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.