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Rule 10.4.11 prohibits the extension of filter pack materials to the ground surface. This rule <br />does provide for augmentation of filter pack materials via the use of a filler tube. <br />According to the Statement of Basis and Purpose for Construction Rules (2 CCR 402-2) (included <br />in the Rules and Regulations for Water Well Construction, Pump Installation, Cistern <br />Installation, and Monitoring and Observation Hole/Well Construction), the minimum well <br />construction standards provided by Rule 10 "establishes minimum well construction standards <br />necessary to provide for the reasonable life of a well, to produce on adequate supply of ground <br />water when such water is available, to prevent the intermingling of water between aquifers, <br />and to prevent contamination of the aquifer and the ground water." The primary concern <br />addressed by Rule 10.4.8 "is the necessity of obtaining a watertight seal to prevent <br />contaminants from entering or moving in the annulus between casings." No basis and purpose <br />was specifically provided for Rule 10.4.11. <br />The Board also discussed implied interpretations of Rule 10.4.8, where contractors may assume <br />that the rule would not apply if the outermost casing extends more than one foot above ground <br />level. The Board affirmed that all rules and construction standards associated therewith should <br />be interpreted in the context and intent of Rule 10.1; that is to insure the protection of the <br />public health and to prevent degradation of the ground water resource. Consequently, the <br />Board will require the installation of a water tight mechanical seal across the annulus between <br />the outermost casing and the production string or sealing with a minimum of ten (10) feet of <br />cement grout as specified in Rule 10.4.8. <br />The Board recognizes that local well construction practices may vary in response to specific <br />geologic, hydrologic, or construction situations, but reiterates that the Water Well Construction <br />Rules are minimum well construction standards that apply universally. Rule 18 provides for a <br />variance for a specific instance or method of construction when the strict application of any <br />provision of the rules presents practical difficulties or unusual hardship. The Board directed <br />staff to evaluate requests for a variance to Rule 10.4.11, to allow the extension of filter pack <br />materials to the ground surface, on a site specific basis, but affirmed the need to comply with <br />Rule 10.4.8 in those circumstances. <br />POLICY <br />The Board of Examiners of Water Well Construction and Pump Installation Contractors affirms <br />that the Water Well Construction Rules are minimum well construction standards that apply <br />universally. The construction standards were developed to insure the protection of the public <br />health and to prevent degradation of the ground water resource as specified in Rule 10.1. Well <br />construction practices that do not provide for these protections will not be tolerated. In order <br />to provide the necessary protection of public health and the ground water resource, and to <br />