EXECUTIVE SUMMARY

At least 636 private wells in 120 Massachusetts municipalities have been contaminated and removed from service within the past 15 years. This number includes wells which have been shown to contain chemicals, petroleum products, pesticides, road salt, bacteria, nitrates, and other constituents in concentrations deemed unacceptable in drinking water. The information concerning private well contamination was obtained from a survey of 275 Massachusetts health boards and from records at the Department of Environmental Quality Engineering and the Massachusetts Department of Public Works. The tabular summary found in Appendix H includes only data which was available from and reported by these sources. Figure 1 on page 7 and Figures 3 -8 on pages 16, 17 and 18 depict the municipalities in which private wells have been known to be contaminated by each contaminant type.

Each of the 176 reports of private well contamination can be categorized by its cause. Improper waste disposal, including insecure landfilling, resulted in 25 of 38 known chemical contamination incidents. Leaking underground petroleum storage tanks were the source of 12 of 22 petroleum related incidents. Use of chemical pesticides in agriculture caused 77 wells in eight municipalities to be closed, while 155 wells still in use contain a pesticide at detectable levels. Road salt application and storage has resulted in private wells in 38 municipalities containing sodium at levels unsuitable for drinking water. Improperly sited or designed septic systems and wells in disrepair have led to bacterial and nitrate contamination of private wells statewide.

In addition to collection of data on contamination, the Board of Health survey addressed the issue of data availability, the occurrence of problems other than contamination, and the existence on the municipal level of regulatory measures and testing programs aimed at protecting and monitoring the quality of private wells. The following survey results are detailed in Section 2 of this document: most health boards do not have accurate data on private well existence or location; private well owners are often faced with localized quantity-related problems and with decreased water quality due to naturally-occurring contamination; 91 municipalities surveyed reported having regulatory measures aimed at protecting private wells from contamination, however these measures are in many cases inadequate; 23 municipalities have some type of monitoring program for the analysis of private well water quality.

In Massachusetts, private wells are only minimally regulated by the state. The state requires well drillers to be registered, the building code requires that a well be installed and proven potable prior to issuance of a building permit, and Title 5 of the Environmental Code regulates the siting of septic facilities in relation to existing wells. There also exist statewide provisions aimed at controlling potential sources of contamination, although these measures are not intended solely to effect private well protection. Municipalities retain the sole authority to regulate the installation of new private wells to ensure their proper siting in relation to preexisting land uses which may pose a threat to the well's integrity. Through regulation and permitting programs, some municipal health boards have achieved comprehensive protection of private wells, however the range over which this authority is exercised varies greatly from town to town. Many municipalities require increased capability to properly institute and implement protection oriented provisions.

In order to foster protection of private wells from further contamination, the Commission recommends a combination of research, technical and financial assistance, citizen education, and strengthened regulatory and source reduction programs. The emphasis is placed on preventive measures with recommendations to enhance and supplement existing capabilities on the local level. Additionally, specific programs within several departments and agencies in the state government, such as the source reduction program, the household hazardous waste collection program grants, and the Bureau of Environmental Health in the 'Department of Public Health should be promoted and made more accessible. Existing legislative initiatives aimed at controlling specific contaminant sources --road salt, pesticides, and underground petroleum storage tanks --must be enacted. The report concludes that although contamination of private wells is a ubiquitous problem in Massachusetts, cooperative efforts between citizens and government can reduce the occurrence of private well contamination.

INTRODUCTION

Approximately seven percent, or 400, 000, of the citizens of the Commonwealth receive their water supplies from private, on-site wells. These residents live in the 275 municipalities statewide where all or some portion of the population has no access to a municipal water system. When first built, many homes were isolated not only from municipal utilities but from potential pollution sources as well. Water flowing from the wells installed on these lots was untainted and naturally protected from contamination by virtue of this seclusion. As growth occurred, new homes, each with their own new well and septic system, were constructed in unbuilt areas. Concurrently with all the new residential development, commercial and industrial uses --gas stations, dry cleaners, car washes, and factories --cropped up, each a potential source of contamination.

This new, denser development posed risks to the integrity of many wells. Existing wells were threatened by pollution from newly installed septic systems on adjacent lots and runoff from the roads built to serve the new homes. Meanwhile, new wells were installed haphazardly, sometimes too close to roads, adjacent septic systems, other wells, or potential pollution sources.

Many municipalities subsequently installed public water and sewer systems. Others did not, leaving a myriad of wells dotted throughout the state vulnerable to pollution from the various adjacent land uses. While both municipal and private well water often draw from the same aquifer, water from private wells is sometimes perceived to be better than municipally supplied water. Due to the natural filtering process achieved as groundwater moves through the geologic deposits underground and the natural occurrence of flavorful minerals, well water, both public and private, is often appreciated for its pleasing taste and clarity. The significant difference between municipal and private water supplies is that public supplies are routinely analyzed for the presence of pollutants undetectable by sight, taste, or smell. While most private water supplies are pure and potable, few have been confirmed so by a certified laboratory. More than 600 private wells have been proven contaminated and it is likely that testing would reveal additional contaminated wells. An undetermined number of private wells are also threatened by activities related to the land uses proximal to the wells.

This study was initiated to determine the extent and nature of private well contamination in order to define the adequacy of individual, local, and state responses to and prevention of contamination. Because information on well location is not generally available, it has historically been difficult to assess the integrity and vulnerability of private water supplies. Random installation and lack of regulation have resulted in a deficiency of data on private wells. The applicability of existing mechanisms related to private water supply pollution and contamination prevention could not be assessed in the absence of real information on policy implementation.

The central tenet behind state private water supply policy is that technical and financial assistance should be provided only when individual or local capabilities are insufficient to protect the public health and the environment. Through Massachusetts General Laws Chapter 21E, which provides for liability assignment and interim funding for clean up of hazardous waste releases, this policy has been applied in response to contamination of private wells. The enactment of the Solid Waste Act of 1987 provides an additional means for coping with contaminated private wells by allowing municipalities to apply for funding for the mitigation of private well contamination by landfills. However, due to the very nature of private wells, their protection must remain the primary responsibility of the well owner. Informed and sensitive well owners and local officials can, with the help of the state, ensure protection of the public health through prevention of further groundwater contamination.

SECTION I: PRIVATE WELL CONTAMINATION

Through the course of its existence, the Special Legislative Commission on Water Supply has addressed the iss~es raised by contamination of water supplies. While data regarding water quality in public water systems is available, no such information had been compiled for private residential, industrial or commercial wells. Yet contamination is not a phenomenon limited to any particular type of water supply; it is a ubiquitous problem which needs to be dealt with on all levels.

Board of Health Survey

In order to evaluate the efficacy of federal, state and local regulatory measures and the ability of private well owners, local officials, and state programs to respond to contamination, it is necessary to establish a baseline of data pertaining to the extent and nature of contamination of private wells. While occasional studies have produced limited information on this type of contamination, no comprehensive picture has been developed. As the installation of private wells has only recently begun to be regulated in a limited number of municipalities, in general there are few precise records on the number and location, let alone the water quality, of private wells in Massachusetts.

A brief questionnaire was mailed to Boards of Health in the 275 municipalities which, according to the 1983 Division of Water Resources (DWR) document "Water Supply Service Population, " had any percentage of the residential population drawing their water supplies from private on-site wells. Response was moderate, with 67 (25%) of the questionnaires being returned by mail. Of the remaining 208 health boards who did not return the written questionnaire, 161 responded to contact by phone, while 47 chose not to respond. Those municipalities included in the survey and the non-respondents are shown in Figure 2.* Because the initial survey was brief and designed primarily to determine the number of Boards cognizant of contamination of private wells, it was necessary to contact most municipalities an additional time in order to solicit and clarify details of the contamination incidents. A tabular summary of the survey results appears in Appendix H.

The interim results of the first round of questionnaires were tabulated prior to initiation of follow-up and confirmation calls. Follow up was conducted for those incidents of contamination by chemicals or petroleum products for which the Commission had no other record, as well as those where the contaminant was not specified. It was assumed that the existence of correlating details of a contamination incident from two or more unrelated sources was sufficient indication of data accuracy; written documentation, such as a consultant's study, a well analysis, or a letter to some interested party, was sought for all contamination incidents. However, such documentation was often unavailable.

Lack of written confirmation or documentation does not imply that contamination did not occur. In many cases, details of contamination incidents were supplied by health board members or employees who had been participating in local affairs for a number of years; it was assumed that these individuals were able to provide an accurate depiction of the problems that have been encountered, even in the absence of physical documentation. Health board members are often informed of a contamination incident through word of mouth rather than through formal reports; this is especially true in smaller municipalities.

Conversely, there are surely a number of contamination incidents which have not been reported to a Board of Health. This might be the case when, due to the nature of the incident or the availability of alternative informational resources, the well owner chooses to cope with the contamination incident privately. Fear of decreased property values or other repercussions related to a contaminated private well might also cause the well owner to refrain from informing any public entity. Thus, information concerning the contamination of private wells is currently available in varying degrees of specificity.

The type of contaminant and severity of contamination also have a bearing not only on whether the well owner informed the Board of Health, but on whether the Board of Health considered it significant enough to report on the Commission survey. A number of respondents noted contamination by nitrates, sodium, or bacteria in answering the survey question concerning problems other than contamination, while responding "no" or "don't know" to the question regarding contamination of private wells. The Barnstable County Health Department has records of nitrates in private wells in all but three municipalities in Barnstable County, yet only five of 15 respondents from that region indicated such contamination. On-site or trace contamination may not be reported or documented, especially if the well was quickly returned to service.

Contamination is a relative term, generally defined in terms of the threat to public health or the concentration of contaminant as compared to some standard. Standards that exist for determination of contamination are based on what is considered to be "acceptable risk", because a level at which no person will ever experience adverse health effects defies definition. Determination of acceptable risk is a difficult task complicated by a number of factors. Synergistic effects may be realized where there is more than one contaminant present, and environmental and health factors such as air quality, occupational exposure to toxins, and personal habits including smoking and alcohol consumption all increase the overall risk realized when an individual is exposed to a particular compound in drinking water. While arguments can be made for more stringent standards due to synergism, a case for lower standards may sometimes be built based on antagonism. Existing standards for most chemicals assume a lifetime exposure to the toxin in the absence of all other factors that might either contribute to, override, or antagonize the effects of the contaminant. Thus, exposure to a compound fora finite period of time and in the presence of other factors will alter the actual risk associated with an exposure.

Contamination of water supplies is an immediate public health issue exclusive of environmental effects, regardless of the fact that such environmental effects may have repercussions affecting public health in the long term. A number of incidents have occurred in Massachusetts in which an aquifer has been contaminated while no drinking water supply was affected. This distinction was important in determining whether threats to water supplies or contaminated closed wells should be included in the survey results. For example, in Lunenburg, 200 private wells were threatened by contamination from industrial activities and, due to a testing error, residents were told their water supplies were contaminated. These residents were supplied water from a tank truck for approximately one month, until the error was discovered. This incident is not included in this report because contamination of a private water supply never occurred. An additional reason why threats to private wells were not included in the report is that in the absence of data on well location, it is difficult to ascertain whether the release of hazardous materials at a particular site has endangered a private water supply. Ignorance of a supply's existence precludes designation of a particular incident as threatening a private well.

Finally, contamination can not be reported until it is discovered. With the burden and expense of monitoring resting primarily on the well owner, analyses of private wells are rarely conducted on a routine basis. Municipalities where monitoring has been encouraged or subsidized have reported a greater number of contaminated wells; it is impossible to estimate the number of wells where contamination has occurred but has not yet been detected.

Although the designation and reporting of a contaminated private water supply is clouded by a number of issues, a total of 120 municipalities have reported some type of private well contamination problem. Incidents range in severity from those easily mitigated through chlorination to those requiring years of planning to implement highly technical and costly restoration programs. Some incidents affected one well, while others impacted dozens. In some municipalities, liability for contamination was easily assessed and assigned, while in others, the contaminant source remains a mystery, forcing well owners, municipalities, or the state to assume the financial burden to resolve the incident.

Figures 1 -8 depict the municipalities included in this study and those municipalities where private wells have been reported to be contaminated by various compounds. A tabular summary of the study results, including data sources, appears as Appendix H.

The survey revealed that private wells in 101 municipalities are contaminated. Information concerning the additional 19 communities was either already on file at the Commission or was received from DEQE or MDPW offices. These 19 municipalities either did not respond to the survey (Becket, Granby, Lanesborough, Mendon, Middleborough, Norfolk, and Whately), were not included in the survey (Bedford, Canton, Danvers, Newton, and Norwood), or did not know of any contamination at the time of filling out the questionnaire (Belchertown, Dedham, Easthampton, Erving, North Attleborough, Oxford, and Rowley). It is likely that either sodium, bacteria, or nitrate, has affected a private well in every municipality in the Commonwealth. However, because contamination by the three is more easily mitigated and may not present as intense of a health threat as the synthetic chemical or petroleum contaminants, such incidents may not be reported to boards of health or the board of health may not have reported them on the questionnaire. Exact figures on sodium, bacteria and nitrate contamination were not obtained as a result of the survey, thus incidents involving these three are not included in the following statistical discussion. The separate issues raised by sodium, bacteria and nitrate contamination are discussed later.

In terms of potential health threats and wells closed per incident, chemicals and pesticides have the most far reaching impacts, while petroleum products had more isolated effects. Chemical contaminants have caused the closure of 169 residential wells, one community well, and five industrial wells in a total of 33 communities. Pesticides have contaminated 77 wells in eight communities. Petroleum products have affected at least 67 wells in 20 municipalities. Table 1 shows that pesticides clearly have the most severe impacts on a community in terms of the average number of wells affected per municipality.

Pesticides have had intense effects on a few municipalities, while chemical contamination incidents are more widespread throughout the Commonwealth, and each incident is likely to affect a great number of wells. Ten of the chemical contamination incidents in eight municipalities affected more than five residences, while three petroleum product contamination incidents in four municipalities affected more than five private wells, as shown in Figures 3 and 4.

Although there is no policy stating so, it is prudent to note that DEQE was involved, either by providing testing or technical assistance, or in recommending mitigative measures, in all but one of the aforementioned incidents involving five or more wells. The exception was in Berkley, where the 1973 contamination incident was handled by the Berkley Board of Health. DEQE was also consulted or otherwise involved .in most of the other incidents involving chemical, petroleum, or pesticide contamination, except those incidents in which the source of contamination was on the same property as the contaminated well.

The usual recommendation for resolving a private well contamination problem has been a connection to a municipal water system, assuming that one exists. In a few cases where contamination was severe and a municipal system did not exist, one had to be created; this has been the case in Mashpee where chemical contamination has impacted wells in three different areas, and in Whately to address widespread pesticide contamination. Alternatively, a well owner may be able to drill a new well penetrating into an underlying uncontaminated aquifer. In some cases, installation of point-of-use treatment such as an activated carbon filter may be the appropriate response.

In the interim period until a permanent solution is implemented, most residents either drink bottled water, receive water from tank trucks, or obtain a temporary connection with a neighboring well. Residents of a few municipalities have been drinking bottled water for an extended period of time. In Leicester, Newton, Whately, and Mashpee, it has been two or more years since residents have been able to drink water from their taps. Some residents of Groton, Carver, Stow, and Westport have been relying on bottled water for six months to a year due to contamination of their private wells.

With enactment in 1987 of the Special Legislative Commission on Water Supply's bill to ensure the purity of bottled water sold commercially in the Commonwealth, Chapter 594 of the Acts of 1987, the use of bottled water protects the consumer from ingesting contaminants. However, bottled water use does not prevent exposure which may occur during showering or bathing. Toxic effects of contaminants can be realized both through skin absorption and through inhalation. It is clear that much direct contact with contaminated water occurs during bathing. In addition, when water containing any dissolved volatile compounds is aerated, as during a shower, the contaminants come out of solution to enter the air as gases, allowing exposure via inhalation. Thus, bottled water is nothing more than an interim and partial solution which can not be relied upon to protect residents from all routes of contaminant exposure.

Contaminant Sources

Many of the issues raised by private well contamination are specific to both the type of contaminant and the source of the contamination. The best response to contamination is to address the problem at the source. Different sources of contamination and methods to control them, along with the extent of their effects on private wells in Massachusetts, are described in the following sections.

Disposal of waste in an environmentally unsound manner is usually the result of ignorance, an unwillingness to incur the cost of proper disposal, and/or a lack of effort and conscience on the part of the waste generator. The federal Resource Conservation and Recovery Act and its counterpart on the state level, the Massachusetts Hazardous Waste Management Act, (MGL Chapter 21C), address the problem of ignorance by insuring that all persons handling a toxic waste are notified of its hazards and the safe methods of handling and disposal. (These two laws are further described in Appendix B.) Small quantity generators and homeowners, however, may slip through the provisions of these regulations if they are unaware of the law, or due to lax enforcement or loopholes. Thus, some users of potentially toxic contaminants may not have knowledge of the appropriate methods of disposal. This was the case in Manchester, where contamination resulted when a resident dumped rat poison in close proximity to the on-site private well. The wen owner was neither aware of the threat to groundwater posed by such an action, nor of the proper way to dispose of rat poison and other household hazardous wastes.

Given knowledge of the hazard, improper waste disposal may still occur if proper methods are too expensive or not readily available. If hazardous wastes are to be produced, they must be safely disposed of, otherwise the threat to humans and the environment can only increase. Yet without the existence of convenient, environmentally sound, and economical waste treatment, storage, and disposal facilities, hazardous wastes will continue to be improperly discarded. Industry would be attracted to a legal and inexpensive disposal method, thus rejecting illegal activities such as "midnight dumping."

Illegal dumping and disposal has accounted for contamination of private wells in Danvers, Dartmouth, Rehoboth, Sandwich, and Westford, and is the suspected cause of contamination in Belchertown, Concord, Fitchburg, Groton, Hudson, and Ipswich. Chemical waste is usually stored in 55 gallon drums, and uncounted numbers of these barrels have been found at sites statewide. In Dartmouth, Rehoboth, and Westford, corroded drums containing hazardous wastes were found first, and then testing of nearby private wells revealed contamination. However, it can take as long as 50 years for a contaminant to move along with the groundwater through the subsurface; add that to the time for the barrel to degrade and allow the contaminants to be released, and it becomes apparent that illegal dumping may not be discovered for quite some time following the dumping episode. In Fitchburg, the existence of improperly stored barrels containing chemical waste was not revealed until a well owner had his water tested after noting a foul odor; the subsequent investigation revealed the drums. In Sandwich, an illness resulted in the testing of well water quality, which led to the discovery of dumping.

While the above incidents; were the result of improper, illegal waste disposal, there are a number of incidents demonstrating the inadequacies of some legal disposal methods. Landfilling has long been the disposal method of choice, however, inadequate landfill technology combined with ignorance of the risks posed by improper landfill siting and construction has led to contamination of private wells in at least nine communities. When these landfills were built, little thought was given to the mechanisms that act in the subsurface and lead to contamination. If water enters a landfill and comes into contact with the wastes buried there, leachate (dissolved wastes) forms. If this concentrated dissolved waste is then allowed to leave the landfill impoundment, it may move, along with the normal groundwater flow, to nearby wells. Water can enter the landfill from any direction, seeping down from the surface, laterally from the sides of the landfill or, at times of high groundwater, water may infiltrate from below the impoundment.

Appropriate technology to prevent water from entering a landfill in the first place exists and is in place at all new landfills in the United States, as required by federal regulation. This technology includes the siting of all landfills in areas of low groundwater tables, and the installation of impermeable liners and barriers on all sides of the impoundment. Proper daily operation and final closure are also vital to groundwater protection. State of the art landfills have impermeable liners designed to prevent the movement of leachate from the waste impoundment to the ground. Above and below the liner are leachate collection systems, which provide for the removal and treatment of leachate.

Most older landfills were not designed with these two important safety technologies, however proper daily operation can help prevent leachate formation and migration. First, by monitoring what is disposed of in the landfill, the toxicity of leachate may be minimized. Contamination cannot occur if potential contaminants are not landfilled. However, virtually every landfill contains hazardous chemicals in some form and quantity. The accumulation in a landfill of small quantities of household waste presents a risk similar to a concentrated amount of the same waste stored in a barrel. Second, daily closure by spreading several inches of topsoil over the impoundment prevents precipitation from coming into contact with and dissolving the wastes; proper grading of the top soil can divert runoff to catch basins where the water may be treated or properly disposed.

Final closure of a landfill is also important to prevent infiltration of water from the surface and subsequent leachate formation. Similar to daily closure, impermeable caps and proper surface grading and drainage prevent precipitation from entering an impoundment. Finally, all landfiJIs, regardless of their construction, contents, or phase of operation, should have monitoring wells installed and routinely sampled. Monitoring wells both upgradient and downgradient of a landfill provide a basis for comparing groundwater quality before and after it enters the vicinity of the impoundment. Routine monitoring, even after landfill closure, ensures early detection of leachate formation and movement, and is vital to preventing contamination of nearby wells.

The communities where private wells are believed to have been contaminated by landfills are listed in Table 2. It should be noted that in all but three of the municipalities listed the landfills have not been proven to be the source of the contamination in the affected wells, although in all cases no other likely source has been identified. In Easton, an ongoing investigation is determining the extent of the contamination.

Table 2: LANDFILL CONTAMINATION

TOWN # and type of wells Year Response

Auburn 11 residentia1 1973 connect to municipal

Berkley 16 residential 1973 connect to municipal

Carver 9 residentia1 1987 pressurized tanker insta11ed

Easton under investigation

Leicester 1 residentia1 1985 bottled water/will drill new well

Mashpee 13 residential 1985 municipal system proposed

Newton 3 residential 1986 bottled water

Tyngsborough 1 community 1982 connect to Taunton municipal

Wilbraham 4 residential 1981 connect to municipal

While none of the landfill contamination incidents can be attributed to any specific technological deficiency, most were relatively old with no leachate collection system nor impermeable liner to prevent the migration of leachate. In Tyngsborough, the landfill was licensed to handle hazardous wastes, but the operator accepted such waste in a form and quantity which the landfill was inequipped for; while in Berkley, hazardous wastes were allowed to be dumped in a sanitary landfill due to some confusion over the landfill license.

It appears that all of the landfill contaminant plumes have spread considerably, affecting a large geographic area and a number of residences. In fact, landfills are the source identified as causing contamination of the greatest number of private residential wells, 57 in total. Additionally, landfill contamination affects lots and residences which do not have on-site wells. In Leicester and Newton, where the contamination only affected a few residences, the contaminated wells were the only ones in proximity to the landfill, and the areal extent of the contamination has not been delineated. In Mashpee, where 13 private wells have been contaminated by a landfill, the contaminant plume has been found to have spread across nearly 100 acres. Thus, the number of residents affected is actually much larger than the number of wells affected would indicate. Likewise, in Tyngsborough, the closure of one community well due to contamination from a landfill affected all of the residents of the condominium complex served by the well. With early detection, plume delineation, and quick remediation, the impacts to private wells may be minimized. However, without monitoring or clean up, the contamination can spread and the threat to the public health may remain.

Speedy responses can mitigate the effects of accidents or spills. Only one incident of chemical contamination of private wells was reported to be the result of an industrial accident. This occurred in Holliston, where a cyanide release from a local industry resulted in the contamination of four residential wells.

Negligent handling of petroleum products, however, has been identifed as the cause of contamination in several private wells. At junkyards or auto repair shops, various automoblile fluids may not be contained or properly discarded. In West Tisbury and Brimfield, petroleum contamination of private wells was believed to have originated from local establishments where petroleum based auto fluids were allowed to seep into the ground and contaminate the water supply. In Millbury, oil was believed to have been introduced directly into th'e groundwater during the drilling of an on-site residential well; pumping of a well on an adjacent property may have then induced the contamination to migrate to that site. Overfilling during an oil delivery in Cohasset caused spillage which is believed to have resulted in the contamination of a well on that property; overfills are common at many sites, however it is rare for spillage to be so great as to cause severe contamination. Likely the most dramatic demonstration of negligence occurred in Dartmouth, where 400 gallons of fuel oil were pumped into a water supply well mistaken for an oil intake pipe.

More than one-half of the petroleum contamination incidents occurred due to the release of products stored in underground tanks. In many of these cases, the extent of the contamination could have been decreased had the storage tank leak been detected early. Anyone who owns an underground storage tank should be apprised of the signs of a leak and the threats posed by product release. Tank owners need to know the importance of inventory control, while oil distributors and deliverers should be observant of their customers' consumption patterns in order to assist them in noting leaks early. In Truro, a tank owner was receiving fuel oil deliveries on a bimonthly basis in the summertime, an indication of abnormally high consumption which could have been due to tank leakage. Attention was not called to this aberration, however, until a private well on a neighboring lot was found to be contaminated by fuel oil. Though the two occurrences have not been confirmed to be related, the need for sensitivity to leakage is nonetheless clearly demonstrated.

Without early detection, large quantities of petroleum may unknowingly be released. The worst incident of this nature occurred in Dover in 1981, where an estimated 3000 gallons of gasoline were released from a tank belonging to Texaco. Like most of the underground storage tank leak incidents, the release was not discovered until a resident noticed petroleum taste and odor in his well water, and tested the well at his own expense. Although Texaco's response was immediate upon being notified of the contaminated well, two months had elapsed before the contamination was confirmed and Texaco notified. After the initial wellowner stopped using his well, the contamination spread, affecting a total of eight wells in Dover and 22 in Walpole.

The Dover incident was typical in that once the source was identified as a leaking tank, the tank was pumped out and removed. Texaco provided bottled water and carbon filters to affected residents until municipal water was extended to the area; the company also initiated a gas recovery progra~.

Responses to petroleum product releases from underground tanks generally follow a pattern similar to that taken in Dover. When municipal water is not available as it was in Dover and Walpole, a new source of potable water is obtained by drilling a new well. Table 3 shows a summary of the incidents in which private wells have been contaminated by petroleum releases from underground storage tanks. Although most of the incidents are unconfirmed, the proximity of the contaminated wells to the listed source supports the hypothesis.

Table 3: WELLS CONTAMINATED BY UNDERGROUND PETROLEUM STORAGE TANK LEAKS

Municipality Year # of wells Source Confirmed? Response

Ashfield 1985 1 UST on property yes new well

Auburn 1979 2 gas station no connect to municipal

Dartmouth 1987 1 auto repair shop no none yet

Dover/Walpole 1981 30 gas station yes connect to municipal

Dracut 1976 8 gas station no connectto municipal

Hingham 1983 3 gas station yes unclear

Hubbardston 1987 1 unconfirmed no none yet

Otis 1975 1 gas station yes may drill a new well

Sandwich 1987 1 gas station yes connect to municipal

Truro 1979 & 1987 2 gas station no new well became contam.

connected to mun. in 1987

Westport 1978 6 gas station (s ) no will drill a new well

Westport 1986 1 unconfirmed no none yet

Pesticides have had the most intense effects of any of the contaminants found in private wells in Massachusetts. Seventy-seven wells in eight municipalities have been contaminated by chemical pesticides. Determination of pesticide concentrations is one of the more costly types of laboratory analyses to conduct, discouraging voluntary monitoring for pesticides by individual well owners. Between 1983 and 1986, The Department of Food and Agriculture (DFA), in cooperation with DEQE and DPH, collected water samples from private wells in 27 communities; these were analyzed for eight pesticides known to occur in groundwater: ethylene dibromide (EDB), 1, 2-dichloropropane (l, 2-D), aldicarb, carbofuran, alachlor, dinoseb, 1, 3-dichloropropene (l, 3-D), and oxamyl. Sixty-one private wells containing pesticides over DEQE interim guideline levels were discovered as a result of this monitoring initiative. A total of 155 wells contained some pesticide in detectable concentrations.

Monitoring for pesticides decreased significantly in 1987, with the DFA conducting limited monitoring of private wells proximal to corn fields where the herbicides atrazine, metolachlor, and alachlor were used and suspected to be present. Sixty-five wells in seven municipalities were sampled, with six wens exceeding guideline levels for one of the three herbicides.

Additionally, four wells in Worthington were contaminated by aldicarb in March, 1982, as a result of a fire in a potato warehouse where the pesticide was stored. It was believed that the water used in extinguishing the fire came into contact with and dissolved the aldicarb. The contaminated water subsequently ran off-site to contaminate the wells. Table 4 summarizes pesticide contamination of private wells in Massachusetts.

Table 4: PRIVATE WELLS CONTAMINATED BY PESTICIDES Results of 1983 -1986 Massachusetts Interagency Pesticide Task Force Monitoring Program

Following detection of a pesticide in a private well in toxic concentrations, residents were advised to cease using the water and many turned to bottled water. In Sunderland and Worthington, residents eventually connected to the municipal system. In Whately, where no municipal system existed, and over 100 private wells either contained pesticides at some concentration or were deemed at significant risk of contamination, the state granted partial funding for construction of a public water system. In the other municipalities, through an agreement reached between the pesticide manufacturers and the affected well owners in cooperation with the Interagency Pesticide Task Force, filters have been provided and maintained by the manufacturers for all well owners whose wells contain pesticides at levels over the interim guidelines and who have chosen to participate.

Plans have not been made to restore any of the aquifers or return water supplies to service; pesticides are still in use in most of the contaminated areas.

The pesticides for which monitoring and detection has occurred in private wells in Massachusetts pose health risks ranging from skin irritation to central nervous system disorders to carcinogenicity. Factors affecting the type of physiological effects caused by pesticide exposure include the chemical makeup, the route of exposure (eg. inhalation, ingestion, or physical contact), concentration of the pesticide in the water, and duration of exposure. Allowable concentrations in drinking water for the pesticides that have been detected in Massachusetts are not mandated by law or regulation; rather, DEQE establishes interim guidelines for safe exposure levels based on available information concerning health risks. These unenforceable recommendations are designed to protect individuals who are exposed over their lifetimes to drinking water containing the pesticide at its guideline level.

Of particular concern is the continual amendment of guideline levels as toxicological data become available. Most such information shows these compounds to be more toxic than initially perceived, necessitating reduction of the recommended safe concentration. For example, the level for alachlor was recently reduced by nearly ninety percent, from 2.0 parts per billion (ppb) to 0.3 ppb; the Massachusetts interim guideline for the pesticide aldicarb is 10.0 ppb, while Wisconsin's standard is one-tenth that, at 1.0 ppb. In addition, guideline concentrations for a number of other pesticides have just recently been established; only after the detection of atrazine and metolachlor in private wells in 1987 did DEQE establish guideline levels for those pesticides.

In the absence of concrete data on risks to human health and the environment posed by pesticide use, and in light of their intrinsic toxicity, methods for limiting their proliferation need to be further explored and more seriously implemented. Because release into the environment is inherent in the use of pesticides, application must be minimized in order to decrease possible exposure. The intelligent use of pesticides may be necessary to reduce crop loss in times of emergency due to pest infestation; however, overuse of chemical pesticides can permanently alter some of the biomechanisms operating within the ecosystem. The destruction of insects which prey on pest species and the genetic selection for resistant pests which do not respond to chemical treatment are direct and common results of pesticide overuse. Consequentially, farmers apply more pesticides in greater quantities, more frequently or in more toxic concentrations in increasingly futile attempts to control chemically resistant pests in the absence of natural biological controls. The result is not only increased quantities of pesticides released into the environment, but greater costs as well. Farmers who do not use chemical pesticides have documented substantial savings in decreased pesticide purchases. The added expense of monitoring for and mitigating the effects of pesticide contamination, regardless of who bears it, dramatically escalates the cost of overreliance on pesticide use.

Sensitive pesticide use is therefore beneficial not only to the private well owner and the environment, but to the farmer as well. Careful pesticide application reduces the risks incurred in use; pesticides enter groundwater as a result of irrigation or precipitation which dissolve pesticide residues remaining on the ground, the crop, or in the air, or that drift off site during application. Once dissolved, the pesticide laden water percolates directly to the underlying aquifer or runs off to nearby surface waters or recharge areas.

The time lapse before a pesticide shows up in a well is related to the pesticide's mobility. Some pesticides are more stable than others, or have faster degradation rates. Depending on these factors, certain pesticides are more likely than others to show up in a well. However, the less pesticide available to dissolve in water; the less risk posed by its use.

Certain methods of pesticide application leave more residue available for dissolution than others. Fixed wing aerial spraying on windy days allows pesticides to drift away from the target area; higher airplane height, faster speeds, and small droplet size are also poor application techniques inconsistent with drift control. Helicopters provide more control over pesticide application than airplanes, as helicopters can hover and spray closer to the ground. Physical barriers such as trees or shrubs surrounding fields can also help prevent drift.

By far the best way to prevent contamination by pesticides is to prohibit the use of highly mobile pesticides and restrict use to those compounds which readily degrade in the environment. Alternatives to pesticide use exist and are becoming more widely accepted as practical and cost-effective, as well as environmentally sound, methods for pest control. Integrated Pest Management (IPM) utilizes various technologies to achieve pest control with limited use of chemical pesticides: predator insects not harmful to crops may be released to keep pest species in check; hybridization is used to develop crops resistant to common pests; simply plowing and tilling can destroy insect pupae and eggs which would otherwise remain in soils through the winter, thus eliminating spring emergence; crop rotation and variation within a field may eliminate the buildup of pests from season to season; ground covers can inhibit weed growth; spot spraying of pesticides is done only when pest populations are deemed to pose a significant threat to the crops.

Aside from reduced costs due to decreased pesticide purchases and improved environmental protection, IPM offers a number of other advantages. First, decreased herbicide use may result in deeper root growth and consequentially lowered moisture stress during dry periods. Second, reduced energy costs for irrigation are realized due to the decreased water needs. Third, crops grown without chemicals bring higher prices in the market. Many farmers report increased crop yields and profits as a result of implementation of IPM techniques. Most importantly, the reduction in risks to neighboring wells, residents, farmers, consumers, wildlife and livestock is well worth the efforts needed to switch from chemical pesticide use to alternative IPM techniques.

In Massachusetts, IPM programs are receiving increased attention. State funding for program implementation by the University of Massachusetts Cooperative Extension were more than doubled between FY'86 and FY'88. Additionally, grants to support research and funds for biological and biotechnological research and field trials have been made available.

Sodium is a naturally occurring constituent of water, and most Massachusetts fresh water supplies have naturally occurring sodium levels between 0.5 and 15 milligrams per liter. Excess sodium most commonly occurs as a result of the use and storage of sodium chloride as a deicer, but septic waste and home water softening units may contribute sodium to a private water supply.

The presence of sodium in drinking water is undesirable at high levels. Aside from imparting an unpleasant taste, high sodium concentrations pose dangerous health threats to certain segments of the population. Sodium intake is widely believed to be related to the development of hypertension in genetically predisposed individuals. The accepted level of 20 milligrams of sodium per liter of drinking water was designed to protect this segment of the population.

Sodium contamination is a problem faced by a number of communities in Massachusetts, the majority of which are located in the western portion of the state, where snowfall, and thus road salt use, are greater. Sodium chloride is an effective and seemingly inexpensive deicing agent, however, if the water supply contamination and related health effects resulting from road salt use are considered, then the costs of road salt use increase substantially. Although the Massachusetts Department of Public Works (MDPW) has committed over a million dollars in state budgeted appropriations in order to correct some of the problems created by road salt on state owned roads, efforts on the state and local levels to prevent such contamination are inadequate, as evidenced by the fact that a total of 38 municipalities reported private well contamination due to road salt use or storage. (Refer to Figure 6 on page 17.)

Information on sodium contamination of private wells was received from health boards and from MDPW as shown in Tables 5, 6 and 7. Those incidents listed in Tables 5 and 6 were all determined to be caused by MDPW deicing practices and MDPW bore the expense of mitigation. For the incidents reported only by Boards of Health or other sources shown in Table 7, the source of contamination was either unclear, unconfirmed, or due to municipal road salting practices.

The MDPW has a salt committee which, after receIvmg a complaint and confirming sodium contamination, reviews the incident to determine if the contamination was the result of any MDPW road salting or salt storage practices. The committee then determines what the most appropriate and cost-effective solution will be. Sodium is not easily removed from a water supply, the only available treatment technique for home use is a reverse osmosis filter, which is able to "screen" the sodium ions through a microthin semi-permeable membrane. In most cases, the MDPW has paid for the homeowners to drill a new well into a deeper, uncontaminated aquifer, or has provided for a connection to an existing municipal system. The procedure has provided homeowners with some mitigation but does not treat the cause of the problem and therefore does not constitute an adequate state response in light of the extent of the salt problem.

Contamination resulting from road salt use needs to be further addressed through reduced salting programs. Some reduced or altered salting practices have already been implemented by MDPW on state roads, and many municipalities have instituted road salt reductions on the local level. Efforts by MDPW to minimize the negative impact of deicing salt use include the purchase of calibrated spreaders and improved operator training. In many instances, these practices have resulted in a reduction in the amount of sodium chloride used per lane mile per application. However reductions in the quantity of salt applied per lane mile per application are not beneficial if the number of applications is increased.

Massachusetts' standard salt application rate of 300 pounds per lane mile on primary roadways is the highest in New England and other neighboring states. Connecticut's application rate ranges from 150 to 160 pounds per lane mile. Maine applies salt at a level of 175 pounds per lane mile in temperatures above 20 0 F. New York, Vermont, and New Hampshire have application rates of 250 pounds per lane mile.

Table 5: SODIUM CONTAMINATION: REPORTED BY MDPW

Table 6: SODIUM CONTAMINATION: REPORTED BY MDPW AND BOARDS OF HEALTH

MUNICIPALITY YEAR # of wells Response

Conway 1986 1 new well

Dudley 1986 1 redirecting drainage

Goshen 1970 20 new wells

Lakeville 1982 8-12 filters

Petersham 1985 1 new well

1986 1 will drill a new well

1987 1 will drill a new well

Table 7: SODIUM CONTAMINATION: REPORTED BY BOARDS OF HEALTH OR OTHERS

In 1976, MDPW reduced the salt application rate for primary roads from 350 pounds per lane mile to 300 pounds per lane mile. In the winter of 1986-1987, the MDPW implemented new road salting practices in certain areas. All secondary roads received a one-half salt, one-half sand mixture. A 4:1 sand to salt mixture was applied to roads on the Cape, although Route 6 and a portion of Route 28 received a 1:1 mix. Additionally, MDPW designated 12 test areas statewide in which deicing was achieved with a 1:1 sand to salt mixture. MDPW also conducted water quality monitoring in these regions to determine the impact of these changes. These experiments proved that road salt application practices could be modified without sacrificing public safety on the roads.

Further sodium reductions need to be implemented in and around environmentally sensitive areas, such as water supply recharge areas, wetlands, rivers, streams, and ponds. Cooperative agreements have been negotiated between MDPW and the towns of Belchertown, Cummington, Goshen, and Pelham to reduce the use of road salt where water supplies are threatened. These agreements were worked out with the assistance of the Lower Pioneer Valley Regional Planning Council and the Office of Planning and Program Management of DEQE. The restricted salting areas were chosen based on careful analysis of aquifers and recharge areas, and of the damage to water supplies that has already occurred. Specific Best Management Practices (BMPs) have been developed for each designated area based on level-of-service criteria for the roadway. BMPs include establishing appropriate sand to salt ratios, application rates and procedures, and careful storage and handling. The salt application rate in these. pilot areas was to be reduced from the state level of 300 pounds per lane mile per application to approximately 100 pounds per lane mile per applicaHon.

The program began in the winter of 1983-1984 when an average of 94 pounds per lane mile per application was applied along a stretch of Route 9 in Goshen. The following winter, the test area was extended to include portions of Route 9 in Belchertown and Cummington, and of Route 202 in Belchertown and Pelham. Salt application rates were kept well below the target of 100 pounds per lane mile in Pelham and Belchertown without any negative impact on road conditions. Though no complaints were received regarding the sections of Route 9 in Cummington and Goshen, the salt application rate in those areas was higher than that desired. Cummington's test area received 122 pounds per lane mile per application, and Goshen's rate increased from 94 pounds per lane mile in 1983-1984 to 169 pounds per lane mile in 1985-1986. The total quantity of salt used in the test area in Goshen increased by 10, 000 pounds in the two-year period due to improper administrative implementation of the program by MDPW.

The Lower Pioneer Valley Planning Council and DEQE have been monitoring wells in the test areas to determine if reduced salting is resulting in lowered sodium concentrations. However, significant changes are not expected to appear for another five to ten years due to sodium residuals that have built up in the soils over previous winters.

The reduced salting experiment on Route 9 and 202 in western Massachusetts has included an evaluation of the impact of reduced salting on road safety. In fact, one study concerning the impact of reduced salting indicated that although there was an increase in minor accidents, there was a decrease in accidents resulting in injury.

MDPW moderately increased the number of areas receiving modified salt applications in the winter of 1987-1988. The efforts of the DPW remain focused on public water supplies and operational tests. While the Route 202 and Route 9 experiments in western Massachusetts and the reductions on the Cape will benefit private wells, widespread improvements in the impact of state salting practices on private wells will not occur until broader changes are made in MDPW methods. MDPW has resisted permanent modifications pending the drafting of a Generic Environmental Impact Report (GEIR) on road salting. The report, delayed over two years, is presently being developed and is expected in the early fall of 1988.

Contamination resulting directly from the improper siting or construction of an on-site water supply well is usually manifested as a coliform bacteria or nitrate problem. Table 8 shows which municipalities have indicated a bacterial or nitrate contamination problem.

Both bacteria and nitrates are contained in septic waste. If a septic system is malfunctioning or improperly sized, designed, or installed, then these contaminants may migrate to a well. In order to set forth minimum uniform standards for septic system design and installation, Title 5 of the state environmental code became effective in 1975. The provisions of Title 5 include minimum soil conditions and lateral distances between septic systems and wells. The standards enhance the protection of private wells by allowing for

degradation and digestion of septic waste in the subsurface, given normal groundwater variations and septic loads. The enforcement of Title 5 by municipal entities has undoubtedly dramatically reduced the number of wells contaminated by septic waste. Unfortunately, exact historical figures on this type of contamination are lacking, and there is therefore no real basis for comparison.

Title 5 is a minimum regulation and its enforcement helps protect private wells in most locales. However, it has been necessary in many municipalities to pass more stringent regulations in order to ensure adequate protection. Twenty-six municipalities indicated that they had expanded on Title 5, Most increased the required distance between components of septic systems and wells to help prevent contamination by allowing for degradation of bacteria and sufficient distance for nitrate attenuation. Limiting the times of year in which percolation tests may be performed also provides for proper siting in areas where seasonal fluctuations in groundwater table levels and soil saturation may render some sites inappropriate for septage disposal.

Setting stricter design standards for septic tank and leaching field sizing may be necessary where wastewater flow is expected to exceed normal variations. Proper sizing is vital to protect against system failure. Septic system overload will result in bacterial contamination if there is insufficient distance between the system and the well for any undigested bacteria to degrade before reaching the well. While most bacteria do not pose a health threat, certain pathogenic bacteria may be present in human waste, thus it is important to maintain this protective distance.

Because nitrates do not undergo significant transformation within the environment, an appropriately dimensioned leaching field is the most reliable means for protecting private wells from nitrate contamination. The leaching field ensures proper dilution of nitrate concentrations by distributing the septic tank effluent over a sufficient land area. Nitrate concentrations may also be decreased through vegetative , uptake of nitrate, which can provide the important plant growth nutrient nitrogen. Lush grass is often observed growing over leaching fields as a result of this fertilizing effect. Additionally, private wells are afforded protection from nitrate contamination by both the lateral and vertical distances between the leaching field and the well screen, as sufficient areal space allows for dispersion of nitrate concentration once the effluent leaves the leaching facility.

Not only is the placement of a private well in relation to a leaching facility or other potential contaminant source important, but factors such as the type of soil in which the well is drilled, how the well is screened and sealed, and whether it is securely covered all affect the likelihood of contamination, as shown in Figure 9.

As depicted in Figure 9, bacteria can enter an improperly constructed or uncovered well from the surface as well as from septic systems. This is a more common cause of bacterial contamination, affecting the 17 municipalities listed in Table 9.

Draft regulations, often referred to as Title 6, exist to govern the construction and installation of private wells. Some municipalities have adopted the draft Title 6, or a modification thereof, as a Board of Health regulation to help prevent contamination realized by improper well design and construction. A summary of the components of the draft recommendations appears as Appendix C. The document is currently undergoing review within DEQE. A revised version is expected to be issued as official guidelines by the summer of 1988.

While regulations can address the problems of septic system and well construction and placement for new installations, they have not resolved substandard conditions on existing lots. Many homes have been built on lots which are too small to accommodate even the minimum distances between septic systems and wells required by Title 5, or which do not have appropriate soils or groundwater levels to allow proper leaching of septic waste. Additionally, no protective distances are required between new installations and wells on adjacent lots. Thus, bacteria and nitrate contamination incidents continue to occur.

Disinfection by chlorination is often a sufficient response for bacterial contamination, however a more complex solution may be necessary, depending on the specific nature of the problem. Improper seals, grading, or covering are relatively simple problems to correct. However, if the contamination was caused by a poorly placed or sized septic system, or if the well or its casing is in great disrepair, contamination will recur unless the deficiencies are corrected. In some cases the only reasonable solution is to drill a new well or to install a new septic system.

Even with the best functioning septic facility and the appropriate placement of wells, contamination may still occur if the septage contains household hazardous waste. Chemicals contained in cleaners, detergents, drain openers, pest control products, aerosol products, and septic system cleaners do not degrade in a septic system or in subsurface soils. In order to prevent contamination of nearby private wells, those products should not be disposed of or used in septic facilities. Such practices are believed to have been the source of trace concentrations of volatile organic chemicals in three wells in Mattapoisett, one well in Bolton, and one in Townsend. These incidents were resolved by pumping the wells to waste until uncontaminated groundwater was drawn in.

It is likely that contamination of private wells by household hazardous waste is more widespread than the survey results indicate. Education as to the proper methods of use and disposal of household chemicals is vital to prevent fUr!ther contamination. In addition, some communities in the Commonwealth have instituted collection and recycling programs to aid residents in the proper disposal of household hazardous waste. The Office of Solid Waste Management in the Massachusetts Department of Environmental Management administers a grants program to encourage the proper disposal of household hazardous wastes. Information on this program appears in Appendix D.

Metals, Radionuclides, and Non-metals

Massachusetts' aquifers are composed of complex geologic deposits which differ statewide. The formations in which wells are drilled contain various elements, some of which are soluble in water. Whether water moving through the rock or soil dissolves the naturally occurring elements is dependent on the water's oxygen content and acidity. Contamination by iron, manganese, uranium, radon, and arsenic has occurred in regions of Massachusetts where these constituents are contained in the rock or soil.

A number of health boards reported that private wells! in their community contain iron and/or manganese in concentrations causing aesthetic problems. Iron and manganese often occur together in soils. The anaerobic conditions underground enable the dissolution of these metals in groundwater. On exposure to air, iron and manganese precipitate out of the water as small particles which discolor the water. The iron or manganese may be deposited on plumbing fixtures, especially those made of ceramic, and can stain laundry and cooking utensils. Water containing these elements is not dangerous to consume, as at toxic levels it is too unappealing to drink. Those municipalities specifying iron or manganese contamination are identified in Appendix G.

Like iron and manganese, radionuclides also occur in the subsurface and dissolve in water under low oxygen conditions. The radionuclides which Massachusetts water supplies are primarily at risk of contamination by are uranium and radon. Radon, which is produced when uranium decays, is usually associated with air pollution. However, radon may be dissolved in water and can be released into the atmosphere when tap water is exposed to air.

DEQE has reported that one private well in Tyngsborough contains uranium and selenium at concentrations exceeding accepted water quality standards. Additionally, a limited survey conducted by DEQE revealed radon concentrations between 200 and 11, 000 picocuries per liter in 24 selected wells statewide. The Massachusetts guideline for radon is 10, 000 picocuries per liter.

Because laboratory analysis for radionuclides is prohibitively expensive, such testing has not occurred on a widespread basis. It is likely that further testing in at-risk areas would reveal additional contamination of private wells by uranium or radon. Due to the geochemical processes which occur in the subsurface, there exist pockets in certain bedrock areas where uranium and radon are present in higher concentrations than were revealed by DEQE's limited survey.

Arsenic is commonly found in the same geologic formations as uranium and radon. Thirty--five private wells in Pepperell and 8 private wells in Amesbury, Holden, Lancaster, Norfolk, and Westford have been closed due to arsenic contamination. An extensive study of arsenic contamination in Pepperell determined that some arsenic may have been contributed by the use of arsenical pesticides in the early part of this century. However, learned opinions vary on that point. It is clear that the natural occurrence of arsenic in groundwater is a significant problem in parts of Massachusetts.

Saltwater Intrusion

Edgartown and Nantucket both reported that private wells along the coast had been closed due to saltwater intrusion. In the subsurface of coastal areas there exists an interface between saline and fresh groundwater. If a well is drilled too close to this boundary, or if an excessive pumping rate is used, saline water may be drawn in, rendering the water unpotable. It is likely that the intrusion of saltwater into private wells has occurred in most coastal communities in Massachusetts.

SECTION II: SUPPLEMENTAL QUESTIONS: Methods and Issues

I. How many private wells exist in your community?

Response to this question varied from "no record" to exact figures. Seventy-four municipalities have no figures on location or number of residential wells in their communities.

Clearly, figures on private well existence and location need to be generated and updated. Contamination and other issues are difficult to address without a reliable base of information on these wells. In many cases contamination can be prevented given knowledge of a well's existence and location. For example, well owners could be informed of an oil spill or storage tank leak upon occurrence and take preventive action; temporarily halting use of a well in such cases may decrease the rate of movement of a contaminant plume, allowing contaminant recovery to occur more quickly and with less difficulty. However, such preventive measures can not take place in the absence of records on location of wells. With less than one half of the survey respondents indicating specific accurate records of private wells, it is obvious that there is a data deficiency which must be corrected.

II. Has your municipality been contacted in the past five years by any private well owner(s) relative to problems other than contamination?

Seventy-three respondents replied affirmatively to this question, citing problems from one of three basic categories: concern about the threat of contamination; decreased water quality, some due to naturally occurring contaminants; and lack of adequate pressure or other quantity related problems. The number of respondents mentioning each topic are shown in Table 10, and Appendix G contains the corresponding town list.

Table 10: PROBLEMS OTHER THAN CONTAMINATION

Concern regarding threat of contamination 13

Decreased quality and/or natural contaminants 21

Quantity related 42

Other 5

Subtotal 81

(More than one response) (-8)

Total 73

It is important that potential contaminant sources are identified and monitored to facilitate early detection of contaminant releases. Well owner concern about activities occurring in the proximity of their source of water supply is an encouraging indication of an awareness which may help avert the spread of contamination. By taking an active role in identifying threats of contamination and having their well water tested regularly at a certified laboratory, well owners have the opportunity to participate in preventive actions, which are usually less costly than cleanup efforts. Boards of Health, in their capacity as information disseminators, need to respond to well owner concerns about water quality threats by educating residents about the dangers posed by various land uses and the signs of various types of contamination.

Health boards can also help residents distinguish between naturally occurring and human related contamination. Iron and manganese are ubiquitous constituents of the geologic deposits which compose many of Massachusetts' aquifers; these two elements commonly exist at unacceptable levels in private wells. However, water containing iron or manganese at levels dangerous to consume possesses an unappealing taste and color, thus precluding the possibility of a health threat. Hydrogen sulfide gas may be present in wells proximal to wetlands, though only one respondent indicated hydrogen sulfide as a problem in their community. The gas, which is not dangerous to consume, imparts an unpleasant taste and odor to a water supply but is easily removed via aeration or filtration devices installed at the point-of-use.

The most commonly cited problems other than contamination were relative to quantity issues. These are usually manifested in areas where too many wells have been installed or where pumping has exceeded aquifer capacity. Forty-two respondents noted complaints such as wells going dry, decreased water pressure or other flow problems, and noticeable drops in the water table. Quantity issues surfaced statewide, and because there exists an accurate understanding of where the basin-wide shortages are, these problems are more likely impacts of localized activities.

III. Does your municipality have any bylaws or ordinances aimed at protecting private wells from contamination?

Ninety-one municipalities indicated that they had some regulatory measure in place. These ranged from aquifer protection districts to well installation guidelines and permitting regulations to increased setback requirements. Confusion over state regulatory measures became apparent in analyzing the response to this question. Many respondents replied affirmatively stating that their municipality enforced setbacks corresponding to Title 5 or that they required a quality analysis before issuance of a building permit. These two are state requirements and are not meant to be enforced at a community's discretion. This interpretational difficulty was compounded by the phrasing of the question, which did not make clear the distinction between statewide regulations and local bylaws or ordinances.

It has nonetheless become apparent that a number of health boards are (1) not aware of their responsibilities and capabilities concerning private well protection and (2) are not implementing or enforcing protection measures where they are needed. These assertions are substantiated by both the confusion observed over state versus local regulation, as well as the significant number of contaminated private wells statewide. Title 5 is a minimum state regulation governing the design and installation of on-site subsurface sewage disposal systems; one of the primary purposes of the provisions of Title 5 is the protection of groundwater supplies and private wells. Local geologic and climatic conditions, however, often dictate the implementation of stricter standards for on-site sewage disposal to protect the public health. Boards of Health have the authority and the responsibility to strengthen Title 5 by regulation where appropriate.

Health boards can also protect private wells through enforcement of setbacks and permitting programs for new well installations. By controlling where private wells are drilled in relation to potential contaminant sources such as septic systems on neighboring properties, abutting roadways and adjacent land uses, health boards can help abate the potential for contamination. Boards of health can also effect private well protection by influencing the passage and enforcement of municipal bylaws or ordinances which may offer protective mechanisms. These would include bylaws regulating hazardous materials and underground storage tanks, as well as comprehensive groundwater protection plans and aquifer protection districts. Appendix A includes the addresses of some organizations which may be of assistance in bylaw development and adoption. Appendix C outlines the components of a private well installation regulation.

It is inappropriate to attempt to correlate the existence of a protection measure and the occurrence of private well contamination based on this survey. Although the questionnaire included a request for copies of applicable local regulations, not all respondents complied with this request, thus making it difficult to ascertain exactly what the regulation or bylaw was aimed at, and when it was passed in relation to existing contamination. Only four communities listed aquifer protection districts in response to this question, indicating that where these measures are in place, they are not directed at protecting private water supplies.

IV. Does your municipality have a monitoring program or similar strategy aimed at ensuring the potability of private wells?

Twenty-three municipalities indicated the existence of some type of water quality monitoring in their municipality. Many respondents noted the state requirement of proof of potable water supply prior to issuance of a building permit, and others require quality analyses for new well installations through bylaws or Board of Health regulations, however these were not included in the count of 23. Half of these monitoring programs are site-specific, where wells surrounding an area of existing or potential contamination, such as a landfill or agricultural area, are analyzed on a regular basis to ensure early detection of the spread of contamination. Appendix F summarizes the programs in those 23 municipalities who responded affirmatively to this question.

Acton, Boxford and Hampden specified that a voluntary program for the testing of private wells is offered at regular intervals. Residents of Sudbury and West Boylston are provided the opportunity to have their well water tested when the municipal water is analyzed. The Stow Board of Health provides testing and subsidizes the cost of analysis. Some municipalities offer the testing service on request at well owner expense. A once-through testing program was conducted in Eastham by the Cape Cod Aquifer Management Project, thus providing a snap shot of the quality of private wells in that community.

While a monitoring program cannot prevent contamination, it does establish a valuable base of information on the types of contamination problems that may be occurring within a community. With this information, additional monitoring schedules can be appropriately framed. Where contamination is discovered, mitigative measures can be developed and methods to prevent contaminant dispersion implemented. Negative test results not only reassure residents of the potability of their supply, but also serve as a basis for comparison in the event of future contamination.

In addition, town-wide monitoring programs can heighten well owner awareness of potential problems and may encourage them to perform subsequent analyses on their own to ensure continued potability. In the absence of routine testing, contamination may not be discovered until it has become widely dispersed, making mitigation and clean up more difficult, creating a situation where prolonged exposure to contaminated drinking water can occur. Whether testing is provided, subsidized, or merely encouraged, it is a vital component of good private well maintenance and protection practices. Appendix E contains a sample form letter with recommendations on what to monitor for, and includes a list certified laboratories. Health boards may send the letter to well owners to promote water quality monitoring.

CONCLUSIONS

Private well contamination is a problem in Massachusetts which encompasses a range of issues from data management to citizen education to environmental law enforcement. This study is a first step toward controlling further contamination of private wells, which in itself is an integral piece of the statewide agenda for protecting and restoring the quality of the environment in Massachusetts. The Board of Health survey and related research revealed that residential well contamination is widespread, with more than one-third of Massachusetts municipalities reporting some contamination problem. While existing mechanisms for resolving contamination are operative, additional efforts are clearly needed to provide consistent access to assistance and to prevent continued contamination of private wells and the environment.

With over 600 contaminated wells having been identified without a comprehensive testing program, it is alarming to imagine the number of contaminated wells such a program would reveal. It is likely that in every municipality there is at least one private well which contains some contaminant in a concentration exceeding recommended levels. Citizens consuming tainted water supplies may not even be aware of the possibility that their water is impure. Most well owners do not conduct routine quality analyses, a vital component of well maintenance which can reveal otherwise undetectable contamination. Early detection of contamination will not only protect the well owner's health, but may also prevent the spread of contaminants to adjacent wells.

Even early detection may not protect the public health if the proper response is not implemented. Such was the case in Dover and Walpole where, following the discovery of gasoline contamination in his well, a well owner ceased pumping. When in use, the well had effectively been intercepting the contaminant plume, preventing its spread. After the resident stopped using his well, the contaminated groundwater was able to move past the first well, subsequently dispersing throughout the area and contaminating 29 neighboring wells. Even if the well owner had understood the ramifications of interruption of the pumping of his well, he could not have informed his neighbors of the threat of contamination without records of their well locations.

The lack of data on well locations also leads to difficulty in preventing contamination before it occurs. Statewide, wells are installed in proximity to potentially contaminating land uses, and new land uses are being allowed where they threaten existing wells. Contamination prevention can occur in conjunction with growth, be it residential, commercial, or industrial, but if a water supply well and a potential contaminant source are to coexist, safeguards must be imposed. This is where municipal efforts are dangerously deficient, as demonstrated by the incidents of contamination which have affected at least 636 private wells in Massachusetts. Virtually everyone of these incidents is the result of an adjacent incompatible land use activity occurring in the absence of contamination prevention safeguards. Many of these incidents could have been prevented through more careful well construction and installation, but the majority were caused by environmentally unsound practices: improper waste disposal, insecure storage of toxic materials, excessive road salt use, and improper pesticide use or storage.

Contamination prevention and control must occur on a number of levels. Well owners must routinely test the quality of their water supplies, maintain their septic systems, and practice safe disposal of household wastes. Equally as important, nearby land users whose activities may threaten a water supply must be sensitive to the environment and willing to modify their practices to allow coexistence with private wells. In addition, the local, state, and federal government can foster protection of on-site wells through the implementation and enforcement of existing regulating statutes as well as the passage of new measures where appropriate. Continued research is needed to address the ever changing issues raised by contamination and to assess the available means for governing potential contaminating sources by education and regulation.

Education is of primary importance on all levels. For example, while the means for protecting against bacterial contamination are widely available and well understood, such contamination continues to occur as variances are granted allowing septic systems to be installed in unsuitable soils or undersized lots. Local decision makers need to become apprised of the sensitivity of groundwater supplies. Homeowners can protect themselves from many sources of contamination by learning the standards for design, installation, and maintenance of their wells and septic systems.

Land users must become more sensitive to the effects of their activities on the environment. Certain processes, such as the application of pesticides, road salt, or fertilizers, can be modified to reduce the threat to private wells. Hazardous chemical waste generators and users of petroleum products can implement safe handling and disposal methods to alleviate risks. In the absence of sensitivity by potential contaminators, the incentive for water supply protection may be fostered through strengthened enforcement of protective regulations, including prosecution of polluters. The price for polluting the environment and threatening the public health must exceed the price differential between inappropriate and appropriate use, handling, and disposal of toxins.

RECOMMENDATIONS

In order to address the issues and problems identified in this report, the Commission offers the following recommendations:

The lack of data on private well locations is a serious deficiency. Without such data, systematic mOhitoring and protection can not occur, ahd technically sound responses to contamination can not be properly designed. Thus, the first step in enhancing protection of private wells is the compilation of data bases at the state and local levels on the location of private wells.

Local governments or Boards of Health can create their own data bases through well permitting programs and the use of Conservation Commission records and building inspectors permits. Conservation Commissions have plans for all projects, including private well installations, that occur within 100 feet of wetlands. Massachusetts General Laws Chapter 40 Section 54A requires proof of a potable water supply prior to issuance of a building permit; if this law has been enforced, then municipalities should have information on file on wells installed since enactment of the law. Unfortunately, though the law was passed in 1974, a recent survey by the Franklin and Hampshire County Cooperative Extension Service found that of 67 municipalities in central and western Massachusetts, only three have been enforcing that law since its enactment, while 10 stated that they have never enforced the law. This law needs to be enforced uniformly and expanded to require a chemical scan in the determination of potability; amendment of Chapter 40 Section 54A in this manner will not only protect the public health but will allow for efficient utilization of the information generated.

The Division of Water Resources currently receives well drillers' reports on the location, yield, and geology of all wells installed in Massachusetts. Data is received on cards which are filed and available for use by agencies and individuals. The logs date back approximately 20 years, including well reports from the late 1960's. The files need to be reorganized and evaluated for accuracy. Once that is accomplished, the information can be entered into a computer data base along with available municipal data, and relevant records from DEQE Division of Water Supply and MDPW. The creation of a comprehensive data base on private wells is vital to private well protection statewide.

Boards of Health are statutorily the local source of assistance and information for well owners. Many boards are understaffed and ill equipped to deal with such requests. Additionally, the survey revealed that there are a minority of health board members who are unaware of their jurisdiction over private wells. A few respondents were not only ignorant of their responsibilities in this area, but were markedly hostile toward the suggestion that private well contamination might be of concern to them.

The distinct need exists for an enhanced capability on the local level to respond to requests for information and assistance, and on the state level to provide reliable information to health boards as well as to respond to individual inquiries. State assistance is needed to enable local entities to respond to contamination on their own, thus decreasing the instances in which the state must step in to handle contamination mitigation. To achieve private well protection, the realm in which state assistance is offered needs to be extended to include municipalities lacking sufficient capacity to implement preventive measures such as land use regulation, well installation standards, and quality monitoring. Various state and private organizations, some of which are listed in Appendix A, currently provide information and technical materials on request. However, outreach directed at local officials having jurisdiction over private wells, and at private well owners themselves, can provide increased consistency in the arena of private well and groundwater protection.

To this end, the Commission recommends expansion of the capabilities of the Department of Public Health (DPH) to establish an office for private well information assistance and referral. Funding of a position within the FY'89 budget would enable the Office of Local Assistance in DPH to provide this much needed service. A private well office would provide a central information clearinghouse for requests, design and distribute educational material directed at well owners, local officials, and land users, and hold workshops for health board members to increase their ability to accomplish their mandated responsibilities.

Where municipalities do not have the capability to respond to a contamination incident, state assistance has been provided, although somewhat inconsistently. Attempts to establish a correlation between state involvement and type of contaminant, nature of source, extent of contamination, or municipal population yielded no systematic response mechanism. A private well office could help respond to contamination incidents by directing health boards and well owners to the appropriate state agency when it is determined that such assistance is necessary.

Additionally, technical assistance is needed to supplement Board of Health capabilities to provide on-site consultations and lab work. Aid of this nature is currently available through regional health offices and certain county health departments; the existing capabilities need to be enhanced in order to provide consistency in the level of assistance available to citizens statewide.

The Commission also recommends a program of limited financial aid for well owners lacking alternatives for relief from contamination. Chapter 21E and the Solid Waste Act of 1987 require that liable parties compensate affected well owners for the costs of mitigating contamination. .However, in Leicester and Newton, the refusal of any entity to accept responsibility for contamination or to provide water suitable for drinking, bathing, and washing, has left four families in those towns without adequate water supplies for an extended period of time. The expense and complexity of development of a permanent solution to a private well contamination incident has also caused lengthy delays in Groton, Mashpee, and Whately. Citizens of Massachusetts are guaranteed the right to clean water in Article 90 of the state Constitution; it is an embarrasment to the Commonwealth that any of its citizens do not have access to potable water because they lack the financial resources to acquire a suitable supply when their well has been contaminated by an outside source. A low interest or no interest loan, or a revolving fund would meet the needs of persons who can not obtain a water supply under extenuating circumstances, without shifting the responsibility of mitigation to the state. The Commission recommends the establishment of such a fund.

Efforts to prevent contamination through control of potential contaminant sources need to be increased. The expense of remediation of contamination far exceeds any costs which may be incurred in prevention. Additionally, contamination results in unquantifiable but grave costs in public health risks and damage to the environment.. A clear majority of the private well contamination incidents described in this report were remediated via provision of a connection to a municipal water system or through drilling a new well. Though the former two options may represent the most cost-effective solution for protection of public health, neither addresses the hazard which remains when contaminants are not removed from the aquifer. Without aquifer reclamation, which in itself is a costly and time consuming process, contaminants remain in the environment causing subsequent damage to other water supplies and wildlife, and disrupting the ecological balance. As further damage occurs, it finally becomes apparent that the solution to a contamination incident does not consist solely of providing alternative water supplies to well owners; as time elapses the eventual expense and complexity of clean up escalates along with the damage.

The obvious alternative to costly remediation is prevention of contamination. Regulatory mechanisms have been proposed or exist and need to be modified to achieve comprehensive private well protection. These have been described in the body of this document and are noted below:

Title 5: The state sanitary code should be modified to increase required setbacks between septic systems and wells, to limit the times of year in which soil suitability tests may be performed, to account for groundwater flow, and to restrict allowable soil types and groundwater levels.

Guidelines for the Installation of Private Wells: Although these currently exist in draft form, they need to be revised and issued as official guidelines.

Underground Storage Tanks: Legislation relative to the protection of the environment through regulation of storage of oil and hazardous materials in underground storage tanks should be enacted.

Pesticides: Legislation to reform the Massachusetts Pesticide Management Act should be enacted, with the inclusion of private wells as critical areas in which pesticide use is restricted.

Road Salt: The Commission's legislation, S -917 of 1988, relative to the protection of water supplies from sodium chloride and other deicing chemicals should be enacted.

Septic Cleaners: The Commission's legislation, S -915 of 1988, regulating sewage system cleaners and additives should be enacted.

Industry Source Reduction: The capabilities of the state's Source Reduction program need to be supplemented and greater incentives for industrial source reduction created.

Through cooperative efforts among government, land users, and well owners, private well contamination can be prevented and public health protected. Regulation, education, and sensitivity must combine to ensure protection of the environment, particularly the groundwater resource, and thus halt continued contamination of private wells throughout the Commonwealth.

APPENDICES

A number of private and public entities statewide can provide information or assistance with private well matters. Some of these departments, organizations, and agencies are listed below.

The following state agencies may be able to provide information or assistance to individuals or health board members requiring help with private well issues.

Department of Environmental Quality Engineering

Department of Public Health

For publications relating to private wells and groundwater protection, including model bylaws, contact:

Association for the Preservation of Cape Cod

Conservation Law Foundation

Massachusetts Audubon Society

Other agencies and associations which may be able to provide assistance or answer questions concerning private wells include:

Rural Community Assistance Program 218 CentralStreet Winchendon, MA 01475

(617) 297-1376

Massachusetts Association of Health Boards 111 Atlantic Avenue Cohasset, MA 02025

(617) 383-0693

Regional Planning Agencies:

Berkshire County Pittsfield (413) 442-1521

Cape Cod Barnstable (617) 362-2511

Central Massachusetts Worcester (617) 756-7717

Franklin County , Greenfield (413) 774-3167

Pioneer Valley West Springfield (413) 781-6045

Martha's Vineyard Oak Bluffs (617) 693-3453

Merrimack Valley Haverhill (617) 374-0519

County Cooperative Extension Services:

Barnstable County Barnstable (617) 362-2511

Berkshire County Pittsfield (413) 448-8285

Bristol County Segreganset (617) 669-6744

Dukes County Oak Bluffs (617) 693-0694

Essex County Hathorne (617) 774-0050

Franklin County Greenfield (413) 774-2902

Hampden County West Springfield (413) 736-7204

Metropolitan Area Boston (617) ~51-2770

Montachusett (617) 345-7376

Nantucket Nantucket (617) 228-6800

Northern Middlesex Lowell (617) 454-8021

Old Colony Brockton (617) 583-1833

Southeastern Regional Taunton (617) 824-1367

Hampshire County Northampton (413) 584-2556

Middlesex County Concord (617) 369-4845

Norfolk County Walpole (617) 668-0268

Plymouth County Hanson (617) 293-3541

Suffolk County Boston (617) 727-4107

Worcester County Leicester (617) 892-1116

APPENDIX B POLICIES, REGULATIONS, AND LAWS

In February, 1987, the Massachusetts Water Resources Commission adopted a policy statement concerning private water supplies. The policy defines state and local authority relating to private wells and addresses four areas of concern: planning and protection, standards and guidelines, contamination, and testing and monitoring. Consistent with other state water policies, the prevention of contamination utilizing proactive techniques is stressed. The policy also calls for the expansion of state standards, guidelines and requirements to apply to the development and maintenance of private wells; because the proper installation of a well impacts the quality of the water at the tap, this element is vital to maintain the policy focus on prevention.

In the absence of state standards, some municipalities have adopted their own regulations governing well installation, instituting a means for local inventory of new wells and consumer protection from any contamination which might occur as a result of improper well development. Such contamination, should it occur, remains the responsibility of the well owner, and the local board of health should be in a position to assist well owners in coping with contamination. However, where, due to the nature or extent of the contamination, local capabilities are insufficient to adequately respond to a problem, state resources may be utilized.

Although federal and state regulations do not specifically relate to private wells, they have addressed contamination of the environment through the preventive means of controlling actual and potential sources of contamination. The transport, use, and storage of most hazardous substances, including petroleum products, chemicals, and pesticides, are governed by various laws at the federal, state, and often local levels. Additionally, liability for the release of oil or hazardous materials into the environment is statutorily defined in both federal and state law.

The Toxic Substances Control Act (TOSCA) and the Resource Conservation and Recovery Act (RCRA) were both enacted into federal law in 1976. Together, the two statutes control the production, movement, and disposal of most chemicals as they are used and subsequently transformed into hazardous wastes. To address the problem of wastes disposed of in an environmentally unsound manner, the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, also known as Superfund) was passed in 1980.

TOSCA is essentially a regulatory control of the creation and distribution of synthetic chemicals. In requiring the EPA to collect information on the characteristics and effects of all existing and new synthetic chemicals to human health and the environment, TOSCA seeks to ensure that uncontrollable or excessively dangerous chemicals are not used. The law does recognize that worthwhile benefits may be associated with many hazardous chemicals, thus the EPA has discretion in regulating particular substances. While for some compounds a complete ban may be necessary to eliminate risk to the public or the environment, a warning label may allow sufficient risk abatement in light of possible benefits realized by many potentially toxic substances. Such is the case with most prescription medication, household cleaners, and insect killers approved for use.

Given that TOSCA allows the use and distribution of a number of synthetic chemicals which may be toxic or hazardous if mismanaged, Congress passed RCRA in order to ensure proper management of hazardous wastes. RCRA established a manifest system in which a document follows a hazardous waste from the time of generation to the point of ultimate disposal, a means of tracking the quantity and fate of all wastes. Because RCRA provides for state implementation, Massachusetts enacted MGL Chapter 21C, the Massachusetts Hazardous Waste Management Act, in 1979. This law conforms to the provisions of RCRA while providing for implementation of the law on the state level.

Likewise, a number of Massachusetts communities have adopted their own hazardous materials bylaws. The adoption of a local bylaw regulating hazardous materials provides the community with the opportunity for close control over hazardous materials used and generated in the locality, as well as ensuring that these materials are not used, disposed of, or transported through sensitive local areas. Additionally, through local action, municipalities can refine the definition of a hazardous waste, which in RCRA and in Chapter 21C, does not specifically include any petroleum products.

RCRA and its counterparts on the state and local levels establish the framework for the regulation of hazardous waste. Even with the myriad of laws and regulations, the improper handling and disposal of hazardous materials and waste continues and often results in the contamination of water resources. The federal Superfund law established the mechanisms for the assignment of responsibility, implementation of clean up and compensation for damages caused by the improper, illegal or accidental disposal of hazardous waste. Congress directed the EPA, through Superfund, to identify and prioritize all hazardous waste sites requiring remedial action; $1.6 billion was appropriated to implement clean up at priority sites nationwide. Because a number of sites in Massachusetts not appearing on the Superfund list were not independently remediated, and because Massachusetts needed a source of funding to cover its share of federal Superfund costs, Chapter 21E of the Massachusetts General Laws was enacted in 1983. The law created mechanisms for identifying and notifying responsible parties, ensuring prompt state intervention to protect the public health, and recovering costs and damages when delays in assigning liability require expenditure of state funds to implement timely remediation.

Although, like chemical substances, the release of petroleum products is governed by Chapter 21E, their use and storage has only recently received sufficient attention. The problems posed by leaking underground petroleum storage tanks have come into focus in the past few years. Storage of petroleum underground was, and still is, the method of choice for fire and explosion prevention, however, protection of groundwater must also be a priority. Federal regulations set forth minimum standards for the underground storage of petroleum products, while regulation at the state level provides for licensing, installation, inventory control, and tank removal. A bill currently before the legislature would authorize the Department of Environmental Quality Engineering (DEQE) and the Department of Public Safety to jointly develop new regulations governing underground storage tanks. New regulations are needed to address public health and groundwater protection along with the public safety concerns which are the focus of the current regulations. New regulations are also necessary to bring Massachusetts into compliance with Federal requirements.

Many municipalities have chosen to address the underground storage tank issue on a local level through passage of bylaws regulating petroleum storage tanks. Such bylaws further the intent of the federal and state laws by regulating the placement of tanks, including specifications for soil corrosivity, installation, and proximity to groundwater tables and wells. Tank construction materials and specifications may also be regulated under a local bylaw. Additionally, local regulations may be used to keep records and ensure inventory control of smaller capacity tanks than are currently regulated.

Statutory control of pesticides is much more complicated. By their very nature, the use of pesticides involves environmental release. In an attempt to control pesticides which pose a threat to public health and the environment, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was completely revised in 1972. Under FIFRA, the EPA must register all pesticides for either general or restricted use. Those pesticides deemed to have potential for adverse environmental or public health effects are classified as restricted use and may be applied only by licensed applicators. All pesticides must be labeled with their active chemical ingredients, the uses for which the pesticide is registered, and directions for its use, storage, and safe disposal. The Massachusetts Pesticide Control Act (MPCA) is FIFRNs counterpart on the state level, .providing for state control over the registration, distribution, and use of pesticides within Massachusetts. A bill currently before the legislature seeks to strengthen the provisions of the MPCA by: establishing a hazard review committee composed of scientists capable of assessing the risks inherent in specific registered pesticides, mandating the expansion and implementation of alternative pest management programs, establishing critical sensitive areas where pesticide use would be more strictly regulated, designating significant uses of pesticides for which a generic environmental impact report would be required in order to quantify adverse effects, and establishing minimum data requirements which would have to be met in order for a pesticide to qualify for registration.

APPENDIX C

COMPONENTS OF THE DRAFT MINIMUM RECOMMENDED STANDARDS

FOR CONSTRUCTION OF PRIVATE WELLS

1. Purpose and Authority Regulations are intended to protect the quality of groundwater withdrawn from private wells. They may be adopted by municipalities by authority granted under General Laws, Chapter 111, Section 31, and General Laws, Chapter 40, Section 21.

2. Definitions Includes pertinent definitions.

3. Requirements for Private Wells Sets forth the conditions under which private wells may be constructed or abandoned; specifies required documents which include:

-permit application -permit -water quality analysis and approval (only for wells to be constructed) -well driller's report (only for wells to be constructed).

4. Well Construction or Destruction Permit Describes the requirement for and content of the application for a permit; the permit application, which is submitted to the regulating agency, should include: -location and design of the well to be constructed or abandoned -summary of potential sources of contamination in proximity to a well to be constructed -written statement of abandonment for wells to be destroyed.

5. Well Driller's Reports Describes the required contents of the well driller's report and the time limit for submittal to the regulating agency.

The report for wells to be constructed should include specific information on: -location of the well -depth, size, and type of well -materials used in well construction -hydrogeologic data -method and results of pump test.

The report for wells to be destroyed should include specific information on: -location of the well -method of destruction -depths, sizes, and types of materials used in the well.

6. Well Location Requires identification of potential sources of contamination in proximity to the well and sets forth minimum lateral distances between the well and potential contaminant sources, including minimum distances from:

-components of on-site and neighboring septic systems

-sewers

-property lines

-public ways

-other adjacent land uses (eg. industries, landfills, commercial operations etc.).

Reserves the right of the regulating agency to increase the allowed distances; requires protection of the well from floods and surface runoff.

7. Well Alignment and Drilling Sets forth conditions under which wells shoud be drilled.

8. Well Casing Describes materials allowed for well casings, required depth and extension above ground surface, thickness of materials and seals, and other specifications.

9. Well Screens Sets forth conditions under which well screens are required and factors to be considered in their design.

10. Protective Seals Describes the requirement of a seal between the well casing and the wall of the drilled hole; specifies allowed materials and seal depth, thickness, and placement for various well types.

11. Surface Construction Sets forth specifications for pump installation, well capping and well vents.

12. Temporary Cover Requires a temporary well cover in the event of interruption of well construction or destruction; specifies allowed materials.

13. Well Development Specifies allowed methods of developing, redeveloping or conditioning a well, and conditions under which a pump test is required; requires submittal of the pump test to the local regulating agency and the appropriate state agency.

14. Disinfection and Other Sanitary Requirements Describes the requirement and allowed methods of well disinfection.

15. Well Destruction Sets forth specific requirements and conditions under which wells may be destroyed or abandoned, including:

-geologic conditions under which various materials may be used for filling or sealing the well

-specific procedures and conditions for placement of the fill material

-suitable impervious filling or sealing materials

-specific procedures for aquifer protection in sensitive areas.

16. Repair or Deepening of Wells Requires that alteration or repair of any existing well meet the requirements of the regulations.

17. Water Sampling Requires a water analysis performed by a certified laboratory; describes sampling procedure; requires that a. copy of the results be sent to the local board of health and the property owner.

18. Water Quality Sets forth standards for determination of potability, including maximum safe concentrations of bacteriological, mineralogical, and chemical parameters, as well as standards for aesthetics.

19. Water Storage Requires approval of the regulating agency for installation of any water storage component.

20. Variances Sets forth conditions and procedures for requesting and granting a variance.

21. General Enforcement Sets forth specific procedures under which orders will be served; provides for hearings and appeals; sepcifies penalties; contains severability clause.

APPENDIX D: Household Hazardous Waste Fiscal Year 1988 Program Summary

Commonwealth of Massachusetts

Executive Office of Environmental Affairs

Department of Environmental Management

Office of Safe Waste Management

Publication:#l5, Ol5 Approved by Daniel Carter, State Purchasing Agent

HOUSEHOLD HAZARDOUS WASTE COLLECTION PROGRAM

GRANT APPLICATION INFORMATION

1. Introduction

During Fiscal Year 1988 (July 1, 1987 to June 30, 1988). the Department of Environmental Management (DEM) will administer grants to cities, town and regional planning agencies for the collection and management of household hazardous waste. Participating communities will be chosen from those communities submitting completed grant applications by applicable deadlines according to priorities listed in this application .

Because of the importance of providing current opportunities for proper disposal of household hazardous waste. DEM will make 75% of the funds available for household hazardous waste collection days. The remaining funds (25%) will be used to for innovative projects that lead to long-term solutions for the safe, efficient and cost-effective management of these wastes.

II. Who May Apply For Funding?

Any city or town may apply for funding, either as an individual community or as part of a regional application.

In addition to cities and towns, the budget appropriation specifies that regional planning agencies (RPAs) are also eligible for funding. Cities and towns may have those institutions apply on their behalf.

In cases where city-wide collections are impractical, applications for events to serve part of a city will be considered. Such applications may be submitted by the city. or. subject to municipal review, by a regional planning agency.

Regional applications, as well as applications through regional planning agencies, are encouraged.

All communities will be reviewed for compliance status with the Massachusetts Committee Against Discrimination in accordance with the requirements of Executive Office of Environmental Affairs regulation 301 CMR 50.00.

III. What Types of Projects Will Be Funded?

Three types of projects will be funded under this program:

A. One-day Collection Events

One-day collections, which communities have traditionally held, are fundable under this category. For the purpose of these collections, the grantee enters a contract with a licensed hazardous waste transporter to set up a temporary collection site for household hazardous waste.

B. Innovative Collection Projects

Projects funded under this category should encourage: 1) new, environmentally sound methods of collecting, treating or disposal of household hazardous waste, 2) increased citizen participation, 3) more cost-effective means of handling these wastes, 4) demonstrated source reduction potential, 5) generation of new and useful information concerning the s~ore of the household hazardous waste problem and how it might be addressed. Projects must comply with applicable federal, state, and local regulations.

Collection projects that might be considered innovative include, but are not limited to permanent or semi-permanent collection facilities, curbside pick-ups, pre-registration of participants, and special programs for specific wastes.

C. Administrative Technical Support

Regional planning agencies can provide municipalities with organizational, technical and administrative support. This includes hiring hazardous waste transporters, negotiating contracts on behalf of municipalities, providing assistance with planning, public education, and publicity for events and acting as administrative liaison with DEM.

Under the FY88 program, the involvement of RPAs is encouraged but not required. Any regional planning agency which has entered into an agreement with a municipality to provide administrative and technical support may apply for state funding to support its activities.

IV. What Are the Application Deadlines?

A. Household Hazardous Waste Collection Events

Event Deadline

Fall 1987 collections October 9, 1987

Spring 1988 collections December 31, 1987

DEM will establish a maximum amount of available funds for Fall 1987. Any unexpended funds will roll-over to the Spring 1988 funding round.

Any applicant not funded in the fall can reactivate its application for consideration in the spring by notifying DEM in writing. A new application will not be required. Information updating the application will be accepted.

B. Innovative Projects

Event Deadline

Application November 1, 1987

C. Administrative/Technical Support

Deadlines for administrative/technical support grants should coincide with the projects to which they apply.

V. Completi.on dates

All projects are to be completed by June 30, 1988.

VI. What Are the Community Responsibilities?

A. Raise local funds

Communities must raise or appropriate local funds based on the estimated collection costs (see Section IX per capita costs) and matching grant percentage listed below.

Communities must provide DEM with documentation that local match funds are available at least 30 days prior to the collection.

B. Establish an Organizing Committee

A local committee consisting of three or more members must be appointed to assume responsiblity for organlzlng and implementing the household hazardous waste collection event.

In the case of a regional collection. at least one person from each of the communities involved must be appointed to serve on the committee.

Names, address, and affiliation, if any, of committee members must be submitted to DEM.

C. Responsibilities of the organizing committee:

Select a collection site, subject to the approval of the hazardous waste transporter and DEM, plan for suitable security, traffic regulation, emergency response.

Hold two or more public education events which will identify household hazardous wastes and their threats to human health and the environment, provide information on substitutes and source reduction and identify acceptable disposal methods.

Collect data as requested by DEM and provide final report to DEM or regional planning agency.

VII. State Awards

State awards will be based on the followtng formula:

50% of estimated collection costs for applicants who have not previously received a state grant for a household hazardous waste collection

35% of the estimated collection costs for communities which have previously received funds

50% of estimated cost of an innovative project

8% of estimated collection cost for administrative grants.

VIII. Funding Priorities

A. For one day collections, applications will be ranked based on the following point system:

Local funds available, or on warrant, by application deadline 1 pt

Applicant has not previously received a State grant for a household hazardous

waste collection 2 pts

Applicant has made provision to cover cost-overruns (through public or private funds) 1 pt

Applicant proposes a joint collection with 1 or more cities/towns 1 pt

Applicant proposes a joint collection with 1 or more towns with a population

less than 3000 (per community) 1 pt

In the event of a tie, priority will be given to communities which have not previously received state funding. Any other ties will be decided by lottery until all available funds are allocated. Communities which do not receive awards will be placed on a waiting list to be funded if all allocated funds are not used.

B. Innovative Projects will be evaluated as follows.

Statement of project goals.

Applicant's qualifications.

Completeness of work plan for proposed project, including time line, information on public education, budget, method of evaluating the project.

Project need and originality.

State-wide applicability.

Provision for cost overruns.

Ability of project to be completed during funding period.

Evidence of ability to continue project as on-going method to manage household hazardous wastes after pilot phase.

Administrative/Technical Support.

IX. Cost Estimation Schedule for one day collections.

The following cost estimates are only for the actual costs of collection, transportation and disposal of household hazardous waste. They DO NOT include the cost of publicity, traffic control or other costs associated with a collection.

The per capita cost estimates listed below are based on the costs of collections held from September, 1986 to June, 1987 with a 2% participation rate. Actual costs for each collection will depend on variables such as extent and effectiveness of publicity, experience of previous collections, agreement with the transporter, general level of awareness on environmental issues, weather and convenience. Cost will be estimated on the basis of the 1985 Massachusetts state census.

Estimated Cost Per Capita Population Range

.80 0-4, 000

.70 4, 001 -8, 000

.60 8, 001 -12, 000

.47 12, 001 -24, 000

.35 24, 001 -36, 000

.30 36, 001 -48, 000

.25 >48, 001

APPENDIX E

SAMPLE FORM LETTER TO ENCOURAGE PRIVATE WELL MONITORING

Dear Private Well Owner:

Although you may not perceive any problems with the water from your well, it would be prudent to have your drinking water tested by a certified laboratory. While your water is likely to be of acceptable quality, there is a possibility that it contains contaminants undetectable be sight, taste, or smell, and you will benefit greatly from knowing the precise quality of your well water.

If contamination is found in your water, contact the Board of Health. Steps can then be taken to determing the source and extent of contamination and whether your family's health is at risk. Even if your well water is found to be free of contaminants, it is to your advantage to have a basis for comparison in the event that contamination occurs in the future. The list below will help you determine which contaminants you should have your well water tested for at one of the certified laboratories noted on the attached list.

If you answer yes to any of the following questions, your well water may be at risk of chemical contamination, and you should have a volatile organic compound (VOC) scan performed:

Do any of the following land uses exist in your vicinity?

-industries

-gas stations

-auto repair shops

-landfills

-dry cleaners

Do you or any of your neighbors

-use a chemical septic tank cleaner?

-dispose of household cleaners or chemicals into your septic system?

-have an automobile which leaks gasoline, oil, or other fluids onto the ground?

-have an underground petroleum storage tank?

The Environmental Protection Agency has set maximum safe levels for some VOCs that may be found in drinking water as listed below:

benzene 5 parts per billion (ppb)

carbon tetrachloride 5 ppb

1, 2-dichloroethane 5 ppb

1, 1-dichloroethylene 7 ppb

p-dichloroethylene 75 ppb

1, 1, 1-trichloroethane 200 ppb

trichloroethylene 5 ppb

vinyl chloride 2 ppb

If you or your neighbors use any insecticides, herbicides or similar compounds, including weedkillers and lawn care chemicals, you should have your well tested for the presence of pesticides. DEQE guideline levels for some pesticides that may be found in drinking water in Massachusetts are listed below:

Alachlor 0.3 ppb

Aldicarb 10.0 ppb

Carbofuran 10.0 ppb

1, 2-dichloropropane 1.0 ppb

1, 3-dichloropropene 1.0 ppb

Dinoseb 5.0 ppb

Ethylene dibromide (EDB) 0.10 ppb

Oxamyl 50.0 ppb

Some homes may be at risk of radionuclide contamination. If you think you may have this type of contamination, you should have your well tested; maximum safe levels are as follows:

Gross alpha activity 15 picocuries per liter (pCi/l)

Radium 5 pCi/l

Radon 10, 000 pCi/1

Uranium 10 pCi/l

Finally, please be sure that the lab performing your water analysis has been certified by the state. A number of companies currently offer water quality analyses free of charge in attempts to attract prospective buyers of home water treatment units. To our knowledge, none of these labs are certified by the state to perform water quality analyses. Don't invest in a home treatment system unless you are sure that you need it. Many contamination problems can be resolved without treatment, and for some contaminants, home treatment units are not an appropriate response.

If you have any questions about private well water quality and testing, please contact the Board of Health.