Issue Paper: Well Construction And Decommissioning

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1 Issue Paper: Well Construction And Decommissioning 1. Introduction And Background Final Draft\gwmp\vol4_rev\appndx-2\wellcons.doc 1.1. Purpose and Scope This issue paper examines prevention of aquifer contamination through proper well construction and/or decommissioning practices. It also addresses well construction practices of the past, such as multi-aquifer perforation, which are a hazard to ground water. As a goal, an effective ground water management program must ensure that proper well construction and decommissioning procedures are required and followed Kitsap County Well Status The precise number of active wells in the State of Washington and Kitsap County is not known, primarily because the submittal rate for well driller reports (commonly known as a well log) has been less than 100% since 1973 and was required only for permitted wells before The total number of active wells in the state is probably in the hundreds of thousands according to estimates from representatives of the State Department of Ecology (Ecology) and the United States Geological Survey (USGS) (Walsh, Fueste, personal communication). The actual number of active wells in Kitsap County is unknown at this time, but is thought to be substantial (over 10,000) based on recorded well logs and the rural nature of the county. (Deeter, Bremerton-Kitsap County Health District(BKCHD)) 1.3. Well Decommissioning Resolving the issue of potential aquifer contamination by improper well construction or decommissioning involves ensuring that existing regulations pertaining to construction and decommissioning are followed. Problem well construction practices of the past may have resulted in wells that should be decommissioned. Given a sufficiently large work-force and ample budget, the Washington Department of Ecology (Ecology) could inspect every new well that is constructed; inspect every existing well that is decommissioned; locate, inspect and properly decommission wells that have been abandoned or were constructed before WAC was adopted. In reality, however, Ecology has sufficient work-force and budget to inspect only a fraction of the wells constructed and decommissioned each year. The number of older wells in need of proper decommissioning can only be estimated. Few records exist for wells installed before submittal of drillers' logs became a legal requirement in The lack of records for older wells makes locating them largely a matter of chance, community memory, and detective work. The principal objective of proper decommissioning procedures is to restore, as far as practicable, the original hydrogeologic conditions at the well site. Proper decommissioning procedures entail sealing the well in such a way that water is excluded from the well and no vertical movement of water is possible. An improperly decommissioned well may: Well Construction And Decommissioning (WC) 1

2 (1) serve as a conduit for contaminated ground or surface water, (2) permit continued flow of water to the surface from an artisan aquifer, (3) alter the pressure conditions within a confined aquifer which may enable water from separate aquifers to mix, therefore allowing poor quality water to mix with good, or (4) present a potential source for personal injury, loss of life and/or property damage at the surface Multi-Aquifer Taps The casing in some of the older, deeper wells in the county are perforated at more than one aquifer level. Such multi aquifer taps effectively cross connect aquifers. A review of crosssection diagrams in Volumes I and II of the Ground Water Management Plan show several wells with multi aquifer taps. The practice is no longer permitted for several reasons. Contamination of an upper aquifer can quickly be spread to a lower aquifer through a well which taps both. Water can be drained from an upper aquifer to a lower aquifer through a connecting well, adversely affecting the water level in the upper aquifer. 2. Current Laws, Practices And Procedures 2.1. Laws and Codes By design, wells provide a link between an aquifer and the surface of the earth. In some cases, more than one aquifer may be tapped by the same well. Modern wells generally consist of well casing that extends downward from the ground surface to an aquifer within a cylindrical bore hole. Washington Administrative Code (WAC) Chapter , Minimum Standard for Construction and Maintenance of Wells, requires that the space between the casing and the wall of the bore hole be sealed to prevent vertical movement of water along the outside of the casing. If this space is not adequately sealed, it may serve as a conduit by which contaminated surface or subsurface water may travel into an aquifer. Inadequate well sealing may also permit soil to come in contact with the well casing which can cause corrosion and perforation of the casing. Under Chapter , WAC any well that is unusable, whose use has been permanently discontinued, which is in such disrepair that its continued use is impractical, or is an environmental, safety, or public health hazard, must be decommissioned. Ecology is the agency responsible for regulating well construction and decommissioning. State standards for well construction and maintenance (WAC ) were originally adopted in 1973; the current version was adopted in April The standards are administered by Ecology. They describe both general requirements for well construction, such as notification and permitting, sealing of the well casing, and enforcement, and specific requirements for construction and maintenance of water supply and resource protection (monitoring) wells. Because of Ecology's budgetary limitations, well construction and decommissioning is largely self-policed by well owners and contractors. Well drillers are required to obtain a license for construction of water wells. Chapter Revised Code of Washington (RCW) Water Well Construction requires that "no person may contract to engage in the construction of a water well...without first obtaining a license Well Construction And Decommissioning (WC) 2

3 by applying" to Ecology. This license may be revoked or suspended for violating the provisions of chapter RCW or regulations of the Washington State Department of Health. Chapter WAC contains the administrative requirements for examination, licensing and regulation of water well contractors. Well contractors are required to notify Ecology of their intent to construct, reconstruct, or decommission a well at least seventytwo hours before starting work; notification is made using forms commonly known as "start cards." A permit must be obtained from Ecology to construct a well that is intended to withdraw more than 5,000 gallons per day or irrigate more than one-half acre of noncommercial lawn and garden. Within thirty days after completion of a well, every well contractor is required to submit to Ecology a complete record (the well log) on the construction or alteration of the well which must include geologic and hydrologic information. The well log and start card requirements were introduced in 1973 and 1988, respectively (Liszak, personal communication). Prior to 1973, Ecology did not require well contractors or owners to submit well logs except for wells under water right permit. As a result, an unknown number of wells exists in the state without any record. In addition, the State has never required identification numbers for private wells. Recognizing the advantages of a statewide well identification system for information retrieval and ground water resource planning, Ecology has established and filled a permanent Planner 3 position in the Policy and Management Section to serve as the lead for the task. The planner has formed a Well Identification Task Force (Task Force) that includes representatives from federal, state and local governments, the drilling industry, consulting firms, the Washington Department of Health(DOH), USGS, and other branches of Ecology. The Task Force is currently evaluating proposed well identification systems and implementation schemes (Walsh, personal communication). The Task Force includes in its goals, tagging every well with a unique identification number and developing and maintaining an identification program as the first step toward determining the number of wells in need of proper decommissioning in the state. The Task Force will conduct a three month pilot program in Kitsap County to label wells with identification numbers or tags. The Public Utility District will tag operational and other wells (e.g., monitoring, decommissioned) both public and private. Drillers participating in the pilot program will tag all new wells and existing wells which need maintenance service. Once a well identification program has been developed, the Task Force will change its name to the Well Abandonment Task Force and shift its focus to developing a strategy for decommissioning appropriate wells. The Well Abandonment Task Force will also be under the lead of Ecology. As preliminary tasks, the Task Force will explore funding options, research well decommissioning programs in other states, and investigate ways in which authority may be delegated to local government. Public cooperation and education will be essential in both the well identifications and well decommissioning projects. According to an Ecology representative, gaining public support for the projects will require public education. Well Construction And Decommissioning (WC) 3

4 Substitute House Bill (SHB) 2796, enacted by the 52nd Legislature, 1992 Regular Session, provided Ecology the authority to delegate a small portion of the Water Well Construction Program to a local health district or county. Upon written request, Ecology may delegate the well sealing and decommissioning portions of the program. The requesting entity must show it has the resources, capability, and expertise, including field inspectors, to administer the delegated program. The delegation includes no funding and is implemented through a memorandum of agreement between the local governing body and Ecology. The act has a "sunset" provision and will expire on June 30, 1996, unless the legislature takes further action on the issue prior to that date DOH And BKCHD Public water supply wells are under the authority of DOH. Before a public water supply well is constructed, the site must be inspected and the plans reviewed and approved by DOH. The site may be inspected again after construction is completed. Under an interlocal agreement between DOH and BKCHD, the Health District performs these functions for systems with fewer than 25 connections. The BKCHD as part of Ordinance , performs inspections when a new private well is proposed to serve a new residence with an on-site sewage system. The District ensures that: (1) the well meets proper siting and setback requirements; (2) the on-site sewage system is properly constructed and located at least 100 feet from the well; and (3) all other sources of contamination meet proper setback requirements. Also, a private well may be inspected when a lending agency requests a report on the water supply for a house. A complete sanitary survey may be done, including a bacterial analysis, with a report sent to the applicant and a copy kept on file at the BKCHD. The Health District also investigates complaints about wells. BKCHD inspectors perform inspections for a variety of purposes that do not involve wells directly, but that bring inspectors into close proximity to wells. According to a representative of Ecology, BKCHD inspectors are commonly the first to notify Ecology of well problems (Liszak, personal communication) Kitsap County Department of Community Development, Building, Zoning and Land Use Sections The Kitsap County Department of Community Development (Building, Zoning and Land Use sections) is not directly involved in well construction or decommissioning. According to a representative of Ecology, however, inspectors of these sections have, in the past, encountered unused or abandoned wells in the course of performing site inspections and have notified Ecology or the BKCHD who in turn notifies Ecology of the well locations (Liszak, personal communication). At this time, it is not possible to estimate the frequency with which this occurs in Kitsap County, but the number is not substantial (Thompson, personal communication) USGS The USGS maintains a ground water database that includes well data acquired for specific projects. The database includes information, such as the latitude and longitude of the well, Well Construction And Decommissioning (WC) 4

5 the Section-Township-Range location, the well depth, well owner, water use, and the lithologic interpretation (i.e., geologic description of rock layers). The database is not a complete inventory of wells in the state. A representative of the USGS estimated that fewer than one-third of the wells in Kitsap County have been entered into the database (Fueste, personal communication). The USGS lacks the personnel needed to expand the database to include all the wells in the state Well Identification Program The PUD is conducting a pilot well identification program for the state. Unique well identification numbers are assigned to individual wells and a permanent tag with the number is attached to the well head. The number will serve to correlate all data base information on the well. Over a thousand existing wells have been tagged and some well drillers are tagging new wells as part of the evaluation. 3. Gaps And Problems 3.1. Inspection and Enforcement In order for any of the construction requirements to work adequately, there must be a better inspection and enforcement program by DOE or an authorized representative of DOE. A representative of the Northwest regional Office of Ecology (NW Office) estimated that the NW Office receives approximately 285 drillers' logs for new wells each month, or approximately 3,400 logs each year, from a seven-county area that includes Kitsap County. Of these new wells, only about 15 each month receive initial inspections; approximately 15 additional wells are inspected each month in response to complaints. (Huggins, personal communication). The number of well inspections by DOE is inadequate to ensure all well drillers use proper construction and sealing techniques, as well as make accurate well information reports. The most obvious data gaps include: (1) knowledge about where and how many existing unused and abandoned wells there are in Kitsap County is lacking; (2) no process has been established to ensure that wells going out-of-service will be properly decommissioned, and (3) the true degree of risk to ground water quality from unused, but not properly decommissioned wells is not adequately documented. Not withstanding item (3) above, the potential for contamination through either improperly constructed wells or improperly abandoned wells is a recognized fact. Existing statutes and regulations for well construction and decommissioning are generally adequate to protect the aquifer systems, but implementation, regulation, and enforcement is deficient. Ecology does not receive enough funding to inspect more than a small percentage of wells during construction or decommissioning. Additional funding for the water resources program will probably be directed toward other higher priority activities. The public, in general, lacks an awareness and good understanding of the importance of proper well decommissioning. Well Construction And Decommissioning (WC) 5

6 4. Recommendations And Strategies WC 1. Support sufficient funding for the well construction and decommissioning program. WC 2. BKCHD evaluate its capability to assume portions of the water well construction program as provided for under SHB 2796 and request delegation of authority to conduct appropriate portions of the program. WC 3. Establish local ordinances (or support legislation) which require sellers of property to disclose to buyers the existence of all wells on the property whether in use or not. WC 4. Kitsap County and cities revise land use and assessment procedures to require property owners to report the number and condition of wells on land they own. WC 5. Support Ecology's well identification program and establishment of a Well Abandonment Task Force to develop a statewide program that is adaptable to implementation at the local level. WC 6. Request BKCHD, in conjunction with Ecology, to develop an education brochure concerning proper well construction and decommissioning practices and their importance to the protection of ground water quality. WC 7. Rescind the "sunset" provision of SHB WC 8. Support legislation which requires individuals who become aware of abandoned wells to report them to BKCHD. WC 9. Support legislation to fund a 5 year well decommissioning incentive program. WC 10.PUD develop a data base of wells with multi aquifer taps. Identify these wells as primary candidates for decommissioning. Well Construction And Decommissioning (WC) 6

7 5. References The materials for this paper have been, for the most part, obtained from a draft issue paper entitled, "Ground Water Quality Issues Related to Well Construction and Abandonment" written by Jacqueline A. Smith of Geraghty and Miller, Inc. and Trudy C. Rolla of the Seattle King Department of Public Health. Additionally, other ground water management programs have been reviewed and information used, as appropriate. Batra, Mo. Drinking Water Operations, Washington Department of Health Bishop, Roy. Well Construction Regulations, Washington Department of Ecology, N.W. Regional Office, Bellevue, Deeter, Jerry. BKCHD Drinking Water Section Huggins, Herman. Well Inspections, Washington Department of Ecology, N.W. Regional Office, Bellevue, Liszak, Jerry. Well Construction and Abandonment, Washington Department of Ecology, N.W. Regional Office, Bellevue, Moseng, Ethan. Drinking Water Operations, Supervisor, Washington Department of Health Scott, Randy. Legislation, Washington State Association of Counties Walsh, Brian. Water Resources and Planning; Well Identification Task Force, Washington Department of Ecology, Olympia Woods, Mike. Legislation, Association of Washington Cities Clark County Ground Water Advisory Committee. Issue Paper #2: Abandoned Wells. Ground Water Management Plan for Clark County, Washington (DRAFT). April, Chapter WAC - Minimum Standards for Construction and Maintenance of Wells. Chapter WAC - Rules and Regulations Governing the Regulation and Licensing of Well Contractors and Operators Chapter WAC - Drinking Water Regulations - State Board of Health Chapter RCW - Water Well Construction Act (1971) Bremerton-Kitsap County Board of Health Ordinance , Rules and Regulations for Public and Private Water Supplies. Well Construction And Decommissioning (WC) 7

DRINKING WATER PROGRAM POLICY/PROCEDURE KITSAP COUNTY DRINKING WATER ADEQUACY REQUIREMENTS FOR SUBDIVISIONS AND BUILDING SITE APPLICATIONS

DRINKING WATER PROGRAM POLICY/PROCEDURE Title: KITSAP COUNTY DRINKING WATER ADEQUACY REQUIREMENTS FOR SUBDIVISIONS AND BUILDING SITE APPLICATIONS Reference: Ordinances 20-1983 (Long Subdivision), 106-B-1990