WI0100007_NOV20112C0005_20110419

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H, Sullins Dee Freeman
Governor Director Secretary
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April 19, 2011
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
j 7009 1680 0000 7514 8512
Dewey Wright Well Drilling
P. O. Box 308
Boone, North Carolina 28607-0308
Attn.: jonanthan Miller - Certification 3501
Reference: NOTICE OF VIOLATIONS of the NORTH CAROLINA
WELL CONSTRUCTION STANDARDS
NOV-2011-2C-0005
RIMS Incident 201100859
J Geothermal Well System Located At Tract 1, New Banner Elk School
Parcel No.: 185811654295
Permit No.: WI0100065
Avery County, N.C.
Dear Mr. Miller:
The Aquifer Protection Section (APS) of the Division of Water Quality (DWQ) is responsible for the
regulation of geothermal well construction activities within the State of North Carolina. On April 15, 2011,
staff of the APS's Asheville Regional Office inspected the subject site and collected water samples from
supply wells on adjacent properties. Based on our inspection including information presented during the
onsite meeting, the following violations of the North Carolina's well construction rules and the permit exist.
VIOLATION 1:
Permit condition number 6 found in Part 1 of the permit states: Each injection well shall be afforded
reasonable protection against damage during construction and use.The observed site conditions indicated
that the wells have not been adequately protected. At least one well was observed to be open at the top of
casing. Additionally, a video recorded onsite indicated well casing had been broken off at grade and
surface water had entered the well casing on or about April 6, 2011,
REQUIRED CORRECTIVE ACTION for Violation:
Onsite wells shall be adequately protected, which may include but not be limited to: restriction of
machinery in the area of the geothermal well construction, completion of wells within a timely manner to
reduce exposure time, securing the wellhead with some means other than tape and plastic, inspection of
each well at the beginning of the day and end of the day to ensure integrity, etc.
One
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North Carolina Division of water Quality—Asheville Regional Office /,/ Nit{j
2090 U.S.Highway 70, Swannanoa,N.C. 28778 Phone[phone] FAX [phone] t� r L a b -
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity 1 Afrirmative Action Employer

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Banner Elk Elementary
VIOLATION 2:
At least one partially completed injection well appeared to have surface water freely entering the well
casing where according to the subject video, the well casing was broken off at grade. Another injection
well observed onsite had no cover over the wellhead. 15A NCAC 2C .0213(c)(1)(F) states that in the
drilling, casing, screening and testing of injection wells, the following procedures shall be utilized:
contaminants are not introduced into underground sources of drinking water unless specifically authorized
by Statute or Rule. The introduction of turbid surface water into wells is considered an illegal injection.
REQUIRED CORRECTIVE ACTION for Violation:
Well casings shall be properly secured and onsite supervision adequate to monitor well casing conditions
to ensure that contaminants (i.e., surface water, rainwater, vandalism, etc.) do not enter the well casing
during the construction phase of the geothermal system. To further reduce the probability of contaminants
entering the aquifer, ensure that: (1) source water for drilling is from a potable water supply that has been
recently tested for total and fecal coliform bacteria; and, (2) you consult an industry specialist to
determine if chlorination of the wells at 100ppm chlorine concentration will not have an adverse impact on
the piping and grout you are using. If no adverse impact is expected, chlorinate remaining incomplete
wells and any other wells prior to final cleanout of the borehole making sure not to over-chlorinate the
1 wells as this could lead to excessive precipitation of minerals.
VIOLATION 3:
The partially completed injection wells present onsite currently have casing. 15A NCAC .0213(d)(5) states
that the casing shall be grouted within five working days after the casing is set. You had indicated that the
intent is to remove the existing casing, however given the conditions present at the site, it has been
acknowledged that removal of the casing will be very difficult. Additionally, permit condition number 2 of
Part II of the permit states that if the casing cannot be removed, it must be driven 5 feet into bedrock and
the annular space grouted from a minimum of 20 feet below land surface (BLS) to surface, as specified in
15A NCAC 2C .0213(d)(1).
REQUIRED CORRECTIVE ACTION for Violation:
Due to the setting of the wells and the proximity to water supply wells, you are required to either grout the
casings according to 15A NCAC .0213, or properly remove the casings of the existing, incomplete wells
(i.e., complete the well according to 15A NCAC .0200) within 60 calendar days from your date of receipt of
this Notice. You should consider grouting and completing the remaining wells immediately following drilling
of the borehole and installation of geothermal piping or completing the wells in a phased approach thereby
leaving fewer wells incomplete for a shorter period of time. This method would allow maximum protection
of the groundwater resource and ensure that the geothermal piping remains properly seated within the
well. At least one onsite well was observed to have geothermal tubing that had "pushed" itself out prior to
grouting. Your current practice of installing geothermal piping and waiting to grout could prohibit proper
installation (i.e., seating) of piping within the well.
Please take the corrective actions for the above violations as necessary to bring this site into
compliance. Based upon our observations at the site and considering the integrity of the existing,
incomplete boreholes, we recommend resuming work immediately to complete the project in accordance
with 15A NCAC 2C .0200. Please ensure that you have adequate capacity in the geobasin prior to
restarting drilling activities. A visual check should be performed daily. Corrective actions must be taken
and reported to the Asheville Regional Office, 2090 US Highway 70, Swannanoa, NC 28778, within 30 days,
from receipt of this Notice unless otherwise noted in the above corrective actions, to avoid
recommendation of civil penalties.

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Banner Elk Elementary
Pursuant to North Carolina General Statute 87-91(a), you are hereby notified that you are in
violation of the Well Construction Standards indicated in Subchapter 2C, Title 15A, of the North Carolina
Administrative Code. These Standards were adopted by the Environmental Management Commission
under authority granted by the North Carolina Well Construction Act. This Notice is given in accordance
with North Carolina General Statutes 87-93, etseq. Your prompt attention to the items described herein is
required. Failure to comply with the State's rules, in the manner and time specified, may result in the
assessment of civil penalties and/or the use of other enforcement mechanisms available to the State.
Please feel free to contact me directly at 828.296.4680 if you should have any questions regarding
this NOV or site in general.
Sincerely,
G. Landon Davidson, L.G.
Aquifer Protection Section Regional Supervisor
Asheville Regional Office
c: Avery County Board of Education-Jeffery Jaynes
Jeff Hurd-MBKahn -scanned version via email
Clark Rowe-David E. Looper&Company-scanned version via email
Linda Wigss-SWPscanned version via email
Michael Rogers-UIC CO scanned version via email
Drew Morgan-WCCC scanned version via email
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-- North Carolina Division of Water Quality—Asheville Regional Office -
2090 U.S.Highway 70, Swannanoa,N.C. 28778 Phone[phone] FAX [phone] atura if Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity 1 Affirmative Action Employer