Water Works 16 - 3/27/03

Inadequate Investigation of Well Failures

( Excerpts from Fellow Correspondent’s letter, continued. )

The NJGS report of November, 1999.

The background section of the NJGS report (i) appears to be a very well written client advocate report, but there is no mention of the repeated non-compliance history of the site in the section. Much more important for a technical report is the question of why the aquifer test and report focused on the evaluation of well QVF-3.

Franklin Township had originally requested help in the evaluation of multiple well failures in Quakertown, not a new certification. Uncertified wells were found far closer to Quakertown in 1997 on the Weston tract. QVF-3 was not even drilled in 1997 when the first well failures occurred. Why were the GSG wells close to Quakertown not evaluated? Why was well QVF-3 tested, a very high production well along an apparent east-west fracture line, and one of the two wells farthest from Quakertown? Remember, Quakertown is roughly northeast of these wells. Interestingly, the other well tested, QVF-2, was the farthest well from Quakertown. Why test these wells while other wells, much closer to Quakertown and operating during well failures, were not tested?

This leads to the question of what caused the well failures and the failure of the Muller Spring in Quakertown in 1997 and 1998. The NJGS has not presented a public report that addresses these failures. Vague innuendo of drought and other well failures occurring throughout New Jersey appear in the minutes of the April 26, 1999 Franklin Township Environmental Commission meeting. However, there was no evidence presented that other well failures were occurring in such a clustered manner as those in Quakertown. NJAC 7:20A-1.7(c) requires that the “Department shall determine the validity of all such complaints. If the complaint is valid the Department shall investigate and make a determination as to cause based upon the facts in each particular case. The Department shall notify the complainant, the certification holder, and the appropriate county agricultural agent of its findings and shall, if necessary, direct that a solution be implemented within 30 days.” Before this permit can be considered, the NJDEP must produce documentation that the requirements of NJAC 7:20A-1.7(c) have been met.

NJDEP and NJGS representatives at the April 26, 1999 Franklin Township Environmental Commission meeting also discussed a U.S. Geologic Survey (USGS) effort to model the quantities of water being used for various agricultural operations. This information is based on different crops, and acreage can be compared with logs kept by the users to check for accuracy of reporting. Has this been done for this operation?

Also at that meeting, Chairman Frank Vodraska asked if the BWA was in any way going to help the people in this area who lost their wells and had to redrill. The response was that there were no funds to do this. However, funds were available to conduct this extensive aquifer test for a private entity, GSG/QVF. Has the state been reimbursed by GSG/QVF for the aquifer testing program? In every allocation case I am familiar with, a private consulting company is hired to conduct the aquifer test for the applicant. Why couldn’t some of this reimbursed cost be applied to the people who lost wells in Quakertown? GSG/QVF is one of the largest agricultural operations in New Jersey.