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Shallow Injection Well Closure - Q & A Summary for the Non-Technical Reader
What is the UIC Program?
UIC stands for the Underground injection Control Program. The UIC program is a federal program under the Safe Drinking Water Act (SDWA), which is managed in Massachusetts by MassDEP. The purpose of the UIC program is to protect underground sources of drinking water by regulating the underground injection of industrial and hazardous wastes and any other fluids having the potential to contaminate groundwater. MassDEP regulates the UIC program in Massachusetts.
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What is injection?
Injection means the discharge of fluids into a formation by gravity or greater pressure through a well.
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What is a UIC well?
Well means a bored, drilled, or driven shaft, a dug hole, a seepage pit, an improved sinkhole, or a soil absorption system. There are five Classes of UIC wells: Class I - V. Class I - III are banned in Massachusetts by MassDEP. Class IV wells are banned except remediation wells at sites overseen by CERCLA, RCRA or MassDEP's Waste Site Clean-up program.
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What are Class IV and V UIC wells?
Class IV: Wells used by generators of hazardous wastes or of radioactive wastes by owners or operators of hazardous waste management facilities or by owners or operators of radioactive waste disposal sites, or by any other person to dispose of hazardous wastes or radioactive wastes into a formation, which within 1/4 mile of the well contains an underground source of drinking water.
Class V: Injection wells not included in Classes I, II, III, or IV. Class V injection wells are further defined in 310 CMR 27.05.
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What is well injection or underground injection?
Well Injection or Underground Injection means the subsurface discharge of fluids through a well.
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What is an Underground Source of Drinking Water (USDW)?
Underground Source of Drinking Water (USDW) means an aquifer or its portion which supplies any public water supply system; or which contains a sufficient quantity of groundwater to supply a public water supply system; and either currently supplies drinking water for human consumption, or contains less than 3000 mg/l milligrams/liter total dissolved solids; and which is not an exempt aquifer.
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Why is this important? What's in it for me?
Four primary interests are at stake here: public health, environmental protection, business owners' financial concerns, and municipal financial concerns.
Industrial floor drain discharges to the ground by Class IV or Class V UIC wells are a suspected source of contamination of public water supplies (see note below) and a confirmed source of contamination of several wells in Massachusetts. Many businesses may be unintentionally polluting the environment in this fashion. The Department is interested in helping such businesses to identify and correct problems that exist now, before they become a more serious environmental problem or financial burden.
The Shallow Injection Well Closure document describes how to correct an unauthorized injection system. Closure costs always include the standard expenses of disposing of any remaining sludge in the system and the structural costs of fixing the system (e.g., sealing the drain or connecting it to a holding tank or sewer). If further remedial work is necessary, additional cleanup costs may also apply. These additional costs usually range from roughly $2,000 for investigation (f) to $10,000 to cleanup a confined, relatively small amount of pollution. That may sound like a lot, and it is for a small business, but it is a fraction of what it may cost to fix the problem should the pollution reach a public water supply.
The threat is real. If you own or operate a dry cleaner shop, vehicle repair garage, auto body shop, machine shop, metal plating facility, furniture stripping operation, or other business which uses hazardous materials, do not jeopardize your financial interests or the environment by ignoring injection wells that may be part of your operation: the longer the pollution is in the ground, the longer it has to spread out, and the more costly it will be to clean it up.
Note: Suspected UIC contamination of Public Water Supply wells in Massachusetts includes: the Kane and Chestnut wells in Hudson, the Turnpike and Hartwell Road wells in Bedford, Wells # 1 and 2 in Groveland and the Ellis well in Norwood.
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How do I know if this document affects me?
This document primarily addresses floor drains and injection wells associated with them, but also applies to discharges to the ground through other entry points. The first thing you need to do is find out where your floor drain(s) leads. This is the most critical piece of information. If the floor drain(s) is ultimately piped to any system discharging beneath the ground (e.g., septic system, dry well or "MDC trap" leading to a leachfield), then this document applies to you. If the floor drain does not lead to a discharge to the ground, or if you do not have any floor drains, you are probably not subject to this document.
If you do not know where your drains lead, find out! Look at old "as-built" plans, perform a dye test, check municipal records, contact the building's architect, perform more sophisticated techniques to trace piping, or even dig up the area. If your drains are not connected to a municipal sewer line, or if you do not have a holding tank, which you pump regularly, your system probably leads to the soil. It is best to assume it does until you determine otherwise.
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What is the minimum I have to do if the document applies to me?
In addition to structurally fixing your floor drainage system you need to follow the guidance in section 5.0 of this document. Section 5.0 details guidance for removing any sludge from your drain system, disposing of this sludge properly, and then sealing off any inlets into the system so nothing else can get into it. It is also a very good idea to have this sludge tested as outlined in Section 5.1; this test will give you a good idea of what may have gotten into the soil as well.
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Do I have to do anything else, or is that it?
That depends. If the Department has given or sent you an official order requiring that you perform the actions specified in section 6.0, then you must perform them. You should know if you have received such a letter or document. They are usually only given to the property owner/operator during an inspection at a facility or sent with a Department notice or order.
If you know that some oil or other hazardous material has gotten into your system, and it could have gotten into the soil, then you should follow the guidance in Section 6.0 and implement the additional closure activities specified.
If neither of these two criteria are met, then you do not have to do anything under section 6.0. However, it is a very good idea to take the actions in section 6.0 anyway, in order to ensure protection of public health and the environment. If your system is clean, and you structurally fix it (for example, by connecting the floor drains to a Department certified holding tank [DEP 01]), you will not have to wonder what liability you might continue to have at the end of your pipe. If some pollution has already gotten into your drain system or the surrounding soil through a UIC, it is cheaper to deal with it now rather than later. If you do not perform these actions, the Department may still require you to clean the drain up if later information indicates that some pollution may have gotten down it and into the soil. By then, it will likely have spread out and be much more costly to clean up.
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Do I have to hire a consultant?
For releases of hazardous materials greater than a certain amount (varying with the particular waste), you will have to hire a Licensed Site Professional (LSP). Otherwise, you do not have to hire one, but the Department recommends that you hire a qualified environmental consultant to make sure you are doing everything according to the state's standards.
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How long has all this been necessary?
The federal Safe Drinking Water Act of 1974 required UIC regulations at the federal level and in the states. Massachusetts' UIC regulations have been in place in since 1982. However, due to inconsistencies between these federally driven regulations and the state building and plumbing codes, many facilities were built in violation of the UIC regulations. The Plumbing Code was revised in 1991 and again in 1992 to resolve these inconsistencies.
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What is the "MCP" that is mentioned throughout this document?
"MCP" stands for Massachusetts Contingency Plan, the state regulations which address releases and threats of releases of oil and hazardous materials to the environment. It sets requirements for reporting releases of oil and hazardous materials to the Department, for hiring an LSP to evaluate the problem created by the release, and for making cleanup decisions.
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Is there a state requirement to use a registered well driller for the installation and decommissioning of monitoring wells?
Yes - although the Massachusetts Department of Conservation and Recreation (DCR), not MassDEP, regulates such activities. Under the provisions of M.G.L. c. 21, ss.8-16 and 313 CMR 3.00, Water Well Diggers and Drillers Registration, monitoring wells must be drilled, installed, and decommissioned by a well driller registered in the Commonwealth of Massachusetts by DCR's Division of Water Supply Protection. The registered well driller must file a well completion report under 313 CMR 3.03(3) for both the installation and abandonment of monitoring wells. This requirement does not apply to (a) soil gas sampling probes, or (b) temporary groundwater wells, in which the installation tool is left in the ground for less than 48 hours.
Further excluded from this requirement are wells used on a temporary basis for the purpose of dewatering excavations and stabilizing hillsides or earth embankments.
Additional information on DCR's Well Drillers Program may be obtained on the Internet at http://www.mass.gov/dcr/waterSupply/welldril/
MassDEP also provides guidance on the design, installation, and abandonment of monitoring wells in Section 4.0 "Piezometers, Observation Wells, and Monitoring Wells" of the DEP's guidance document: Standard References for Monitoring Wells WSC-91-3101, April 1991 (which is available through the MA State Bookstore at: http://www.sec.state.ma.us/spr/spridx.htm); Supplement: Standard References for Monitoring Wells - Small Diameter Driven Well Supplement, January 1999, which may be obtained on the Internet at http://www.mass.gov/dep/cleanup/laws/policies.htm#finpol.
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Where do I get more information?
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