reviewing abandoned well records for local health departments

COMMON PROBLEMS WHEN

REVIEWING WATER WELL PLUGGING

RECORDS

COMMON PROBLEMS

The old well was not plugged.

WAS THERE A PERMIT REQUIREMENT TO PLUG THE OLD WELL?

IF SO, WHY WASN’T THE WELL PLUGGED?

DID THE CONTRACTOR PROVIDE A REASON?

MOST COMMON REASONS FOR NOT PLUGGING THE

WELL Well owner wants to keep

it.

Can’t locate it.

Well is under driveway.

Pump is stuck.

These reasons are sometimes code for: “I don’t want to pay to have my well plugged.”

OWNER WANTS TO KEEP THE OLD WELL, NOW WHAT?

Per the well code, the well owner can keep the old well.

But, are they actually using it?

DEQ has example letters and forms to address this with the well owner.

If not, per Rule 168, you can order an abandoned well be plugged.

DOES THE OLD WELL FALL INTO ONE OF

THESE CATEGORIES?

No longer used

In complete disrepair

Left uncompleted

Threat to groundwater resources

Health or safety hazard

WHEN DO YOU “STICK TO YOUR GUNS” AND

REQUIRE THE WELL BE PLUGGED?

Well in contamination area

Safety hazard

Well left uncompleted due to positive coliform samples.

Some LHDs take a very hard stance on this and do not approve the new well until the old well is plugged.

Unable to locate the well

HOW MUCH EFFORT WAS PUT INTO SEARCHING FOR IT?

DID YOU INQUIRE ABOUT THE WELL LOCATION WHEN YOU CONDUCTED THE PREDRILLING SITE REVIEW?

COMMON PROBLEMS

With patience and effort, buried wells can be located.

COMMON PROBLEMS

Some situations will be a judgment call.

Use common sense and consult with DEQ if needed.

WHEN DO YOU REQUIRE A WELL OWNER TO TEAR UP A CEMENT DRIVE TO FIND AND PLUG A WELL?

COMMON PROBLEMS

A well depth of “?” or “unknown” on the plugging record.

WHY DON’T THEY KNOW THE DEPTH?

DID THEY MEASURE THE WELL DEPTH? IF NOT, WHY NOT?

WERE THERE OBSTRUCTIONS IN THE WAY?

DID THEY SEARCH FOR THE ORIGINAL DRILLING RECORD TO DETERMINE DEPTH?

COMMON PROBLEMSContractors who

show a pattern of stuck obstructions should be evaluated closely.

ARE THEY PUTTING FORTH AN EFFORT?

DO THEY HAVE THE EQUIPMENT?

Using and excavator or backhoe to attach to the drop pipe and yank will typically break off the drop pipe down in the well.

This does not meet the intent of the well code.

Once the obstructions are removed, measuring the well depth is easy.

COMMON PROBLEMSUnapproved

plugging material used.

Rock Well = Neat Cement

Sand, peastone or soil are used only in special circumstances.

VIOLATION OF RULE 164

COMMON PROBLEMSWell owner plugging a

public well or a well that is not their primary residence.

Examples:

• apartment building

• hunting camp

• small businessVIOLATION OF RULE 162

COMMON PROBLEMS

Unregistered contractors plugging wells.

• pump installers or plumbers

• environmental consultants

• demolition contractors

• water treatment companies

VIOLATION OF RULE 162

Demolition company illegally plugged 17 rock wells with bentonite, and did not remove the obstructions.

The wells were drilled-out and re-plugged by a well drilling contractor.

COMMON PROBLEMS

Contractor submits a dry hole drilling record with no plugging information for the dry hole.

VIOLATION OF RULE 162

COMMON PROBLEMS

Two sets of rules, one for contractors and one for well owners.

THIS MAY COME BACK TO HAUNT YOU!

Well owners are sometimes allowed to violate the well code when plugging their own well = SELECTIVE ENFORCEMENT.

Well owners do not have the knowledge or equipment to plug most wells.

OTHER STUFF

If a contractor does not properly construct or locate a well, the contractor is responsible for plugging the well.

RULE 169

OTHER STUFF

Temporarily abandoned wells must comply with the well code.

“Temporarily abandoned” wells don’t include:

• well too close to a contamination source

• well in a pit

• un-grouted well

RULE 170

Submitting Known False Data on Plugging Records is a FELONY:

UTTERING:

Present a forged document

PUBLISHING:

Create a forged document

&

Double-check all water well records for accuracy and completeness before you send them to the DEQ!

PLEASE

Or they will get sent back…

Please use our office as a resource for dealing with abandoned wells:

Jim McEwan

mcewanj@michigan.gov

517-241-1413

Jim’s hands-on, how-to well plugging manual is near completion!

QUESTIONS?

Spring is just around the corner!