A lot of bandwidth is spent talking and learning about the pump in pump and dump, but the real issue is the dump. All fifty states recieve Fedral funding and as such must play by the Feds rules. The dump in pump and dump is considered a class 5 injection well, and as such is subject to "big brothers oversight" which dictates local states regulations regarding the dump. At first glance it appears to be harmless, but I spent the weekend trying to devine my way through the EPA's rules for a class five injection well. Like everything in big government the regs are broad sweeping and ambiguous. Back to the story, they do not like them unless monitoring wells are installed to monitor the injection and meticulous record keeping is done. This sheds a lot of light on why when we started moving towards closed loop over open we were heralded as champions by the people who regulate me. I moved away from only doing open loops for the same reason everyone eventually does.... To many projects with uncontrolled outcomes in regard to the exchange. The Feds have another agenda that no one wants to address, class five injection wells in relation to private pump and dumps. Since all of our bread is buttered by the FED's one way or another they get thier way. I still do a fair amount of pump and dumps but the market is moving toward the exclusion of them without complying with class five regs even for a residential project. This was all brought on by a discusion with a DIY guy who was treating the incoming water and dumping the water back into the aquifer. His position was that since he got a free unit with a copper coil it was justified. I would hope that here we advocate the longer look, and responsible stewardship of our groundwater as it is not a finite resource. Thanx for listening Eric
Things are going the other way down here in FL Fear is that improperly grouted closed loop bores will allow saltwater intrusion and cross aquifer contamination, so the man is now happier to have our drillers case down to the confining layer and do reinjection. We are still technically allowed to dump on the surface in North Florida, though SW FL admin code requires reinjection.
This is all very regional specific as we all have different but simmalar issues. When a closed loop bore goes through multiple water bearing units it is allways about the grout. In your case: sodium based bentonite grout ain't worth a hoot in saltwater. There is no one solution for everybody. Thank the Lord for multiple exchanger types. Eric
Eric: I look out my bedroom window at Lake Erie lapping at my back yard/errosion barrier, but I still worry about our finite fresh water supply. I will give you a PM in a few about sealing some manifold crocks. Mark
The Feds intentionally left the class V regs ambiguous enough to allow each state to dictate their own rules (it seems). Water is claimed and "owned" by the States. It has become complicated enough to where states fight states over who has water rights- where water courses through multiple states. Look at the water wars of Georgia (Lake Lanier). Understanding state regulations can be so confusing that it takes more than just reading the law to interperate to true meaning. It seems to me that there is a need for a matrix with a listing of the states in one direction and earth coupled loop options in the perpendicular direction. Loop choices could then be categorized from best option to worst option and prohibited. The matrix would require frequent updates of course. It would take guess work out and enable non experts to know the loop options available for the proposed location.
Good practices are universal so the 3 things we would be concerned with are grout, return well and standing column rules. Water regs should not confuse local pros, nor should well drilling be a DIY project. Not only might these rules be different state to state, but in the context of geo open loop rules (ordinances) vary at the county, township, city and village level. Federal rules can occasionally get in the mix as well. i.e. open loop is perfectly legal in MI, but not in Dryden Township. MI DEQ/DNR lets us dump into wetlands or lakes, but the Great Lakes are regulated by the Corps of Engineers etc. Further, with so much more emphasis on closed loop most of these questions come up far less frequently than you think. Compiling your matrix is a Herculean task for modest gain as MI driller is not concerned with CA geo rules most of the time. If one decides to travel and work in CA then one must learn their rules, but still need not know 48 other states + territories. So while this list might be nice, I sure hope the feds don't pick your idea out of the suggestion box and spen 14.2 million on it's developement.
