Late Well Reports, Missing Tag, and Old Hand-Dug Well on the Same Parcel
On May 2, a licensed driller completes three wells on one parcel: a new 200-ft domestic well, a replacement well 30 ft from an old 1950s hand-dug well, and a 40-ft monitoring piezometer for a consultant. The driller attaches tags to the domestic and replacement wells but not the piezometer. The old hand-dug well is 36 inches in diameter, 18 ft deep, and remains open with a loose wooden cover. The owner wants to use the old well for irrigation and asks the driller to install a small pump. It is now June 25, and no well reports have been filed. The driller says the 30-day clock starts when the owner pays the invoice. The county has asked for copies.
1. What reports are required and when? Does the payment date control the deadline?
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Payment does not control the reporting deadline. The driller must file the required well report for each well within 30 days of completion. The domestic well and replacement well were completed May 2, so the reports are already late by June 25. The monitoring piezometer also needs the applicable report unless the rules specifically exempt it. If the old well is decommissioned, an abandonment or decommissioning report is also required. The driller should file the reports immediately, accurately showing completion dates, depths, casing, grout, static water level, and tag numbers. The driller should not backdate the reports or wait for payment. Late filing can trigger compliance action and can delay the owner's ability to document the well.
2. Can the old hand-dug well be put into irrigation service? What must happen first?
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The old hand-dug well should not simply receive a small pump. It is a 36-inch unsealed dug well with a loose cover, which is a contamination and safety risk and is unlikely to meet current construction standards. Irrigation is also not a domestic exempt use, so a water right would be needed before using it for that purpose. The driller should first determine whether the well can be properly reconstructed with a sanitary seal, casing, and cap, or whether it should be decommissioned. In most cases, decommissioning by a licensed driller, removing the pump and debris, filling and grouting the well, and filing the abandonment report is the safer path. The driller should not install a pump in an open dug well and call it an irrigation supply.
3. What compliance risks arise from the missing tag and late reports, and how should the driller correct them?
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Missing tags and late reports are compliance deficiencies. The driller should attach the required tag to the piezometer if the rules require it, or document why it is not required, and file all overdue reports now. The driller should also correct any inaccurate information, such as the completion date, rather than trying to make the record look timely. The county copies should match the filed reports. If the old well is decommissioned, the driller should file the abandonment report and keep a copy for the owner. The driller should explain to the owner that unresolved reporting and tag issues can delay future permits and may result in enforcement.