[All] Public Input needed re: New rules for boreholes and other test wells

[Louisette Lanteigne]

Hi folks
The Ministry of the Environment is seeking public comment on a draft manual on test holes and dewatering wells.  A “test hole” is a type of “well” that is made to obtain information about groundwater, and is not used or intended for use as a source of water for consumption. It includes virtually all the boreholes that are used to monitor groundwater quality or quantity, including contamination.

The draft Test Holes and Dewatering Wells: Requirements and Best Management Practices manual provides a plain language summary of the Wells Regulation (O. Reg. 903/90) and other legislation on test holes and dewatering wells. It provides best management practices on test hole and dewatering well siting, construction, maintenance and abandonment.
Comments may be made between December 10, 2012 and April 09, 2013 on the EBR website. 
http://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTE1ODU0&statusId=MTczNDQ2&language=en

Ideas to Mention to protect our Groundwater: 
-Bore hole depths are often too shallow to reasonably assess risk, (particularly in regards to moraine systems!) We need a criteria for reasonable depth that goes down deeper than surface water influences. (The sediment that moves due to rain )  Example: Ira Needles Mega Mall in Waterloo, most of the bore hole data only went down 3 meters. The data was initially meant to build a roadway but they used the same data to build a huge mall.  This data was  to shallow to reasonably assess risks to wells or the moraine.  This project is located beside a landfill leaking Vinyl Chloride.  It's a landfill where the methane is too wet to rise. 
-There is no criteria defining what data is considered "outdated".  Example: With the Highland Mega Quarry in Melancthon they were using bore hole data from the 1940's. 
-There is no criteria to prioritize the most recent data. In regards to the Owen property in Waterloo Ontario of Wideman Road, an Ontario Municipal Board hearing took place. The Board chair favoured an outdated bore hole study (20 years old)  that stated there is no recharge on site rather than to accept the Region of Waterloo's more current data which clearly identified the entire area as primary recharge in maps produced by the Region. The fate of our municipal water supplies should not be left to the discretion of the Board's preference to use outdated reports! 
-There is no mandated test times for bore hole testing so test dates often negate to monitor for high water levels related to spring thaw. (West Side Lands, Melancthon, Mount Nemo showed this. They are all Stantec studies.)
-There is no set protocols for how many bore holes should be used or rules regarding the location of their placement.  What laws exist to make sure that they don't use the driest areas to do their studies? 
-Engineering firms are not liable for the work they do once they sign off on pre-development studies. If something happens due to poor data,  they are not responsible but they do stand to profit from re-mediation contracts. We need to hold these firms liable for the quality of the work they do. If a house sinks because the structure was built on a bog, hold them accountable! If their work shows gross negligence that results in ecological damages, make them fix it at their expense. 
-We must mandate 12 month creek studies with mini piezometer  monitoring. This will give us a better view to avoid flood risks, water contamination issues (road salt!) and it protects fisheries.  Also a great way to create pre-development baseline data,  that way if there is a net loss to the water, damages to fish habitats, creeks or wells, we will have the data to know who is responsible to remedy the situation! It should be mandatory to share this data with conservation authorities and  the Healthy River Ecosystem Assessment System (THREATS)
-Bore holes cannot reasonably determine if a hill slope is a recharge area or not due to the irregular distribution of sediment created by glacial melt. They must use Ground Penetrating Radar to view the recharge capacity on hill slopes. This theory is proven at the Arkell research centre with the University of Guelph.  Just because it's a slope doesn't mean it's not recharge. 
-Natural Clay is not impervious. It simply slows the rate of water transference so even if a property is clay covered it should not negate proper bore hole studies to assess risks. 
-In regards to Quarries, make sure we test deeply to analyse if there is a Karst System or water soluble sediments to prevent sink holes, earthquakes, water contamination issues etc. 
-We must have regard to monitor for draw down impacts related to water taking from quarry pits.  How will creeks, wells or recharge flow and flow rates  be adversely impacted and we need to understand this regardless of buffer zone delineations. If it has an impact beyond the bufferzone we still need to gather reasonable data to mitigate the risks. 
-Currently over withdrawl of aquifers are contributing to 1/4 of the rise of sea levels globally speaking.  Water is diverted from aquifers to tributaries leading to the oceans. Bore hole data is needed not only for pre-development data, but to establish long term post development impacts to determine the state of our current moraine systems. We need to take advantage of the opportunity we have to keep some of these pre-development bore holes active to monitor the state of the resource over the long term. 
-Bore hole data must be supported with quaternary geological information where pre existing data exists. This will give a better understanding on the nature of the land and it's broader function in connectivity to offsite groundwater connectivity.  If a proposed quarry is sitting in between a recharge area and a well, municipalities need to know of that to make informed decisions to allow them to  reasonably comply to the Provincial Policy Statement, the Clean Water Act, the Source Water Protection act etc. 
-Modflow is a computer program that generally assumes aquifers are simply self contained on site. When paired with Quarternary geological information, reasonable bore hole data and data of sediment type, it can be a good tool to map Moraines but it should never be used in isolation of the other data. 
-Modflow is highly subjective in nature in terms of data input so clear written explanations on source of information should be provided to the point the data can be reasonably scrutinized and replicated by auditing processes. 
-Periodic auditing of hydrology data should be conducted to assure that companies involved are following proper protocols and procedures.  
-Follow up monitoring should ALWAYS be done by a third party hired by the City at the developer's/pit owner's  expense to assure reasonable monitoring data is gathered that is non biased.  
-If a developer is implementing roof runoff drainage systems or other techniques to replace the function of natural recharge, bore hole data should be mandatory  to make sure the water levels are actually being replaced.  If the system is not functioning to the satisfaction of the municipality,  let the municipality keep a check worth the value of that system. This will assure due diligence to make sure the system is functioning as designed and gives an economic incentive to assure good quality work. 
Lulu :0) 
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