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Wells Regulation 903 - Information You Will Want to Know

by Mary Jane Conboy PhD., P. Geo.
Chair of Regulation 903 Working Group


Ontario Regulation 903, under the Ontario Water Resources Act, is the regulation governing, construction maintenance and decommissioning of wells and was revised this summer with changes to take affect December 31st, 2007. The Wells Regulation covers all wells including public and private, municipal and rural, agricultural, commercial and industrial as well as test holes, dewatering wells, and monitoring wells. It sets out minimum standards for siting, constructing, tagging and reporting, maintaining and decommissioning wells. The regulation also sets out the licensing requirements.

APGO members have been very active highlighting concerns with Regulation 903 and impacts on their practice. APGO responded by establishing a Regulation 903 working group to facilitate communication amongst interested members. APGO met with the Ministry of Environment (MOE) on this issue twice and many members attended consultation sessions held late 2006 and early 2007 to discuss proposed changes that were posted on the Environmental Bill Registry.

There were a number of issues that were especially relevant to APGO members, which resulted in a great deal of feedback to the MOE. Key issues included whether APGO members would be exempt from a Class 5 license, disinfection standards applying to contaminated sites, cost and expertise when using well technicians for university research projects and in monitoring wells established through the Groundwater Monitoring Network, to name a few.

The distinction between a monitoring well and a drinking water well is important in the revised regulation. Generally speaking, working on drinking water wells presents a greater risk to established drinking water supplies than does working on monitoring wells that do not supply potable water for consumption. An APGO member who works for a well contractor can install monitoring wells with an auger by hand. Monitoring wells can be finished below ground and equipment can be installed to monitor water level and other groundwater characteristics without a Class 5 license. In contrast, the regulation ensures greater protection of drinking water wells as all potable water supplies must be finished above ground, and licensed P.Geo.'s are not allowed to install monitoring or sampling equipment that is left in a drinking water well for more than 24 hours. "This is disturbing to many of our members who are well trained professionals and have done this for years prior to the revised regulation in 2003. This has not been rectified in 2007, despite the APGO bringing this to the MOE's attention" said APGO President, Steve Usher. Another issue that concerns President Usher was the need for a well contractor's license, "APGO maintains that firms that employ P.Geo.'s and have the appropriate insurance should not have to be licensed as well contractors since the firms already hold Certificates of Authorization with PEO or APGO and employ trained professionals."

A license is not required for low risk activities such as: inspecting, monitoring, sampling or testing a well using equipment that is not left unattended in the well; using equipment that was already installed in the well; or installing equipment unless the installation involves an alteration of the well other than notching the top of the casing.


A new class of license has been added for a total of 5 classes of well technician licenses.

Class 1 - Construction, repair and decommissioning of drilled wells and decommission dug wells

Class 2 - Construction, repair and decommissioning of dug wells.

Class 3 - This license holder can perform different tasks depending on the conditions of the license. It is issued to allow specific practices and it is based on experience and expertise.

Class 4 - Pump installer - Installs pumps, not licensed to do well construction, upgrades or decommissioning

Class 5 - Install and supervise the installation of sampling, monitoring, testing and pumps in test holes and dewatering wells. Construction of test and dewatering wells with non-powered equipment. Qualified professional engineers and geoscientists as well as certified engineering technicians and technologists are exempt from needing a Class 5 licence but must work for a well contractor.

Disinfection standards have been revised and greater detail incorporated into the legislation. Chlorine residuals will need to be assessed at the time of disinfection and again after 12 - 24 hours. Chlorinated water must be drawn off away from the well and septic system and residual assessed prior to using the water supply. The disinfection process does not apply to test holes, dewatering wells or flowing wells.

A Best Practices Manual will be developed by the MOE to ensure that well professionals have the support they need to make appropriate decisions and to help with field interpretation. The primary audience for this manual is the drilling community but many APGO members will find it helpful. The MOE has indicated that APGO input will be sought during the development of this manual.

One last issue highlighted in discussion with APGO members is the definition of well owner as the well purchaser. This may have implications for consultants who contract well work for their clients and members should look into the implications for budgeting for decommissioning these wells in the future.

The Ministry will be releasing a guidance document, which will provide clarification and the ministry's position on specific issues. The final Regulation 903 is posted on the Environmental Bill of Rights registry at: http://www.ebr.gov.on.ca/ERS-WEB-External/. The registry number is 010-0098.

For more information on APGO, please contact info@apgo.net

Delivery Notice: This newsletter is issued 6 times per year to all APGO members. Non-members may also subscribe and receive the newsletter with access to non-member-only content. For more information, please see www.apgo.net.

Field Notes is published by APGO and is edited by Wendy Diaz, P.Geo. If you have comments or wish to contribute material to this newsletter, please contact Wendy Diaz, P.Geo., or Andrea Waldie, P.Geo., Executive Director/Registar.

Copyright 2007, Association of Professional Geoscientists of Ontario (APGO)