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Reviewing

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Title: Reviewing


1
Reviewing Abandoned Well Records For
Local Health Departments
2
COMMON PROBLEMS WHEN REVIEWING WATER WELL
PLUGGING RECORDS
3
COMMON PROBLEMS
The old well was not plugged.
WAS THERE A PERMIT REQUIREMENT TO PLUG THE OLD
WELL? IF SO, WHY WASNT THE WELL PLUGGED? DID
THE CONTRACTOR PROVIDE A REASON?
4
MOST COMMON REASONS FOR NOT PLUGGING THE WELL
  • Well owner wants to keep it.
  • Cant locate it.
  • Well is under driveway.
  • Pump is stuck.

These reasons are sometimes code for I dont
want to pay to have my well plugged.
5
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.
6
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

7
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.
8
COMMON PROBLEMS
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?
9
With patience and effort, buried wells can be
located.
10
COMMON PROBLEMS
WHEN DO YOU REQUIRE A WELL OWNER TO TEAR UP A
CEMENT DRIVE TO FIND AND PLUG A WELL?
Some situations will be a judgment call. Use
common sense and consult with DEQ if needed.
11
COMMON PROBLEMS
A well depth of ? or unknown on the plugging
record.
WHY DONT 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?
12
COMMON PROBLEMS
Contractors who show a pattern of stuck
obstructions should be evaluated closely.
ARE THEY PUTTING FORTH AN EFFORT? DO THEY HAVE
THE EQUIPMENT?
13
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.
14
Once the obstructions are removed, measuring the
well depth is easy.
15
COMMON PROBLEMS
Unapproved plugging material used.
  • Rock Well Neat Cement
  • Sand, peastone or soil are used only in special
    circumstances.

VIOLATION OF RULE 164
16
COMMON PROBLEMS
  • Well owner plugging a public well or a well that
    is not their primary residence.
  • Examples
  • apartment building
  • hunting camp
  • small business

VIOLATION OF RULE 162
17
COMMON PROBLEMS
  • Unregistered contractors plugging wells.
  • pump installers or plumbers
  • environmental consultants
  • demolition contractors
  • water treatment companies

VIOLATION OF RULE 162
18
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.
19
COMMON PROBLEMS
Contractor submits a dry hole drilling record
with no plugging information for the dry hole.
VIOLATION OF RULE 162
20
COMMON PROBLEMS
Two sets of rules, one for contractors and one
for well owners.
Well owners are sometimes allowed to violate the
well code when plugging their own well
SELECTIVE ENFORCEMENT.
THIS MAY COME BACK TO HAUNT YOU!
21
Well owners do not have the knowledge or
equipment to plug most wells.
22
OTHER STUFF
If a contractor does not properly construct or
locate a well, the contractor is responsible for
plugging the well.
RULE 169
23
OTHER STUFF
Temporarily abandoned wells must comply with the
well code.
  • Temporarily abandoned wells dont include
  • well too close to a contamination source
  • well in a pit
  • un-grouted well

RULE 170
24
Submitting Known False Data on Plugging Records
is a FELONY
UTTERING Present a forged document
PUBLISHING Create a forged document

25
PLEASE
Double-check all water well records for accuracy
and completeness before you send them to the DEQ!
Or they will get sent back
26
Please use our office as a resource for dealing
with abandoned wells Jim McEwan mcewanj_at_michigan.
gov 517-241-1413
Jims hands-on, how-to well plugging manual is
near completion!
27
QUESTIONS?
Spring is just around the corner!
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