July 10, 2015 TWG Recap (Draft)

July 10, 2015 – Draft

TWG Meeting Recap
Beaver Run Resort
Breckenridge, CO

Next TWG Meeting:
10:00 – 11:00 AM, Friday, October 9, 2015
Basement Conference Room
333 West Hampden Ave.
Englewood, CO

Attendees:

Joe Meigs, Keith Branstetter, Bruce Heir, Joel Canfield, Gene Wagner, Bryan Beckner, Todd Hunter, Mike Weidorn, Doug Stephenson, Fred Baros, Thom Hanna, Brad Himes, Scott Orr

Moderator for July 2015 Meeting:

Joe Meigs

Proposed Moderator for October 9

Gene Wagner

DWR Report

Permit activity is similar to last year. Report summarized below.

7-10-15 TWG Recap (Draft) Table

CDPHE Discharge Permits

Contractors reported that progress for more streamlined CDPHE discharge permit process has been very slow. CDPHE has expressed interest in visiting a job site to see what well testing or drilling looks like. Contractors reported mixed experiences in obtaining CDPHE permits; some have found CDPHE discharge permitting to be fairly easy, others have found permitting to be very challenging. In some cases, CDPHE discharge permits require real-time monitoring for certain parameters, such as chlorine used for disinfection.

It was suggested that CWWCA members meet with Andrew Ross and Lillian Gonzales of the CDPHE to develop a process for streamlined CDPHE discharge permitting or exemptions for standard drilling activities. The concern is that the big contractors are under the regulatory microscope, while small contractors may be completely unaware of the need for CDPHE discharge compliance.

Well Construction Rules

A Second Draft of the Water Well Construction Rules was circulated in June. Only one comment has been submitted so far from contractors on the Second Draft. The comment period is until the end of the July.

There is concern that the second draft of the rules are more lenient than the first draft of the rules. Specifically, one concern is that requirements for Type II wells do not appear to include a centralizer requirement through the grouted interval. In particular, there is concern that some Laramie-Fox Hills wells are considered Type II wells, not Type I wells in areas where the Laramie is at the ground surface.

Example: Laramie-Fox Hills well with poor water quality in Laramie coals. 40-feet of grout required above the production zone, however no centralizers are required at the top and bottom of the 40-foot grout section. In addition, coals with aggressive water quality may be located above the grouted section and will corrode steel well casing. There was discussion about increasing the minimum grout interval to 50-feet for Type II wells to require use of centralizers. There was discussion about special permit requirements

There was concern that the Second Draft of the Rules does not adequately address cistern installations. The CWWCA has suggested that cistern installations on water wells should be subject to a separate permitting process. The DWR does not intend to permit cistern installations separately from the existing well permit. There was discussion regarding adding cistern installation reporting the Well Construction and Test Report or Pump Installation and Test Report.

There were concerns expressed by the CWWCA members that input provided verbally at the Rules Stakeholders Meetings were not recorded by the DWR. The only way to be sure that your comments are heard by the DWR is to provide specific, written comments.

Rules Variance Request Guidance

The DWR will not allow a blanket variance exemption. The DWR and CWWCA would be glad to help develop “boiler plate” variance requests to aid contractors in preparation of those requests and aid the DWR in efficient review. An individual is needed to take the lead in preparing example variance requests for discussion.

Well Inspection Program

The CWWCA is in the second year of lobbying to fund the well inspection program. A letter from the CWWCA was provided to the Joint Budget Committee requesting funding from the well inspection program. The Joint Budget Committee responded that the DWR needs to also request funding of the program. Due to TABOR, it is difficult for the DWR to request any funding.

It was noted that there are many environmental monitoring wells that have been in existence for more than one year and are not permitted. Not only is this a violation of the Rules, it is also an example of inadequate oversight and a lost opportunity for permitting revenue by the DWR.

It was reported that the initial well inspection program was initially intended to inspect 7 to 8-percent of constructed wells.

Scope of Plumbing Board

DWR met with Plumbing Board in February 2015 regarding oversight. DWR has drafted a proposal to exclude pressure tanks from Plumbing Board authority. The DWR has supported a legislative change that makes it clear that pressure tanks can be installed by Water Well Contractor. The Second Draft of the Rules requires “water conditioning” to be installed upstream of the pressure tank, which would be regulated by the Plumbing Board. Water treatment, which is the process to make water potable, remains under the purview of Water Well Contractors.

Future Topics
DWR report
CDPHE discharge permits
Well construction rules
Well inspection program
Plumbing Board

Respectfully submitted by Daniel O. Niemela

 

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