Horizontal Environmental Wells – Look Before You Leap

The horizontal environmental well (HEW) marketMost HDD contractors are constantly looking to increase sales and profits. If profits can be increased without buying more equipment and hiring additional crews, it’s even better.

Many contractors look outside of their normal geographical area for additional work; there is a strong demand in areas where oil well fracking in prevalent. One market segment that is seems to resurface periodically in HDD circles is the horizontal environmental well (HEW) market.

This business segment consists of using horizontal directional drilling methods for soil sampling and the construction of monitor, injection and extraction wells for the clean-up of contaminated soil and/or groundwater. The HEW market has been around since the late 1980s and horizontal wells have been installed in every state. Some contractors have been successful in this market but others have gone out of business (Longbore Inc. and FlowMole Environmental) and/or have moved away from the HEW business. So is this a market suitable for all HDD contractors?

Working at a hazardous waste sites and installing wells are different operations from the typical HDD utility installation. Among the differences are licensing requirements, health and safety regulations, well vs. pipeline construction details and the constant oversight from consultants.

So before you jump into an HEW project, let’s look into some of the differences from a typical HDD utility installation project.

Licensing Requirements
Most, if not all states have specific licensing requirements for well drillers. HEWs may fall under water well licensure regulations, and, in some instances, a more specialized monitor well license may be required. Complicating the issue is the fact that the requirements to obtain the proper certificate varies widely from state to state. Let’s just look at the state of Texas requirements.

In order to obtain a monitor well license, an individual must complete the application and mail a $215 check to the Texas Department of Licensing and Regulation (TDLR). Note that you must provide your social security number and a criminal background check will be run. Sounds fairly easy, right? Well, not so fast — as part of the application, you must show you have completed 50 verifiable monitor well installations under the direct supervision of a Texas licensed driller.

Let’s assume you have the experience to complete the form and the Department approves the application. The next step is to send $55 to the testing company and take the test. But be warned, the test is not a “slam dunk” — the failure rate in 2013 was 30 percent.

Congratulations, you have passed the test and it’s time to go to the field and drill a horizontal well in Texas. You send your best driller in the field and get the project going. Sounds easy, right? Unfortunately, Texas is a state where the operator of the rig performing the work must hold the license. Does that mean the licensee must be at the site, on the rig the entire time? Maybe, the regulations provide that a licensed driller may supervise an unlicensed assistant if the licensed driller is onsite at all times during the drilling or:
(2) is represented at the well site by an unlicensed assistant, capable of immediate communication with the licensed driller or pump installer at all times and the licensed driller or pump installer is no more than a reasonable distance from the well site, but no further than a two-hour arrival time; and
(3) inspects the well site at least once in every 24-hour period of operation.

OK, you drilled the well and the client is happy — you are a successful Texas licensed monitor well driller. Again, not so fast. You have to send in the well report to the Texas Department of Licensing and Regulation (TDLR) within 60 days of the work being completed. Now, you’re done. Well, only for this year and that well. If you wish to remain a licensed driller, you need to complete four hours of continuing education (CE) per year. The TDLR provides a list of registered providers for the CE and you must get the training from a registered provider. This is an additional time and cost just to maintain the license. Finally, you’re done, but don’t forget the $215 check you sent to get your license is a yearly fee.

The heck with it, you say, I’ll just pop into Texas, complete the well without a license and no one will know. That could work if the consultant and owner aren’t worried about the well report being sent. Let’s say you get caught installing a HEW without the proper license in Texas (or even offer to install the well without a license). The fine may range from $500 to $3,000 for the first violation.

Note that we just talked about Texas; each state is different. It may be that only the company needs the license, not the individual driller on the rig. The take-away should be that the HDD driller needs to look carefully at the specific state licensing regulations before agreeing to an HEW project.

Health and Safety Regulations
The Occupational Health and Safety Administration (OSHA) has rules for personnel working at uncontrolled hazardous waste sites, specifically detailed in the Code of Federal Regulations — applicable section 29 CFR 1910.120. Within the 1910.120 section are several regulations that are applicable to working on sites where HEWs will be installed, including minimum training requirements and baseline medical monitoring guidelines. A word of caution — the OSHA guidelines specifically refer to work at uncontrolled hazardous waste sites and emergency responders. Don’t be fooled. Any HDD contractor working at a site with contamination in the ground is either under this OSHA regulation by federal law or by the contact signed with the consultant or site owner.

Let’s look at the training requirements and medical monitoring guidelines:

Training: Without getting into the paragraph/section/subsection details, all workers on the site must have an initial 40 hours of instruction off the site and a minimum of three days actual field experience under the direct supervision of a trained, experienced supervisor. After the initial training, employees must undergo refresher training for eight hours on a yearly basis. So let’s think about the costs involved before you can even set foot on an HEW site. Say you are running a Vermeer 24×40 rig with a three-person crew, plus a supervisor and you find an online class that will provide the required 40 hours of training for $400. Your costs will include:

Training class 4 employees at $400 each            $1,600.00
160 man hours at an average cost or $22/hr.       $3,520.00
Total training costs for crew                                 $5,120.00

That’s just to get started.

Medical Monitoring: Because your employees may be exposed to dangerous chemicals and/or may be required to wear respiratory protection, they must undergo a physical exam normally consisting of an overall “fit for duty” exam (audiometric testing for hearing, spirometry for pulmonary function, vision test) and blood tests. The exam is required yearly and the records of the exam must be kept for 30 years. And, by the way, if you fire the employee or he/she quits six months after the initial or annual exam, you must provide him/her with an exit physical. What is the cost of the medical monitoring?

Cost of baseline exam and blood work –
$600 per employee            $2,400.00
Time to travel to clinic and take exam –
six hours per employee            $528.00
Total medical monitoring            $2,928.00

The above not include any recordkeeping costs and remember the physical exam is annual and you may be required to provide an “exit” physical for employees.

So just to comply with the initial training and medical monitoring requirements of the OSHA guidelines will cost more than $8,000 for a three-person crew, plus supervisor. Please note that the OSHA CFR 1910.120 consists of 43 pages of regulations and you must fully understand all of the rules and regulations before you place your employees on an HEW project. Additionally, there may be state, local or site specific regulations that are required.

Pipelines vs. Wells
Let’s assume that you have gone through the licensing process and are confident that you’re compliant with OSHA 29 CR 1910.120 along with any other state, local and/or site specific regulations. Now, it’s time to drill a well. Heck, it can’t be very hard — you drill pipelines all the time, right? Well, there are some major differences. First, we can look at well construction regulations. Again, most, if not all, states have specific regulations on how environmental wells are to be constructed. The rules can be related to the size of the borehole vs. the outside diameter of the well or what types of drilling fluids can or can’t be used to install wells. Yes, there are other drilling fluids than bentonite. The guidelines may call for a “surface seal” at the top of the well. Best of all, the regulations most likely do not cover horizontal wells. Then what? You must work with your client and the regulatory agency to obtain variances to account for the difference between vertical and horizontal wells. This can be a time-consuming process for the driller.

Also, in most utility installations, once we are clear of utilities and as long as we stay in the easement, our only concerns are the entry and exit locations. A horizontal well is designed to either monitor, remove and/or treat contamination in the subsurface. The means the well must be placed in a precise location underground. Missing the target in many cases means re-drilling the borehole, often several times, until the precise target depth can be achieved.

One of the most difficult issues a utility HDD contractor encounters is that instead of just drilling a borehole for a solid pipe in the ground, an HEW installation must be constructed so water flows into a well. This means the drilling fluid must be carefully monitored. Dense and highly viscous drilling mud may close off the pore spaces in the soil, limiting the ability for groundwater to flow into the well. The site owner or consultant may actually limit the density of your drilling mud, or, in some cases, the contract will require you to use a bio-degradable drilling fluid that is not often used in utility HDD applications.

Finally, once the well is in the proper location, well development must take place. This procedure, using both chemical and physical means, removes the drilling fluid from inside of the well, from the annular space between the well and the bore hole and from the formation surrounding the bore. This is an important step and specific procedures are required to make sure the drilling mud is properly removed.

We just discussed only two of the many differences between installing a utility conduit and well. An HDD contractor must realize that the end goal of an HEW is not to just “get the pipe in the ground,” but to precisely place a well at an exact location in the subsurface and to ensure the well will perform as specified.

Project Oversight
The final topic to be discussed can be the biggest challenge facing an HDD driller on an HEW project: oversight. On most utility projects, the HDD driller may see a site inspector once a day as they travel along the right of way. However, on an HEW project, there will be at least one consultant (geologist or engineer) at the site all day, every day. At a minimum, the geologist or engineer will take notes and monitor the project area for contaminants in the work zone. In some cases, the consultant may be actively involved in decisions regarding the work, such as minimum bend radius of the well, the exact location of the bore path, type and properties of the drilling mud. They also will have the authority to stop work at any time for any reason. To make this even more disconcerting, the odds that the oversight geologist has significant directional drilling experience is remote. Many good HDD contractors can be intimidated by this constant oversight.

The above detailed challenges, licensing requirements, health and safety regulations, well vs. pipeline construction details and the constant oversight from consultants, are not insurmountable issues for most HDD utility contractors. However, before you accept a HEW project, you must perform some due diligence and make sure you’re prepared for the differences between a utility project and a well installation.
In other words — Look before you leap.

David S. Bardsley, PG – Texas, Missouri, Tennessee, is business development manager at Directed Technologies Drilling.
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