&EPA
United States
Environmental
Protection Agency
Region 9
Ground Water Office (WTR-9)
EPA 909-F-00-003
May 2000
A shallow
injection well
includes any
subsurface
excavation, such
as a drywell,
seepage pit, septic
system, leach field,
or unlined sump,
through which
waste water is
disposed below
ground.
Potential Drinking Water
Contaminants in
Motor Vehicle Waste:
benzene
1,2 dichlorethane
trichloroethylene
methyl tert-butyl ether
(MTBE)
Evaluating Motor Vehicle Waste:
A Self-Audit Checklist
Used or spilled fuel, solvents, waste oil, paints, and other maintenance fluids pose
a risk to the environment but may be especially harmful if they enter someone's
drinking water supply. Floor drains at facilities which use these substances should
be evaluated. Facility managers should know if floor drains lead to a municipal
sewer line, to a surface discharge, or to a shallow injection well.
A shallow injection well is any subsurface excavation, such as a drywell, seepage
pit, septic system, leachfield, or unlined sump, through which waste water is
disposed below ground. Shallow injection wells allow waste to percolate into soil.
Because of their potential to contaminate underground sources of drinking water,
they are regulated through the U.S. Safe Drinking Water Act, Underground Injection
Control (UIC) regulations. New regulations for shallow injection wells at vehicle
repair facilities, called motor vehicle waste disposal wells, were published December
7,1999:
1. The construction of new motor vehicle waste disposal wells is prohibited
as of April 5, 2000.
2. Motor vehicle waste disposal wells constructed prior to that date should not be
used for the discharge of fluids containing wastes that may endanger an
underground source of drinking water. Additional requirements may be imposed
on injection wells located in Source Water areas (see page 3.)
Many floor drains leading to shallow injection wells were constructed for disposal
of stormwater runoff, snow melt, or wash water. According to the new UIC
regulations, storm water drainage wells located at motor vehicle facilities that are
intended for storm water management but that also may receive insignificant
amounts of fuel due to unintentional small volume leaks, drips, or spills at the
pump are not considered motor vehicle waste disposal wells and are not subject
to the prohibition. However, these wells are considered stormwater disposal wells,
and may still pose a risk to water quality if they are not managed.
No disposal wells can be used for the disposal of wastes which may degrade
underground sources of drinking water. All well owners are required to submit
inventory information to their state or federal Underground Injection Program.
This self-audit checklist is intended to help facility owners and operators determine
if they have a stormwater well or a motor vehicle waste disposal well, and provide
them with information on how to comply and reduce environmental liability.
This self-audit checklist is for compliance assistance. It is not required that you
provide this information to EPA unless specifically requested by a regulatory agency.
(continued)
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Motor Vehicle Waste Disposal:
Self-Audit Checklist
1. WASTE GENERATION: Does your facility:
Repair engines or engine parts?
Change oil and other fluids (antifreeze, brake fluid)?
Dispense fuel?
Clean and/or finish, paint, repaint motor vehicles, including boats/aircraft?
Offer self-service car wash to customers without supervision?
Use any of the following: fuel, motor oil/engine lubricants, degreasers,
engine batteries, paint and paint thinners/removers, anti-freeze?
If you answered yes to ANY of the above questions,
select "yes" here and go to Section 2.
If you answered "no"to ALL of the questions, see box 1A.
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
YES NO
1A: If your facility
does not generate
motor vehicle
waste, the motor
vehicle waste
regulations do not
apply to your
facility. If you use
floor drains, it may
help you assess
your environ-
mental liability if
you use or store
other chemicals.
2. WASTE CONTAINMENT / Best Management Practices (BMPs)
Is your facility regulated through a hazardous materials permit? Yes
Is your facility routinely inspected by a regulator or by an environmental consultant? Yes
Does your facility use equipment to limit spills, and reduce or eliminate wet floor cleaning?
Are waste fluids stored in separate labeled containers?
Are all wastes stored above ground in covered, bermed containers until they are removed?
Can you document the legal disposal of all waste fluids to a licensed waste hauler?
If you use recycling equipment, can you or your recycling service
document that the equipment (especially filters) are maintained? Yes No
Are all employees and other users of maintenance areas
trained in the proper use and disposal of motor vehicle fluids, cleaners and wastes?
If you answered no to any of the above questions, select "no" here.
If you answered yes to ALL of the questions, select "yes" here.
Go to Section 3.
Yes
Yes
Yes
Yes
Yes
YES
No
No
No
No
No
No
No
NO
| 3. WASTE DISPOSAL
Does your facility
have any floor
drains, sumps,
sewer grates, or
other constructed
outlets?
YES
Answer this question individually for each drain at your facility.
Is each drain or
outlet plumbed
to a municipal
sewer line?
NO, or I DON'T KNOW
Is this drain or constructed outlet exposed, so that it can
receive rain runoff and/or snowmelt?
3A. OUTTHEBACK.
If motor vehicle waste fluids are
draining onto the ground, you may
be contaminating soil and ground
water. You should contact an
environmental consultant
(geologist, engineer or soil
scientist) or regulator to help you
assess if any clean-up is required,
and how to manage wastes to
prevent additional problems.
3B. TOTHEWASTEWATERTREATMENT
PLANT. Facility should retain copies of
blueprints of sewer hookup and sewer bill for
verification. Facility is probably not subject to
UlCrequirements, but note that your facility
may be subject to pretreatment requirements
by the local sewer and/or stormwater agency.
3C. INTOTHE GROUND.
If you answered YES to
Section 2, this drain may
be a stormwater
injection well. You
should inventory your
injection well, and
continue to use Best
Management Practices to
prevent the accidental
disposal of fluids other
than storm water and car
wash water (from
exteriors.) Future
regulations may apply.
If you answered NO to
Section 2, go to 3D.
3D. If you answered YES to
Section 1 and NO to Section 2,
this drain could be a motor
vehicle waste injection well,
and you are required to comply
with Underground Injection
Control regulations, as detailed
in this brochure.
WHY KEEP DRY DRAINS?
If you answered YES to Section 1
and YES to Section 2, you need to
investigate whether or not to close
your drain(s), which could cause
pollution and unneccessary liability
if there is a spill.
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How Motor Vehicle Repair Facilities
Can affect Underground Sources of Drinking Water
1. Waste from maintenance activities is discharged
directly to floor drain that opens to a sump.
2. Waste from restroom facilities is discharged to
septic system or other subsurface disposal unit.
Sewage from toilets and other domestic wastewater
from sinks, showers and washing machines depends
on bacteriological treatment in a septic tank to
remove disease causing organisms. Mixing
chemical wastewaters with sewage may destroy that
bacterial action, causing backups or contamination.
3. Stormwaterfrom roof (and/or maintenance areas,
if there is no roof) catches drips and leaks of waste
from pavement and disposes of them into subsurface
disposal unit.
4. As shown in this drawing, some facilities combine
waste streams into one subsurface disposal unit. It
may be a vertical excavation, or it may be through
leachfields, as shown. Pipe and concrete joints may
weaken over time, allowing fluids to seep out.
5. The amount of water used at the facility, the
amount of rainfall in the area, the condition of the
disposal unit, and the hydrogeology all affect the
potential of wastes to contaminate ground water.
^Drinking Water Well
[j contaminants collected at the water table can flow
with ground water to a drinking water well
or surface discharge point (creek, stream, spring)
aquifer
6. If a drinking water well draws water from a
contaminated aquifer, water must be treated for
safety, or the well shut down. Groundwater
remediation can cost millions of dollars. Drilling new
wells or buying surface water is also expensive.
Private drinking water well users might not be
protected by any state or local monitoring program
and could unknowingly drink contaminated water.
IF YOU HAVE
A SHALLOW INJECTION WELL:
• Comply with the Inventory Requirement: report
your injection well to your state or federal UIC program.
• Protect the drain from spills, leaks, or disposal of
all fluids except for storm water, and water from exterior
vehicle washing.
• Contents of any subsurface units should be sampled
to determine if fluids or sludges contain hazardous
substances.
• Consult an environmental professional, or one of
the free services listed, to get more information about
Best Management Practices:
www.epa.gov/region09/p2/autofleet
or www.ccar-greenlink.org, (888) GRN-LINK.
Drinking Water Source
Protection
Public Water Suppliers are now required to
insert information in the bill, called the
"Consumer Confidence Report," that alerts their
customers to the quality of the drinking water,
the areas where water comes from (also called
Source Water Areas or Watersheds) and
potentially contaminating activities in those
areas.
Complying with environmental
protection regulations will reduce
your risk of becoming a pollution
problem for your community. If
you operate an injection well in a
watershed, you may be subject
to more protective regulations.
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EPA's Audit Policy and self-disclosure policy encourages businesses who discover violations to promptly disclose,
correct and prevent violations. If appropriate criteria are met, EPA will not seek gravity-based penalties. For more
information, please call the Small Business Office at (800) 368-5888 EST, or see their website at www.epa.gov/sbo.
Definition of motor vehicle waste disposal well:
144.81 (16) Motor vehicle waste disposal wells (are defined
as wells) that receive or have received fluids from vehicular
repair or maintenance activities, such as an auto body
repair shop, new and used car dealership, specialty repair
shop (e.g. transmission and muffler shop) or any facility
that does any vehicular repair work.
Fluids disposed in these wells may contain organic and
inorganic chemicals in concentrations that exceed the
maximum contaminant levels (MCLs) established by the
primary drinking water regulations (see 40 CFR Part 142).
These fluids also may include waste petroleum products
and may contain contaminants, such as heavy metals
and volatile organic compounds, which pose risks to
human health.
DISCLAIMER: The statements in this document are intended solely as
guidance. This document is not intended, nor can it be relied upon, to
create any rights enforceable by any party in litigation with the United
States. EPA or the program Primacy Agency may decide to follow the
guidance provided in this document, or to act at variance with the guidance
based on its analysis of the specific facts presented. This guidance may
be revised without public notice to reflect changes in EPA's approach to
implementing the authorities discussed in the document or to clarify and
update text.
Ground Water Protection/UIC
Programs in EPA Region 9
CALIFORNIA
Call EPA
(415) 972-3537,
or the California
Regional Water
Quality Control
Board near you
www.swrcb.ca.gov
HAWAII
Call the Safe
Drinking Water
Branch, Hawaii
Department of Health
(808) 586-4258
www.hawaii.gov/
health/eh/sdwb/
index.html
INDIAN COUNTRY
Call (415) 972-3544,
or
http://www.epa.
gov/region09/
cross pr/indiai
index.html
NEVADA
Call the Nevada
Division of
Environmental Protection
Water Permit Program
(775) 687-4670
www.state.nv.us/ndep/
bwpc/bwpc01.htm
ARIZONA
Call the Arizona
Department of
Environmental
Quality, Aquifer
Protection Permit
Program, at (602)
207-4573
www.adeg.state.
az.us/environ/water
To report your injection well, or
request compliance assistance
NATIONWIDE - CALL (800) 426-4791, the SAFE
DRINKING WATER HOTLINE (E.S.T.)
EPA REGION 9 UIC PROGRAM: (415) 972-3542
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 9 GROUND WATER OFFICE (WTR-9)
75 HAWTHORNE STREET, SAN FRANCISCO, CA 94105
FIRST CLASS MAIL
U.S. POSTAGE
PAID
Permit G-35
OFFICIAL BUSINESS - PENALTY FOR PRIVATE USE $300
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