THE ORCBS > Environmental Compliance > Programs & Guidelines > Wellhead Protection >

MSU WHHP: Element 3 - Contaminant Source Inventory (CSI)

Background

The purpose of the CSI is to identify known and potential sources of groundwater contamination within the WHPAs. Once identified, the contamination sources can be managed in order to reduce the risk they pose to the drinking water supply.

Unlike municipal water supply systems that supply water to both private and public users, the MSU water supply system provides water to mostly users at MSU. Since access was available to almost all properties within the WHPAs, more comprehensive facility inspections than those normally associated with a CSI were possible. As such, common approaches used by most communities for conducting a CSI were modified to fit the conditions at MSU.

After the initial CSI was done in 1999-2000, it was found that there were fewer problems to deal with than had been expected. The ones that were found were taken care of in an expedient fashion.

The MSU CSI consisted of six primary tasks:

1. A federal and state database search (EcoSearch).
   
   
2. Walk-through environmental inspection of properties within the State-approved WHPAs. The inspections took 13 months to complete, with 54 properties being inspected. The inspections involved a field walk-through investigation of the properties sometimes accompanied by, and always followed up with, interviews of property managers. Data obtained during the inspection were recorded on a form developed by the MSU Team.
   
   
3. USTs and ASTs - Preparation of a comprehensive listing of all known underground and aboveground storage tanks (USTs/ASTs) on campus. Considerable effort has been made by MSU to identify problematic storage tank systems and remediate any associated environmental concerns. Most of MSU's UST systems have been permanently removed or have been replaced with aboveground storage systems. During the CSI, information regarding MSU storage tanks was collected in order to confirm that no significant environmental risk is associated with these tanks.
   
   
   
   
4. Water Well Records Review - Identification of Abandoned Wells - Collection of available information on the water wells as part of a campus-wide abandoned well program. MSU has a variety of well types on campus. Examples of such wells include water supply wells (Type I and Type II), monitoring wells, lysimeters, and irrigation wells. To access the status of MSU wells and find abandoned wells, the MSU Team developed a well database from the available MSU water well records. These records included: State water well records available from the Ingham County Health Department, MDEQ, documents available in MSU well files, and Physical Plant Engineering and Architectural Services Department document archives. Other sources of well information included an interview with former MSU employee familiar with the campus area and onsite inspections of MSU properties.
   
   
5. A review of known and potential sources of contamination within portions of the MSU WHPAs extending off-campus. MSU reviewed the EcoSearch report for listed sites within MSU WHPAs that extend off-campus. MSU staff augmented the EcoSearch information through follow-up reviews. Additionally, MSU staff conducted a limited drive-by inspection of the off-campus WHPAs and obtained relevant information about the findings from the MDEQ.
   
   
6. Railroads - A limited review of rail transport through the MSU campus. Two rail lines, CSX and Grand Trunk, are located within the WHPA for MSU. Listed below are the top ten transported hazardous materials in 1997 for the U.S. The list should serve as a general representation of the types of materials expected to be transported through campus.
   
   

   Rank	Common Name	DOT Class
   1	Sodium Hydroxide, Solution	8
   2	Petroleum Gases, Liquefied	2.1
   3	Sulfuric Acid	8
   4	Ammonia, Anhydrous, Liquefied	2.2
   5	Asphalt and Tars	9
   6	Chlorine	2.3
   7	Sulfur, Molten	9
   8	Vinyl Chloride, Inhibited	2.1
   9	Methanol	3
   10	Sulfur, Molten	4.1

For a list of the DOT class definitions (click here)

The MSU Emergency Coordinator is currently updating the emergency management plan for potential rail accidents on the MSU campus. The Wellhead Protection Team plans to work with each rail line to inform them of the WHPAs and to coordinate any spill prevention and training activities.

Results of the Contaminant Source Inventory

Information obtained for the methods mentioned above were used to assign a "hazard category" to each of the inventoried sites. The hazard categories for potential sources of contamination are based on a two-tier system.

• Category I - Sites of Known Contamination
• Category II - Sites of Known or Suspected Potential Contaminate Use

Evaluation of Category I and II Sites

MSU has dedicated extensive resources to ensure campus properties are managed in an environmentally safe manner. Furthermore, MSU has trained personnel dedicated to pollution prevention and minimizing the environmental impact of campus operations. Although there are both Catergory I and II sites on the MSU campus, there have been significant efforts to address these sites and reduce their risk to the environment. It was important to identify which Category I and II sites required additional management activities. As such, the MSU Team developed a ranking system to categorize the sites relative to their need for additional management activities. Sites included in the CSI were assigned a Contaminant Source Rating (CSR) by a review committee. The CSR system used was as follows:

1a. Requires Action. Current problem, such as a spill with obvious contamination. Examples: chemicals discharged into a septic tank of the ground; leaking UST.

1b. Investigate Potential Contamination. Situation usually associated with contamination, but no obvious evidence of contamination.

1c. Action Being Taken. Contamination has been assessed and action is being taken.

2. Requires Secondary Containment, Change in Design or Structure. No current release of contamination. Examples: Aboveground storage with no pad or containment; chemical storage in an area with no containment near a floor drain.

3. Requires Administrative Controls or Work Place Changes. Examples: AST with pad but no written guidelines or absorbents; mixing pesticides in the field with no written guidelines.

4. Requires No Action. Examples: Leaking Underground Storage Tank (LUST) that was removed and remediated completely; pesticide storage in a contained structure.

Breakdown of first CSI done in 1999-2000
4. Requires No Action	72.7%
3. Requires Administrative Controls	10.6%
2. Requires Secondary Containment	12.5%
1c. Action Being Taken	2.3%
1b. Investigate Potential Contamination	1.9%
1a. Requires Action	0.0%

 

Breakdown of first CSI done in 2002
4. Requires No Action	87.3%
3. Requires Administrative Controls	3.0%
2. Requires Secondary Containment	7.5%
1c. Action Being Taken	1.1%
1b. Investigate Potential Contamination	1.1%
1a. Requires Action	0.0%

MSU WHPP: Management Strategies

Wellhead Protection Program