May 2014 Newsletter

Have You Checked the Condition of Your Monitoring Wells?  
By: Wesley E. Stimpson, LSP, Loss Prevention Committee

Since 2006, Potentially Responsible Parties (PRPs) at 28 different sites have had the unacceptable condition of monitoring wells noted during site audits.   At 19 of the sites, the lack of protection and general condition of the wells were of sufficient concern as to have the MassDEP highlight it as an MCP violation and include it in a Notice of Noncompliance (NON) issued to the PRP.

The LSPA's Loss Prevention Committee has completed a review of Notices of Audit Findings (NOAFs) for the seven year period from FY 2007 to FY 2013 searching for NOAFs that discuss the condition of monitoring wells.  The committee found 20 NOAFs from the Western Region (WERO), five from the Central Region (CERO) and three from the Northeast Region (NERO) that identified this issue.  The Southeast Region (SERO) did not identify this issue at any sites over the same period. 

The most common concern noted by MassDEP was the lack of well security.  Locks and cover bolts were missing, interior plugs were missing or non-functional.  In addition, ground conditions and grout seals surrounding wells were compromised such that water could easily enter the wells.  Roadway boxes and protective well pipes were missing and in a few cases the wells were completely destroyed and filled with soil.  In many cases these wells were still being sampled to collect long-term data to support monitored natural attenuation as a remedial solution or similar Phase IV activities. 

Not all NOAFs identified this issue as a violation.  WERO cited well conditions as a violation in 14 of the 20 NOAFs from that region.  Three of the NONs were written just for the well condition violation.  CERO identified this as a violation in all five of the NONs they issued and NERO noted it in three NOAFs but did not include it as a violation in any NONs. 

The most often cited MCP requirement in the NOAFs was Section 40.0028: Well Maintenance and Security.  All of WERO citations were to this section.  CERO referenced 40.0017: Environmental Sample Collection and Analyses at two sites, and 40.0191(2): Response Action Performance Standard (RAPS) and 40.0028: Well Maintenance and Security at one site each (the relevant portions of these sections have not changed in the final amendments to the MCP for 2014.) 

In the May 2009 edition of the LSPA News, the LSPA presented the results of a survey seeking information from the membership as to when they were recommending abandoning monitoring wells.  While not conclusive, most respondents indicated that they were recommending closing the wells when the Permanent Solution was submitted or within a few years thereafter.  From this recent exercise, it also appears that PRPs, as well as LSPs, need to ensure that any monitoring wells that remain comply with the requirements of MCP Section 40.0028.  In addition, the LSP should consider routinely informing the PRP of the requirement to properly close out those monitoring wells that are no longer serving their intended purpose, as was concluded in the May 2009 article.