Your Ref:
Our Ref: PPC/BU8100
Date: 05 July 2005
FAO Graeme Jackson
Estates Manager
Alco Waste Management Ltd
Dixon House
Joseph Noble Road
Lillyhall Industrial Estate
Workington
Cumbria
CA14 4JH
Dear Mr Jackson,
THE POLLUTION PREVENTION & CONTROL (ENGLAND & WALES)
REGULATIONS 2000, AS AMENDED, (THE PPC REGULATIONS);
THE LANDFILL (ENGLAND AND WALES) REGULATIONS 2002
CELL 5A-COMMENTS ON CQA REPORT
Permit reference:
BU8100
Following the submission of the CQA report for Stage 3, Cell 5A-Asbestos Cell, the
following comments have been made:
1. The Engineer’s logs provided show that the supervision of the works was only part time
and not full time as stated in the CQA Report. Further, there is reference to a testing
regime for the clay liner used for previous cells in terms of the frequency of testing and
the minimum values which are expected for each test. This data is supposed to be
presented in Appendix D but is absent. Without this data it is difficult to decide if the
individual tests have met the required criteria or not.
2. It is noted that in paragraph A2 that Cumbria Waste Management awarded the
commission to Cumbria Contracting Services; is this correct?
3. The Specification and CQA Plan is not presented in Appendix D of the report as stated
in the contents page. There is a record from the correspondence that the testing
frequencies and minimum values expected for the testing of the clay liner are the same as
those used in previous cell construction works. Paragraph A3 states that “the CQA of
both the construction and testing was generally carried out in accordance with the
documents and plans” this would suggest that on some occasions some construction and
testing was not in accordance with said documents and plans. Please clarify which parts
of the construction process did not meet the design or testing procedures.
4. The testing frequencies and minimum values cannot be found in the report therefore it
has not been possible to categorically say whether or not an individual test has met the
minimum criteria because the minimum values are not presented. Please provide a
comprehensive Specification and CQA Plan.
Environment Agency
Ghyll Mount, Gillan Way, Penrith 40 Business Park, Penrith, Cumbria. CA11 9BP
Tel: 01768 866666 Fax: 01768 865606
5. The testing frequencies appear not to be in accordance with the EA guidance and as such
the clay liner has been sampled with reliance on one or two results which may or may
not be representative of the clay source material. Please provide a table to show the
comparison between the EA guidance frequencies and those used for this clay liner.
What area of clay liner was installed in constructing this cell?
6. A clay source characterisation report has not been presented although again it is
documented that one exists and was prepared for the previous cell construction works.
Please provide the relevant source characterisation report.
7. Appendix C has the laboratory results presented in a matrix format. The dry density
results should be presented along with the moisture content and then plotted onto the
appropriate graph to identify the percentage compaction and percentage voids from any
particular sample. Please provide dry density results and a graph showing the NDG data
plotted.
8. There is no evidence on the test data sheets that the laboratory who undertook the testing
is accredited to do the tests which have been done. Please provide accreditation details
from the laboratory for those tests undertaken.
9. Section C3 Clay Liner Construction and Testing – the numbers of tests and the results
quoted seem to be inaccurate. Clarification is needed of the results and how these plot
onto the appropriate graph.
10. The characterisation and permeability results are not evenly distributed through the 12
layers installed as the 3.0 metre thick clay liner. Particular concern is drawn to the upper
4 layers where only 2 plasticity determinations, 2 laboratory moisture content
determinations and 2 sand replacement tests and 1 grading determination. It is noted that
no samples were taken for the assessment of the permeability and only 5 permeability
tests were undertaken in total.
11. There is no determination of stone thickness on the plan (Dwg No. L102/Cell5A.ASB./1)
only references A to D. Please provide actual recorded levels and thicknesses for these
points.
12. There is no formal text in the report detailing the installation of the leachate drainage
blanket or sump construction details. Please provide this information and show
compliance with the design, specification and CQA Plan.
In essence, the design and specification are suitable for the purpose of intended use, but the
presentation of the report needs to be re-submitted to include all the information. The CQA
report must be robust and demonstrate that the cell was constructed to the design and
specification in the CQA Plan.
Environment Agency
Ghyll Mount, Gillan Way, Penrith 40 Business Park, Penrith, Cumbria. CA11 9BP
Tel: 01768 866666 Fax: 01768 865606
If you have any queries, please call me on 01768 215852.
Yours sincerely
Elly Whiteford
Environment Officer, SW Team.
Environment Agency
Ghyll Mount, Gillan Way, Penrith 40 Business Park, Penrith, Cumbria. CA11 9BP
Tel: 01768 866666 Fax: 01768 865606