United States
                  Environmental Protection Agency
                 Office of Water
                 Washington, D.C. 20460
EPA816-R-00-017
November 2000
&EPA
Conversion of a Motor
Vehicle Waste Disposal Well
                                    ~ A UIC Director's Guide
       "Class V wells at motor vehicle service facilities may not be
       subject to the rule, if motor vehicle waste fluids are prevented
       from entering the well..."

       -- Revisions to the Underground Injection Control (UIC) Regulations for Class V
       Wells - Final Rule, December 1999

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                             TABLE OF CONTENTS



1.   Purpose of this Document  	1

2.   What Does EPA Consider to be a Motor Vehicle Waste Disposal Well?	2

3.   What Are the New Regulatory Requirements for Motor Vehicle Waste Disposal Wells?	3

4.   What Are the New Requirements for Conversion
    of an Existing Motor Vehicle Waste Disposal Well?	4

5.   What Are the Factors to be  Considered When Authorizing the
    Conversion of a Motor Vehicle Waste Disposal Well to Another Kind of Class V Well?  	5

6.   Does the Owner/Operator of an Existing Motor Vehicle Waste
    Disposal Well Need to Provide Notification Prior to Conversion of the Well? 	9

7.   Does the UIC Program Director Need to Permit Converted Wells? 	9

8.   Summary	10

9.   Need More Information?	11

Attachment A:
Pre-Notification Form  	12

Attachment B:
Suggested Best  Management Practices (BMPs) for Motor
Vehicle-Service Facilities with "Converted" Wells	14

Attachment C:
Common Questions from Owners  and Operators Converting Wells in the State of Maine  	16

Attachment D:
Special Terms Used in this  Guidance Document	20

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1.   Purpose of this Document
This document outlines for Underground Injection Control (UIC) Program Directors and
their staff, the new requirements for allowing the conversion (reclassification) of a motor
vehicle waste disposal well to another type of Class V injection well.  The guidance also
discusses other UIC requirements that may affect a conversion and additional factors
that may need to be considered such as Best Management Practices (BMPs).
The Safe Drinking Water Act provisions and Environmental Protection Agency (EPA) reg-
ulations described in this document contain legally binding requirements. This document
does not substitute for those provisions or regulations, nor is it a regulation itself. Thus,
it does not impose legally-binding requirements on EPA, States,  or the regulated com-
munity, and may not apply to a particular situation  based upon the circumstances.
The purpose of this document is to specifically address the conversion provision of the
Class V Rule published on December 7, 1999 (40 CFR §144.89(b)).  It is optional for
States or Regions to include this provision to allow owners and operators of existing motor
vehicle waste  disposal  wells to convert their well to another type of  Class V well.
Depending on specific conditions and policies in a State,  EPA and State decisionmakers
may choose not to allow for the conversion of a motor vehicle waste disposal well to
another type of Class V injection well. For States where conversions will be allowed, any
decisions regarding a particular facility will be made based on the applicable statutes and
regulations.  EPA and State decisionmakers retain the discretion to adopt approaches
(e.g.,  on  a  case-by-case  basis)  that  differ  from  this  guidance  where  appropriate.
Therefore, interested parties are free to raise questions and objections about the appro-
priateness of the application of this guidance to a particular situation, and EPA will con-
sider whether or not the recommendations or interpretations in the guidance are appro-
priate in that situation. EPA may change this guidance in the future.
EPA published the Class V Rule in the Federal Register on December 7, 1999. The Rule
became effective on April 5, 2000.  For additional information on the new requirements of
the Class V Rule and the associated  compliance schedules, see 64 Federal Register
68546 and the Sfafe Implementation Guidance for the Revisions to the Underground
Injection Control Regulations for Class V Injection Wells (EPA 816-R-00-008).

Please Note:

This document was not developed to assist owners or operators to convert their Class
V motor vehicle waste disposal well. Owners and operators should contact their UIC
Program Directors for information on how to complete their conversion.

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2.   What Does EPA Consider to  be a Motor Vehicle Waste
     Disposal Well?


The Class V Rule defines motor vehicle waste disposal wells at 40 CFR §144.81(16) as:
   "wells that receive or have received fluids from vehicular repair or maintenance activities, such as an
   auto body repair shop, automotive repair shop, new and used car dealership, specialty repair shop
   (e.g., transmission and muffler repair shop), or any facility that does any vehicular repair work."
These wells often take the form of floor drains, work sinks, or washbasins leading to dry-
wells, cesspools, or septic systems.
CLARIFICATION:

In general, waste water from hand washing with regular soap in bathrooms or sanitary
facilities is sanitary wastewater that can be disposed of through septic systems.
However,  if a facility has a sink in the service area that discharges to a septic system
or dry well, and employees wash their hands using organic solvents that are typically
used for cleaning parts, it would be considered a motor vehicle waste disposal well.
Specifically, a Class V well receiving floor washing water,  parts washing water,
or other waste water containing motor vehicle waste fluid at a motor vehicle
maintenance facility, would be considered a motor vehicle waste disposal well.

Finally, the definition of a well at 40 CFR 144.3  makes no distinction between  above
and below grade wastewater disposal systems. A subsurface  fluid distribution  system
such as a mound or peat biofilter system that meets the definition of a well  (see
Attachment D) and is used for the  disposal of motor vehicle waste fluids is a Class V
motor vehicle waste disposal well.

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3.    What Are the New Regulatory Requirements for Motor
      Vehicle Waste  Disposal Wells?
   The Class V Rule:


   •   Bans new motor vehicle waste disposal wells nationwide.
      Bans existing motor vehicle waste disposal wells (with a waiver provision)
      in regulated areas designated by the UIC Program Director.
Owners and operators of existing motor vehicle waste disposal wells in regulated areas
have two options: (1) close their wells;1 and (2) seek a waiver from the ban and obtain a
permit.2
Some States may adopt the conversion provision of the Class V Rule and allow well
owners and operators to convert their existing motor vehicle waste disposal well to
another kind of Class V well (with permission from the UIC Program Director). The adop-
tion of this conversion provision is at the discretion of the UIC Program Director. Upon
completion of the conversion process, converted wells  would not be subject to
the new requirements found in the Class V rule.
1  Before closing a Class V well, the owner or operator must notify the UIC Program
  Director of his/her intent to close the well at least 30 days prior to well closure (40
  CFR§144.88(b)(1)(vii)).

2  EPA envisions that UIC Directors will grant waivers through the issuances of permits.
  Minimum permit requirements are: (1) fluids released in the wells must meet drinking
  water Maximum Contaminant Levels (MCLs) and other health-based standards at
  the point of injection, (2) monitoring requirements must be specified to characterize
  the quality of the injectate and sludge, both initially and on an ongoing basis, and (3)
  best management practices, such as recycling and waste minimization must be
  specified (40 CFR §144.88).

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4.   What are the New Requirements for Conversion of an
     Existing  Motor Vehicle Waste Disposal Well? (40 CFR
     §144.89(b))
The UIC Program Director may allow a motor vehicle service facility to convert an exist-
ing Class V motor vehicle waste disposal well to another type of Class V well. The con-
verted Class V well would be allowed to receive only other liquids such as stormwater or
snow melt. The following conversion conditions are specified in the regulation:
      All motor vehicle fluids are segregated by physical barriers and are not
      allowed to enter the well. An owner or operator may be allowed to continue
      using their well if all motor vehicle fluids stored or generated at the facility (i.e.,
      both products and wastes) are segregated from the well by a curb, berm, and/or
      other containment structures.
      Note: The use of a semi-permanent plug as a means of segregating waste is not sufficient to con-
      vert a motor vehicle waste disposal well to another type of Class V well.
      Injection of motor vehicle waste is unlikely based on a facility's compli-
      ance history and records showing proper waste disposal.  The owner or
      operator should be able to supply documentation of their past compliance history.
Example:

Owners or operators of existing motor vehicle waste disposal wells may request a con-
version under limited circumstances such as: multiple bay garages in which all but one
of the floor drains are closed, and the bay with the open drain only receives wash
water from exterior vehicle wash, or multiple bay garages in which all but one of the
floor drains are closed, and the bay with the open drain receives only snow melt.
NOTE: A converted well is still subject to the non-endangerment criteria at 40 CFR §144.12, the inventory
requirements found at 40 CFR §144.26, and the closure criteria found at 40 CFR §144.89(a).

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5.    What Are the Factors to be Considered When
      Authorizing the Conversion of a Motor Vehicle Waste
      Disposal Well to Another Kind of  Class V Well?
UIC Program Directors may authorize a conversion in cases where they can ensure that
unintentional or illicit discharge of motor vehicle waste fluids into the well is unlikely,
based on the facility's compliance history and availability of adequate records showing
proper waste management and disposal.
UIC Directors must ensure owners and operators comply with the following:

   A.  Comply with non-endangerment criteria (40 CFR §144.12) and closure
       requirements (40 CFR §144.89(a))

   B.  Segregate motor vehicle fluids from the well (40 CFR §144.89(b))

   C.  Demonstrate continuous compliance with all appropriate rules and regulations
       and proper waste disposal practices (40 CFR §144.89(b))

UIC Program Directors may also:

   D.  Specify best management practices (BMPs) such as employee training and
       sign posting
A.  Comply with non-endangerment criteria (40 CFR §144.12) and closure require-
   ments (40 CFR §144.89(a))
The definition of motor vehicle waste disposal well includes "wells that receive or have
received"  fluids from vehicular repair.  When evaluating what an  owner or operator
would have to do to convert a well, UIC Program Directors should consider the history
and use of the well.
A well must be closed in a manner that prevents movement of contaminated flu-
ids into underground sources of drinking water (USDWs), which may cause a vio-
lation of Maximum Contaminant Levels (MCLs) or other health-based standards,
or may adversely affect public health (40 CFR §144.89(a)). Additional or more spe-
cific closure requirements may be  imposed by the UIC Program Directors.

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Closure of a Class V well may include:
      Analysis, disposal and/or management of any soil, gravel, sludge, liquids, or
      other materials removed from or adjacent to the well in accordance with all
      applicable regulations and  requirements. (Note: Based on sampling results of
      motor vehicle waste disposal wells, many contaminants such as heavy metals
      and volatile organic compounds are found at levels above the MCLs and other
      health-based standards in  the wells and adjacent to the wells.)
      Proper cleaning of the well and attached conveyances (e.g., wastewater collection
      system) to remove contaminants residing in the sludge, fluid, or scum.  (Note:
      Flushing the well may cause a violation of 40 CFR §144.12 if contaminants are
      present.)
      If needed, sampling of the injectate to demonstrate the absence of motor vehicle
      fluid related contaminants.
Example:

Prior to authorizing a well conversion from an existing motor vehicle waste disposal well
to a vehicle wash well, you may want to consider the effect of large amounts of vehicle
wash water flushing through the converted well. Based on the length of time the well
was used for motor vehicle fluid disposal, and the specific wastes discharged — you
may want to require the owner or operator to conduct a site evaluation to determine the
impact of continued use of the converted well on  USDWs. If the site evaluation shows
contamination of soil and/or ground water you should  require the owner/ operator to go
through all the steps of closure  (except final plugging of the well) before allowing  them
to "re-open"  or convert the well. All contaminated sludge, soils, and ground water must
be removed  and properly disposed of prior to "re-opening" the converted well (144.82(a)
and 144.82(b)).

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B. Segregate motor vehicle fluids from the well (40 CFR §144.89(b))
Owners and operators must use physical  barriers to prevent motor vehicle fluids from
entering the converted well, such as:
       Construction of curbs, berms, and/or other containment structures to isolate the
       work area and the associated well that is being converted from motor vehicle
       waste fluids generated or stored in other areas of the facility.
       Note: Curbs, berms, and other containment structures may present a tripping hazard at a facility
       and therefore must meet all applicable Occupational Safety and Health Administration (OSHA) or
       State equivalent regulations and requirements.
      A semi-permanent plug cannot be used to segregate waste.
       Note: The use of semi-permanent plugs (also known as plumber's plugs) to segregate motor vehicle
       waste fluids from other fluids such as snow melt and exterior vehicle wash water cannot be used to
       convert motor vehicle waste disposal wells.
       Prohibition of motor vehicle service and maintenance activities that generate
       fluid wastes in the areas that drain to the "converted" well. The converted well
       may only receive such liquids as snow melt, rain drip, and exterior vehicle wash
       water.
       Prohibition of the storage of motor vehicle fluids (e.g., motor oil, antifreeze, and
       used motor oil and hydraulic fluids) within the perimeters of the areas that drain
       to the "converted" well.

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C. Demonstrate past history and continuous compliance with all appropriate rules
   and regulations and proper waste disposal practices
      Facility has a good history of compliance with appropriate regulations and
      requirements (e.g., UIC well inventory information submitted, previous UIC
      inspections indicate compliance or corrective actions were taken to return to
      compliance, and absence of violations under other Federal or State require-
      ments (such as the Resource Conservation and Recovery Act (RCRA) or
      Occupational Safety and  Health Act (OSHA)).
      Proper waste disposal practices and recycling, along with appropriate records of
      such activities.
UIC Directors may want to:
D. Specify best management practices (BMPs) that should be implemented, such as
   employee training and sign posting
Attachment B lists selected BMPs that may be appropriate for motor vehicle service facil-
ities with converted wells.
Attachment C "Common Questions from Owners and Operators Converting Wells in the
State of Maine" contains specific questions and answers on containment structures, fluid
storage and allowable discharges.
                                      8

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6.   Does the Owner/Operator of an Existing Motor Vehicle
     Waste Disposal Well Need to Provide Notification Prior
     to Conversion  of the Well?
An owner/operator can only convert a motor vehicle waste disposal well to another type
of Class V well with the permission of the UIC Program Director.  The rule does not out-
line the process for obtaining permission. However, 40 CFR144.88(b)(1)(vii)of the Class
V Rule requires owners or operators of existing motor vehicle waste disposal wells to
notify the Director 30 days  before closing  or converting their wells.  This  requirement
allows for a more accurate inventory, and provides a mechanism for oversight of well clo-
sures and conversions.  To collect the closure information from the owner/operator, the
EPA has developed a form entitled "Preclosure Notification for Closure of Injection Wells"
for use by Direct Implementation Programs  (See Attachment A). Primacy Programs may
use this form or modify the form to collect the required information from well owners and
operators prior to closing and converting their motor vehicle disposal well.
Note: A State may adopt the Pre-closure Notification form as the mechanism for owners or operators to
request a conversion.  However, a conversion cannot take place until it has been authorized by the UIC
Director.
7.   Does the UIC Program Director Need  to Permit
     Converted Wells?
The Class V Rule does not require site-specific permitting of converted wells and leaves
such decisions to the UIC Program Director's discretion.  However, some States have
suggested that to ensure compliance when authorizing conversions, UIC Programs may
have to increase oversight and/or require owners and operators to obtain a permit or
conduct periodic monitoring of the injectate.
                                     9

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8.   Summary

EPA's requirements for motor vehicle well conversion are as follows:
      144.12 and 144.82 Ensure non-endangerment from Class V wells that are
      converted from motor vehicle waste disposal wells
      144.26 and 144.83 Submit inventory
      144.89(a) Close out well properly (prevent fluid movement and contamination of
      USDWs)
      144.89(b) Conversion must be authorized by the UIC Director and requires the
      use of physical barriers, preventing motor vehicle fluids from entering the wells,
      and a good compliance history and waste management plans of the facilities.
Additional factors the UIC Program Director may consider are as follows:


   •  Site evaluation


   •  Remediation


   •  Best Management Practices


   •  Oversight by UIC Program


   •  Monitoring to ensure compliance
                                      10

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9.   Need More Information?
For additional information on the new requirements of the Class V Rule and the associ-
ated  compliance schedules,  see  64  Federal Register 68546 and the  Sfafe
Implementation  Guidance  for the Revisions to  the Underground  Injection Control
Regulations for Class V Injection Wells.
      For additional information on State implementation of the rule, see the EPA
      State Implementation Guidance for the Revisions to the Underground Injection
      Control Regulations for Class V Injection Wells (EPA No. 816-R-OO- 008).
      For copies of other guides associated with the Class V Rule, visit the OGWDW
      Website: http://www.epa.gov/safewater/uic/c5imp.html.
                                     11

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 Attachment A
Type or print all information.  See reverse for instructions.
                                                                                     Form Approved 12/99
                                                                                     OMB Control No.2040-0214
                                  CLASS V WELL  PRE-CLOSURE NOTIFICATION  FORM

                            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               OFFICE OF GROUND WATER AND DRINKING WATER
1. Name of facility:	

   Address of facility:.
   City/Town:	  State:	  Zip Code:.

   County:	  Location:	

2. Name of Owner/Operator:	
   Address of Owner/Operator:.
   City/Town:	  State:	  Zip Code:.

Legal  contact:	 Phone number:	
3. Type of well(s):	  Number of well(s):.
4. Well construction (check all that apply):

EHorywell                    EJ Septic tank                   EJ Cesspool
CD Improved sinkhole         EH Drainfield/leachfield           EH Other	
5. Type of discharge:.
6. Average flow (gallons/day):	  7.  Year of well construction:.
8. Type of well closure (check all that apply):
EH Sample fluids/sediments                                       EH Clean out well
EH Appropriate disposal of remaining fluids/sediments             I   I Install permanent plug
EH Remove well & any contaminated soil                          EH Conversion to other well type
EH Other (Describe):	

9.  Proposed date of well closure:	
10. Name of preparer:	 Date:.
                                           PAPERWORK REDUCTION ACT NOTICE
The public reporting and recordkeeping burden for this collection of information is estimated to average 1.5 hours per respondent. Burden means the total
time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This
includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and
review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required
to respond to, a collection of information unless it displays a currently valid OMB control number.

Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested  methods for minimizing
respondent burden, including through the use of automated collection techniques to the Director, Regulatory Information Division, U.S. Environmental
Protection Agency (2137), 401 M St., S.W., Washington, D.C. 20460.  Include the OMB control number in any correspondence.  Do not send the completed
form to this address.

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INSTRUCTIONS

You must complete this form to notify the U.S. EPA that you intend to close a Underground Injection Control (UIC) Class V
well at your facility. You may complete one form for more than one of the same type of Class V well at each facility. For
example, if you will be closing two drywells that are of similar construction at your facility, you may use one form.

The numbers below correspond to the numbers on the form.

1.   Supply the name and street address of the facility where the Class V well(s) is located. Include the City/Town, State
    (U.S. Postal Service abbreviation) and Zip Code. If there is no street address for the Class V well, provide the route
    number or locate the well(s) on a map. If available, for the "Location" provide the Latitude/Longitude of the well or the
    legal description of the facility.

2.   Provide the name and mailing address of the owner of the facility or if the facility is operated by lease, the operator of
    the facility.  Include the name and phone number of the legal contact for any questions regarding the information
    provided.

3.   Indicate the type of Class V well that you intend to close.  For example, motor vehicle waste disposal well or cesspool).
    Provide the number of wells of this well type at your location that will be closed.

4.   Mark an "x" in the appropriate box to indicate the type of well construction. Mark all that apply to your situation.  For
    example, for a septic tank that drains into a drywell, mark both the "septic tank" and "drywell" boxes. Please provide a
    generalized sketch or schematic of the well construction if available.

5.   List or describe the types of fluids that enter the Class V well. If available, attach a copy of the  chemical analysis
    results and/or the Material Safety Data Sheets for the fluids that enter the well.

6.   Estimate the average daily flow into the well in gallons per day.

7.   Provide the year that the Class V well was constructed. If unknown, provide the length of time  that your business has
    been at this location and using this well.

8.   Mark an "x" in the appropriate box(s) to indicate briefly how the well closure is expected to proceed. Mark all that apply
    to your situation. For example, all boxes except the "Remove well  & any contaminated soil" and "Other" would be
    marked if: the connection of an automotive service bay drain leading to a septic tank and drainfield will be closed, but
    the septic system will continue to be used for washroom waste disposal only, and the fluids and sludge throughout
    the system will be removed for proper disposal, the system cleaned, a cement plug placed in the service bay drain
    and the pipe leading to the washroom connection, and the septic tank/drainfield remains open for septic use only.  In
    this example, the motor vehicle waste disposal well is being converted to another well type (a large capacity septic
    system).

9.   Self explanatory.

10. Self explanatory.

The purpose of this form is to serve as the means for the Class V well owner or operator's notice to the UIC  Director of
their intent to close the well in accordance with Title 40 of the Code of Federal Regulations (40 CFR) Section 144.12 (a).
According to 40 CFR §144.86, you must notify the UIC Program Director at least 30 days prior to well closure of you intent
to  close and abandon your well.  Upon receipt of this form, if the Director determines that more specific information is
required to be submitted to ensure that the well closure will be conducted in a manner that will protect underground
sources of drinking water (as defined in 40 CFR §144.3), the Director can require the owner/operator to prepare, submit
and comply with a closure plan acceptable to, and approved by the Director.

Please be advised that this form is intended to satisfy federal UIC requirements regarding pre-closure notification only.
Other state, tribal or local requirements may also apply.
                                                       13

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Attachment B
Suggested Best Management Practices (BMPs) for
Motor Vehicle-Service  Facilities with "Converted" Wells
Design/Physical BMPs:
Floor Drains       If floor drains must exist in areas performing motor vehicle mainte-
                  nance and repair activities, they should be connected to a holding
                  tank (meeting Federal, State, and/or local requirements) or sani-
                  tary sewer (with approval from the publicly owned treatment work
                  or POTW). All holding tank waste should be disposed of properly.
                  (Note: Floor drains in sanitary facilities (e.g., bathrooms) connected to a septic
                  system are not motor vehicle waste disposal wells if they receive sanitary waste
                  only.)
Work Areas
Physically separate work areas such as maintenance bays and
chemical  storage areas from vehicle wash bays with floor drains
(e.g., using curbs, berms, or other containment structures).
Procedural BMPs:
Training
Employees should be trained in the proper operation of equipment;
loading and unloading of materials; spill control and emergency
procedures; and the reuse/recycling of materials.
                  Employees should be trained prior to working with equipment or
                  handling of materials, and should be refreshed periodically or
                  when new regulations or procedures are developed.
                  Employees should be made aware of Material Safety Data Sheets
                  (MSDS) and understand the information contained on them.
                                     14

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                  Develop employee awareness about the environmental and the
                  economic benefits of waste reduction and pollution prevention, and
                  the consequences of ignoring environmental rules and regulations.
Communication
Post signs reminding employees not to perform motor vehicle repair
and maintenance activities in the areas with converted floor drains;
not to dispose of waste or spills into drains; perform proper spill con-
trol procedures; and given emergency response information.
Record Keeping
Updated facility plans (to reflect the current configuration) and
copies of associated approvals and permits should be maintained
on file at the facility.
                  Maintain waste disposal and recycling records.
                  Maintain inventory records for materials that would be a RCRA
                  waste once used and compare them to hazardous waste disposal
                  records.
                                       15

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Attachment C

State of Maine

Common Questions on the Conversion of a Motor Vehicle Waste Disposal Well to
Another Type of Class V Well

In the State of Maine, owners and operators of motor vehicle waste disposal wells have
been allowed to convert their wells to other types of Class V wells. The main reason for
the conversion is to deal with  the winter problem of  snow melt water from cars and
trucks. The Maine Department of Environmental Protection (MDEP) reviewed a draft of
the EPA Conversion Guide and suggested we  include some specific issues/questions
that arise when  an owner/operator (O/O) requests a conversion from a State.  The fol-
lowing questions and answers reflect some of MDEP's experience with authorizing con-
versions and may give UIC Directors a better idea of the issues raised by owners and
operators. The following are responses that the State of Maine provides to these ques-
tions.  They are included here as useful information to help other States decide how they
might want to address these questions if they arise.
Use of Curbs and Berms:
O/O:              If I am going to use curbs, berms, and/or other containment
                  structures to isolate a converted well, how should I place
                  them?
MDEP:            Curbs, berms, and/or other containment structures should be
                  placed to isolate the converted well and its associated drainage
                  area from motor vehicle waste fluids generated or stored in other
                  areas of the facility.
O/O:              If I would like to install berms to isolate a work area for the
                  converted well, how high should the berms be?
MDEP:            We recommend the use of low (1"-2"), rounded-edge berms that
                  are painted with a bright color such as blaze orange or yellow.
                  Note: Berms may represent a tripping hazard. While berms are not
                  covered by the Federal Occupational Safety and Health
                  Administration (OSHA) Standards, some State's may have devel-
                                     16

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                  oped their own, more stringent requirments for the use of berms.
                  UIC Directors should contact the agency responsible for administer-
                  ing safety and health requirements for State specific information.

                  Note: Berms do not need to be very high to hold back spills.  A
                  one-inch berm with 100 sq. ft. of floor space behind it will hold
                  back a spill of about 62 gallons (provided the floor is level).
O/O:              What kind of material would be allowed to make up the berms?
MDEP:            We recommend concrete berms. Many businesses go to their
                  nearest pre-cast concrete manufacturer for "speed bumps." Also,
                  some environmental product supply companies sell pre-fabricated,
                  six-foot long, plastic sections. Metal "L"s can be fabricated by
                  local metal shops to make up berms. In general, any material that
                  will not be degraded by chemicals in the motor vehicle fluids
                  should work. Adsorbent booms, foam sidewall berms, and flexible
                  dikes are not appropriate berm materials.
O/O:              How should we install the berms?  Can we bolt the berms into
                  the floor?
MDEP:            Berms must be permanently adhered to the floor.  Without an
                  adhesive or sealant under the berm, fluids can seep under it and
                  between sections. Also, berms loosely stuck to the floor can easily
                  be dislodged,  especially if a portion is subject to car or truck traffic
                  within the service area.  Simply bolting berms into the floor is not
                  an acceptable method of berm installation.
Allowable Fluid Discharge:


O/O:              What kinds of fluid can be discharged to the converted wells?
MDEP:            Converted wells can receive snow/ice melt, rain drip, and wash
                  water from exterior washing of cars and light trucks.  Cleaning is
                  restricted to the exterior of the vehicle. Engine, undercarriage,
                  and transmission washing is prohibited. Cleaning operations
                                      17

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                  should minimize the detachment of paint residues, heavy metals,
                  or other potentially hazardous materials from vehicle surfaces.
                  The use of acids, bases, metal brighteners, degreasing agents or
                  steam is also prohibited. We recommend the use of non-toxic,
                  phosphate-free cleaners with cold water as cleaning agent.
                  Wash water from engine, undercarriage and transmission washing
                  and from the cleaning of the interior of truck trailers and other
                  large commodity-carrying containers must be collected and dis-
                  charged to a municipal sewer system or treated in a closed-loop,
                  wash water recycling system.
O/O:              / have an autobody repair shop.  Can I discharge wash water
                  with a small amount of sanding residues to the converted well?
MDEP:            Wash water carrying a small amount of nonhazardous sanding
                  residues (e.g., catalyzed autobody filler,  such as Bondo) from
                  autobody repairs does not constitute a motor vehicle waste.  Wash
                  water discharging to floor drains in the sanding areas, which carry
                  a small amount of sanding residues would be allowed to enter the
                  converted well.
Motor Vehicle Fluid Storage:
O/O:              Can I store motor oil, antifreeze, and hydraulic fluids within
                  the perimeters of the areas that drain to the converted well?
MDEP:            No, you are not allowed to store motor vehicle fluids (e.g., motor
                  oil, antifreeze, and used motor oil and hydraulic fluids) within the
                  perimeters of the areas that drain to the converted well.
O/O:              If it is not possible to remove all hazardous materials from the
                  area that drains to the converted well, can I put up a second-
                  ary containment structure to meet the requirement?
MDEP:            If it is not possible to remove all hazardous materials from the area
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                  that drains to the converted well, a secondary containment struc-
                  ture is an  acceptable alternative in Maine. Waste oil burners and
                  275-gallon heating or waste oil tanks are often located within
                  areas served by the converted wells.  In these cases, we require a
                  secondary containment to be built around the oil tank.  This sec-
                  ondary containment can be made out of cinder block and mortar
                  berm  around the base of the tank and its fittings, and must be
                  large  enough to capture the entire contents of the tank should it
                  rupture. Also, secondary containment is required around above-
                  ground holding tanks that collect wastewater from other part of
                  your facilities (e.g., vehicle service areas) if these tanks are locat-
                  ed in the area served by the converted drain.
O/O:              What should I do if I need to keep small containers of motor
                  vehicle fluids and other hazardous materials at my facility?
MDEP:            You are not allowed to store 55-gallon drums or other smaller con-
                  tainers in the areas that drain to the converted well.  You must
                  move these containers to other areas that are not served by the
                  converted well, so that the content of these containers will not
                  accidentally enter the converted well.
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Attachment D

Special Terms Used this Guidance Document
Included below are definitions that were added or modified as a result of the Class V
Rule.  Readers seeking additional information or clarification are directed to the pream-
ble of the final rule and 40 CFR §§ 144.3 and 146.3.
Cesspool means a "drywell" that receives untreated sanitary waste containing human
excreta, and which sometimes has an open bottom and/or perforated sides.
Drywell means a well, other than an improved sinkhole or subsurface fluid distribution
system, completed above the water table so that its bottom and sides are typically dry
except when receiving fluids.
Improved sinkhole means a naturally occurring  karst depression or other natural
crevice found in volcanic terrain and other geologic settings which have been modified
by man for the purpose of directing and emplacing fluids into the subsurface.
Motor Vehicle Waste Disposal Well means a well that receives or has received
fluids from vehicular repair or maintenance activities, such as an auto body repair shop,
automotive repair shop, new and used car dealership, specialty repair shop (e.g.,  trans-
mission and muffler repair shop), or any facility that does any vehicular repair work.
Point of Injection  means the last accessible sampling point prior to waste fluids
being released into the subsurface environment through a Class V injection well.  For
example, the point of injection of a Class V septic system might be the distribution box -
the last accessible sampling point before the waste fluids drain into the underlying soils.
For a drywell, it is likely to be the well bore itself.
Sanitary Waste means liquid or solid wastes originating solely from humans and
human activities, such as wastes collected from toilets, showers, wash basins, sinks
used for cleaning domestic areas, sinks used for food preparation, clothes washing oper-
ations, and sinks or washing machines where food and beverage serving dishes, glass-
es, and utensils are cleaned. Sources of these wastes may include single or multiple res-
idences, hotels and motels, restaurants, bunkhouses, schools, ranger stations, crew
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quarters, guard stations, campgrounds, picnic grounds, day-use recreation areas, other
commercial facilities, and industrial facilities provided the waste is not mixed with indus-
trial waste.
Septic system means a "well" that is used to emplace sanitary waste below the sur-
face and is typically comprised of a septic tank and subsurface fluid distribution system
or disposal system.
Subsurface fluid distribution system means an assemblage of perforated pipes,
drain tiles, or other similar mechanisms intended to distribute fluids below the surface of
the ground.
Well means a bored, drilled, or driven shaft whose depth is greater than the largest sur-
face dimension; or, a dug hole whose depth  is greater than the largest surface dimen-
sion; or, an improved sinkhole; or, a subsurface fluid distribution system.
Well  injection means the subsurface emplacement of fluids through a well.
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