilities
 within each of the four groups identified in Table 9 are evaluated by comparing the measured flow
 rates for a specific time period with the calculated flow rates from different sources during the same
 time  period.  This methodology for evaluating the source of measured flow has been described by
 Gross et al. [1990] as follows.

          •      Identify the potential sources of flow based on double-liner system design, climatic
                and hydrogeologic setting, and operating history.

          •      Calculate the flow rates from each potential source.

          •      Calculate the time frame for flow from each potential source.

          •      Evaluate the potential  sources of flow by  comparing  measured flow rates  to
                calculated flow rates at specific points in time.

         Additionally, comparisons of the chemical  constituents in  liquids  contained  in  surface
impoundments or leachates from landfills  with the chemical constituents in the flows from the LDCRSs
often  provide insight into  whether a source of the flow is top liner leakage.

         The interpretation methodology described above was used to evaluate  the sources of flow
from the 93 individually monitored cells and ponds presented in Tables 2 through 7. A review of the
data on measured flow rates from the four groups of facilities  and  an interpretation of the data are
provided in the remainder of this section  of the report.
                                            43

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6.2      REVIEW OF DATA                                                       •;

6.2.1    Group I Facilities

Introduction

         Group I facilities were constructed with geomembrane top liners and geonet LDCRS drainage
layers.  There are three  landfill facilities (seven cells) and two  surface impoundment facilities (six
ponds) in this group. End  of construction  flow rate  data are available for four landfill cells and all
surface impoundment ponds. In addition, data are available for all cells and ponds duringitheir active
lives. No data for closed cells are available.

         The only potential source of flow from the LDCRSs of the Group I facilities is top liner leakage
and any small amount of construction water that drains from granular collection trenches in the LDCRS
during the early active life of the facilities.

Landfills

         For the four Group I cells for which end of construction data is available, average measured
flow rates ranged from 3 to 470 Iphd (0.3  to 47 gpad), and maximum weekly  measured flow rates
ranged from 10 to 560 Iphd (1 to 56 gpad).  These flows are primarily attributed to construction water
draining from granular collection trenches and top  liner leakage.

         All  seven  cells from  the three Group I landfills appear to have exhibited top liner leakage
during their active lives, with average flow rates ranging from 0 to 220 Iphd  (0 to  22 gpad). Maximum
weekly flow rates of 110 to 860 Iphd (11 to 86 gpad) and maximum monthly flow rates of 20 to 160
Iphd (2 to 16 gpad)  were  measured for these cells. These maximum flow rates are up to about seven
times greater than the average values. The maximum LDCRS flows typically corresponded jto high flow
rates from the LCRSs, which usually occurred shortly ( e.g., from a few days to a few weeks) after
storm events.  It should also be noted that all of the  Group I landfills are located in relatively moist
climatic regions. All other things being equal, smaller  rates of top liner leakage would be bxpected at
facilities located in dry climates where leachate production rates  are low.
                                             44

-------
 Surface Impoundments

          Of the six Group 1 ponds, only two (i.e.. Surface Impoundment E, Pond 2 and Surface
 Impoundment  F)  have exhibited flow  since the  start  of operation.  One pond  (i.e.. Surface
 Impoundment E,  Pond 2) exhibited  no flows  until a 20-mm (1-in.) long defect  developed along a
 geomembrane seam on the side slope of the pond.  Flow through the defect averaged 30,000 Iphd
 (3,000 gpad).  Flow was not observed after the defect was repaired.  The other pond (i.e.. Surface
 Impoundment F) initially  exhibited an average flow of  1,380  Iphd (138 gpad} at 0.5  months after
 construction. The flow was due, in part, to top liner  leakage.  After a geomembrane defect was
 discovered and repaired and the LDCRS was flushed with water, the flow rate decreased steadily with
 time and was very low (i.e., about  2 Iphd (0.2 gpad}) from two to eight months after the end of
 construction. Based on a chemical analysis of the LDCRS flow for a primary constituent in the pond
 liquids, the flow observed during this time can be attributed to flush water slowly draining from the
 LDCRS. At nine months, the geomembrane top liner was damaged and the average flow rate increased
 to 950 Iphd (95 gpad). The geomembrane was repaired, a ponding test was performed to locate any
 additional geomembrane defects, and the LDCRS was again flushed with water. After this repair, the
 flow rates decreased with time  and remained very low from 10 to 52 months after the end of
 construction. By several  months after the repair, the flows appeared to be just flush water based on
 chemical analysis.

         At  53 months, the maximum liquid height in Pond 2 of Impoundment E was increased to a
. higher level.  Based on the increased flow rate and on chemical analysis of constituents in the  flow,
 it was determined  that top liner leakage was again occurring. Since the observed leakage coincided
 with an increase in the maximum liquid height in the pond, it is likely the pond had a geomembrane top
 liner defect on its side slope. The liquid height in the pond was  decreased and the LDCRS was again
 flushed. Chemical characteristics of  the LDCRS liquids went back to normal (i.e., a primary chemical
 constituent in the  pond liquids was not detected in the  LDCRS liquids) within several months.  The
 LDCRS flow  rates  again decreased and remained low until 88 months after the end of construction.
 Prior to 88 months, beginning at 81 months, top liner leakage again began occurring based on testing
 of chemical constituents in the LDCRS flow. At 88  months, the average flow rate increased rapidly
 to 250 Iphd  (25 gpad), and the facility was taken out of service.  An investigation of the top liner
 indicated that the geomembrane had a number of small holes which were located primarily on the base
 of the  pond.  It was  also reported by the surface impoundment owner that the  scrim  of the
 geomembrane was exposed in a number of places and the strength properties of the geomembrane
 were significantly  less (i.e.,  50  percent or  less)  than  the  specified original  properties of the
 geomembrane.  A new geomembrane comprised of the same polymer as the old geomembrane was
                                            45

-------
installed over the old geomembrane.  The owner reported that the new geomembrane had a different
formulation than the old geomembrane, which was installed in 1983.

         One reason for the absence of top liner leakage at four of the Group I ponds and only four
occurrences of top liner leakage at  the  other two Group I ponds  is that these facilities were all
subjected to ponding tests and/or leak location surveys as part of the owners' internal or third-party
CQA program.  It was reported that geomembrane holes identified during the leak location surveys
and/or ponding tests were repaired. Additionally, geomembrane holes that developed during operation
were typically repaired.

         It is interesting to note that none of the geomembrane top liners at the Group I surface
impoundments were protected by an overlying protective soil  layer or other material.

Comparison Between Observed and Calculated Leakage Rates For Landfills and Surface Impoundments

         It is useful to compare the observed top liner leakage rates at the monitored landfills and
surface impoundments to the calculated top liner leakage rates. For the Group I landfills, the observed
flow rates are, on average, somewhat smaller than the calculated top liner leakage rate of 600 Iphd
(60 gpad) given in Table 1 for ht = 0.03 m {0.1 ft) and kmin >  1 cm/s. However, the calculated value
appears to  represent a reasonable upper bound of the observed values.  In contrast, observed flow
rates from,the Group I ponds are typically much smaller than the calculated top leakage rate of..6,300
Iphd (630 gpad) given in Table 1 for ht = 3 m (10 ft)  and kmin > 1 cm/s.

         Giroud and Bonaparte [1989a,b] presented evidence suggesting that a geomembrane hole
frequency of 3 to 5 holes per hectare (1 to 2 holes per acre) and a geomembrane hole size of 3 x 10"6
m2  (3 x 10"5 ft2)  may be assumed for  calculating   "representative"  flow rates due ito holes in
geomembranes installed using rigorous CQA programs. It is apparent from the observations of the
monitored surface impoundments that the foregoing assumptions regarding the frequency and/or size
of geomembrane holes may, in some cases, be too conservative for geomembrane installations that
include ponding tests and/or  leak location surveys as part  of a CQA program and the repair of
geomembrane holes that develop during operation. The use of these techniques reduced the frequency
and/or size of geomembrane holes in the Group I surface impoundments in this study below the values
assumed by Giroud and  Bonaparte. Their assumptions were based on analyses  of the performance of
geomembranes  that had  not been subjected  to ponding  tests,  leak  location surveys,  and/or
geomembrane repair during operation.
                                            46

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 6.2.2    Group II Facilities

 Introduction

          Group II facilities were constructed with geomembrane top liners and sand LDCRS drainage
 layers. There are seven landfill facilities (18 cells) and three surface impoundment facilities (five ponds)
 in this group, with all of the facilities located in relatively moist climatic regions. End of construction
 data are available for  16 of the landfill cells and two of the surface impoundments.  Data are also
 available for 16 of the cells and all of the ponds during their active lives, and for two closed cells.
                                      *u
          The potential sources of flow from the LDCRSs of the Group II facilities are construction
 water and top liner leakage.

 Landfills

          For the 16 Group II cells for which end of construction data are available,  the hydraulic
 conductivity of the LDCRS drainage material is in the range of 10'3 to  10'1 cm/s.  For this  range of
 hydraulic conductivity, drainage of construction water could have occurred for about one day to one
 year after  installation of the  top  liner.  AH 16  of the landfill cells show LDCRS flows  shortly after
 construction. The average measured flow rates at the end of construction ranged from 60 to 17,000
 Iphd (6 to 1,700 gpad), with seven of the cells exhibiting average flow rates of 1,000 Iphd (100 gpad)
 or more. The maximum end of construction flow rates for the cells ranged from 440 to  32,000 Iphd
 (44  to 3,200 gpad),  with  two of the cells  exhibiting maximum flow rates of more than  10,000 Iphd
 (1,000 gpad). These maximum values were up to eight times greater than the average  values.

         Excluding the four cells of Landfill J (discussed subsequently), the remaining 12 Group II cells
 for which data are available exhibited flows during their active lives which are thought to be due to
 top liner leakage. The average flow rates from the 12 cells potentially attributable to top.liner leakage
 ranged from  0 to 2,200 Iphd (0 to 220 gpad), with the  maximum flow rates being up to about five
 times larger than the average values. The maximum monthly flow rates ranged from 0.4 to 3,300 Iphd
 (0.04 to 330 gpad), and the maximum weekly flow rates ranged from 0 to 4,300 Iphd (0 to 430 gpad).
 It  is  noted that top liner leakage has clearly occurred at Cell 1 of Landfill V. A slope failure occurred
 at this facility shortly after construction. The failure was confined to the lining system on the 12-m
 (40-ft) high, 3H:1 V (horizontalrvertical) side slope.  The failure involved  the downslope sliding of the
 0.6-m (2-ft) thick sand LCRS drainage layer and underlying geotextile cushion layer on the HOPE
 geomembrane top liner. Flow from the cell had not been monitored prior to the failure.  Shortly after
the failure,  however, the flow rate from the LDCRS was found to be almost 1,500 Iphd  (150 gpad)!
                                             47

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The lining system was subsequently repaired, and the flow rate from the LDCRS decreased.  At 22
months after the end of construction, the average measured flow rate from the cell was 200 Iphd
{20 gpad).  Interestingly, the six cells at which CQA programs were not implemented (i.e;, Landfills L
and Q) had larger flow rates attributable to top liner leakage (i.e., averaging from 130 to 2,200 Iphd
(13 to 220  gpad)) than the cells at which CQA programs were implemented (i.e., averaging from 0.1
to 200 Iphd (0.01 to 20 gpad).                  ;          '                 •      '.

         As discussed by Bonaparte and Gross [1990], Landfill J is a special Group II facility because
                                                                               I
it was constructed with the compacted clay component of the bottom  liner above, rather than below
(as is usual), the geomembrane component. In addition, at Landfill J the LDCRS is continuous between
cells, thereby allowing flow to cross from one cell to the next.  A detailed analysis of LDCRS flows
from the Landfill J  cells was presented  by  Gross et al. [1990].   Their analysis indicated average
construction water  flow rates of 60 to  17,000 Iphd  (6 to 1,700 gpad) for  the cells.   Average
consolidation water  flow rates from the four Landfill J cells ranged from 6 Iphd (0.6 gpad) for Cell 3,
which was filled slowly over 18 months, to 1,700 Iphd (170 gpad) from Cell 1, which wasjfilled in one
month.  The relatively high average flow  rate of 2,700 Iphd (270 gpad) observed for Cell 3 at 30
months after construction  was due to flooding of the LDCRS in an adjacent cell for a leak location
survey. Based on an analysis of chemical  constituents in flow from the LDCRSs and LCRSs, the top
liners at two of the  four Landfill J cells (i.e., Cell 1 and Cell 4) leaked.  In the case of Cell 1, no top
liner leakage was observed until several years after closure, at which time  an average flow from the
LDCRS of 140 Iphd  (14 gpad) commenced.  In the case of Cell 4,  no top liner leakage was observed
until about  24 months after construction, when the LDCRS began experiencing an average flow of
                                                                                        \
about 120 Iphd (12  gpad). An evaluation of the methods used to construct Cells 1 and 4 resulted in
the conclusion that  the most likely cause  of top liner leakage was the development of a hole at the
LCRS pipe penetration of the geomembrane top liner in these cells.

Surface Impoundments

         For the two Group II surface impoundments ponds for which end of construction flow data
available, the hydraulic conductivity of the LDCRS drainage material is about 10"2 cm/s. For this value
of hydraulic conductivity, drainage of construction water could have occurred for  several months after
installation  of the top liner. The average measured flow rates at the end of construction, for the two
ponds were 990 and 1,020 Iphd (99 and 102 gpad), and the maximum monthly flow rates were 1,230
and 1,300 Iphd (123 and 130 gpad).

         Three of the five ponds from the Group  II surface impoundments had average flow rates
during their active lives potentially attributable to top liner leakage and construction water of 20 to 250
                                            48                                :

-------
 Iphd (2 to 25 gpad), and maximum monthly flow rates of 90 to 310 Iphd (9 to 31 gpad). Ponding tests
 or leak location surveys were reportedly performed as part of the CQA program at all of these ponds.
 The remaining two ponds {i.e.. Ponds 2 and 3 of Surface Impoundment H) had average flow rates
 potentially attributable to top liner leakage of 230 to 19,780 Iphd (23 to 1,978 gpad), and maximum
•monthly flow rates of 300 to 27,440 Iphd (30 to 2,744 gpad). It should be noted that leak location
 surveys were performed in both of the ponds  before they were  put into operation.  The results of
 chemical quality testing of the LDCRS liquids indicated that top liner leakage was occurring in both of
 these ponds shortly after the ponds were put into operation.  At 25 months, the geomembrane top
 liners in the two ponds were repaired.  After 25 months, the average measured flow rates from these
 two ponds decreased significantly and ranged from 400 to 440 Iphd (40 to 44 gpad).

 Comparison Between  Observed and Calculated Leakage Rates for Surface Impoundments

         Similar to the Group I ponds, flow rates from the Group II ponds were typically much smaller
 than the calculated leakage rate through a geomembrane hole of 6,300 Iphd (630  gpad)  given in
 Table 1 for h = 3 m (10 ft) and kmln >  1 cm/s.  The exception to this is for Ponds 2 and 3 of Surface
 Impoundment H, which experienced significantly higher flows than the other ponds.  After the
 geomembrane top  liners in the two ponds were repaired, however, the flow rates from these ponds
 became more consistent with the measured flow rates from the other ponds.

 6.2.3    Group III  Facilities

Introduction

         Group III  facilities  were constructed with composite top liners and geonet LDCRS drainage
layers. There are ten landfill facilities (37 cells)  and two surface impoundment facilities (four ponds)
in this group.  End  of construction data are available  for seven  landfill  cells  and two  surface
impoundment ponds.  In addition, data are available for 31 cells and three ponds during  their active
lives, and for 17 closed cells.

         For the Group III facilities, top liner leakage rates should be low and should not occur for
some period after construction (due to the containment capabilities of composite top liners).  Since
geonets were used in the LDCRS  drainage layers of these  facilities,  there  should not  be any
construction water (except for a small amount of water that drains from granular collection trenches
in the LDCRS). Therefore, flows from the LDCRSs of Group 111 facilities should result primarily from
consolidation of the clay component of the top liner.
                                            49

-------
Landfills

         For the seven  Group 111 cells for which end of construction data is available,  average
measured flow rates ranged from 0 to 1,900 Iphd (6 to 190 gpad), and maximum measured flow rates
ranged from 0 to 6,400 Iphd (0 to 640 gpad).  These flows are attributed to construction  water
draining from granular collection trenches and consolidation water.

         With one exception, all of the 31 Group III landfill cells for which data are available exhibited
flows from their LDCRSs during their active lives.  Average flow rates during the active lives of these
                                              I                                  '
cells ranged from 0 to 1,300 Iphd (0 to  130 gpad); with 15 of the 31 cells exhibiting flows less than
200 Iphd (20 gpad), 24 of the cells exhibiting flows less than 500 Iphd (50 gpad), and 28 of the cells
exhibiting flows  less than 1,000 Iphd (100 gpad).  Based on the calculated breakthrough times for
seepage through the top liner, the LDCRS flows from these cells during their active lives are primarily
                                                                                I
attributable to consolidation water. The flow rates are consistent with the calculated range of values
for flows due to consolidation water of  1 to 1,500 Iphd (1 to 150 gpad) reported in Section 4.5.

         For the 17 Group III cells that are closed or covered with a geomembrane or soil layer (i.e..
Landfill F, Cells 1 to 4, Landfill G, Cells 1 to 6, Landfill H, Cell 1, and Landfill T, Cells 1 to 6), ongoing
LDCRS flows may be due to continuing consolidation or secondary compression of the clay component
of the top liner.  In addition, a portion of the flows from Landfills H and T, which have a geomembrane
top liner on their side slopes, may be due to top  liner leakage.  While there is no direct'evidence of
leakage through the composite top liner of any of the closed cells (i.e., there is no chemical constituent
data for the LDCRS), the possibility of minor top liner leakage cannot be ruled out because the LCRS
at the facilities  continues to  produce  liquid, and the  calculated breakthrough time for the clay
component of the composite top  liner is less than the time period between the start of the active life
and the recording of the LDCRS flows.

Surface Impoundments

         For the two Group III ponds for which  end of construction data is available, the average
measured flow rates were 53 and 1,590 (5.3 to 159 gpad). These flows are attributed to construction
water draining from granular collection trenches and consolidation water.

         The three  Group III ponds that have data from their active lives exhibited average measured
LDCRS flow rates ranging from 0 to 960 Iphd (0 to 96 gpad), and maximum monthly flow nates ranging
from 0 to  1,380 Iphd  (0 to  138 gpad). The flows from these  ponds are primarily attributed  to
consolidation water.  Top liner leakage is  thought  to have  occurred for one  pond (Le.,  Surface
                                            50

-------
 Impoundment C, Pond 2). For this pond the average measured flow rate increased from 4 to 960 Iphd
 {0.4 to 96 gpad) after the liquid height in the pond was increased at 38 months after the end of
 construction.  It cannot be determined from the available information how flow entered the LDCRS in
 such a short time period after the  liquid height in the pond  was increased  as the top liner was  a
 composite on the base and side slopes. A geomembrane top liner defect was found on the side slope
 of the pond and repaired. Subsequently, the average flow rate decreased to 40 Iphd (4 gpad).

 Flow Rate Over Time

          For both landfill and surface impoundment facilities it is interesting to observe how the flow
 rate of consolidation water from  a facility decreases over time (e.g.. Landfill T, Cell 9 and  Surface
 Impoundment C, Pond 3). For example, for Landfill T, Cell 9, the average flow rate at about seven to
 twelve months after construction was 230 Iphd {23 gpad). By 13 to 1 8 months, the average flow rate
 had decreased to 150 Iphd (15 gpad). The flow decreased still further over time and was 20 Iphd {2
 gpad)  at 26 to 30 months after construction.

 6.2.4     Group IV Facilities

 Introduction

          Group IV facilities  were constructed  with composite top liners and sand LDCRS drainage
 layers.  There are eight landfill facilities (14 cells) and one surface impoundment facility (two ponds)
 in this group.  End of construction data are available for ten landfill .cells.  Data are  also available for
 twelve cells and all surface impoundment ponds during their active lives.  No data for closed cells are
 available.

         At the end of construction, flows from the LDCRSs of the Group IV facilities should be due
 primarily to drainage of construction water.  Subsequently, consolidation water will  contribute to the
 flow from those facilities in which a conventional compacted clay layer was used in the composite top
 liner.  For one of the facilities (Landfill I), a 6-mm (0.25-in.) thick GCL was placed directly under the
 geomembrane.  This GCL is installed with the bentonite in a  dry  state.  The bentonite in the GCL
 hydrates in the presence  of water, thereby forming a low-permeability barrier.  Due to its thinness,
 consolidation water from  the GCL should not be a source of significant flow from the LDCRS of this
facility.
                                             51

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Landfills                                                                         i

         Seven of the 14 Group IV cells have a layer of compacted clay as the soil component of the
composite top liner, and seven have a GCL.

         At the Group IV facilities for which end of construction flow rate data is available (i.e., nine
landfill cells), the hydraulic conductivity of the drainage material is on the order of 10"2 cm/s. For this
value of hydraulic conductivity, drainage of construction water could have occurred for several months
after installation of the top liner. Flow rate data at the end of construction are available for three cells
with a compacted clay layer in their composite top liner.  For these three cells, the average measured
flow rates were 0, 15, and 23,300 Iphd (0, 1.5, and 2,330 gpad). The average measured flow rates
at the  end of construction for the seven Group  IV cells that were  constructed with a GCL in their
composite top liner ranged from 0 to 890 Iphd (0 to!89 gpad), with five of the cells exhibiting average
flow rates of less than 100 Iphd (10 gpad).  The jmaximum weekly flow rate for thesejseven cells
ranged from 0 to 2,900 Iphd (0 to 290 gpad).                                       ;

         Flow rate data are available for five active cells with a compacted clay layer as a component
of the composite top liner. Average measured flow rates from the LDCRSs of these cells ranged from
40 to 500 Iphd (4 to 50 gpad). Three of the five cells exhibited flows of less than 200 Iphd (20 gpad).
These flow rates are consistent with the range of flow rates attributed to consolidation water observed
for the Group III cells.

         Flow rate  data are  available for seven active cells with a GCL as a component of the
composite top liner. In one of the seven cells, no LDCRS flow was observed.  For five of the six cells
exhibiting flow, average flow rates of 50 Iphd (5 gpad) or less were observed.  For the remaining cell,
an average flow of 120 Iphd  (12 gpad) or less was observed.  Maximum weekly flows for the  seven
cells were 430 Iphd (43 gpad) or less.  These flow rates could be accounted for by a combination of
compression and continuing  drainage of  the  sand  LDCRS drainage layer or leakage  through the
geomembrane top liner on the side slopes of the cells (the GCL only extends over the base of the cells).

Surface Impoundments

         Both Group IV ponds were constructed with a composite top liner on the base slope and a
geomembrane  top liner  on the side slope.  Average measured flow rates from one of the ponds (i.e..
Surface Impoundment B, Pond 1) ranged from 2 to 1,120 Iphd (0.2 to 112 gpad) during the active life
of the pond. The maximum monthly flow rates from this pond ranged from 7 to 1,340 (0.7 to 134
gpad).  These flows are primarily attributed to consolidation water  and leakage through  the
                                            52

-------
 geomembrane top liner on the side slope of the pond. It is known that top liner leakage was occurring
 in this pond during 35 to 37 months after the end of construction based on analysis of LDCRS flow
 for chemical constituents found in the pond liquid. This incidence of top liner leakage coincided with
 an increase in the liquid level in the pond. The LDCRS flow rate decreased when the liquid level was
 lowered.  It therefore appears that the geomembrane top liner on the pond side slope had a defect.
 The flow rate from the LDCRS of the second pond (i.e.. Surface Impoundment B, Pond 2) was zero
 from 20 to 43 months after construction; for this latter pond, consolidation water flows apparently
 ceased prior to flow rate measurement and quantifiable top liner leakage did not occur.

 6.3      INTERPRETATION OF DATA

 6.3.1     Group I  and Group II Landfills

          It is interesting to compare the flows attributable to top liner leakage for the Group I and II
 landfills (excluding Landfill J). For this comparison, the 21 landfill cells have been subdivided into those
 that had a CQA program (14 cells)  and those that did not have a CQA program (seven cells). From
 Table 10, it can be seen that of the 14 cells that had a CQA program, six had average flow rates less
 than 50 Iphd (5 gpad), and eleven had average flow rates less than 200  Iphd (20 gpad).  All 14 cells
 that had a CQA program exhibited both  average and maximum flow rates less than 1,000 Iphd (100
 gpad), which is EPA's recommended action leakage rate value for landfills.  Of the seven cells that did
 not have a CQA program, one cell had a average flow rate less than 200 Iphd (20 gpad), and five cells
 exhibited average  flow rates greater than 1,000 Iphd (100 gpad).  For the cells without a CQA program
 for which maximum flow rate data is available (i.e., six cells), all of the cells exhibited maximum flow
 rates of up to 500 Iphd (50 gpad)  or more, and four of the cells exhibited  maximum flow rates  of over
 1,000 Iphd (100 gpad).

         On the  basis of the limited available flow rate data, it appears that cells with properly
 constructed geomembrane top liners that have undergone CQA monitoring will consistently limit top
 liner leakage to a value of less than 1,000 Iphd (100 gpad). From the data in Table 10, it also appears
that implementation of a CQA program during construction significantly reduces top liner leakage rates
in comparison to facilities that do not have a CQA program.
                                            53

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Table 10.        Comparison of average and maximum measured flow rates at Group I and il landfills
                [Notes: Excludes Landfill J].
LDCRS Flow Rates for
Landfills With CQA
Less than 50 Iphd
From 50 to 200 Iphd
From 200 to 500 Iphd
From 500 to 1 ,000 Iphd
More than 1 ,000 Iphd
LDCRS Flow Rates for
Landfills Without CQA
Less than 50 Iphd
From 50 to 200 Iphd •
From 200 to 500 Iphd
From 500 to 1 ,000 Iphd
More than 1 ,000 Iphd
Average
6
5
2
1
"
Average

1

1
5
Maximum
Monthly
5
4
-
- .
'
Maximum
Monthly
-
-
-
-
-
Maximum
Weekly
i-
1
1
;3
-
Maximum
Weekly
-
'-
:-
2
4
                                           54

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 6.3.2    Group III and Group IV Landfills

         As was done with the Group I and II landfills, the flows from the LDCRSs of the Group III and
 IV landfills (excluding Landfill I) can also be compared (Table 11).  In the case of Group I and II landfills,
 flows from the LDCRSs were due primarily to top liner leakage.  For Group III and IV landfills, flows
 were primarily due to consolidation water.

         From Table 11, it can be seen that 39 of the 42 Group III and IV landfill cells for which data
 exist have average consolidation water flow rates of less than 1,000 Iphd (100  gpad), and 36 of the
 42 cells have average consolidation water flow rates less than 500 Iphd (50 gpad). Maximum flow
 rates are somewhat higher, with 26 of the 37  cells for  which data is available exhibiting maximum
 flows less than 1,000  Iphd (100 gpad), which is EPA's recommended action leakage rate for landfills.
 From these flow rates, it appears that landfills with composite  top liners may occasionally exhibit
 LDCRS flow rates exceeding 1,000 Iphd (100 gpad).  While consolidation water is not necessarily an
 environmental  concern, EPA intends to consider all flow  from the LDCRS as top liner leakage unless
it is demonstrated (in a response action plan) to be from  another source. The above interpretations,
however, should be interpreted cautiously because consolidation water flow rates vary with time and
the reported values may not be maximums.
                                            55

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Table 11.        Comparison of average and maximum measured  flow  rates at Group III and IV
                landfills [Notes: Excludes Landfill I].
LDCRS Flow Rates for
Landfills With CQA
Less than 50 Iphd
From 50 to 200 Iphd
From 200 to 500 Iphd
From 500 to 1 ,000 Iphd
More than 1 ,000 Iphd
LDCRS Flow Rates for
Landfills Without CQA
Less than 50 Iphd
From 50 to 200 Iphd
From 200 to 500 Iphd
From 500 to 1 ,000 Iphd
More than 1,000 Iphd
Average
7
14
TO;
3:
3
Average
-
1
2 i
2
- !
Maximum
Monthly
2
8
5
-
3
Maximum
Monthly
-
-
2
1
2
Maximum
Weekly
'-
1
3
4
J3
i
Maximum
Weekly
'.-
-
-
-
,-
                                            56

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                                        REFERENCES

 Bonaparte, R., Giroud, J.P., and Gross, B.A., "Rates of Leakage Through Landfill Liners", Proceedings,
 Geosynthetics '89, San Diego, Feb 1989, Vol. 1, pp. 18-29.

 Bonaparte, R. and Gross, B.A., "Field Behavior of Double-Liner Systems", Waste Containment Systems:
 Construction, Regulation, and Performance, Geotechnical Special Publication No. 26, American Society
 of Civil Engineers, New York, 1990, pp. 52-83.

 Brown, K.W., Thomas, J.C., Lytton, R.L., Jayawickrama, P., and Bahrt, S.C., "Quantification of Leak
 Rates Through Holes in Landfill Liners", EPA Report CR 810940, Cincinnati, 1987, 147 p.

 EPA,  "Background Document: Proposed Liner  and Leak Detection  Rule", EPA\530-SW-87-015,
 prepared by GeoSyntec Consultants, May 1987,  526 p.

 Faure, Y.H., "Nappes E'tanches: De'bit et Forme  de t'Ecolement en Cas de Fru/te", thesis, University
 of Grenoble, France, Dec 1979, 263 pp. (in French)

 Faure, Y.H., "Design of Drain Beneath Geomembranes:  Discharge Estimation and Flow Patterns in
 Case of Leak", Proceedings, International Conference on Geomembranes,  Denver, Vol. 2, June 1984,
 pp. 463-468.

 Fukuoka, M., "Outline  of Large Scale Model Test on Waterproof Membrane", unpublished report, May
 1985,24pp.

 Fukuoka, M., "Large Scale Permeability Tests f or Geomembrane-Subgrade System", Proceedings, Third
 International Conference on Geotextiles, Vienna, Austria, Vol. 3, April 1986, pp. 917-922.

 Giroud, J.P., "Geotextile Drainage Layers for Soil Consolidation",  Civil Engineering for Practicing and
 Design Engineers, Vol. II, 1983, pp. 275-295.

 Giroud, J.P., "Impermeability:  The Myth  and a Rational Approach",  Proceedings, International
 Conference on Geomembranes, Denver, Vol. 1, June 1984, pp. 157-162.

Giroud, J.P. and Bonaparte, R., "Leakage Through Liners Constructed with Geomembranes - Part I.
Geomembrane Liners", Geotextiles and Geomembranes,  Vol. 8, No. 1, 1989a, pp. 27-67.
                                           57

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                                                                                                  A

                                                                                                  9
Giroud, J.P. and Bonaparte, R., "Leakage Through Liners Constructed with Geomembranes - Part II.
Composite Liners", Geotextiles and Geomembranes, VoL 8, No. 2, 1989b, pp. 78-111.

Giroud, J.P., Khatami, A., and Badu-Tweneboah, K.,  "Evaluation of the Rate of Leakage Through
Composite Liners", Geotextiles and Geomembranes, Vol. 8, No. 4, 1989, pp. 337-340.

Giroud, J.P., Badu-Tweneboah, and Bonaparte, R., "Rate of Leakage Through a Composite Liner Due
to Geomembrane Defects", Geotextiles and Geomembranes, Vol. 11, No. 1, 1992, pp. 1-28.

Gross, B.A., Bonaparte, R., and Giroud, J.P., "Evaluation of Flow from Landfill Leakagfe Detection
Layers", Proceedings, Fourth International Conference on Geotextiles, Vol. 2, The Hague> Jun 1990,
pp. 481-486.

Jayawickrama, P., Brown, K.W., Thomas, J.C., and Lytton, R.L., "Leakage.Rates Through Flaws in
Geomembrane Liners", Journal of Environmental Engineering, ASCE, Vol. 114, No.  6, Dec 1988, pp.
1401-1420.                           '       |       .                           i

Linsley, R.K., Jr., Kohler, M.A., and Paulhus, J.H., "Hydrology for Engineers", McGraw-Hill, Inc., New
York, NY, 1975, 482 p.                                                          i
                                                                               i

Schiffman,  R.L., "Consolidation of Soil Under Time Dependent Loading and Varying  Permeability",
Highway Research Board Proceedings No.  37, 1958, pp. 584-617.

Sherard, J.L., "The Upstream Zone in Concrete-Face Rockfill Dams", Proceedings of a Symposium on
Concrete Faces Rockfill Dams - Design, Construction, and Performance, sponsored by the Geotechnical
Engineering Division of the American Society of Civil Engineers, ed. J. Barry Cooks  and James L.
Sherard,  Detroit, Oct 1985, pp. 618-641.                                           ;

Terzaghi, K., Theoretical Soil Mechanics, John Wiley and Sons, Inc., New York,  1943, 527 p.
                                           58

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 A..      REGULATORY BACKGROUND

 A.1      INTRODUCTION

          The purpose of this appendix to the report is to describe regulatory developments under the
 Resource Conservation and Recovery Act (RCRA) of 21 October 1976 that led to the design criteria
 for leakage detection, collection, and removal systems (LDCRSs) and the action leakage rate  (ALR)
 concept in EPA's final rule of 29 January 1992.


 A.2      EPA FINAL RULE OF 26 JULY 1982

          Minimum technology requirements for lining systems.at hazardous waste landfill, waste pile,
 and surface impoundment units  were first promulgated by EPA on 26 July 1982 (47 FR 32274). (A
 "unit" was defined in the preamble to the final rule as "the contiguous area of land on or in which
 waste is placed".) These requirements  (in amendments to Chapter 40 Sections 264 and 265 to the
 Code of Federal Regulations (CFR) (i.e., 40 CFR  265 and 266))  included:  (i) a single liner "that is
 designed, constructed,  and installed to prevent any migration of wastes" out of the unit during the
 active life (including the closure period) of the unit; and (ii)  for landfills  and waste  piles, a leachate
 collection system that limited the leachate depth over the liner to 0.3 m (1 ft).  In the preamble to the
 EPA final rule of 26 July 1982, EPA recognized that the requirement that a liner "prevent any migration
 of wastes out of a unit" would  dictate the type of liner that could be used. For landfills, EPA only
 recognized geomembranes as being able to meet this standard. For surface impoundments and waste
 piles that were closed by removing or decontaminating wastes and waste residues, a compacted soil
 liner or geomembrane could be used. The EPA final rule of 26 July 1982 also required monitoring and
 inspection of liners during their construction and installation.
A.3      HSWA AMENDMENTS OF 8 NOVEMBER 1984 TO RCRA

         In the 8  November 1984  Hazardous and Solid Waste Amendments (HSWA) to RCRA,
Congress imposed the first double-liner requirements  for hazardous waste landfills and surface
impoundments.  Under Sections 3004(o)(1)(A) and  3015 of HSWA, certain landfill and surface
impoundment units were required to have "two or more liners and a leachate collection system above
(in the case of a landfill) and between the liners". The leachate collection system between the top and
bottom liners  was referred to as the "leak detection system". Although waste pile units were not
required to have a  double-liner system,  certain waste piles were  required  to have a leak detection
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system. Under Section 3004(o)(4)(B) of HSWA, the leak detection system for the units was required
"to be capable of detecting leaks of hazardous constituents at the earliest practicable time". Section
3004{o)(5)(B)  of HSWA allowed the  use of a  particular  liner system  (i.e., "a  top finer designed,
operated and constructed of materials to prevent the migration of any constituents into such liner
during the period such facility remains in operation (including any post-closure monitoring period)" and
a bottom liner consisting of a "3-foot thick layer ofrecompacted clay or other natural material with a
permeability of no more than 1 x Iff7 centimeter per second") until EPA issued regulations lor guidance
to meet the requirements of HSWA. HSWA also listed deadlines for EPA to promulgate regulations or
issue guidance documents for double-liner systems.                                 ;
A.4      EPA DRAFT GUIDANCE OF 24 MAY 1985                                ,

         In  response to the requirement of HWSA  that EPA to  promulgate  regulations or issue
guidance documents for double-liner systems, EPA issued a guidance document on 24' May 1985
entitled "Draft,  Minimum Technology Guidance on Double Liner Systems for Landfills and Surface
Impoundments  - Design,  Construction,  and Operation"  (EPA/530-SW-85-014).   This|  draft EPA
document provided guidance on liner system designs, in addition to the design in Section 3004{o)(5)(B)
of RCRA as amended by HSWA (hereafter referred to as RCRA), that met the requirements of Section
3004(o)(1)(A) of RCRA.   Two double-liner systems were described  in the  draft EPA guidance
document.  The first double-liner system included a geomembrane top liner and a composite bottom
liner.  The second double-liner system included a geomembrane top liner and  a low-permeability  soil
bottom liner.   The document also  provided guidance on construction quality assurance (CQA)
procedures for  the  various liner system  components to  ensure, to the degree possible, that  the
constructed facility met the design specifications and  performance requirements.

         In both double-liner systems described in the EPA draft guidance document, the thickness
of the geomembrane top liner was at least 0.75 mm (30 mil) if the geomembrane was covered by a
protective soil layer or waste after installation or 1.1> mm (45 mil) if the geomembrane was feft exposed
for an extended period or operated without a protective soil layer.  The geomembrane top liner was
also chemically  resistant to degradation by waste and leachate and met certain other requirements.
                                             I
         The two double-liner systems described in the draft EPA guidance document differed only
in their bottom liners. The first bottom liner was a composite liner comprising a  geomembrane upper
component and a  compacted  low-permeability  soil  layer lower  component.   The geomembrane
component of the bottom liner met requirements similar to  those for the geomembrane top liner. The
soil component  of  the bottom  liner was  at  least 0.9-m (3-ft) thick and had a saturated hydraulic
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 conductivity of no more than 1 x 10'7 cm/s. The second bottom liner described in the draft EPA
 guidance document was a compacted soil liner that met the requirements of the bottom liner allowed
 by HSWA!  According to EPA, this liner had a saturated hydraulic conductivity of no more than 1 x
 10~7 cm/s, had a minimum thickness of 0.9 m (3 ft), and was of sufficient thickness  to "prevent the
 migration of any constituent through the liner during  the facility's active life and post-closure care
 period".

          In both of the double-liner systems described in the draft EPA guidance document, the top
 liner of landfill units was overlain by a "primary" leachate collection system consisting of a 0.3-m (1 -ft)
 thick (minimum) granular drainage layer that had a saturated hydraulic conductivity of not less than
 1  x 10"2 cm/s, was placed with a minimum slope of two percent, and was  chemically resistant to
 degradation by waste and leachate.  A synthetic drainage layer, such as a geonet, could be used in
 lieu of a granular drainage layer if it was shown to be equivalent to, of more effective than, a granular
 drainage layer meeting the minimum requirements. In  any case, the leachate collection system was
 designed to limit the leachate depth on the top liner to 0.3 m (1 ft) to meet the EPA  final rule of 26
 July 1982.

          In both double-liner systems described in the EPA draft guidance document, a "secondary"
 leachate collection system was included between the top and bottom liners. This secondary leachate
 collection system was designed to rapidly detect, collect, and remove liquids that enter the system so
 as to "produce little or no head of liquid on the bottom liner". The  secondary leachate collection
 system described by EPA was basically the same as the  primary leachate collection system (i.e., a 0.3-
 m (1-ft) thick (minimum) granular drainage layer that had a minimum saturated hydraulic conductivity
 of 1 x 10"2  cm/s, was placed  with a minimum slope of 2 percent, and was chemically resistant to
 degradation by waste and leachate). EPA also indicated in the document that a synthetic drainage
 layer, such  as a geonet, could be used in lieu of a granular drainage layer if it was shown to be
 equivalent to a granular drainage layer meeting the minimum requirements.

A.5      EPA FINAL RULE OF 15 JULY  1985

         On 15 July 1985, EPA issued  a final rule (50 FR 28702) amending  existing regulations to
reflect those statutory provisions of HSWA that took effect immediately or shortly after its enactment.
This rule  incorporated into the existing  regulations (i.e., into 40 CFR 264  and 265) the HSWA
provisions  (under  Section  3004(o)(5)(B)  of  RCRA)  requiring that,  until  EPA  issued  regulations
implementing the double-liner system requirements of Sections 3004(o)(1)(A) and 3015 of RCRA,
certain facilities must have a double-liner system that meets or exceeds the specific requirements of
the provisions. The 15 July 1985 rule  required facilities  to have  a top liner and a compacted soil
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bottom liner (i.e., the liner system allowed by Section 3004(o){5)(B) of RCRA).  For landfills, the top
liner was required to be a geomembrane, but for surface  impoundments the top liner ;could  be a
compacted soil layer or a geomembrane. The bottom liner was deemed to satisfy the HSWA provisions
if it was "constructed of at least a 3-foot thick layer of recompacted clay or other natural material with
a permeability of no more than 1 x 10'7 centimeter per second".  The rule also required  a leachate
collection system between the top and bottom liners at surface impoundments and landfills and above
the top liner at landfills.                                                   .       \
A.6      EPA PROPOSED RULE OF 28 MARCH 1986                               '

         On 28 March 1986, EPA promulgated regulations on double-liner systems as required by
HSWA. The proposed rule contained minimum technology requirements for double-liner systems and
leachate collection and removal systems (51 FR 10706). This proposed rule, commonly]referred to
as the proposed "Double-Liner and Leachate Collection System Rule" or simply the "Double-Liner Rule",
would, when finalized, amend the double-liner system requirements of 40 CFR 264 and 265.

         The minimum technology requirements in the proposed Double-Liner Rule were! essentially
those of the draft EPA guidance document of 24 May 1985.  Two double-liner system options were
provided in the  proposed rule (51 FR 10709). Both incorporated geomembrane top liners; however,
one option allowed a compacted soil bottom liner, while the other option allowed a composite bottom
liner.  There was no minimum thickness requirement for the geomembrane top liner given in the
regulations.

         The compacted soil bottom liner option closely resembled the design standard^ of Section
3004{o)(5)(B) of RCRA, as codified in the EPA final  rule of 15 July 1985. The compacted soil bottom
liner of the proposed rule differed from that of the standard of Section 3004(o)(5)(B) in that it required
the bottom liner to not only meet a minimum design requirement (i.e., be at least 0.9-m (3-fjt) thick and
have a hydraulic conductivity of no more than 1 x 10"7 cm/s), but also meet a  minimum performance
standard (i.e., prevent the migration of any constituent through the liner during  the facility's active life
and post-closure care period). This performance standard was similar to that presented in  the draft
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EPA guidance document of 24 May 1985. The composite bottom liner option of the proposed Double-
Liner Rule was also similar to that  in .the draft EPA guidance document, with the exception that no
minimum thickness  was specified in the  proposed  rule for the geomembrane or  compacted soil
component of the composite bottom liner. However, in the preamble (51 FR 10710)  to the proposed
rule of 28 March 1986 EPA noted that the soil component should be at least 0.9-m (S-ft)ithick.  The
proposed rule required the compacted soil component to have a hydraulic conductivity of no more than
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  1x10" cm/s and to minimize the migration of any constituent through the geomembrane component
  of the liner if a defect were to develop in the geomembrane prior to the end of the post-closure care
  period of the facility.

          The proposed  rule also provided minimum requirements for the leachate  collection and
  removal system above the top liner of landfills and between the top and bottom liners  of landfills and
  surface impoundments.  Consistent with the EPA final rule of 26 July 1982 and draft EPA guidance
  document of 24 May 1985, the LCRS above the top liner was required to be designed, constructed,
  and operated to collect and remove leachate and ensure that the leachate head on the top liner did not
  exceed 0.3 m (1  ft).  In addition, the LCRS between the top and  bottom liners was  required to be
  "designed, constructed, maintained, and operated to detect, collect, and remove liquids that may leak
 through any area of the  top liner during the active life and post-closure care period".  No hydraulic
 conductivity requirement for the LCRSs was given in the proposed  rule.
 A.7      EPA NOTICE OF 17 APRIL 1987

          On 17 April 1987, EPA issued "Hazardous Waste Management System; Minimum Technology
 Requirements: Notice of Availability of Information" (52 FR 12566).  The notice contained data on the
 two bottom liner designs (i.e., compacted soil liner and composite liner) presented in the EPA proposed
 rule of 28 March 1986.  In this notice, EPA compared  the two liner systems with respect to leak
 detection performance  characteristics, leachate collection efficiency, and leachate migration into and
 through  the  liner.  Based on the data,  EPA concluded  that the proposed composite bottom liner
 contained leachate and  enhanced leachate collection significantly better than the proposed compacted
 soil  bottom liner.  Based on the information in  this notice,  along with  the minimum technology
 requirements of the proposed "Liner/Leak Detection System Rule", EPA decided that the final "Double-
 Liner Rule" would only  allow the use of a composite bottom liner (i.e., a compacted soil bottom liner
 will not be allowed).
A.8      EPA PROPOSED RULE OF 29 MAY 1987

         On 29 May 1987, EPA proposed minimum technology requirements for LDCRSs at certain
land  disposal units  (52  FR 20218).   These requirements  were intended to meet the previously
mentioned statutory provisions in  Section 3004(o)(4)(A) of RCRA that specifically call for EPA to
establish minimum standards for "leak detection systems".  The proposed rule, commonly referred to
as the "Liner/Leak Detection System Rule" or simply "Leak Detection System Rule", required all new
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landfills, surface impoundments, and waste piles to have an approved LDCRS that was capable of
detecting leakage "at the earliest practicable time".  The proposed rule also required  waste piles to
meet essentially the same double-liner system requirements as landfills.  Lastly, the proposed rule
codified CQA requirements for landfills, waste piles, and surface impoundments.

         The  proposed Liner/Leak  Detection System  Rule contained  both  minimum  design
specifications  and  minimum performance  requirements  for  the  LDCRS.   The minimum  design
requirements consisted of:  (i) a minimum bottom slope of 2 percent; (ii) for granular drainage media,
a minimum thickness of 30 cm (12 in.) and a minimum hydraulic conductivity of 1 cm/s^and (iii) for
synthetic drainage media, a minimum hydraulic transmissivity of  5 x  10"4 m2/s.  The performance
requirements consisted  of:  (i) a minimum leak detection sensitivity of 10 Iphd (1 gpadj; and (ii) a
maximum steady-state leak detection time of 1 day.                                ,  ,;

         In the proposed Liner/Leak  Detection System Rule of 29 May 1987,  EPA introduced  the
concept of an action leakage rate (ALR), which was defined as (52 FR 20222) "the rate of leakage
from  the top liner into the LCRS that triggers interaction between the owner or operator and  the
Agency to determine the appropriate response action for the leakage".  EPA proposed to establish  the
ALR as follows:                                 |

                          "(1)  Using a standard value of (EPA is proposing to select a final value
                from the range of 5-20 gallons/acre/day); or

                          (2)  A review by the  Regional Administrator of an owner or operator
                demonstration,  and a finding by the Regional Administrator, that a site-specific  top
                liner action leakage rate is appropriate for initiating review of the actual leakage rate
                to determine  if a response action^ is necessary.   The site-specific top liner action
                leakage rate  demonstration must be based on  allowing only very  small isolated
                leakage through the top liner that does not affect the overall performance of the  top
                liner."

         The concepts of rapid and extremely large leakage (RLL) and response action plan (RAP) were
also introduced in the proposed Liner/Leak Detection System Rule. The RLL was defined as  (52 FR
20237) "the maximum design leakage rate that the LDCRS can remove under gravity flow conditions
(i. e., without the fluid head on the bottom liner exceeding one foot of water in granular leak detection
systems and without the fluid head exceeding the thickness of synthetic leak detection systems)."
The RAP was  defined as (52 FR  20222) a plan "which consists of an  assessment of the. reason for
leakage, the current conditions of the unit components..., the potential for migration out of the. unit
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 of hazardous waste constituents at levels exceeding health-based standards, and an assessment of the
 effectiveness of various responses."
 A.9            EPA FINAL RULE OF 29 JANUARY 1992

          On 29 January 1992, EPA finalized the proposed rules of 28 March 1986 and 29 May 1987
 (i.e., the Double-Liner Rule and the Leak Detection System Rule). This final rule (57 FR 3462) amended
 the  double-liner and LDCRS requirements of 40 CFR  264 and 265 for certain land  disposal  units,
 including some waste piles.  The final rule also codified CQA requirements for landfills, waste piles,
 and surface impoundments.

          The double-liner system and LCRS required in the final rule are essentially the same as those
 presented in the proposed 28 March 1986 rule. The double-liner system requirements can be satisfied
 by a geomembrane top liner  and composite  bottom liner consisting of a  geomembrane upper
 component and 0.9-m (3-ft) thick compacted soil layer lower component with a hydraulic conductivity
 of no more than 1 x 10~7 cm/s. The LCRS requirements can be met by a drainage system that limits
 the depth of leachate over the top liner to 0.3 m (1 ft).

         The LDCRS requirements in the final rule are somewhat different than those presented in the
 proposed EPA rule of 29  May 1987. In the final rule, the design requirements consist of the following:
 (i) a minimum bottom slope of one percent; (ii) for granular drainage media, a minimum thickness of
 0.3 m (1 ft) and a minimum hydraulic conductivity of 1 x 10~2 cm/s for landfills and waste piles and
 1 x 10'1  cm/s for surface impoundments; and (iii) for synthetic drainage media,  a minimum hydraulic
 transmissivity  of  3 x  10"5  m2/s for landfills  and waste  piles  and 3  x 10'4 m2/s  for surface
 impoundments.  The previously-mentioned performance requirements given in the 29 May 1987
 proposed rule for LDCRSs were not promulgated in the final rule.

         In the final rule of 29 January 1992, EPA included the RAP concept and combined the ALR
 and RLL concepts of the  proposed 27 May 1987 rule.  In the final rule the RLL was renamed the ALR
 and defined as (57 FR 3474) "the maximum design leakage rate that the leak detection system can
remove without the fluid head on  the bottom liner exceeding one foot". As stated in the preamble to
the final rule, "the Agency believes that units meeting the minimum technical requirements would not
require leakage rates below 100 gpad for landfills and waste piles  and 1,000 gpad for surface
impoundments". However, EPA also indicated in the preamble that they recognize "that a number of
site-specific factors  affect the maximum flow capacity of a leak detection system, and owners or
operators may want to propose alternative action leakage rates".
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