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A White Paper on Statewide Water-Well Construction Standards
By Todd Giddings, Ph.D., P.G., PGWA Education Committee Chairman
Definition of a White Paper, from Wikipedia, the free encyclopedia: “A white paper is an authoritative report or guide informing readers in a concise manner about a complex issue and presenting the issuing body's philosophy on the matter. It is meant to help readers understand an issue, solve a problem, or make a decision.”
Statewide water-well construction and decommissioning standards (hereinafter called Standards) for Pennsylvania are both a technically complex issue, due to the wide geologic variety of Pennsylvania’s aquifers, and are a politically complex issue, because the Standards would have the Department of Environmental Protection (DEP) telling landowners how they must construct and decommission (properly seal) wells on their private property. These complexities, especially the political issues, have kept the Pennsylvania Legislature from enacting legislation to create these Standards for more than 20 years.
I have prepared this PGWA White Paper to inform you, and to hopefully motivate you to support the Bills that are in the current legislative session. You can be an active supporter by contacting your Senator and your Representative. Their phone numbers and addresses are available at www.legis.state.pa.us .
The definition of a water well in the new legislation is appropriately very broad, and includes in addition to water-supply wells, recharge wells, geothermal supply wells, geothermal closed-loop system boreholes, monitoring wells, and test borings. Because the construction and decommissioning of all public water-supply wells in Pennsylvania are already appropriately regulated by existing DEP regulations, public water-supply wells are exempt from the new legislation. Oil and gas wells are similarly exempt.
Where? The new water-well construction Standards will apply to all of Pennsylvania. Existing county and local water-well construction standards that are equal to or more stringent than the new statewide Standards will remain in effect. The new statewide Standards will supersede existing local requirements that have lower standards for water-well construction and decommissioning.
Here are the reasons why Pennsylvania needs these Standards now:
4½ million people (37%) of Pennsylvania’s population use groundwater as their potable water source. The groundwater resources of Pennsylvania need to be protected against contamination entering through improperly constructed residential wells, improperly constructed geothermal heat pump system boreholes, and improperly decommissioned wells.
Pennsylvania has an estimated 80 trillion gallons of groundwater residing underground in its aquifers. This vast volume of water is enough to submerge the entire state beneath eight feet of water if it were brought to the land surface. This groundwater resource must be protected from contamination so it remains available for use by Pennsylvanians.
It is estimated that more than 15,000 new water wells are constructed in Pennsylvania each year. The absence of any residential well Standards allows wells to be improperly constructed and to threaten the quality and quantity of Pennsylvania’s groundwater.
Pennsylvania has the second-highest number of residential wells of any state in the nation. Clearly, the widely-utilized groundwater resources of Pennsylvania are a very important water resource worthy of protection.
Pennsylvania is one of only two states with no Standards. The other 48 states all have standards for the proper construction of residential water wells to protect their state’s groundwater resources. Pennsylvania needs to catch up to protect the resource and to protect public health.
Beginning more than 14 years ago, the PGWA has been instrumental in the development of legislation to create residential water well construction Standards in Pennsylvania. The Pennsylvania legislature has failed to pass this earlier legislation to create Standards for residential well construction. This legislation needs to become law in this 2015 legislative session.
Improperly constructed residential wells have been identified as potential threats to groundwater quality within Source Water Protection Areas of public water-supply wells. There are documented cases of improperly constructed residential wells providing a pathway for surface and subsurface contamination to impact Pennsylvania’s groundwater resources.
An unknown but large number of boreholes for geothermal heat pump system vertical heat-exchangers are being constructed in Pennsylvania each year. There are no Standards requiring geothermal heat pump system boreholes to be sealed with impervious grout to protect the quality of Pennsylvania’s groundwater resources. The unsealed boreholes provide direct flow pathways for contamination to enter our aquifers.
Due to large number of geothermal boreholes that are being constructed, improperly sealed geothermal heat pump system boreholes could pose a threat to Pennsylvania’s groundwater resources that could surpass the threats posed by improperly constructed residential wells.
The International Ground Source Heat Pump Association (IGSHPA) is an internationally recognized authority on the design and construction of vertical heat-exchanger boreholes for geothermal heat pump systems. IGSHPA offers a geothermal training course for well drillers on the proper design and construction of closed-loop geothermal heat pump systems, including the proper construction and sealing of the vertical heat-exchanger boreholes.
The IGSHPA vertical geothermal borehole construction standards require the use of impervious grout to seal the entire length of the borehole around the loop pipes to prevent the movement of contaminants down the borehole into aquifers. Construction of geothermal heat pump system boreholes in compliance with these IGSHPA standards ensures that the boreholes are sealed to prevent the entrance of contaminants into Pennsylvania’s aquifers.
Geothermal heat pump system boreholes are being constructed within the capture zones (area of direct groundwater flow to the well) of many public water-supply wells that may serve many thousands of people. Improperly constructed geothermal boreholes have been identified as one of the top three threats to public groundwater supply wells in source water protection studies.
Many public water systems have groundwater as their primary source or as a supplemental source. Pennsylvania requires all public water-supply wells to be properly constructed to protect the quality of the groundwater and the health of the public drinking the water from the public water system. Properly constructed residential water wells protect the quality of the quality of the groundwater produced from the well and thereby protect the health of the family using the groundwater from their well.
Residential wells need their own set of Standards for the same reasons public water-supply wells have construction standards throughout Pennsylvania. Properly constructed residential water wells also protect the quality of the groundwater in Pennsylvania’s aquifers. Contamination entering the groundwater through improperly constructed residential water wells can move within the aquifer and impact nearby public water-supply wells and other residential wells.
The new State Water Plan has set the creation and implementation of Standards for residential water wells as its most important and its first legislative priority to protect Pennsylvania’s groundwater quality and the health of Pennsylvania’s citizens. The PGWA has conducted public training on proper residential well construction to support this new State Water Plan.
For several years, the PGWA has been conducting public training demonstrating the method of proper construction for residential wells and for geothermal heat pump system boreholes to support the first legislative priority stated in the new State Water Plan. The PGWA has also been demonstrating the proper decommissioning of residential water-supply wells in its public training.
So here is my health and safety protection analogy part one: Research clearly showed that wearing seat belts and installing airbags in vehicles saved lives when accidents occurred. Our Federal government enacted the seatbelt and airbag regulations that we take for granted today. By analogy, the new Standards will be the “seatbelts and airbags” to protect the quality and quantity of Pennsylvania’s groundwater resources and the health of her residents.
The second-part of my health and safety protection analogy is that you must pass a written test on the traffic regulations to get a driver’s license. If you don’t know the traffic regulations, you won’t be driving safely. By analogy, well drillers must be required to pass a written test on the new Standards so that they will know who is regulated, what the Standards require, how to construct a well to meet the Standards, where wells should not be located, when the Standards apply, and why the Standards exist.
Today, without the new Standards, anyone can become a Pennsylvania Licensed Drilling Contractor simply by paying a $75 license fee. There can be no grandfathering of these currently licensed drilling contractors under the new Standards, because some of them do not know how to properly grout a water-well casing, and they do not understand why every water-well casing needs to be properly grouted. They also do not know how proper construction and proper decommissioning protects Pennsylvania’s groundwater quantity and quality, and protect the health of her residents. And yes, an improperly constructed well costs less than a properly constructed well.
So how much more will it cost a homeowner for a properly constructed water well that meets the new Standards? Studies have found that the cost increase to construct a well so that it meets the Standards will be an average of only 10% to 15% more. Many currently-licensed drilling contractors are voluntarily constructing their water wells to the new Standards today, because they know it is the “right thing to do” to protect Pennsylvania’s groundwater resources.
What are the three Consumer Affairs Committee amendments to HB 48?
Amendment One: “Requires the Environmental Quality Board to adopt the water well construction and decommissioning standards recommended by the American National Standards Institute and the National Ground Water Association.” The PGWA believes that it should have a significant role in tailoring these generic standards to fit Pennsylvania’s very diverse geologic conditions and thereby ensure that the quality and the quantity of Pennsylvania’s groundwater are adequately protected.
Amendment Two: “Amends the definition of “water well” to create an exemption for wells dug on “normal agricultural operations”, as defined by the Right to Farm Act.” This amendment exempts almost all of Pennsylvania’s farms from the new Standards. The PGWA believes that to protect the quality and quantity of groundwater produced from Pennsylvania’s thousands of existing farm wells, new farm wells should not be exempt from the new Standards.
Amendment Three: “amends the definition of “water well” to clarify that wells dug for the purpose of coal mining or that comply with the Surface Mining Conservation and Reclamation Act, Bituminous Mine Subsidence and Land Conservation Act or the Coal Refuse Disposal Act are exempt.” The PGWA believes that to protect the quality and quantity of the groundwater produced from coal-mining related wells, new coal-mining related wells should not be exempt from the new Standards.
Please contact your Senator and contact your Representative and tell them to support this new legislation. You can pick some reasons from the list of 16 above or you can tell them your own reasons why this legislation needs to become law in this session. You should also tell your legislators whether or not you support the three amendments to HB 48. The phone numbers for your own legislators are listed at www.legis.state.pa.us .
To print a copy of this White Paper, click on this link.