Do I have to drill a new well for my PWS?
Do I have to drill a new well? This is probably most frequent questions we get when it comes to public water systems for small businesses, and while I'd like to give an easy yes or no answer, the real truth is, it depends on a lot of factors.
BASIC REQUIREMENTS. In Texas, the technical requirements for siting and construction of a well to supply water to a public system are found in the Title 30, Part 1, Chapter 290, Subchapter D, commonly referenced as 30 TAC §290.41. The rules are very detailed and quite prescriptive. For instance, there are a number of setback requirements ranging from 10-feet to 1/4-mile, there are requirements for the disinfection of drilling muds and plans and specifications must be sealed by a licensed professional engineer and approved by the TCEQ and the state must be notified of the date of pressure cementing. The overarching principle is that from start to finish, including the siting, drilling, completion, development and operation, a public water supply well must be designed and constructed in such a manner as to ensure that the water coming out of the well is protected from potential pollution hazards.
PRESSURE CEMENTING. Pressure cementing between the casing and borehole is probably one of the primary differences between the typical domestic well construction and a public water supply well. The method used to pump the cement must be in conformance with current American Water Works Association (AWWA) standards. The cement must fill the entire space from the top of the shallowest formation to be developed all the way to the surface. The purpose of pressure cementing is to minimize the chances of surface contaminants entering the aquifer. This is aided by the additional requirement of a 6-ft concrete sealing block, graded to drain away from the wellhead. This entire process is a specialized one that many drillers are either not capable of performing or not willing to take on. This, along with the cost of materials, tends to greatly increase the price of constructing a public water supply well over a conventional water well of similar depth and type.
EXCEPTIONS. Many business owners, who begin to research the topic on their own, are led to believe that because of the regulatory specifications for PWS wells, an existing well not constructed to those standards cannot be used. That's not necessarily the case, though. The TCEQ's Technical Review and Oversight Team (TROT) can grant exceptions to each of the various requirements, if it can be demonstrated that a particular well will not likely be contaminated, despite it not meeting the standards. The review period takes a minimum of 90-days and it's helpful for a licensed professional engineer, experienced in dealing with TCEQ to prepare the submittal. Wells with exceptions, often require additional monitoring or testing, as a condition of the exception approval. These additional requirements can add up over time, ultimately making the cost of operations of an existing well more expensive than a well constructed according to the standards laid out in the 30 TAC 290.
CONSTRUCTION IMPROVEMENTS. When converting an existing well to PWS usage, there are often several components that need to be improved, and for which exceptions are not usually granted. The concrete sealing block mentioned above is a good example of that. Many domestic wells either have no sealing block or only a small block that doesn't meet the standards found in 30 TAC §290.(c)(J). Suitable sampling taps, backflow prevention devices, water meters and intruder-resistant enclosures are all examples of other construction improvements for which requesting an exception would not be appropriate.
AUTHORIZATION. One final thing to note, granting of an exception does NOT constitute authorization or approval to use the well. It's merely, one step in the approval process. TCEQ's Plan Review Team (PRT), ultimately approves or denies the use of a well after a 60-day review period. PRT will NOT approve a well if it does not meet the standards laid out in 30 TAC §290, without an exception though. All plans submitted to PRT must be signed and sealed by a licensed professional engineer. Our engineering team has years of experience working with small businesses, pump installers, groundwater conservation districts, local government offices and the TCEQ to ensure that the job gets done right, the first time, as quickly as possible. Contact us today to get the process started.