DEPARTMENT OF ENVIRONMENTAL PROTECTION
BUREAU OF RESOURCE PROTECTION
Massachusetts Closure Requirements for
Underground Injection Control (UICs) Wells
(including shallow injection wells)
RDEFFECTIVE DATE: JULY 3, 2008
GUIDANCE #: BRP/DWM/DW/G04-3
? Bureau of Resource Protection
o Underground Injection Control (UIC) Program
o Ground Water Discharge Program
? Bureau of Waste Prevention
o Industrial Wastewater (IWW) Program
? Bureau of Waste Site Clean-up Waste
o Remediation Program – Remediation Wells
SUPERSEDES GUIDANCE: Massachusetts Closure Requirements for Shallow Injection Wells (UICs) - December 1994
Acting Assistant Commissioner
Bureau of Resource Protection
MassDEP on the World Wide Web: http://www.mass.gov/dep
Printed on Recycled Paper
Revised Massachusetts Closure Requirements
for Underground Injection Control (UICs) Wells
The Massachusetts Department of Environmental Protection, (hereinafter referred to as
“MassDEP”), in cooperation with local and federal agencies, regulates discharges of fluids to
protect the quality of ground and surface water resources used for drinking water and other
purposes. The Underground Injection Control (UIC) Program regulates discharges of fluids
having the potential to contaminate groundwater (310 CMR 27.00). Shallow injection wells are a
subcategory of Class IV and V UIC wells. Injection wells include most subsurface leaching
systems, with the exception of septic systems designed to serve single family homes or those
designed to serve non-residential structures serving 20 persons or fewer used solely for sanitary
wastewater disposal. In general septic systems properly permitted by the local Board of Health
are exempt from the reporting requirements of 310 CMR 27.00. Common examples of shallow
injection wells in Massachusetts are dry wells, septic systems, discharges from floor drains in
industrial areas, leaching catch basins, and oil/water separators leading to a infiltration structures
(some of these discharge types are banned unless a Ground Water Discharge permit is obtained
from MassDEP). Floor drains themselves are not injection wells, however, they are a common
point of entry to subsurface leaching systems, which do constitute Class IV or V injection wells.
The discharge of liquid wastes to the environment via shallow injection wells has been a source
of contamination suspected in many cases of public drinking water supply well closures and a
confirmed source of contamination of public drinking water wells in Massachusetts (see note
below). The costs resulting from such contamination include possible public health problems and
are both environmental and financial. To prevent migration of any contamination from an
injection well is much less costly than to treat or to develop a new water sources. Prevention
serves to protect people and the environment from long-term or irrevocable damage.
Pursuant to the MasssDEP UIC regulations cited above, the use of an underground injection well
is prohibited where the potential exists for pollutants to enter it (e.g., by means of a floor drain or
other means) and where the presence of the pollutants causes or is likely to cause a violation of
any Massachusetts Drinking Water Regulation, or in the opinion of MassDEP adversely affects,
or is likely to adversely affect, the health of persons.
With the exception of those discharges authorized under the Department's Ground Water
Discharge Permit program, 314 CMR 5.00, MassDEP defines this prohibition as including the
use of most Class IV or V injection wells with an indoor point of entry at facilities which use,
store, or otherwise manage hazardous materials and/or wastes as defined in 310 CMR 30.000 and
310 CMR 40.0000. 314 CMR 5.05 identifies certain activities that are exempt from a ground
water discharge permit under 314 CMR 5.00 but would be subject to the reporting requirements
of the UIC program. Nevertheless, any proponent of a discharge at a UIC facility exempted
under the Ground Water Discharge Program must file a UIC Registration form (WS-06a,b&c or
WS-06e http://www.mass.gov/dep/water/approvals/dwsforms.htm#uic) with the UIC Program
prior to initiating the discharge.
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Note: Suspected UIC contamination of Public Water Supply wells in MA include: the Kane and
Chestnut wells in Hudson, the Turnpike and Hartwell Road wells in Bedford, Wells # 1 and 2 in Groveland and the Ellis well in Norwood.
The owner or operator of a facility where an unauthorized injection well is located must immediately discontinue the unauthorized use of the injection well in accordance with 310 CMR 27.04 and 27.10. The use of a Class IV or V injection well may be discontinued by: sealing the floor drain(s) or other conduit which leads to it, connecting the drain(s) to a certified industrial wastewater holding tank or connecting to a municipal sewer system. Refer to section 7.0 of this document for additional guidance on discontinuance of an unauthorized use or on obtaining and submitting a permit, registration, certification or application.
This guidance document applies to the closure of all unauthorized and authorized-by-rule Class
IV or V shallow injection wells in Massachusetts. An authorized-by-rule well is a Class IV/V well for which a permit is not required from any MassDEP program. However, the owner or operator must submit a UIC Class IV/V registration form to the UIC program in order for that well to be authorized to discharge.
Most Class IV wells (wells that inject hazardous waste into or above the aquifer) are banned, with one exception: remediation wells that are approved under Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental, Response Compensation Liability Act (CERCLA) are authorized-by-rule and must also be registered with MassDEP as a Class IV well. Remediation wells can be Class IV or Class V wells based on the level of contaminants injected or the nutrient additive. There are two types of Class IV/V remediation wells; one type involves the application of “remedial additives” in a Class IV/V injection well and the other involves the “re-injection” of recovered and treated groundwater. Class IV/V wells authorized by the MassDEP’s Waste Site Clean-up Program are authorized-by-rule and fulfill their registration
requirement by submittal of the Remedial Monitoring Report (RMR) Form with MassDEP as a Class IV/V well. All closure procedures should be performed as specified in this document.
The information contained in this document is intended to be used as guidance and does not in itself create any substantive or procedural rights, enforceable by any party in any administrative proceeding with the Commonwealth. In addition to summarizing specific regulatory requirements, this document also provides guidance on what measures MassDEP considers acceptable to meet the general requirements set forth in the regulations. Parties using this guidance should be aware that there might be other acceptable alternatives for achieving compliance with such general regulatory requirements. Approval to use such alternatives must be obtained from the Department.
The regulatory citations provided throughout this document are not meant to be, and should not be relied upon as, a complete list of all applicable UIC regulatory requirements. Consult 310 CMR 27.00
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The purpose of this guidance document is to outline the components of UIC closure as well as to
alert the party undertaking that closure of potential responsibilities under the Massachusetts
Contingency Plan (hereinafter referred to as “MCP”), MGL c.21E and 310 CMR 40.0000,
Massachusetts UIC Program (310 CMR 27.00) and Massachusetts Hazardous Waste Regulations
(310 CMR 30.000).
Closure procedures discussed in this document include:
o filing of all appropriate forms;
o decommissioning an injection well;
o identifying, excavating, and managing contaminated materials encountered during the
o conducting confirmatory sampling in the footprint of the excavation. If contamination by oil and/or hazardous material (OHM) is encountered in soil or groundwater,
the provisions of the MCP and guidance provided by MassDEP’s Bureau of Waste Site Cleanup
(BWSC) policies are applicable. Under the authority of M.G.L. c. 21E, the MCP establishes
specific requirements for providing notification to MassDEP and responding to releases of OHM
to the environment. Assessment-only activities may be conducted without approval from
MassDEP prior to notification under the MCP. Contamination discovered during the assessment
phase must be reported to MassDEP in a manner consistent with the criteria presented in the
The MCP requires those who conduct response actions (e.g., Immediate Response Actions
[IRAs], Release Abatement Measures [RAMs], Comprehensive Response Actions [CRAs]) to
employ a Licensed Site Professional (LSP) to oversee assessment and cleanup actions and to
document that such actions are performed in compliance with the MCP. LSPs are qualified
professionals in assessment and cleanup activities who are licensed by the Commonwealth.
Performance of a Limited Response Action (LRA) does not require the use of an LSP, except as
specified under "Excavation and Management of Contaminated Soils" (section 6.3). A list of
LSPs is available at: http://www.mass.gov/lsp/lsphome.htm.
4.0 SAMPLING PROTOCOL
Sampling and analyses should be performed in accordance with the MCP guidelines and
requirements. In particular, the provisions of "Environmental Sample Collection and Analyses"
(310 CMR 40.0017) and the performance standards described in 310 CMR 40.0191 should be
To ensure that all chemical analyses of samples taken as part of closure and assessment activities
meet the quality control and performance standards for data used to support decisions under the
MCP the analyses should meet the requirements for the applicable methods as specified. In
MassDEP’s Compendium of Quality Assurance Guidelines and Quality Control Requirements and Performance Standards for Selected Analytical Methods Used in Support of Response
Actions for the Massachusetts Contingency Plan (MCP) – WSC – 02 – 320 (hereinafter referred
to as “Compendium)”.
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The MCP Analytical Methods in the Compendium use the sample preparation and processing
protocols of commonly used EPA SW-846 and MADEP analytical procedures and articulate
quality control provisions, performance standards, analyte lists, reporting formats, and other
methodological elements. The Compendium can be found on the MassDEP website at:
http://www.mass.gov/dep/cleanup/laws/overmcp.doc. In certain limited circumstances, a
laboratory can submit Quality Assurance/Quality Control data for the analysis of chemicals to
demonstrate proficiency under a performance based method option. Please contact MassDEP
for advice on using this approach.
5.0 INITIAL CLOSURE ACTIVITIES
Procedures noted below in 5.1 and 5.2 must be performed in every case of shallow injection well
5.1 Removal of Existing Sludge/Wastewater:
Prior to performing any other closure procedures outlined in this document, any existing sludge
or wastewater from the Class IV or V well (e.g., dry well, oil/water separator or MDC trap,
septic system, other structure) should be pumped and disposed of as discussed below.
MassDEP recommends that a sample of the sludge/wastewater be analyzed before disposal. The
results of the sludge/wastewater sample should be used to pre-characterize the oil and/or
hazardous material, which may also be present in the environment surrounding the injection well.
Sludge/wastewater samples from the injection well should be analyzed for:
o volatile organic compounds
o petroleum hydrocarbons
o total metals;
o other parameters based on specific knowledge of oil and/or hazardous materials used,
stored or disposed of at the site, and the site's general history. For the appropriate methods refer to http://www.mass.gov/dep/cleanup/laws/overmcp.doc.
As indicated by the results of these initial analyses, additional testing of the sludge/wastewater
may be required to determine for disposal purposes whether the material is a hazardous waste
under 310 CMR 30.000, the Massachusetts Hazardous Waste Regulations. A licensed hazardous
waste hauler must transport hazardous wastes. Non-hazardous industrial wastewaters may be
taken to a Wastewater Treatment Facility (WWTF). You must obtain prior approval from the
WWTF prior to the delivery of the wastewater to their facility for disposal.
Separators (also known and used as oil/water separators, sand traps, gas traps, and “MDC traps”)
should be cleaned and sludge/wastewater disposed of as noted above in section 5.1. Except in
cases where the separator will remain in use for non-UIC purposes (e.g., the system will now
be connected to a sewer line or to a certified holding tank), the separator should either be
removed or backfilled with clean fill, sand, or gravel with both the inlet(s) and outlet(s) plugged
with a permanent seal.
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6.0 ADDITIONAL CLOSURE ACTIVITIES
Procedures outlined in sections 6.1 - 6.4:
o must be performed in cases in which MassDEP has issued a Notice of Noncompliance
(NON) or enforcement order specifically requiring these procedures to be performed.
o should be performed as part of remedial actions in cases in which a known release or
threat of release as defined in the MCP of OHM to the environment has occurred or exists.
In these situations, all relevant requirements of the MCP and c.21E must be satisfied.
o are recommended by the MassDEP to be performed as best environmental management
practices in all other cases.
6.1 Decommissioning of Class IV/V UIC System
After removal of the contents (see "Removal of Existing Sludge/Wastewater" (section 5.1)) of
the Class IV or V well, the well should be decommissioned according to the following criteria.
Remedial activities associated with contamination in the impacted leaching media are discussed
in "Excavation and Management of Contaminated Soils" (section 6.3).
o Drywells/Cesspools: Excavate and remove the underground structure. All inlets to the
system must be plugged.
o Septic Systems: Visually inspect the tank. Tanks that are watertight, without holes or
cracks may be put back into service for sanitary waste only (no industrial or commercial
process wastewater should be tied into the septic system) after they have been emptied
and cleaned of all hazardous/industrial wastewater. The local Board of Health shall be
notified if holes and/or cracks are identified in a system, including the tank(s), pipes or
distribution box. Actions to remove the tank should be coordinated with the local Board
of Health. The leachfields may be put back into use to receive sanitary wastewater if they
are not contaminated or in failure. If they are contaminated or in failure a replacement
field must be coordinated with the local Board of Health.
o Other Systems: Any other injection well system should also be excavated and removed,
or have inlets and outlets sealed off. Decommissioning of monitoring wells must be done
by a well driller registered by MA Department of Conservation and Recreation (DCR) –
Division of Water Supply Protection following DCR regulations, which can be found at
http://www.mass.gov/dcr/waterSupply/welldril/lawsregs.htm. Additional information on
DCR's Well Drillers Program may be obtained on the Internet at:
o The registered well driller must file a well completion report for both the installation and
abandonment of the monitoring wells.
All excavation holes must be backfilled as noted under "Confirmatory Sampling" (section 6.4.A).
6.2 Samples Proximate to Point of Discharge
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A minimum of two soil grab samples should be collected from different locations and analyzed
in accordance with the following:
A. Each sample should be collected at, or below and within one foot of, the point of
discharge to the ground;
B. Each sample should be screened for total organic vapors in headspace using a portable
photoionization detector (PID) or flame ionization detector (FID) as described in
Appendix II, "Jar Headspace Analytical Screening Procedure." These data should be
expressed as total organic vapor in ppm (v/v) as benzene.
C. The samples should be analyzed using the applicable analytical methods as specified in
MassDEP’s Compendium as follows:
1.) VOCs: The sample with the highest headspace reading response or concentration
in ppm should be analyzed for the presence of VOCs.
2.) Petroleum Hydrocarbons: Each sample should be analyzed for the presence of
petroleum hydrocarbons using the guidance presented in Characterizing Risks Posed
by Petroleum Contaminated Sites: Implementation of the MADEP VPH and EPH
D. Quality Assurance / Quality Control – The decisions made as part of a shallow well
closure activity are dependent on the quality of the data generated as part of the
investigation. Following well-established quality assurance (QA) and quality control (QC)
procedures is essential for generating data that can be used confidently in decision
making. MassDEP guidance: Compendium of Quality Assurance and Quality Control
Requirements and Performance Standards for Selected Analytical Method
(Compendium)s, should be used. The data submitted to MassDEP, as part of a shallow
well closure support package will be reviewed using the criteria described in the
D. Each sample should be analyzed for the presence of metals and other parameters
according to the corresponding criteria noted section 5.1.
6.3 Excavation and Management of Contaminated Soils
If contamination above an applicable MCP notification threshold is identified in the soil
surrounding the injection well, response actions under the MCP are required to remediate the
contaminated soil by soil excavation or other remedial methods.
MassDEP notification pursuant to the MCP may not be required, if the contaminated soil can be
excavated and disposed of according to the Limited Removal Action (LRA) limits in 310 CMR
40.0318, The Limited Response Action (LRA) limits are:
o Not more than 100 cubic yards of soil contaminated solely by a release of oil or waste oil
may be excavated.
o Not more than 20 cubic yards of soil contaminated by a release of hazardous material, or
a mixture of oil or waste oil and hazardous material may be excavated.
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o Notification to MassDEP is required if groundwater contamination above a notification
threshold is encountered, or if any 2 or 72 hour notification criterion is triggered while
conducting an LRA. Notification is also required if the removal action cannot be
accomplished within the LRA volume limits specified above.
Excavated contaminated soils should be managed according to the MCP, the Massachusetts
Hazardous Waste regulations, and related MassDEP Policies. Contaminated soils should be
segregated from uncontaminated soils based on total organic vapor headspace readings and
visual and olfactory observations and stockpiled separately. Soils contaminated with a listed
hazardous waste or identified as exhibiting a characteristic of a hazardous waste are subject to
the management and disposal requirements of 310 CMR 30.000. All excavated contaminated soil,
including that generated as a result of an LRA, should be managed as set forth in 310 CMR
40.0030 and 310 CMR 30.000 in a manner that ensures the protection of health, safety, public
welfare, and the environment. If temporary storage of contaminated soil is necessary, stockpiled
soil should be placed on, and covered with, a polyethylene tarp (6-mil minimum thickness).
Contaminated stockpiles that are to be managed off-site may not remain at the location any
longer than 120 days.
Parties performing a LRA should note that, although a LSP is not required to perform the LRA,
an LSP must nonetheless be employed if the Bill of Lading for soil management is to be used to
manage soils generated by the LRA.
6.4 Confirmatory Sampling
A. Confirmatory Soil Samples
1. Once the contaminated soil has been excavated, separate soil grab samples should be
taken from the bottom and sides of the excavation to characterize the levels of residual
contamination in the remaining soils and determine whether additional remedial actions
may be needed. These samples should be analyzed for the parameters identified by
2. Once all contaminated soil is excavated and confirmatory samples taken, the
excavation should be backfilled with clean compacted fill. For safety reasons, no hole
should be left open or unsecured overnight.
B. Follow Up
1. If the results of samples do not require notification under the MCP and there is no
reason to suspect ground water contamination at or down gradient from the injection well,
the following items "B.2" and "B.3" may be skipped.
2. If the results of the confirmatory soil samples are above an MCP notification threshold,
the party undertaking the closure shall notify the BWSC at the appropriate MassDEP
regional office and continue all further remedial activities in accordance with the MCP.
Note: If excavation has been conducted as an LRA and the confirmatory sample analyses
indicate that contamination exists above a notification threshold, the party conducting the This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD Service - 1-800-298-2207.Page 8 of 11 This information is available in alternate format. Call Debra Doherty, ADA Coordinator at 617-292-5565. TDD Service - 1-800-298-2207.
work may continue to remove soil as an LRA provided the action still falls under the
volume and time limitations noted in section 6.3. If the activity cannot be concluded
within the LRA limits, the party must notify MassDEP under the 120 Day notification
requirements. Excavation may be continued as a Release Abatement Measure (RAM).
3. If there is reason to suspect groundwater contamination at or down-gradient from the
injection well, the party undertaking the closure should conduct further sampling. If
groundwater contamination above applicable Reportable Concentrations is confirmed, the
party must notify (if notification has not already occurred) the Department's BWSC
accordingly and continue all further remedial activities in accordance with the MCP.
7.0 SUBMITTALS TO MassDEP
7.1 Submittals to UIC Program:
o Complete UIC Pre-Closure Form at least 30 days prior to closure. (Appendix II). If the
shallow injection well has not previously been registered with the UIC Program send a
copy of the Pre-Closure form to the UIC Program in Boston. If the facility owner or
operator needs to close the well prior to the 30 days notice required by the Pre-Closure
form, permission must be sought from the appropriate UIC staff. In the Appendix I is a
list of Massachusetts’s cities and towns with the address and telephone numbers for the
four MassDEP regional offices and MassDEP’s Boston office. Upon completion of the
Class IV / V well closure, the owner or operator must submit a to the UIC Program in
Boston. This form will establish the date of closure of the well (Appendix III).
o In cases where soil sampling and associated activities are required due to the issuance of
an enforcement order from MassDEP’s UIC program, the following must also be
submitted to the UIC program:
? a site plan with locations of floor drains or entry points to the Class IV/V well,
treatment systems, points of discharge to the ground, screening and sampling
locations, the boundaries of the excavated area; and
? screening and analytical results.
Submittals of the Pre & Post-Closure Notification Forms should be made to UIC Program:
MassDEP Boston thOne Winter Street – 5 Floor
Boston, MA 02108
Attn: UIC Program
Copies of the Pre-Closure Form should also be sent to: the local Board of Health and the public
water supplier(s) in the area of discharge.
Questions on closures related to Industrial Wastewater Discharges should be made to the
Industrial Wastewater Program contacts in the appropriate Regional Office: (see contact
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Questions on closures related to discharges covered by the Groundwater Discharge
Program should be made to the Groundwater Discharge Program contacts in the appropriate
Regional Office: (see contact information below):
Questions on closures related to discharges covered by the Waste Site Clean-up
Remediation Program should be made to the Waste Site Clean-up Program contacts in the appropriate Regional Office: (see contact information below):
Questions on closures related to discharges covered by UIC Registration Program should be
made to the UIC Program contact the Boston Office: (see contact information below):
South East Regional Office (SERO)
BRP Ground Water Discharge Program - (508) 946-2750
BWP Industrial Waste Water Program - (508) 946-2826
BWSC Site Management & Enforcement - (508) 946-2862 (Remediation Wells)
North East Regional Office (NERO)
BRP Ground Water Discharge Program – (978)-694-3215
BWP Industrial Waste Water Program - (978)-694-3277
BWSC Site Management & Enforcement - (978)-694-3218 (Remediation Wells)
Central Regional Office (CERO)
BRP Ground Water Discharge Program - (508)-792--2722
BWP Industrial Waste Water Program - (508)-792-2757
BWSC Site Management & Enforcement - (508)-792-2805 (Remediation Wells)
Western Regional Office (WERO)
BRP Ground Water Discharge Program - (413)-755-2279
BWP Industrial Waste Water Program - (413)-755-2239
BWSC Site Management & Enforcement - (413)-755-2249 (Remediation Wells)
Underground Injection Control (UIC) Program
BRP/DWP/UIC - Boston Office – 617-348-4014
7.2 Submittals to BWSC and Record Retention:
Documentation associated with the closure of a shallow injection well should be submitted
and/or retained as specified in the MCP.
Submittals to the Bureau of Waste Site Cleanup should be made at the appropriate MassDEP
Regional office. Appendix I is a list of Massachusetts’s cities and towns (indexed by regional
jurisdictions), which provides the address and telephone numbers for the four regional offices
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