You finally got it!  Your “No Further Action (NFA) Letter,” “Covenant Not To Sue” or whatever they call it in your state.  After extensive investigation, months of remediation, years of monitoring and the seemingly endless wait for regulatory agency approval you are finally done.  WELL…...not quite.  You may have one, a few dozen or a few hundred monitoring wells at your facility that now need to be abandoned.

We are all holding on to way too much these days, too many clothes that don’t fit, too much paper, and way, way, way too many email messages.  I bet the inventor’s of Outlook never thought it would be used as an electronic filing system.  Now that you have your NFA you don’t want to be hanging onto those monitoring wells.  You can’t wear them, they won’t increase in value and they cannot possibly have any sentimental value.  If someone met the love of their life bailing wells on some steamy August afternoon I definitely want to hear about it.  All I ever got was sucked dry by mosquitoes, chased by hornets, terrorized by black snakes and spiders, attacked by fire ants, bitten by ticks, stuck by nettles and a bad case of poison ivy.  Oh, and I sliced my thumb opening a vial of sulfuric acid to preserve the groundwater samples.  Some might say I was one of the lucky ones.  I may need therapy because I broke out in hives just writing this article.

There are actually requirements that monitoring wells be abandoned after they are no longer needed.  It has been my experience that many facilities are not aware of these requirements.  Several years ago I was discussing the issue of monitoring well abandonment with a state inspector.  In comparing notes we both realized that there were numerous facilities that we had visited that had not abandoned their monitoring wells.  She asked me why I thought facilities were not performing monitoring well abandonment.  My response was that the facilities were not aware of the requirement or the reasons that abandonment should be performed and the NFA letter they received does not mention it.  At least none of the NFA letters I have seen mention it.  A statement similar to the following:  “This NFA will become effective upon the proper abandonment of all monitoring wells that were part of this remedial action” is all that would be needed to ensure that monitoring wells get properly abandoned but that would be too easy. 

The fact is that monitoring well abandonment is required.  If you don’t believe me here are some of the state laws/regulations that require monitoring well abandonment:

• In Pennsylvania, Act 610 the Water Well Drillers License Act
• In Michigan, Groundwater Quality Control Act Part 127, 1978 PA 368
• In Indiana, State Rule 312 Indiana Administrative Code (IAC) 13-10-2 and Indiana Code 25-34-9.

(If I have not referenced the requirements in your state please contact me and I will forward that information.)

Some of the reasons that it is important to abandon monitoring wells include the following:

• Elimination of the safety hazard of the well (the physical hole in the ground).
• Elimination of a pathway for migration of contamination
• Prevention of  hydrologic changes in the aquifer system, such as the changes in hydraulic head and the mixing of water between aquifers.

I hope this gives you a compelling reason to proceed with your monitoring well abandonment.  If you need assistance, contact August Mack Environmental.  We can help and won’t charge extra for the mosquitoes, hornets, black snakes, spiders, fire ants, ticks nettles or poison ivy.  And don’t worry about missing out on the chance to meet the love of your life, come to one of our networking events and you just might meet someone.