The Underrated Importance of Monitoring Wells

12 Feb The Underrated Importance of Monitoring Wells

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According to the New Jersey Department of Environmental Protection (NJDEP) Division of Water Supply and Geoscience (DWSG), over 20,000 new permits are issued to drill wells in the state of New Jersey each year. If you own or are considering purchasing a property in New Jersey that is currently undergoing an environmental investigation, chances are that either a monitoring well, injection well, recovery well, piezometer, or soil vapor extraction well exists on the property.

Who’s Responsible?

Once a permit is filed to drill a well with the NJDEP and your name is listed as the property owner on the permit, you (or your company) become responsible for that well. As a property owner (and now a well owner), you need to become familiar with N.J.A.C. 7:9D Well Construction and Maintenance, Sealing of Abandoned Wells; and N.J.S.A. 58:4A-4.1 et seq. Responsibilities of Well Owner, Drilling Contractors, Violations. The NJDEP specifically states that “Property owners are responsible for the maintenance of all wells located on the property and the decommissioning of the well at the end of its life.”

Lost and Damaged Monitoring Wells

Monitoring wells, regardless of type, are the most important aspect of an environmental investigation, yet they are often the most neglected. Protective manholes and/or concrete pads may be damaged, manhole covers missing bolts, lid gaskets damaged or missing, and Cherne plugs (aka expansion plugs) damaged and/or not locked. Consequently, if damaged or not properly sealed, a well that is being used to collect samples for laboratory analysis or for the collection of groundwater elevations could easily become a contributor to — and further degrade — existing groundwater contamination. Specifically, wells located in parking lots with car and/or truck traffic are most prone to damage. Stormwater from the parking lots, often dotted with oil stains, could flow towards the monitoring well manholes. If not properly sealed, the stormwater could enter the well and negatively impact groundwater, causing additional unforeseen and costly issues. Further, if wells are not locked or secured, they are susceptible to vandalism and sabotage without your knowledge.

The loss or damage of a well could prove to be costly and time consuming to remedy. Consider the following:

• If needed as part of the on-going environmental investigation, a damaged monitoring well needs to be repaired. Once repaired, if the elevation of the outer and/or inner casing changes, the well will need to be resurveyed by a licensed surveyor.
• If a monitoring well is noted to be damaged beyond repair but a monitoring well is still required in that location, the existing monitoring well is required to be properly abandoned and replaced. The replacement well needs to be installed within 10 feet of the former well.
• If a monitoring well is lost or damaged to the point where it cannot be properly decommissioned, the NJDEP “Guidance for Damaged, Destroyed, or Lost Wells” provides the information necessary to close these wells. The property owner or agent needs to provide the NJDEP Bureau of Water Allocation and Well Permitting (BWAWP) information about the damaged or lost well in writing. This information includes the well owner or responsible parties contact information, program interest (PI) number, location information, well permit number, and well construction details. In addition, information must be submitted indicating what caused the well to be lost. If a well can’t be found, the well owner is required to provide details on what actions were performed to attempt to locate it. Examples of such actions include: interviewing the original well driller (if possible); interviewing on-site employees; using a metal detector, magnetometer, or ground penetrating radar (GPR); obtaining original survey information; submitting Open Public Records Act (OPRA) Request of License Site Remediation Professional (LSRP) Form A and Form B; and even excavation in an attempt to locate the well. This information must be submitted in a letter to the BWAWP. Along with the letter, you also need to include photographs, drawings, diagrams, maps, survey data, LSRP reports that contain site details, original correspondence with the NJDEP or any other state, County or Local agencies, and well driller notes.

How to Protect Your Monitoring Well

The NJDEP recommends protecting wells through different means, including marking with neon paint, using concrete barriers, using fences or ropes to isolate the well from surrounding areas, and placing steel plates over the well. These methods are suitable for sites being redeveloped, but not for sites that are active and still in operation. If your site is not being redeveloped, proactive tracking and maintaining an accurate inventory of all the wells on your property is the best, most effective, and most feasible way to avoid added costs to protect your wells until they need to be properly decommissioned.

In accordance with N.J.A.C. 7:9D-2.4(a)1, well permit numbers must be permanently affixed to each well. Additionally, you should maintain copies of all Well Permits, Well Records, Monitoring Well Certification/As-Built Certification (Form A) and Monitoring Wel Certification-Location Certification (Form B). Each of these forms should have the well permit number and site-specific Well ID or name. Additionally, the well locational information (Northing and Easting Coordinates) should be recorded so a surveyor can locate the well if needed. Wells should be inspected annually and photographed in order to document their condition. Additionally, the photographs should depict the well and an observable landmark for reference to assist in locating a well.

ESA Knows Monitoring Wells

Monitoring wells are essential for collecting the data needed to manage your site. They provide valuable information on groundwater elevations, flow, and quality. When ESA begins working on a property already undergoing an environmental investigation, well inspection and well inventory is one of our first priorities. ESA maintains well databases for each client site, along with a third-party application that visually documents well conditions and location. This information can easily be shared with our clients.

Proper tracking and maintenance of monitoring wells is the single most important facet of an environmental investigation, yet it is also the most neglected. Ignoring your wells can only lead to additional costs and headaches in the future.

References

New Jersey Department of Environmental Protection (NJDEP)

N.J.A.C. 7:9D Well Construction and Maintenance, Sealing of Abandoned Wells

N.J.S.A. 58:4A-4.1 et seq. Responsibilities of Well Owner, Drilling Contractors, Violations

Guidance for Damaged, Destroyed or Lost Wells