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As a Wellhead Protection Area Inspector in the Groundwater Permits Division of Water Management, my job is to ensure that businesses located close to community supply wells are properly managing and disposing of their chemical wastes. MDE’s Water Supply Program assigns wellhead areas for me to investigate as part of their Source Water Assessment Program.
The Wellhead Protection Program is designed to protect public drinking water supplies by managing the land surface around a well where activities may affect water quality. The Safe Water Drinking Act Amendments of 1986 required EPA to provide training, guidance and approval over state wellhead protection programs. Established in 1991, Maryland’s program provides technical assistance, funding, information, and advice to local governments and water suppliers to help them protect their water sources. All states have EPA-approved state wellhead protection programs. Subsequent amendments require states to complete source water assessments for all public water systems, which is integral to this program.
Some key elements of a Wellhead Protection Program include:
- Delineating wellhead protection areas
- Inventorying contaminants
- Using best management practices to prevent discharges
- Having contingency plans in the event drinking water sources are contaminated or disrupted
- Siting new wells carefully
- Filling and sealing abandoned wells properly
- Equipping wells in flood prone areas with watertight caps
To sustain wellhead protection in commercially populated areas, facilities such as auto repair/auto body shops, dry cleaners, print shops, schools, mobile home parks, gas stations, public works/state highway facilities and chemical manufacturers are inspected.
The inspection process involves:
- Making unannounced facility visits
- Conducting interviews
- Making waste type and hauler inquiries
- Documenting hauler receipts
- Touring the sites
- Making pollution prevention recommendations
- Referring site-specific problems to the appropriate MDE administration including oil control, waste management, and air regulation
Noncompliance
An operation that is noncompliant is either flagged, or issued a Notice of Violation (NOV). A flagged facility receives a recommendation letter to improve pollution prevention efforts. Examples may include secondary containment for stored chemicals, the use of oil absorbent socks in floor drains, or limiting vehicle washing to exteriors only with no soap use. With an NOV, I document the situation with photos and hand a written document to the owner, giving the individual 30 days to correct the infraction. The owner can write for a specific extension, if necessary, to complete the corrective action. Once they are in compliance, the businesses are required to submit “after” photos, whereupon I write a facility closure letter. Follow-up site inspections are performed and compliance is reviewed.
With owners that take no action after an NOV, a certified letter is sent reviewing treatment options and specifying a time period by which to respond. If no response is sent, the case is referred to the Compliance Program to issue fines.
Education is Key to Compliance
The most vital part of my site investigations is the education of facility owners. Keeping vehicle washwater out of the groundwater has become a big component of our program. Business owners have misconceptions, such as: “As long as washwater is going down a drain and the soap used on cars is biodegradable, everything is O.K.” More and more businesses have increasing fleets of vehicles that are washed on the premises. The problem occurs when discharged washwater enters the stormwater ditch or drain untreated. Spent washwater can contain detergents, road salts, metals, oils, paint chips, Volatile Organic Compounds, (VOC’s) and brake dust. Surfactants in the soap reduce oxygen in water, allowing pesticides to be more easily absorbed by fish.
Owners with floor drains or vehicle washing operations have these options:
- Seal the floor drain with concrete
- Hook-up to sanitary sewer
- Install a holding tank, to be pumped periodically by a certified hauler
- Apply for a groundwater discharge permit, periodic testing may be required
- Take vehicles to a commercial car wash that is either permitted on a sanitary sewer or has a recycling system
- Mobile onsite wash systems are reviewed and considered, as long as an impervious surface material is used and water is discharged to a sanitary sewer or holding tank
I have written educational brochures including, “A Dry Cleaner’s Guide To Wastewater Management”, “Vehicle Washwater:
Keeping It Out Of Our Waters”, and the just completed “Management Of
Photochemical Wastes”. These pamphlets along with tire, waste oil and solvent
hauler lists and best management practices for individual industries are
distributed to business owners. Most owners, equipped with the most relevant
knowledge, can then make the most appropriate treatment decisions for their
discharge. They also may appreciate MDE’s willingness to make their compliance
easier.
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