I am writing to voice opposition to the new requirement that all private class IIIC wells be grouted using a pumpable grout.  3/8" Bentonite Chips have long been allowed to be poured form the surface for wells with a 20ft grouting requirement.  They provide 100% solids grout seal and also provide structural support for well casing.  Bentonite chips have designed by the manufacturer specifically for this purpose, and I see no evidence to change existing private well regulations regarding their use.   

I am writing to voice opposition to the new requirement that all private class IIIC wells be grouted using a pumpable grout. 3/8" Bentonite Chips have long been allowed to be poured form the surface for wells with a 20ft grouting requirement. They provide 100% solids grout seal and also provide structural support for well casing. Bentonite chips have designed by the manufacturer specifically for this purpose, and I see no evidence to change existing private well regulations regarding their use

I copied the above and fully agree.

I am also in agreement with Richard O’Dell‘s comments above.

I have read the updated proposed well regs concerning the grouting requirements for a class 3C well to now be pumped through a tremie pipe. I strongly oppose this as the state has allowed 3/8” bentonite chips to be poured 20’ for many years. We live in a fairly rural area and probably 90%  of our wells are class 3C. The pouring of bentonite chips has always been an effective and trouble free way of grouting for our company and many around us. I feel like the proposed pumping of grout for class 3C wells needs to definitely be reviewed further. Thank you 

I am also in agreement with the above comments concerning the Grout requirements, thank you, James Maupin

With yard space becoming tighter and lot sizes smaller, it has always been a challenge on smaller lots to get 10 feet off foundations without going into a utility easement. With the new changes of 15 feet off of foundations and now 5 feet off property lines, thousands of homes will no longer be able to legally have a irrigation well. This change alone is going to reduce by my estimate 30% of irrigation wells which for me is easily going to be 100 wells a year. ($30,000 in permits) This rule is going to empower those who don't pull permits and inhibit the rule abiding drillers that pull permits. If termite treatment is no longer an issue, I don't understand and was never explained why the new rule has moved us even farther from foundations. And the explanation for being 5 feet off property lines is so wells don't accidently get drilled on wrong property, which in my 15 years of doing this (roughly 10,000 wells) this has never happened. 

Also for us shallow well drillers, shallow wells (Example a 30 foot well), it doesn't make sense to pump grout on shallow wells, and isn't practical in field. We have to pour the grout and truthfully speaking a pour fills the void better than pumping ever could. Lastly also pertaining to new grouting standards. Casing is now to be cut off 5 feet underground then grouted. Many of our static water tables are above 5 feet, and in many areas here you will hit water 3-4 feet in the ground, making this impossible. 

I am writing to voice opposition to the new requirement that all private class IIIC wells be grouted using a pumpable grout.  3/8" Bentonite chips have long been allowed to be poured from the surface for wells with a 20' grouting requirement.  They provide 100% solids grout seal and also provide structural support for the well casing.  Bentonite chips are designed by the manufacturer specifically for this purpose, and I see no evidence to change the existing private well regulations regarding their use.

I copied the above and fully agree.

The stricken language below is opposed. This proposed section of regulation eliminates the pouring of grout in wells that calls for a 20ft or less grout depth.

This will cause an unnecessary increase in well construction cost to the citizens of Virginia. VDH has approved specific Grouting materials that are designed to be installed by gravity pour through air and water columns. 

I am requesting the stricken language below be returned to the regulation

a. Placement using a grout pump or tremie pipe from the bottom of the annular space upward in one operation until the annular space is filled, whenever the grouting depth exceeds 20 feet. Pouring of grout is acceptable for drilled wells whenever grouting depth does not exceed 20 feet.

I am writing to voice opposition to the new requirement that all private class IIIC wells be grouted using a pumpable grout. 3/8" Bentonite Chips have long been allowed to be poured form the surface for wells with a 20ft grouting requirement. They provide 100% solids grout seal and also provide structural support for well casing. Bentonite chips are designed by the manufacturer specifically for this purpose, and I see no evidence to change existing private well regulations regarding their use

I copied the above and fully agree.

I would like to voice my opposition to the 15' setback requirement from all building foundations. This is particularly cumbersome for smaller lot sizes where a 15' setback from the foundation may not be possible for an irrigation well. Given that there is now no separation distance from a private well to termite-treated foundations, what is the justification for increasing the setback from 10' to 15'?

I am in opposition to the new proposed well setback regulations. This makes it very difficult when providing a well location for our customers and will make 30-40% of our projects unable to creat a well location. To my knowledge of more than 40 years in this industry, we have not had a contamination issue with the current set back regulations.

I also agree with Cameron from C & G’e comment regarding the same

With new homes being built closer together, the 15’ set back will hurt homeowners and the industry. I would not like to see this pass

With new homes being built closer together, the 15’ set back will hurt homeowners and the industry. I would not like to see this pass.

I agree with C&Gs comment

With regard to the proposed amendments to the grouting placement methods referenced above, I am opposed to these changes and agree with the comments previously made by Richard O'Dell and Robert Royall.

We are in opposition to the proposed well setback regulations and agree with the comments made by C & G.

I am opposed to the proposed changes to the regulations regarding the grouting placement methods.

I am against the proposed changes concerning the grouting placement methods. I agree with the previous comments made by Robert Royall.

I oppose the new requirements for a packer on all pvc cased wells. They are unavailable at this time. 

I agree with C&G’s comment

The term "biorentention pond" is not found in any of the DEQ Stormwater Specifications and DEQ "recommends" other setbacks such as infiltration trenches, bioretention, vegetated swales, wet ponds and extended detention ponds. Why is the no mention of these other types of BMP's and there appears to be a conflict with the recommended setback from DEQ and the new proposed setbacks?

12VAC5-630-450D5 Defines setbacks to proposed onsite sewage disposal systems when the annular space can't be filled. This is defining the setback to an onsite sewage disposal system, if Chapter 630 is not supplemental to Chapter 610, wouldn't Chapter 610 be the controlling Chapter when designing an onsite sewage disposal system? Since there are no setbacks to abandoned wells in Chapter 610, how would a setback in Chapter 630 control a setback in Chapter 610? For an example, they are proposing siting a dispersal area 20' from an abandoned bored well that has no records of a grout and they only filled the inner well area, would I then deny an onsite sewage disposal application based off codes in Chapter 630?

What is the justification for using chlorine to abandon wells. If disinfection of water in the void space of the well is critical, why would it also not be required to do a disinfection of the water in the annular space prior to a grout of a well. I don't understand the public health significance of disinfecting water that will not be consumed by people. If you disinfect the water then put "clean fill" in the well that is full of pathogens and bacteria, what was accomplished? 

Also based of the new procedures the WSSP will need to disinfect the well, sample and test chlorine levels and wait 5 to 24 hours prior to abandoning the well. Is this the intent now? I think this would increase cost of the abandonment while providing no additional public health benefit.

12VAC5-630-431G1 could be revised to be more specific, it should define what a "complete application" is. It should reference 12VAC5-630-230 as far as what a complete application is.