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4 - Management Strategies
Managing existing and potential sources of contamination is the most critical component of a local WHP program. As part of its initial WHP planning effort, MSU implemented a number of management strategies that continue today. Those activities and upcoming management priorities are described in this section.
Agricultural Best Management Practices
Right to Farm and GAAMPs
The large majority of the MSU WHPAs lies within the agricultural land south of Mt. Hope Road and bounded by Hagadorn and Collins Roads. The agricultural research facilities located within these areas are operated in conformance with the Michigan Right to Farm Act Generally Accepted Agricultural and Management Practices (GAAMPs), and in compliance with MDEQ NPDES, SPCC, and HAZMAT requirements. Additionally, the agricultural research facilities are operating under a voluntary and informal Environmental Management System (EMS).
NPDES CAFO Permit
The Livestock research facilities have been operating under a NPDES CAFO Permit since 2005. An engineering evaluation for structural integrity of all manure storage structures has been completed and all manure and nutrients are managed under a Comprehensive Nutrient Management Plan, with activity reports being submitted annually to MDEQ.
Michigan Agriculture Environmental Assurance Program
Activities are currently underway to secure Michigan Agriculture Environmental Assurance Program (MAEAP) verification for all Livestock research facilities in the areas of Farmstead and Livestock. Three facilities were verified in 2014. These programs will continue to require regular facility and operational inspections, along with maintaining higher standards for overall operations, training, and knowledge by research facility managers and personnel. More information about the MAEAP process can be found on the program website: www.maeap.org.
Storage, handling and application of pesticides are conducted in conformance with the GAAMPs for Pesticide Utilization and Pest Control, which is updated and published annually. The storage, handling and application of pesticides (which includes pesticides, fungicides, insecticides, rodenticides, and herbicides), is also conducted in compliance with the Federal Insecticide, Fungicide and Rodenticide Act, Federal Worker Protection Standard, and Public Act 451, Natural Resources and Environmental Protection Act, Part 83, Pesticide Control. This pertains to all pesticide material storage, handling and application on MSU property, and is not exclusive to the agricultural land.
Storage, handling and application of manure is conducted in conformance with the GAAMPs for Manure Management and Utilization, updated and published annually. Manure management is also conducted in compliance with MDEQ NPDES Stormwater and CAFO permit requirements, and CNMP initiatives. MSU’s internal operational procedures exceed those of the GAMMPs, CAFO, and MAEAP standards as staff members utilize an extensive soil and manure sampling program to monitor nutrient levels, base application windows on University and community activities and corresponding prevailing winds, immediately incorporate all manure applications, and do not make winter land applications of manure.
Fertilizer and Nutrient Management
Storage, handling, and application of fertilizer and nutrients is conducted in conformance with the GAAMPs for Nutrient Utilization, which is updated and published annually. Fertilizer management is also conducted in compliance with MDEQ NPDES Stormwater permit requirements, and CNMP initiatives.
Irrigation management is conducted in conformance with the GAAMPs for Irrigation Water Use Management, which is updated and published annually. MSU continues to follow and meet Michigan Department of Agriculture (MDA) water use reporting guidelines, and has implemented water conservation practices, backflow prevention measures, and permanent isolation setbacks for all wells.
Management of Identified Known and Potential Sources of Contamination
Storage of Hazardous Materials
Fuels, solvents, pesticides, and other hazardous waste materials stored in amounts greater than thirty gallons have secondary containment of sufficient volume to contain 1.1 times the volume of the largest vessel sitting inside the containment. Active floor drains have been eliminated in all storage areas. Regular inspections of all fuel storage locations are completed by EHS personnel with deficiency notifications provided to research facility managers for mitigation.
Removal and disposal of Hazardous Wastes
The MSU EHS has an ongoing hazardous waste collection and training program available to all MSU facilities. Arrangements for pick-up and disposal of these materials can be made by calling 355-0153.
Survey of Campus Buildings
EHS will continue to monitor the buildings within the WHPAs for hazardous material use and storage. EHS conducts an annual survey to determine the types and amounts of hazardous materials being used and/ or stored in all campus buildings, including those within the Wellhead Protection Areas.
Incorporation of Wellhead Protection into the Campus Master Plan
The Campus Master Plan will be updated in 2016. As part of that update the University Zoning Ordinance will be reviewed and updated to include language for the Agricultural District that guides physical development in relationship to the Wellhead Protection Plan.
Incorporation of Wellhead Protection into the MSU Construction Standards
Revisions to MSU’s Division One Standards were made to incorporate activities to prevent hazardous substances used during construction work from being discharged into the environment. MSU’s Division One Construction Standards (general requirements) include the addition of Construction Standards for Wellhead Protection.
Development of a GIS to Manage Wellhead Protection Data
As part of the WHP plan update, a WHP GIS database is being generated. The data will include the delineated WHPAs, campus buildings, and the CSI. For security reasons, this GIS system will be available only to specific departments on campus, including: the IPF Department of Power and Water, Land Management Office and Engineering and Architectural Services; Environmental Health and Safety (EHS).
Properly Decommissioning Abandoned Wells
Water wells have been used to extract drinking water on the MSU campus since 1855. Additionally, other types of wells, such as monitoring wells, test wells, and lysimeters, have also been installed on the campus property for various purposes.
Previously, given the development history of the campus and the large number of known and/or potential abandoned wells, MSU implemented an abandoned well program. The program outlined the procedures that MSU followed to identify and address abandoned wells. The program consists of four main components:
- Well identification
- Prioritization of wells for abandonment
- Well plugging
- Documentation of plugging procedures
The campus has plugged all identified abandoned wells located within its boundaries. A total of 66 wells were plugged between July 2005 and August 2006. Most recently four wells were abandoned and plugged in 2011. Although MSU staff members suspect there could be additional abandoned wells, their locations are unknown. Due to the fact that the suspected wells are located on agricultural land, and may have been plowed over, attempts have been made to find them using equipment such as metal detectors. At the time of this report, no additional abandoned wells have been located.
A completed Abandoned Well Plugging Record has been prepared for each well that was plugged. Copies of these records were provided to the State of Michigan, Ingham County Health Department, and to the MSU Department of Power and Water.
Other strategies discussed include providing technical assistance and additional monitoring of production well quality. These strategies are discussed below.
Members of the MSU Wellhead Protection Team provide ongoing technical assistance to managers and staff to promote work practices that protect groundwater. This may include reporting potential problems and recommending solutions that result from regular and periodic contaminant source inventories and providing training at annual farm managers' and academic departments, and researchers' meetings.
Monitoring - Production Wells
MSU collects water quality samples necessary to comply with state and federal drinking water requirements for Type I water suppliers. In addition to this monitoring, MSU collects water samples for coliform bacteria analysis from all production wells on a monthly frequency.
WHPP: Contingency Plans
Wellhead Protection Program