United States Office of Ground Water EPA/816-R-99-014d
Environmental and Drinking Water (4601) September 1999
Protection Agency
The Class V Underground Injection
V>EPA Control Study
Volume 4
Wells That Inject Fluids From Carwashes
Without Engine or Undercarriage
Cleaning
-------
Table of Contents
Page
1. Summary 1
2. Introduction 3
3. Prevalence of Wells 4
4. Wastewater Characteristics and Injection Practices 6
4.1 Injectate Characteristics 7
4.2 Well Characteristics 10
5. Potential and Documented Damage to USDWs 18
5.1 Injectate Constituent Properties 18
5.2 Observed Impacts 18
6. Best Management Practices 19
7. Current Regulatory Requirements 20
7.1 Federal Programs 20
7.1.1 SDWA 20
7.1.2 CWA 22
7.2 State and Local Programs 22
Attachment A: Injectate Quality Data For Wells That Inject Fluid from Carwashes Without Engine or
Undercarriage Cleaning 24
Attachment B: State and Local Program Descriptions 35
References 45
September 30, 1999
-------
WELLS AT CARWASHES WITHOUT ENGINE OR
UNDERCARRIAGE CLEANING
The U.S. Environmental Protection Agency (USEPA) conducted a study of Class V
underground injection wells to develop background information the Agency can use to evaluate the risk
that these wells pose to underground sources of drinking water (USDWs) and to determine whether
additional federal regulation is warranted. The final report for this study, which is called the Class V
Underground Injection Control (UIC) Study, consists of 23 volumes and five supporting appendices.
Volume 1 provides an overview of the study methods, the USEPA UIC Program, and general findings.
Volumes 2 through 23 present information summaries for each of the 23 categories of wells that were
studied (Volume 21 covers 2 well categories). This volume, which is Volume 4, covers Class V wells
at carwashes without engine or undercarriage cleaning.
1. SUMMARY
Wells used to dispose of washwater that was used to wash only the exterior of vehicles
(sometimes called "wand washes") are the only carwash wells within the scope of this volume of the
Class V UIC Study1 These are typically located at coin-operated, manual carwashes where people
use hand-held hoses to wash vehicles. Even though the term "carwash" is used, the category includes
wells that receive used washwater at facilities designed for washing all kinds of vehicles, including cars,
vans, trucks, buses, boats on trailers, etc.
The cleaning solutions used at these carwashes generally consist of soap solutions, rinsewater,
and wax, and are not expected to contain significant amounts of degreasing agents or solvents such as
methylene chloride or trichloroethylene (because these wells, as defined, are not supposed to be
receiving engine or undercarriage washwater, which is more likely to contain such substances). As a
result, the spent washwater disposed in a carwash well (as defined in this report) primarily contains
detergents, road salts, sediments, and incidental contaminants that may be washed from a vehicle's
exterior, comparable to typical storm water runoff. Although there are no data on the issue, there is
also concern that de-icing agents may be rinsed from cars and enter ground water. The data available
on the quality of fluids entering carwash wells indicate that the concentrations of antimony, arsenic,
beryllium, cadmium, lead, and thallium in the injectate typically exceed primary drinking water maximum
contaminant levels (MCLs) and health advisory levels (HALs). Some samples show that ethylene
glycol, methylene chloride, naphthalene, and tetrachloroethene also have exceeded primary MCLs or
HALs, indicating that degreasers may in fact be working their way into the washwater at some facilities.
Injectate pH and aluminum, iron, and manganese concentrations exceed secondary MCLs.
1 Class V wells used to inject fluids from carwashes where engine or undercarriage washing is
performed were classified as industrial wells and wells that receive both carwash wastewater and waste
fluids from vehicle maintenance activities were classified as motor vehicle waste disposal wells in the July
29, 1998 proposed revisions to the USEPA Class V UIC regulations.
September 30, 1999
-------
Two possible contamination incidents involving carwash wells were reported in Hawaii in the
early 1990s. The nature and extent of contamination are unknown, but both wells were closed.
Although there are only these two reported contamination incidents associated with carwash
wells, there is concern over the potential for such wells to be vulnerable to spills or illicit discharges.
Because the facilities are usually unsupervised (meaning an attendant is not onsite), individuals may in
fact wash their engines or undercarriages using degreasers, wash the exterior of their vehicles with
chemicals other than common soap solutions, or may pour used oil, antifreeze, or other hazardous
materials down these drains. No actual contamination incidents associated with this kind of illicit
discharge, however, were discovered during the course of this study. Industry representatives also
assert that illegal dumping of unauthorized materials into drains at self-service carwashes is less of a
problem now than in the past, due to increased environmental awareness and the greater availability of
hazardous material collection centers.
The inventory results for these wells are very uncertain because most responses to the state and
USEPA Regional survey conducted for this study did not distinguish carwash wells from other kinds of
commercial or industrial wells. These survey results suggest that there are up to 4,651 documented
carwash wells and approximately 7,192 estimated carwash wells in the U.S. Although the wells are
documented in 14 states, 99 percent of the documented wells and 98 percent of the estimated wells are
located in nine states: Alabama, Mississippi, New %rk, Washington, Maryland, Iowa, West Virginia,
California, and Maine. Many states estimate that more than the documented number of wells exist,
although these estimates are typically based only on best professional judgment and the true number of
wells is unknown. As sewer system hookups become increasingly available to carwash owners, it is
expected that the number of Class V carwash wells will decrease. Many states close carwash wells
when they find them.
Although West Virginia permits carwash wells by rule (in accordance with the existing federal
UIC program), other states with the majority of documented and estimated carwash wells are
developing and implementing more extensive regulatory programs to address these wells. Specifically:
Alabama, Maryland, Mississippi, New Hampshire, New %rk, and Washington (when the well
meets best management practice requirements) issue individual permits.
California requires reporting of discharges from carwash wells.
Iowa bans carwash wells.
Maine issues discharge licenses for new wells and permits for existing wells.
September 30, 1999
-------
2. INTRODUCTION
Wells that inject wastewater from carwashes qualify as Class V injection wells as long as the
wastewater is not a hazardous waste as defined under the Resource Conservation and Recovery Act
(RCRA) and implementing regulations. Using the existing list of Class V well types in 40 CFR
§146.5(e), carwash disposal wells are either "dry wells used for the injection of wastes into a
subsurface formation" (per §146.5(e)(5)), or if the wastewater is disposed via a septic system, "septic
system wells used to inject the waste or effluent from ... a business establishment" (per §146.5(e)(9)).
In the 7957 Class V UIC Report to Congress, carwash wastewater disposal wells were considered to
be industrial process water and waste disposal (5W20) wells (USEPA, 1987).
Carwashes are commonly divided into three types: tunnel, rollover, and wand. These different
types of carwashes are characterized in the following way in USEPA's development document for
effluent limitations guidelines and standards for the "auto laundries" point source category (USEPA,
1980):
Tunnel wash: This is the most common type of carwash in the U S. and is usually housed in a
long building. The vehicle is pulled by a conveyer or driven through the length of the building,
passing through separate washing, rinsing, waxing, and drying areas. In the washing area,
detergents and water are applied and dirt is mechanically removed either by brushes or high-
pressure streams of water. The vehicle is then rinsed with clean water to remove the dirt and
soap. Finally, the vehicle is dried, usually by a blower. All of the used wash and rinse water is
collected in a floor trench. In many tunnel washes, the wash and rinse waters are kept separate
by a dam placed in the trench.
Rollover wash: In a rollover wash, the vehicle remains stationary while the washing equipment
passes over the vehicle. This is similar in design to exterior pressure washes that utilize high-
pressure streams of water in lieu of brushes. At both of these types of carwashes, all of the
wastewater is collected in a single trench, usually situated beneath the vehicle.
Wand wash: In this type of wash, the car remains stationary in a garage-type structure (called
a bay) while the customer washes the vehicle using a high-pressure stream of soap and water
from a hand-held wand. The wash and rinse waters are typically collected in a single trench or
sump.
On July 29, 1998 (63 FR 40586), USEPA proposed revisions to the Class V UIC regulations.
This notice proposed to put wells used to inject fluids from carwashes into two different well categories
depending on whether the carwashes perform engine or undercarriage washing (see 63 FR 40599).
Wells at carwashes "that are specifically set up to perform engine or undercarriage washing" would be
included in the "industrial well" category. By contrast, wells at coin-operated, manual carwashes where
people use hand-held hoses to wash only the exterior of vehicles would be classified as "other industrial
September 30, 1999
-------
wells,"2 as would those at any other vehicle washing facility not set up to perform engine or
undercarriage washing.
Following this proposed distinction, this volume of the Class V UIC study focuses only on wells
that inject fluids from carwashes where no engine or undercarriage washing is performed. These are
primarily wand wash facilities described above, although USEPA recognizes that engine or
undercarriage washing can and does occur at some wand washes.
3. PREVALENCE OF WELLS
For this study, data on the number of Class V carwash wells were collected through a survey of
state and USEPA Regional UIC Programs. The survey methods are summarized in Section 4 of
Volume 1 of the Class V Study. Table 1 lists the numbers of Class V carwash wells in each state, as
determined from this survey. The table includes the documented number and estimated number of wells
in each state, along with the source and basis for any estimate, when noted by the survey respondents.
If a state is not listed in Table 1, it means that the UIC Program responsible for that state indicated in its
survey response that it did not have any Class V carwash wells.
Many states and USEPA Regions administering the UIC program acknowledge that wells at
carwashes without engine or undercarriage cleaning probably exist, but they have not been able to
determine exactly how many exist for a variety of reasons. Chief among these reasons is that many
states do not permit or inventory these wells. Other states group carwash wells with wells at
laundromats or with other industrial wells.
Ninety-nine percent of the documented wells and 98 percent of the estimated wells are located
in nine states: Alabama, California, Iowa, Maine, Maryland, Mississippi, New York, Washington, and
West Virginia. Washington reports the largest number of wells, 3,900. However, this number is an
estimate based on the number of registered non-contact cooling water wells and carwash wells (both
with and without engine or undercarriage cleaning) in the state. These wells are grouped together in one
category and, according to state staff, cannot be differentiated in the state's records. Several other
states also group carwash wells with other well categories and report a single documented number
based on the total number of registered wells in those categories: New York (<174), West Virginia
(<223), Alabama (<162), and New Jersey (<28). Only three other states document more than 10
carwash wells: New Hampshire (as many
2 The wells in the proposed "other industrial well" category are: (1) wells used to inject fluids from
carwashes that are not specifically set up to perform engine or undercarriage washing; (2) wells used to
inject noncontact cooling water that contains no additives and has not been chemically altered; (3) wells
used to inject fluids from laundromats where no onsite dry cleaning is performed or where no organic
solvents are used for laundering; and (4) wells used to inject wastewater from food processing operations.
The other three kinds of wells included in the other industrial well category are addressed in separate
volumes of the Class V Study.
September 30, 1999
-------
Table 1. Inventory of Wells at Carwashes Without Undercarriage
or Engine Cleaning in the U.S.
State
Documented
Number of
Wlls
Estimated Number of \\fells
Number
Source of Estimate and Methodology1
USEPA Region 1
MA
ME
NH
6
63
11 (response)
14(inventory)
>6
<63
1 1 (response)
14(inventory
)
No estimate provided, but state suspects more than 6 exist.
Best professional judgement. No estimate provided, but state suspects
that fewer wells exist than documented.
The documented number of wells is inaccurate because they are found
only when inspections are performed.
USEPA Region 2
NJ
NY
VI
<28
<174
0
<28
1,000
50
Permits database documents 28 "other industrial" wells, of which carwash
wells are a subset.
Estimate of 1,000 "other industrial" wells based on best professional
judgement.
Region 2 estimate based on review of inspection reports and business
directory.
USEPA Region 3
MD
WV
38
<223
>38
>223
No estimate provided, but state suspects more than 38 exist.
Based on best professional judgement, state estimates that more than 223
other industrial wells exist.
USEPA Region 4
AL
MS
<162
9
>162
410
162 represents the number of permitted other industrial wells. State
estimates that more than 162 other industrial wells exist.
Estimate based on best professional judgement; 5 carwashes in each of 82
counties.
USEPA Region 5
MI
8
8
N/A
USEPA Region 6 - None
USEPA Region 7
IA
NR
>1,000
Best professional judgement based on ten years of Iowa experience and
discussions with trade organizations and county sanitarians.
September 30, 1999
-------
Table 1. Inventory of Wells at Carwashes Without Undercarriage
or Engine Cleaning in the U.S. (Continued)
State
Documented
Number of
Wlls
Estimated Number of \\fells
Number
Source of Estimate and Methodology1
USEPA Region 8
WY
0
3
Estimate provided by Robert Lucht, Wyoming Department of
Environmental Quality, Water Quality Division.
USEPA Region 9
CA
HI
NV
20
5
0
220
5
30
Best professional judgement.
N/A
Best professional judgement and gross estimates.
USEPA Region 10
AK
OR
WA
1
0
<3,900
10
25
>3,900
Best professional judgement.
Wells are closed when found; the number of existing wells is not
documented.
No estimate provided, but state expects that more wells exist.
All USEPA Regions
All
States
4,651 +/-
7,195+7-
As indicated above, many of these documented and estimated numbers are
for all types of "other industrial" wells, of which carwash wells are a
subset.
1 Unless otherwise noted, the best professional judgement is that of the state or USEPA Regional staff completing the survey
questionnaire.
N/A Not available.
NR Not reported.
as 14), Maryland (38), and California (20). Many states estimate that more than the documented
number of wells exist.
4. WASTEWATER CHARACTERISTICS AND INJECTION
PRACTICES
Very little information is available on the characteristics of carwash well injectate. There are
several reasons for this lack of data. First, these wells are often not a high priority for state programs.
Instead of requesting sampling and analysis of injectate, states may simply close the wells when they are
discovered. Second, wells that receive carwash water often receive wastes from car maintenance
areas or from carwashes that also clean engines or undercarriages, qualifying the wells as motor vehicle
September 30, 1999
-------
waste disposal wells or industrial wells. The injectate going into these wells is not representative of that
entering carwash wells as defined for the purpose of this study.
The information that is available for carwash injectate is presented in Section 4.1 below This is
followed by a summary of the limited information available on carwash well design characteristics
(Section 4.2) and operational practices (Section 4.3).
4.1 Injectate Characteristics
Injectate from carwashes has been shown by limited data to contain detergents, dissolved solids
(salts), elevated biochemical oxygen demand levels, and elevated levels of suspended solids (sand and
grit) (NC DEHNR, 1997 and USEPA, 1994). Some detergents may contain metals such as arsenic
and nutrients such as phosphorus and nitrogen (ECOL, 1995). The injectate also often contains metals
(lead and chromium, among others), volatile organic compounds (VOCs), and oils and grease.
However, metals are not expected in appreciable concentrations at carwashes that do not perform
engine or undercarriage washing.
The injectate characteristics information presented in this section is based on data from 16
carwash facilities in New York, one sampling event each in 1997 at two carwashes in Montana,
sampling events at 17 carwash facilities in Maryland, and three sampling events at a combined carwash
and laundromat facility in Montana in the 1997 to 1998 time period. The quality of the background or
feed (i.e., source) water was not measured in any of these events, even though it could affect the quality
of the injectate samples.
The New "Vbrk Department of Environmental Conservation sampled 16 wells at carwashes
without engine or undercarriage cleaning in Suffolk and Nassau counties, New York. The complete
data set is included as Table A-l in Attachment A to this volume. The injectate was sampled and
analyzed following any type of water treatment that may have occurred, which is indicated on the table.
State officials explained that, although these facilities are not set up to perform undercarriage or engine
washing, it is possible that these activities could occur at the two self-service facilities. Table 2 presents
a summary of the parameters for which there are MCLs and/or HALs.
The most common inorganic constituents present in the New York carwash well injectate are
total Kjeldahl nitrogen (TKN), chloride, methylene blue active substance (MBAS), oil and grease, total
dissolved solids (TDS), and total suspended solids (TSS). Of the detected inorganic constituents, only
chloride and TDS exceeded the secondary MCLs. In addition, several metals were detected above
the MCLs: aluminum, antimony, beryllium, cadmium, iron, lead, and thallium. Of these, the following
metals also exceeded the HALs: antimony, arsenic, beryllium, cadmium, and thallium. Of the detected
organic constituents, methylene chloride and tetrachloroethene were present above the primary MCLs.
September 30, 1999
-------
Table 2. Summary of Data from Car Wash Samples in New \brk
Parameter
Chloride
Nitrite
Nitrate
IDS
Chloroform
Ethylbenzene
Methylene Chloride
Tetrachloroethene
Toluene
Xylene
m+p-Xylene
o-Xylene
Aluminum
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Nickel
Selenium
Silver
Thallium
Zinc
Number of
Observations
14
8
8
7
5
3
3
1
4
1
3
3
15
15
1
2
16
15
16
15
16
16
1
3
4
16
Range of
Concentrations
(mg/1)
10.8-302
<05- 0.931
<05-3.71
230 - 546.0
0.001-0.057
0.001 -0.017
0.0017-0.016
0.079
0.0012-0.038
0.017
0.0045 - 0.060
0.002 -0.013
0.295-13.100
0.0066-0.123
0.0032
0.0014 - 0.026
0.001 -0.009
0.001 -0.0278
0.0139-0.460
2.120-19.700
0.0044 - 0.0598
0.0118-0.0682
0.0026
0.0011-0.007
0.0024 - 0.0068
0.0895 - 0.482
Drinking Water
Standards*
mg/1
250
1
10
500
0.1/0.08t
0.7
0.005
0.005
1
10
10
10
0.05-0.2
0.006
0.05
0.004
0.005
0.1
1.3
0.3
0.015
0.1
0.05
0.1
0.002
5
P/S
s
p
p
s
p
p
p
p
p
p
p
p
s
p
p
p
p
p
s
s
p
p
p
s
p
s
Health Advisory
Levels**
mg/1
_
_
_
_
0.6
0.7
_
_
1
10
10
10
-
0.003
0.002
0.0008
0.005
0.1
_
_
_
0.1
_
0.1
0.0005
2
N/C
C
N
N
N
N
N
N
C
C
N
N
N
N
N
N
Source: New York Department of Environmental Conservation, 1999
* Drinking Water Standards: P= Primary; S= Secondary.
** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.
-No standards or advisory levels available.
T0.1 is the current MCL, 0.08 is the proposed rule for Disinfectants and Disinfection By-products: Total for all THMs combined
cannot exceed the 0.08.
September 30, 1999
-------
Table 3 summarizes quality data for injectate sampled at Dane's Carwash and Libby Auto, two
carwash facilities in Libby, Montana, in 1997. The complete data set is included as Table A-2 in
Attachment A to this volume. The samples were analyzed for the presence of several metals. Iron,
lead, and manganese exceeded the MCLs. In addition, the concentration of total cadmium at Libby
Auto equaled the primary MCL, and antimony exceeded the noncancer HAL. The Montana carwash
well samples were not analyzed for the presence of organic constituents.
Table 3. Summary of Data from Carwash Samples in Montana
Parameter
Aluminum, Total
Antimony, Total
Arsenic, Total
Barium, Total
Benzene
Beryllium, Total
Cadmium, Total
Chromium, Total
Chromium, Dissolved
Copper, Total
Iron, Total
Lead, Total
Manganese, Total
Mercury, Total
Nickel, Total
Selenium, Total
Selenium, Dissolved
Silver, Total
Thallium, Total
Zinc, Total
Concentrations
(mg/1)
LibAuto
0.105
O.003
0.025
<1
NA
<0.002
0.0050
<0.05
<0.05
<0.5
0.91
0.0096
0.077
0.001
O.05
O.025
0.025
0.025
O.001
<2.5
Dano
3.22
0.004
0.025
<1
NA
O.002
0.0025
0.05
O.05
O.5
3.90
0.0172
0.243
0.001
O.05
O.025
0.025
0.005
O.001
<2.5
Drinking Water
Standards*
mg/1
0.05-0.2
0.006
0.05
2
0.005
0.004
0.005
0.1
0.1
1.3
0.3
0.015
0.05
0.002
0.1
0.05
0.05
0.1
0.002
5
P/S
s
p
p
p
p
p
p
p
p
p
s
p
s
p
p
p
p
s
p
s
Health Advisory
Levels**
mg/1
-
0.003
0.002
2
0.1
0.0008
0.005
0.1
0.1
-
-
-
-
0.002
0.1
-
-
0.1
0.0005
2
N/C
N
C
N
C
C
N
N
N
N
N
N
N
Source: USEPA Region 8,1999
* Drinking Water Standards: P= Primary; S= Secondary.
** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.
-No standards or advisory levels available.
September 30, 1999
-------
Table 4 displays a summary of water quality data for one sampling event at each of 17 car
dealerships and car washes in Maryland. Thirteen of these facilities are new and used car dealerships
or automotive sales and service facilities. Also included is one truck and construction equipment repair
facility; one vehicle repair, servicing, and cleaning facility; one geotechnical construction company; and
one maintenance facility for transportation vehicles. These data are for samples taken from wells
receiving exterior vehicle washwater. If a parameter is not included in the table, it was either not
detected or the sample was not analyzed for that parameter. The complete data set is included as
Table A-3 in Attachment A to this volume. Measurements of pH exceeded the upper end of the
secondary MCL range, with two of five samples above the range. Two metals, cadmium and iron,
exceeded MCLs. Cadmium was the only inorganic constituent reported above the HALs. A large
number of organic constituents were reported above detection limits in the Maryland carwash samples.
Three of these organic constituents were reported at levels above the MCLs and HALs: ethylene
glycol, naphthalene, and tetrachloroethene.
On March 19, 1992, the Jackson Hole Airport Rental Carwash septic system in Jackson,
Wyoming was sampled. Table 5 presents the water quality data from this sampling event. None of the
organic or inorganic constituents were reported above the MCLs or HALs.
A&J Suds and Scrub in Libby Montana, submitted the results of three sampling events as part
of the requirements for a UIC permit. The facility's well receives a combination of carwash and
laundromat effluent. As a result, the injectate data are not entirely representative of carwash well
injectate. Table 6 summarizes these data; the complete data set is included as Table A-4 in Attachment
A to this volume. Several of the metals were reported above the MCLs: aluminum, cadmium, iron,
lead, and manganese. The cadmium concentration also exceeded the noncancer HAL. None of the
organic constituents were present in concentrations above the MCLs or HALs.
4.2 Well Characteristics
Figures 1 and 2 display standard treatment systems for wand wash carwash facilities in
Tennessee. Based on these diagrams, some wells consist of septic systems and/or sand filters. Others
may simply be dry wells.
Arkansas strongly suggests that car and truck washing facilities include a grit chamber and
grease trap in the design of their injection wells; however, this is not a requirement (ADPC&E, 1996).
In Wyoming, carwash septic systems are designed to accommodate 200 gallons per vehicle unless they
can show that they use a lesser amount based on the design of an automatic system (WYDEQ/WQD,
1999). No additional information is available on the design, construction, or siting of carwash wells.
September 30, 1999 10
-------
Table 4. Summary of Data from Carwash Samples in Maryland
Parameter
PH
Benzene
Chloride
1 ,2-Dichlorobenzene
1 ,4-Dichlorobenzene
Diethyl Phthalate
Ethylene Glycol
Ethylbenzene
Methylene Chloride
Naphthalene
Tetrachloroethene
Toluene
Xylene
Cadmium
Chromium
Iron
Lead
Magnesium
Nickel
Zinc
Number of
Detections
7
1
1
1
1
3
9
3
1
4
2
6
1
1
1
1
1
1
1
1
Range of
Concentrations
(mg/1)
3.5-9.5
0.004
26
0.009
0.0065
0.012-0.019
<01%-9.6
0.025-0.182
0.004
0.0074 - 4.620
0.002 - 0.022
0.016-0.077
0.057
0.016
0.008
2.4
0.013
14
0.055
0.24
Drinking Water
Standards*
mg/1
6.5-8.5
0.005
250
0.6
0.075
-
-
0.7
0.005
-
0.005
1
10
0.005
0.1
0.3
0.015
-
0.1
5
P/S
s
p
s
p
p
p
p
p
p
p
p
p
s
p
p
s
Health Advisory
Levels**
mg/1
-
0.1
-
0.6
0.075
5
7
0.7
-
0.02
-
1
10
0.005
0.1
-
-
-
0.1
2
N/C
C
N
N
N
N
N
N
N
N
N
N
N
N
Source: Mary land Department of the Environment, 1999
-No standards or advisory levels available.
* Drinking Water Standards: P= Primary; S= Secondary.
** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.
September 30, 1999
11
-------
Table 5. Data from Carwash Samples Taken at Jackson Hole Airport Carwash Facility
Parameter
Ammonia (as N)
Benzene
Chloride
Ethylbenzene
Methylene Chloride
Nitrate
IDS
Total Phenols
1 ,2-Dichlorobenzene
1 ,4-Dichlorobenzene
1 , 1 -Dichloroethane
1 ,2-Dichloroethane
1 ,2-Dichloroethene
1 ,2-Dichloropropane
Tetrachloroethene
Trichloroethene
1,1,1 -Trichloroethane
Toluene
Total Xylenes
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Concentration
(mg/1)
0.55
0.0006
12
1.0
<1
0.25
372
O.05
O.001
0.001
<0.001
<0.001
<0.001
0.0026
<0.001
<0.001
<0.001
<0.0005
0.0075
<0.05
1.23
<0.001
<0.05
<0.005
<0.001
<0.005
<0.05
Drinking Water
Standards*
mg/1
_
0.005
250
0.7
0.005
10
500
_
0.6
0.075
_
0.005
_
0.005
0.005
0.005
0.2
1
10
0.05
2
0.005
0.1
0.015
0.002
0.05
-
P/S
p
s
p
p
p
s
p
p
p
p
p
p
p
p
p
p
p
p
p
p
p
p
Health Advisory
Levels**
mg/1
30
0.1
_
0.7
_
_
_
4
0.6
0.075
_
0.04
_
0.06
_
0.3
0.2
1
10
0.002
2
0.005
0.1
_
0.002
_
0.1
N/C
N
C
N
N
N
N
C
C
C
N
N
N
C
N
N
N
N
N
September 30, 1999
12
-------
Table 5. Data from Carwash Samples Taken at Jackson Hole Airport Carwash Facility
Parameter
Concentration
(mg/1)
Drinking Water
Standards*
mg/1
P/S
Health Advisory
Levels**
mg/1
N/C
Source: WDEQ/WQD, 1999
-No standards or advisory levels available.
* Drinking Water Standards: P= Primary; S= Secondary.
** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.
Table 6. Summary of Water Quality Data from
A&J Suds & Scrub Libby, Montana
Parameter
Aluminum, Total
Antimony, Total
Arsenic, Total
Barium, Total
Benzene
Beryllium, Total
Bromodichloromethane
Bromoform
Bromomethane
Cadmium, Total
Carbon Tetrachloride
Chlorodibromomethane
Chloroform
Chloromethane
2-Chlorotoluene
4-Chlorotoluene
Chromium, Total
Copper, Total
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
Concentrations
(mg/1)
11/05/97
13
<0.003
O.025
<1
NA
<0.002
NA
NA
NA
0.0064
NA
NA
NA
NA
NA
NA
<0.05
<0.5
NA
NA
NA
1/12/98
NA
NA
NA
NA
O.0005
NA
O.0005J *
<0.0005
<0.0005
NA
<0.0005
<0.0005
0.015
0.0005
<0.0005
<0.0005
NA
NA
<0.0005
<0.0005
<0.0005
7/27/98
NA
NA
NA
NA
<0.0005
NA
<0.0005
<0.0005
<0.0005
NA
<0.0005
<0.0005
0.009
<0.0005
<0.0005
<0.0005
NA
NA
<0.0005
<0.0005
O.0005
Drinking Water
Standards*
mg/1
0.05-0.2
0.006
0.05
2
0.005
0.004
0.1/0.08*
0.1/0.08*
_
0.005
0.005
0.1/0.08*
0.1/0.08*
_
-
_
0.1
1.3
0.6
_
0.075
P/S
s
p
p
p
p
p
p
p
p
p
p
p
p
p
p
p
Health Advisory
Levels**
mg/1
-
0.003
0.002
2
0.1
0.0008
0.06
0.4
0.01
0.005
0.03
0.06
0.6
0.003
0.1
0.1
0.1
_
0.6
0.6
0.075
N/C
N
C
N
C
C
C
C
N
N
C
N
C
N
N
N
N
N
N
N
September 30, 1999
13
-------
Table 6. Summary of Water Quality Data from
A&J Suds & Scrub Libby, Montana
(Continued)
Parameter
Dichlorodifluoromethane
1 ,2-Dicholoroethane
1 , 1 -Dichloroethene
cis-1 ,2-Dichloroethene
trans- 1 ,2 -Dichloroethene
1 ,2-Dichloropropane
Ethylbenzene
Fluorotrichloromethane
Hexachlorobutadiene
Iron, Total
Lead, Total
Manganese, Total
Mercury, Total
Methylene chloride
Naphthalene
Nickel, Total
Selenium, Total
Silver, Total
Styrene
1,1,1 ,2-Tetrachloroethane
1 ,2,3-Trichloropropane
Tetrachloroethene
Thallium, Total
Toluene
1 ,2,4-Trichlorobenzene
1,1,1 -Trichloroethane
1 ,1 ,2-Trichloroethane
Vinyl Chloride
Concentrations
(mg/1)
11/05/97
NA
NA
NA
NA
NA
NA
NA
NA
NA
12.5
0.0453
0.474
<0.001
NA
NA
<0.05
0.025
<0.005
NA
NA
NA
NA
O.001
NA
NA
NA
NA
NA
1/12/98
<0.0005
0.0005
0.0005
0.0005
0.0005
O.0005
O.0005
O.0005
O.0005
NA
NA
NA
NA
<0005
O.OOOSJt
NA
NA
NA
0.0005
0.0005
0.0005
0.00085
NA
O.0005J t
O.0005
0.0005
0.0005
0.0005
7/27/98
0.0005
0.0005
0.0005
0.0005
0.0005
O.0005
O.0005
O.0005
O.0005
NA
NA
NA
NA
0.00081
0.00056
NA
NA
NA
0.0005
0.0005
0.0005
0.00085
NA
0.0021
O.0005
0.0005
0.0005
0.0005
Drinking Water
Standards*
mg/1
_
0.005
0.007
0.07
0.1
0.005
0.7
_
_
0.3
0.015
0.05
0.002
.005
_
0.1
0.05
0.1
0.1
_
_
.005
0.002
1
0.07
0.2
0.005
0.002
P/S
p
p
p
p
p
p
s
p
s
p
p
p
p
s
p
p
p
p
p
p
p
p
Health Advisory
Levels**
mg/1
1.0
0.04
0.007
0.07
0.1
0.06
0.7
2
0.001
_
_
_
0.002
_
0.02
0.1
_
0.1
0.1
0.07
0.04/0.5
_
0.0005
1
0.07
0.2
0.003
0.0015
N/C
N
C
N
N
N
C
N
N
N
N
N
N
N
N
N
N/C
N
N
N
N
N
C
September 30, 1999
14
-------
Table 6. Summary of Water Quality Data from
A&J Suds & Scrub Libby, Montana
(Continued)
Parameter
Xylenes
m+p-Xylene
o-Xylene
Zinc, Total
Concentrations
(mg/1)
11/05/97
NA
NA
NA
<2.5
1/12/98
<0.0005J t
O.OOOSJt
<0.0005
NA
7/27/98
0.00059
0.00059
0.0005
NA
Drinking Water
Standards*
mg/1
10
10
10
5
P/S
p
p
p
s
Health Advisory
Levels**
mg/1
10
10
10
2
N/C
N
N
N
N
Source: USEPA Region 8,1999
* Drinking Water Standards: P= Primary; S= Secondary.
** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.
NA = Not analyzed for that constituent.
- No standards or advisory levels available.
T J = Estimated value. Present, but less than the limit of quantitation.
* 0.1 is the current MCL, 0.08 is the proposed rule for Disinfectants and Disinfection By-products: Total for all THMs
combined cannot exceed the 0.08.
September 30, 1999
15
-------
Figure 1. Carwash Designed with Sand Filter Oil/Water Separator
Or;
EPTIC TANK
FIELD LJ WES
fc:
L,
W1RT
niMP
-J~t
J SANDnum
j
SEDJMem'TRAJ*
uict:TDEC,l»5
WASH BAY
WASH BAY
*
FLOOR UKAIN
WASH BAY
JfcCHANtCAL ROOM
September 30, 1999
16
-------
Figure 2. Sand Filter Oil/Water Separator Design
P3HPTOTAJLE FILTERED WATER FKOU
[KJ11QH lit HL1V41 TO BriMPUHU PUiT
THB SArtft riLttll TANK IS ID BK SIZED ACra*J>tN<;
Tnim MAXIMUM ftow lutiTtuTitii PATUJTV N
TUB FILTH IB TO BB CIXAKHl B V BKMO VIHC THE
LVffTAMlNATEHUND WiPOlSfOSIHC UH II IN
A LICEflSBOBOLJD WASTE LxMOflM
TDEC,
ik !-'.:v:'-/-;'/.,":;.*'"';.; '.:,jj
I'^j 'L ji ' '',*" ' V" " "' ' \ ^' |i
Pi?t KROLl THE SEDIUEITT TRAP
KLOW
1 AND 19 USED TTJ FILL TDK M AJORTTY OF TIIE FILTCjt
A FiLl EK r AHKII; B PLATED BETWEEN TIIE SAND AHJI THE STONL
HIIHHKK 37 STONE ISPUJltp AjrtX^pTHt HnrnTUlM DRAJW tiff.
Tllla Hit IS rtKKIKAl tU(UK£ ONES LIED IN UMJN f-IELUl
September 30, 1999
17
-------
5. POTENTIAL AND DOCUMENTED DAMAGE TO USDWs
5.1 Injectate Constituent Properties
The primary constituent properties of concern when assessing the potential for Class V carwash
wells to adversely affect USDWs are toxicity, persistence, and mobility. The toxicity of a constituent is
the potential of that contaminant to cause adverse health effects if consumed by humans. Appendix D
of the Class V Study provides information on the health effects associated with contaminants found
above drinking water standards or health advisory limits in the injectate of carwash wells and other
Class V wells. As discussed in Section 4.1, the contaminants that have been observed above drinking
water standards (i.e., MCLs) or HALs in carwash well injectate are aluminum, antimony, arsenic,
beryllium, cadmium, iron, lead, thallium, manganese, chloride, pH, TDS, ethylene glycol, methylene
chloride, naphthalene, and tetrachloroethene.
Persistence is the ability of a chemical to remain unchanged in composition, chemical state, and
physical state over time. Appendix E of the Class V Study presents published half-lives of common
constituents in fluids released in carwash wells and other Class V wells. All of the values reported in
Appendix E are for ground water. Caution is advised in interpreting these values because ambient
conditions have a significant impact on the persistence of both inorganic and organic compounds.
Appendix E also provides a discussion of mobility of certain constituents found in the injectate of
carwash wells and other Class V wells.
5.2 Observed Impacts
Hawaii state officials report that two possible contamination incidents resulted from the injection
of carwash water into a Class V well. First, Budget Rent-A-Car near the Hilo, Hawaii, airport owned
and operated a dry well to which they discharged carwash water. Although the nature and extent of
contamination were unknown, USEPA issued an administrative order in 1991 for the facility to install a
system that recycled the carwash water, and the facility complied. Second, the McKinley Carwash in
Honolulu, Hawaii, disposed of carwash water into an oil/water separator with an injection well a few
blocks from a lagoon. Although the nature and extent of contamination were unknown, the well was
closed (Cadmus, 1999).
Five public commenters on the July 29, 1998 Class V proposed rule (63 FR 40586) described
incidents observed at self-service carwashes, where solvents have been used and engine cleaning
activities have occurred, resulting in potentially dangerous fluids being disposed in floor drains at these
facilities. Some commenters added that VOC contamination of ground water might have been caused
by the misuse of solvents at carwashes without engine or undercarriage cleaning. However, none of
these commenters provided documentation of any contamination incidents (USEPA, 1998).
September 30, 1999 18
-------
6. BEST MANAGEMENT PRACTICES
When possible, effluent from carwashes should be discharged to sewer systems or holding
tanks, thus reducing the amount of injected wastewater. When discharge to a sewer system or holding
tank is not possible, the amount of effluent entering the injection well can be reduced by capturing and
recycling as much water as possible, using filters, oil/water separators with recyclable absorbents,
reclamation systems, and other appropriate technologies. Using these practices, some carwashes
currently recycle 100 percent of their captured waste water (USEPA, 1992).
The State of Washington has published a best management practices (BMP) manual for
carwashes entitled "Vehicle and Equipment Washwater Discharges: Best Management Practices
Manual." The manual states that an acceptable treatment system should be constructed with a gravity
separation unit (e.g., an API Separator, Coalescing Plate Separator, or a containment sump with a
gravity separation overflow and positive control valve). Also, the effluent should be treated after gravity
separation to further remove residual oil and metals. The manual recommends that a 4 to 5 foot deep
multimedia filter (e.g., a multimedia peat sand filter) be used to remove heavy metals. Sampling ports
should be installed to facilitate sampling of the influent and effluent of the treatment system and gravity
separation unit. With proper operation and maintenance of the system, the average total suspended
solids should be less than 75 ppm, while oil and gas should be less than 10 ppm. The treatment system
should not be located above the frost line and it should not produce an effluent that will exceed the state
ground water quality standards. Sanitary wastes should not be discharged in to the treatment system
(ECOL, 1995). The manual also outlines a maintenance program for the carwash well treatment
system, which should include the following steps:
Daily inspection and weekly cleaning of grit traps.
Maintenance of gravity separation units according to manufacturer's recommended
maintenance procedures.
Regular monitoring of treated effluent is recommended. Oil and grease should be monitored
every six months and metals should be monitored annually.
Multimedia filters should be replaced as necessary.
Solids removed from the treatment system should be disposed of in a manner that does not
cause pollution to waters of the state (disposal methods may include sanitary landfill disposal).
A log of all maintenance activities should be kept at the site and made available to the
Washington State Department of Ecology and/or local authorities when requested.
In 1996, the New York State Department of Environmental Conservation (NYDEC) issued a
guidance memorandum on vehicle washing with plain water. According to the memorandum, any
facility should conduct all vehicle maintenance operations in a dedicated area that ensures proper
disposal of any incidental or accidental spillage of fluids. The facility should use only clean water, as
opposed to water that has already been used for cleaning, when washing vehicles and washing should
be done in a manner to minimize runoff. Runoff should be directed away from surface waters to the
extent practicable. The facility also should take measures to reduce water usage (e.g., the use of high
pressure wands which make cleaning more effective in a shorter period of time) (NYDEC, 1996).
September 30, 1999 19
-------
The Southwest Carwash Association provides carwash operators with large signs to be placed
in public view that outline USEPA regulations and the harmful effects of illegal dumping (Space, 1998).
Finally, the contaminant load of the injectate can be reduced by regularly inspecting treatment
equipment, tanks, and chemical containers for leaks; calibrating treatment and application equipment
regularly; and using biodegradable soaps and chemicals instead of solvent-based solutions.
Accumulated pit dirt should be processed to separate solids, contaminants, and wastewater. Dried pit
dirt and residual liquid waste should then be hauled to waste disposal sites in accordance with federal,
state, and local waste disposal regulations (USEPA, 1992).
7. CURRENT REGULATORY REQUIREMENTS
Several federal, state, and local programs exist that either directly manage or regulate Class V
carwash wells. On the federal level, management and regulation of these wells falls primarily under the
UIC program authorized by the Safe Drinking Water Act (SDWA). Some states and localities have
used these authorities, as well as their own authorities, to extend the controls in their areas to address
concerns associated with carwash wells.
7.1 Federal Programs
7.1.1 SDWA
Class V wells are regulated under the authority of Part C of SDWA. Congress enacted the
SDWA to ensure protection of the quality of drinking water in the United States, and Part C specifically
mandates the regulation of underground injection of fluids through wells. USEPA has promulgated a
series of UIC regulations under this authority. USEPA directly implements these regulations for Class
V wells in 19 states or territories (Alaska, American Samoa, Arizona, California, Colorado, Hawaii,
Indiana, Iowa, Kentucky, Michigan, Minnesota, Montana, New "Vbrk, Pennsylvania, South Dakota,
Tennessee, Virginia, Virgin Islands, and Washington, DC). USEPA also directly implements all Class
V UIC programs on Tribal lands. In all other states, which are called Primacy States, state agencies
implement the Class V UIC program, with primary enforcement responsibility.
Carwash wells currently are not subject to any specific regulations tailored just for them, but
rather are subject to the UIC regulations that exist for all Class V wells. Under 40 CFR 144.12(a),
owners or operators of all injection wells, including carwash wells, are prohibited from engaging in any
injection activity that allows the movement of fluids containing any contaminant into USDWs, "if the
presence of that contaminant may cause a violation of any primary drinking water regulation ... or may
otherwise adversely affect the health of persons."
Owners or operators of Class V wells are required to submit basic inventory information under
40 CFR 144.26. When the owner or operator submits inventory information and is operating the well
such that a USDW is not endangered, the operation of the Class V well is authorized by rule.
Moreover, under section 144.27, USEPA may require owners or operators of any Class V well, in
September 30, 1999 20
-------
USEPA-administered programs, to submit additional information deemed necessary to protect
USDWs. Owners or operators who fail to submit the information required under sections 144.26 and
144.27 are prohibited from using their wells.
Sections 144.12(c) and (d) prescribe mandatory and discretionary actions to be taken by the
UIC Program Director if a Class V well is not in compliance with section 144.12(a). Specifically, the
Director must choose between requiring the injector to apply for an individual permit, ordering such
action as closure of the well to prevent endangerment, or taking an enforcement action. Because
carwash wells (like other kinds of Class V wells) are authorized by rule, they do not have to obtain a
permit unless required to do so by the UIC Program Director under 40 CFR 144.25. Authorization by
rule terminates upon the effective date of a permit issued or upon proper closure of the well.
USEPA Region 2 requires operators of manned carwash facilities to submit additional
information, including: explanations of the facility's operating practices, materials safety data sheets for
chemicals used at the facility, sampling results from sludge in the well, and a site maintenance plan.
Additionally, operators must post a sign in the washing bay indicating that only the top and side of a
vehicle should be washed, and that only environmentally sound soaps and waxes (i.e., those that are
biodegradable and nontoxic) should be used. If a carwash is unmanned, Region 2 requires the facility
to apply for a Class V UIC permit (Cadmus, 1999).
Separate from the UIC program, the SDWA Amendments of 1996 establish a requirement for
source water assessments. USEPA published guidance describing how the states should carry out a
source water assessment program within the state's boundaries. The final guidance, entitled Source
Water Assessment and Programs Guidance (USEPA 816-R-97-009), was released in August
1997.
State staff must conduct source water assessments that are comprised of three steps. First,
state staff must delineate the boundaries of the assessment areas in the state from which one or more
public drinking water systems receive supplies of drinking water. In delineating these areas, state staff
must use "all reasonably available hydrogeologic information on the sources of the supply of drinking
water in the state and the water flow, recharge, and discharge and any other reliable information as the
state deems necessary to adequately determine such areas." Second, the state staff must identify
contaminants of concern, and for those contaminants, they must inventory significant potential sources
of contamination in delineated source water protection areas. Class V wells, including carwash wells,
should be considered as part of this source inventory, if present in a given area. Third, the state staff
must "determine the susceptibility of the public water systems in the delineated area to such
contaminants." State staff should complete all of these steps by May 2003 according to the final
guidance.3
3 May 2003 is the deadline including an 18-month extension.
September 30, 1999 21
-------
7.1.2
Pursuant to a 1976 settlement agreement and subsequently the 1977 Clean Water Act (CWA)
Amendments, USEPA was required to develop a program and adhere to a schedule in promulgating
effluent limitations guidelines and pretreatment standards for 65 toxic pollutants and classes of pollutants
for 21 major industries. The "Auto and Other Laundries Point Source Category" was one of the
categories mandated for study and possible effluent limitations guidelines and standards development by
the 1976 Settlement Agreement. However, in 1982, the auto and other laundries category, which
included carwashes, was excluded from regulation. As a result, the only federal program that address
special carwash wells are those under the SDWA.
7.2 State and Local Programs
As discussed in Section 3 above, 99 percent of the documented and 98 percent of the
estimated carwash wells in the nation exist in nine states: Alabama, California, Iowa, Maine, Maryland,
Mississippi, New York, Washington, and West Virginia. Attachment B to this volume describes how
each of these states, in addition to New Hampshire and Wyoming, currently control carwash wells.
The statutory and regulatory frameworks for injection wells associated with carwash facilities in
the states that report having the most carwash wells fall into two major groups.
In the three states in which the Class V UIC program is directly implemented by USEPA
California, Iowa, and New Yorkthe states have additional requirements for Class V wells
above and beyond the existing federal program. In California, Regional Water Quality Control
Boards can prescribe requirements for discharges to injection wells. In Iowa, unless carwash
wastewater can be shown to be sanitary waste, it is banned from disposal in onsite wastewater
treatment and disposal systems. Finally, New York requires State Pollution Discharge
Elimination System (SPDES) permits for discharges to ground water.
Primacy states for Class V wells apply a range of requirements to carwash wells. Alabama,
Mississippi, Maryland, Wyoming, and New Hampshire issue individual permits. Washington
also issues individual permits to existing wells as long as carwash wells meet BMP
requirements. However, Washington prohibits all new Class V injection wells that inject
industrial, municipal, or commercial waste fluids into or above a USDW.
September 30, 1999 22
-------
New Hampshire and Maryland require sampling and testing of effluent, and New
Hampshire also requires ground water sampling and testing. Carwash wells in West
Virginia are authorized by rule unless the Office of Water Resources requires an
individual permit. Maine requires a waste discharge license for Class V injection wells.
September 30, 1999 23
-------
ATTACHMENT A
INJECTATE QUALITY DATA FOR WELLS THAT INJECT FLUID
FROM CARWASHES WITHOUT ENGINE OR UNDERCARRIAGE CLEANING
Table A-l. Results of 16 Car Wash Samplings in New \brk
Parameter
Chloride (mg/1)
MBAS (mg/1)
TKN (mg/1)
Nitrite (mg/1)
Nitrate (mg/1)
Oil&Grease (mg/1)
IDS (mg/1)
TSS (mg/1)
Chloroform (mg/1)
Ethylbenzene (mg/1)
Methylene Chloride
(mg/1)
Tetrachloroethene
(mg/1)
Toluene (mg/1)
Xylene (mg/1)
m+p-Xylene (mg/1)
o-Xylene (mg/1)
Aluminum (mg/1)
Type of Treatment
None
63.8
.135
5.6
<05
<05
<.05
NA
26
.057
.563
SET
85.1
.165
3.22
<.05
<.05
21.2
NA
25.0
.038
.769
SET
30.1
.204
2.8
<.05
<.05
16.4
NA
44.0
.016
1.83
0
F
8.86
<.025
NA
NA
NA
6.0
NA
14.0
.0017
NA
F&
SET
10.8
20.5
NA
NA
NA
<5.0
NA
21
.001
.365
F&
SET
/SS
48.2
6.2
NA
NA
NA
6.8
NA
39
.012
.003
.079
.002
.017
8.730
SET
103
<.025
NA
NA
NA
13.8
NA
31.0
1.65
SET
47.9
<.025
NA
NA
NA
18.8
NA
20.0
.0053
.017
.060
.031
2.95
SET
302
45.8
7.8
NA
NA
30.4
NA
126
1.350
SET
NA
<.025
.56
.106
<05
51.8
353
42.0
.058
.013
.421
SET
NA
<.025
.56
<.05
..268
79.2
383
86.0
.001
.001
.0026
.0045
.002
.480
SET
83.3
<.025
NA
NA
NA
5.4
253
44.0
.0012
.310
SET
108
47.8
NA
NA
NA
<5.0
353
<10
.559
SET
53.2
2.77
.28
.931
3.71
3.4
230
60
.0052
13.100
SET
78
3.44
.56
<.05
<.05
15.9
433
14
1.010
SET/SS
230
2.17
1.54
<05
<.05
34.4
546
58
2.510
September 30, 1999
24
-------
Table A-l. Results of 16 Car Wash Samplings in New \brk (Continued)
Parameter
Antimony (mg/1)
Arsenic (mg/1)
Beryllium (mg/1)
Cadmium (mg/1)
Chromium (mg/1)
Copper (mg/1)
Iron (mg/1)
Lead (mg/1)
Nickel (mg/1)
Selenium (mg/1)
Silver (mg/1)
Thallium (mg/1)
Zinc (mg/1)
Type of Treatment
None
.0197
.0036
.0095
.214
2.380
.0212
.0216
.0016
.253
SET
.030
1
.003
4
.014
8
.183
3.58
0
.030
5
.020
.001
1
.295
SET
.022
7
.005
7
.010
5
.195
4.72
0
.027
8
.034
7
.435
F
.0129
.0016
.0234
NA
.028
.0129
.0895
F&
SET
.0122
.0014
.0039
.0107
.0139
3.240
.0182
.0195
.264
F&
SET
/SS
.0066
.026
.0009
5
.0010
.0167
2.940
.0044
.0682
.0026
.0024
.257
SET
.0633
.0054
.0250
.285
6.540
.0382
.0331
.0070
.396
SET
.0132
.0011
.0055
.0807
2.120
.0107
.0132
.160
SET
.123
.0032
.0013
.0227
.460
12.20
.0598
.0318
.464
SET
.0090
.0021
.0052
.111
2.660
.0130
.017
.268
SET
.0176
.0027
.0063
.118
4.350
.0140
.0155
.364
SET
.0010
.0073
.0492
3.040
.0079
.0168
.139
SET
.0127
.0050
.0192
.0924
2.910
.0320
.0177
.369
SET
.018
.0012
.0278
.168
19.700
.0265
.0192
.0068
.280
SET
.0094
.0010
.0176
.126
2.190
.0174
.0118
.0056
.250
SET/SS
.0129
.0090
.0112
.119
4.490
.0258
.0327
.0059
.482
Source: NYDEC, 1999
SET: Settling Tanks
F: Filter
S/S: Self Service Facility
NA: Not Analyzed
September 30, 1999
25
-------
Table A-2. Data from Carwash Samplings in Montana
Parameter
Aluminum, Total
Aluminum, Dissolved
Antimony, Total
Antimony, Dissolved
Arsenic, Total
Arsenic, Dissolved
Barium, Total
Barium, Dissolved
Beryllium, Total
Beryllium, Dissolved
Cadmium, Total
Cadmium, Dissolved
Chromium, Total
Chromium, Dissolved
Copper, Total
Copper, Dissolved
Iron, Total
Iron, Dissolved
Lead, Total
Lead, Dissolved
Manganese, Total
Manganese, Dissolved
Mercury, Total
Mercury, Dissolved
Nickel, Total
Nickel, Dissolved
Selenium, Total
Concentrations
(mg/1)
LibAuto
0.105
0.031
0.003
0.003
O.025
O.025
<1
<1
O.002
O.002
0.0050
0.0044
O.05
0.05
O.5
O.5
0.91
0.44
0.0096
O.0075
0.077
0.072
O.001
O.001
0.05
O.05
0.025
Dano
3.22
0.289
0.004
0.003
O.025
O.025
<1
<1
O.002
O.002
0.0025
0.0025
O.05
0.05
O.5
O.5
3.90
0.53
0.0172
O.0075
0.243
0.202
O.001
O.001
0.05
O.05
0.025
Drinking Water
Standards
mg/1
0.05-0.2
-
0.006
-
0.05
-
2
-
0.004
-
0.005
-
0.1
0.1
1.3
-
0.3
-
0.015
-
0.05
-
0.002
-
0.1
-
0.05
P/S
s
p
p
p
p
p
p
p
p
s
p
s
p
p
p
Health Advisory
Levels
mg/1
-
-
0.003
-
0.002
-
2
-
0.0008
-
0.005
-
0.1
0.1
-
-
-
-
-
-
-
-
0.002
-
0.1
-
-
N/C
N
C
N
C
N
N
N
N
N
September 30, 1999
26
-------
Table A-2. Data from Carwash Samplings in Montana (Continued)
Parameter
Selenium, Dissolved
Silver, Total
Silver, Dissolved
Thallium, Total
Thallium, Dissolved
Zinc, Total
Zinc, Dissolved
Concentrations
(mg/1)
LibAuto
O.025
0.025
0.025
O.001
O.001
<2.5
<2.5
Dano
O.025
0.005
0.005
O.001
O.001
<2.5
<2.5
Drinking Water
Standards
mg/1
0.05
0.1
-
0.002
-
5
-
P/S
P
s
P
s
Health Advisory
Levels
mg/1
-
0.1
-
0.0005
-
2
-
N/C
N
N
Source: USEPA Region 8,1999
* J = Estimated value. Present, but less than the limit of quantitation.
**0.1 Current MCL, 0.08 is the proposed rule for Disinfectants and Disinfection By-products: Total for all THMs combined
cannot exceed the 0.08.
-No standards or advisory levels available.
September 30, 1999
27
-------
Table A-3. Results of Car Wash Samplings in Maryland
Parameter
Chloride (mg/1)
pH (SU)
TPH (mg/1)
Ethylene Glycol (mg/1)
Oil&Grease (mg/1)
Antimony (mg/1)
Arsenic (mg/1)
Beryllium (mg/1)
Cadmium (mg/1)
Chromium (mg/1)
Cyanide (mg/1)
Copper (mg/1)
Iron (mg/1)
Lead (mg/1)
Magnesium (mg/1)
Mercury (mg/1)
Nickel (mg/1)
Selenium (mg/1)
Silver (mg/1)
Sodium (mg/1)
Presto
n
Ford*
134
ND
ND
ND
0.01
6
0.00
8
ND
2.4
0.01
3
14
ND
0.05
5
ND
ND
36
Grimes
Truck Center?
7.0
ND
6.4
Village
Volvo*
1.4-
186
Fuller
ND
Gam-
bacorta*
<.01%
57
Nevi-
aser*
.108
McCoy
6.3
3.9
Attention
to
Detail Auto
Salon, Inc.t
5.9
4.3
9.6
Barrett
3.5
24
Carlto
n
Massey
Inc.*
9.5
-
120
County*
ND
ND
Dave
Wilson*
ND
Frostrom
&
Sons, Inc.*
26.1
Good
News
Salisbury*
13.1-
14.1
Hay ward
Baker
Inc**
9.3
280
ND
Preston
6.82
8
ND
Shipley
Transpor
t***
26
ND
September 30, 1999
28
-------
Table A-3. Results of Car Wash Samplings in Maryland (Continued)
Parameter
Thallium (mg/1)
Zinc (mg/1)
USEPA Method 624
Acetone (mg/1)
Benzene (mg/1)
1 , 4-Dichlorob enzene
(mg/1)
Ethylbenzene (mg/1)
Methylene Chloride
(mg/1)
2-Propanol (mg/1)
Tetrachloroethene
(mg/1)
Toluene (mg/1)
USEPA Method 625
Benzo(b)fluor-anthene
(mg/1)
Bis(2-
ethylhexyl)phthalate
(mg/1)
Butylbenzylphthalate
(mg/1)
1,2-Dichlorobenzene
(mg/1)
Presto
n
Ford*
ND
0.24
Grimes
Truck Centert
AUND
A UNO
Village
Volvo*
Fuller
0.06
1
0.00
9
0.00
9
Gam-
bacorta*
0.004
0.025
0.004
0.046
Nevi-
aser*
0.182
0.022
0.077
0.056
McCoy
All
ND
0.008
5
0.025
0.019
Attention
to
Detail Auto
Salon, 1 IK.
AHND
Barrett
1.6
1
0.016
All
ND
Carlto
n
Massey
Inc.*
0.12
0
0.06
7
0.14
1
County*
All
ND
Dave
Wilson*
All
ND
Frostrom
&
Sons, Inc.*
14.000
Good
News
Salisbury*
Hay ward
Baker
Inc**
AHND
0.086
Preston
0.023
0.002
0.027
Shipley
Transpor
t***
September 30, 1999
29
-------
Table A-3. Results of Car Wash Samplings in Maryland (Continued)
Parameter
1,4-Dichlorobenzene
(mg/1)
Diethylphthalate
Di-n-butylphthalate
Di-n-octylphthalate
(mg/1)
Naphthalene (nig/1)
2-Methylnaphthalene
(mg/1)
Pheneanthrene (mg/1)
1,2,4-
Trimethylbenzene
(mg/1)
Total Xylenes (mg/1)
Presto
n
Ford*
Grimes
Truck Centert
Village
Volvo*
Fuller
0.00
65
0.00
74
Gam-
bacorta*
0.019
0.008
0.140
1.6
0.072
Nevi-
aser*
0.019
McCoy
0.012
0.004
1
Attention
to
Detail Auto
Salon, 1 IK.
Barrett
Carlto
n
Massey
Inc.*
4.62
0
County*
Dave
Wilson*
Frostrom
&
Sons, Inc.*
0.068
0.130
0.057
Good
News
Salisbury*
Hay ward
Baker
Inc**
0.021
0.012
Preston
Shipley
Transpor
t***
Note: For most of these constituents, a blank cell indicates the sample was not analyzed for that parameter. Samples that were reported as having some USEPA Method 624 or 625 constituents
present were analyzed for all constituents in that series. A blank cell under these Methods indicates a ND value for all constituents other than those with values greater than detection limits. If all
parameters in the series were reported as "ND," that is indicated in the main row for each method.
ND = Not detected
*Car dealership and service facilities 'Truck and construction equipment repair facility
"Geotechnical Construction Company 'Vehicle repair, servicing, and cleaning facility
""Maintenance facility for transportation vehicles
September 30, 1999
30
-------
Table A-4. Injectate Quality Data from A&J Suds & Scrub
Libby, Montana
Parameter
Aluminum, Total
Aluminum, Dissolved
Antimony, Total
Antimony, Dissolved
Arsenic, Total
Arsenic, Dissolved
Barium, Total
Barium, Dissolved
Benzene
Beryllium, Total
Beryllium, Dissolved
Bromobenzene
Bromochloromethane
Bromodichloromethane
Bromoform
Bromomethane
n-Butylbenzene
sec-Butylbenzene
tert-Butylbenzene
Cadmium, Total
Cadmium, Dissolved
Carbon Tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
Chloroform
Concentrations
(mg/1)
11/05/97
13
0.494
<0.003
<0.003
<0.025
O.025
<1
<1
NA
<0.002
<0.002
NA
NA
NA
NA
NA
NA
NA
NA
0.0064
0.0064
NA
NA
NA
NA
NA
1/12/98
NA
NA
NA
NA
NA
NA
NA
NA
0.0005
NA
NA
<0.0005
<0.0005
0.0005J *
<0.0005
O.0005
<0.0005
0.0005
0.0005
NA
NA
0.0005
0.0005
O.0005
O.0005
0.015
7/27/98
NA
NA
NA
NA
NA
NA
NA
NA
0.0005
NA
NA
0.0005
0.0005
0.0005
0.0005
O.0005
O.0005
0.0005
0.0005
NA
NA
0.0005
0.0005
O.0005
O.0005
0.009
Drinking Water
Standards*
mg/1
0.05-0.2
-
0.006
-
0.05
-
2
-
0.005
0.004
-
-
-
0.1/0.08*
0.1/0.08*
-
-
-
-
0.005
-
0.005
-
0.1/0.08**
-
0.1/0.08**
P/S
s
p
p
p
p
p
-
p
p
p
p
p
p
Health Advisory
Levels**
mg/1
-
-
0.003
-
0.002
-
2
-
0.1
0.0008
-
-
0.01
0.06
0.4
0.01
-
-
-
0.005
-
0.03
-
0.06
-
0.6
N/C
N
C
N
-
C
C
N
C
C
N
N
C
N
C
September 30, 1999
31
-------
Table A-4. Injectate Quality Data from A&J Suds & Scrub
Libby, Montana (Continued)
Parameter
Chloromethane
2-Chlorotoluene
4-Chlorotoluene
Chromium, Total
Chromium, Dissolved
Copper, Total
Copper, Dissolved
l,2-Dibromo-3-
chloropropane
1 ,2-Dibromoethane
Dibromomethane
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
Dichlorodifluoromethane
1 , 1 -Dichloroethane
1 ,2-Dicholoroethane
1 , 1 -Dichloroethene
cis-1 ,2-Dichloroethene
trans- 1 ,2 -Dichloroethene
1 , 1 -Dichloropropene
1 ,2-Dichloropropane
1 ,3-Dichloropropane
cis-1 ,3-Dichloropropene
trans-1 ,3-Dichloropropene
2,2-Dichloropropane
Concentrations
(mg/1)
11/05/97
NA
NA
NA
0.05
<0.05
<0.5
<0.5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1/12/98
<0.0005
<0.0005
<0.0005
NA
NA
NA
NA
<0.001
O.0005
O.0005
<0.0005
0.0005
O.0005
O.0005
O.0005
O.0005
0.0005
0.0005
O.0005
O.0005
0.0005
0.0005
O.0005
O.0005
0.0005
7/27/98
O.0005
O.0005
0.0005
NA
NA
NA
NA
0.001
O.0005
O.0005
0.0005
0.0005
O.0005
O.0005
O.0005
O.0005
0.0005
0.0005
O.0005
O.0005
0.0005
0.0005
O.0005
O.0005
0.0005
Drinking Water
Standards*
mg/1
-
-
-
0.1
-
1.3
-
-
-
-
0.6
-
0.075
-
-
0.005
0.007
0.07
0.1
-
0.005
-
-
-
-
P/S
p
p
p
p
p
p
p
p
p
Health Advisory
Levels**
mg/1
0.003
0.1
0.1
0.1
-
-
-
-
-
-
0.6
0.6
0.075
1.0
-
0.04
0.007
0.07
0.1
-
0.06
-
-
-
-
N/C
N
N
N
N
N
N
N
N
C
N
N
N
C
September 30, 1999
32
-------
Table A-4. Injectate Quality Data from A&J Suds & Scrub
Libby, Montana (Continued)
Parameter
Ethylbenzene
Fluorotrichloromethane
Hexachlorobutadiene
Iron, Total
Iron, Dissolved
Isopropylbenzene
p-Isopropyltoluene
Lead, Total
Lead, Dissolved
Manganese, Total
Manganese, Dissolved
Mercury, Total
Mercury, Dissolved
Methylene chloride
Naphthalene
Nickel, Total
Nickel, Dissolved
n-Propylbenzene
Selenium, Total
Selenium, Dissolved
Silver, Total
Silver, Dissolved
Styrene
1,1,1 ,2-Tetrachloroethane
1 ,1 ,2,2-Tetrachloroethane
1 ,2,3-Tetrachlorobenzene
Concentrations
(mg/1)
11/05/97
NA
NA
NA
12.5
0.44
NA
NA
0.0453
0.0084
0.474
0.216
0.001
O.001
NA
NA
<0.05
<0.05
NA
<0.025
<0.025
0.005
0.005
NA
NA
NA
NA
1/12/98
O.0005
O.0005
0.0005
NA
NA
O.0005
0.0012
NA
NA
NA
NA
NA
NA
<0005
O.0005J t
NA
NA
0.0005
NA
NA
NA
NA
O.0005
O.0005
0.0005
O.0005
7/27/98
O.0005
O.0005
0.0005
NA
NA
O.0005
0.0005J t
NA
NA
NA
NA
NA
NA
0.00081
0.00056
NA
NA
0.0005
NA
NA
NA
NA
O.0005
O.0005
0.0005
O.0005
Drinking Water
Standards*
mg/1
0.7
-
-
0.3
-
-
-
0.015
-
0.05
-
0.002
-
.005
-
0.1
-
-
0.05
-
0.1
-
0.1
-
-
-
P/S
p
s
p
s
p
p
p
p
s
p
Health Advisory
Levels**
mg/1
0.7
2
0.001
-
-
-
-
-
-
-
-
0.002
-
-
0.02
0.1
-
-
-
-
0.1
-
0.1
0.07
-
-
N/C
N
N
N
N
N
N
N
N
N
September 30, 1999
33
-------
Table A-4. Injectate Quality Data from A&J Suds & Scrub
Libby, Montana (Continued)
Parameter
1 ,2,3-Trichloropropane
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
Tetrachloroethene
Thallium, Total
Thallium, Dissolved
Toluene
1 ,2,4-Trichlorobenzene
1,1,1 -Trichloroethane
1 ,1 ,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes
m+p Xylene
o Xylene
Zinc, Total
Zinc, Dissolved
Concentrations
(mg/1)
11/05/97
NA
NA
NA
NA
O.001
O.001
NA
NA
NA
NA
NA
NA
NA
NA
NA
<2.5
<2.5
1/12/98
<0.0005
<0.0005J t
<0.0005
0.00085
NA
NA
0.0005J t
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005J t
O.OOOSJt
<0.0005
NA
NA
7/27/98
<0.0005
<0.0005
<0.0005
0.00085
NA
NA
0.0021
0.0005
<0.0005
<0.0005
<0.0005
<0.0005
0.00059
0.00059
<0.0005
NA
NA
Drinking Water
Standards*
mg/1
-
-
-
.005
0.002
-
1
0.07
0.2
0.005
-
0.002
10
10
10
5
-
P/S
P
P
P
P
P
P
P
P
P
P
s
Health Advisory
Levels**
mg/1
0.04/0.5
-
-
-
0.0005
-
1
0.07
0.2
0.003
-
0.0015
10
10
10
2
-
N/C
N/C
N
N
N
N
N
C
N
N
N
N
Source: USEPA Region 8,1999
* Drinking Water Standards: P= Primary; S= Secondary.
** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.
NA = Not anlayzed.
-No standards or advisory levels available.
TJ = Estimated value. Present, but less than the limit of quantitation.
*0.1 Current MCL, 0.08 is the proposed rule for Disinfectants and Disinfection By-products: Total for all THMs combined
cannot exceed the 0.08.
September 30, 1999
34
-------
ATTACHMENT B
STATE AND LOCAL PROGRAM DESCRIPTIONS
This section describes the programs of the following nine states that report having 99 percent of
documented wells and 98 percent of estimated wells associated with carwash facilities: Alabama,
California, Iowa, Maine, Maryland, Mississippi, New York, Washington, and West Virginia. In
addition, the New Hampshire and Wyoming programs are described to provide additional examples of
how states control these wells. These 11 states, which have substantially different regulatory structures,
provide a sample of the ways in which carwash wells are controlled. Several are Direct Implementation
states or have incorporated the federal UIC rules by reference. California, New York, and Iowa, all
Direct Implementation states, have state requirements that may supplement USEPA's implementation of
the UIC program with requirements arising from the states' wastewater management program or
pollution discharge elimination program. In addition, Washington has a strong antidegradation policy
that stringently limits injection wells.
Alabama
Alabama is a UIC Primacy state for Class V wells. The Alabama Department of
Environmental Management (ADEM) has promulgated requirements for Class V UIC wells under
Chapter 335 of the Alabama Administrative Code (AAC).
Permitting
The operator of an existing or proposed Class V well must submit a permit application to
ADEM including the following information (335-6-8-. 14(a) through (e) AAC):
Facility name and location;
Name of owner and operator;
Legal contact;
Depth, general description, and use of the injection well; and
Description of pollutant injected, including physical and chemical characteristics.
ADEM is required by the AAC to assess the possibility of adverse impact on a USDW posed
by the well, and to determine any special construction and operation requirements which may be
required to protect a USDW (335-6-8-. 15(1) AAC). If the ADEM determines that the proposed
action may have an adverse impact on a USDW, the applicant may be required to submit a permit
application in the manner prescribed for Class I and Class HI wells. The state requires such
applications to be made on USEPA's Consolidated Permit Application Form 1 and Form 4, which
require the submission of extensive and detailed information. ADEM also has specified the information
required to be submitted in its UIC regulations (335-6-8-.09 (1) through (7) AAC). When those
permit application requirements are applied, as they apparently have been in at least two situations
involving lead contamination from a car wash facility and lead and chromium contamination from an
external truck wash facility, the permit application processing and issuance procedures follow the rules
September 30, 1999 35
-------
for Class I and IE wells (335-6-8-. 15(2) AAC). The AAC specifies that "Class V wells may be
allowed insofar as they do not cause a violation of primary drinking water regulations under 40 CFR
Part 142" (335-6-8-.07 AAC). At present, an unknown number of wells, including car wash wells, in
the state are not permitted.
Siting and Construction Requirements
Class V wells are specifically exempted from the siting and construction requirements (found in
335-6-8-.20 through 335-6-S-.24) pertaining to Class I and HI wells (335-6-S-.25 AAC). The wells
are required to be constructed in such a manner that they may not cause a violation in USDWS of
primary drinking water regulations (defined as 40 CFR Part 142). When required by ADEM, new
Class V wells must be constructed by a well driller licensed by ADEM (335-6-S-.25 AAC). The state
requires facilities seeking permits for industrial wells to submit construction plans and well specifications
prior to permit approval, but construction requirements may differ depending on the proposed injectate.
Operating Requirements
Class V wells must be operated in a manner that may not cause violation of primary drinking
water regulations under 40 CFR 142. ADEM may order the operator to take necessary actions to
prevent violation, including closure of the well (33 5-6-8-. 16 AAC).
A method of obtaining grab and composite samples of pollutants after all pretreatment and prior
to injection must be provided at all sites. Spill prevention and control measures sufficient to protect
surface and ground water from pollution must be taken at all sites (335-6-S-.22 AAC).
Monitoring requirements may be specified in the permit, by administrative order, by directive,
or included in the plugging and abandonment plan (335-6-8-.2S AAC). Two car wash wells that have
had known contamination incidents are required to conduct monthly monitoring.
Plugging and Abandonment
A plugging and abandonment plan may be required by permit or administrative order. If
necessary it may be required to include aquifer cleanup procedures. If pollution of a USDW is
suspected, ground water monitoring may be required after well abandonment (335-6-S-.27 AAC).
California
USEPA Region 9 directly implements the UIC program for Class V injection wells in
California. The California Water Quality Control Act (WQCA), however, establishes broad
requirements for the coordination and control of water quality in the state, sets up a State Water Quality
Control Board, and divides the state into nine regions, with a Regional Water Quality Control Board
that is delegated responsibilities and authorities to coordinate and advance water quality in each region
(Chapter 4 Article 2 WQCA). A Regional Water Quality Control Board can prescribe requirements
September 30, 1999 36
-------
for discharges (waste discharge requirements or WDRs) into the waters of the state (13263 WQCA).
These WDRs can apply to injection wells (13263.5 and 13264(b)(3) WQCA). In addition, the
WQCA specifies that no provision of the Act or ruling of the state board or a regional board is a
limitation on the power of a city or county to adopt and enforce additional regulations imposing further
conditions, restrictions, or limitations with respect to the disposal of waste or any other activity which
might degrade the quality of the waters of the state (13002 WQCA).
Permitting
Although the Regional Water Quality Control Boards do not permit injection wells, the WQCA
provides that any person operating, or proposing to operate an injection well (as defined in §13051
WQCA) must file a report of the discharge, containing the information required by the regional board,
with the appropriate regional board (13260(a)(3) WQCA). Furthermore, the regional board, after
any necessary hearing, may prescribe requirements concerning the nature of any proposed discharge,
existing discharge, or material change in an existing discharge to implement any relevant regional water
quality control plans. The requirements also must take into account the beneficial uses to be protected,
the water quality objectives reasonably required for that purpose, other waste discharges, and the
factors that the WQCA requires the regional boards to take into account in developing water quality
objectives, which are specified in §13241 of the WQCA ((13263(a) WQCA). However, a regional
board may waive the requirements in 13260(a) and 13253(a) as to a specific discharge or a specific
type of discharge where the waiver is not against the public interest (13269(a) WQCA).
California counties take a variety of approaches to regulation of carwash and similar types of
wells. Some counties prohibit these wells. For example, Merced County prohibits the construction of
"dry/drainage" wells, defined as a well constructed for the purpose of disposing of waste water,
hazardous material, or drainage water unless it can be shown that the quality of the water being
introduced into the well will not have an undesirable impact on ground water and/or the well's
construction will not permit the intermixing of aquifers or provide a conduit for the vertical movement of
known or potential contaminants (Merced County Code, 9.28.060B.1). This authority has generally
prohibited such wells in Merced County. Santa Clara County prohibits "sewer wells, cesspools,
seepage pits, and similar excavations" as a public nuisance (Santa Clara County Health and Safely
Code B11-20). Other counties regulate such wells under their County Water Quality Ordinances.
Yolo County, for example, defines industrial liquid waste treatment system as wastes, excluding human
wastes, from any producing, manufacturing, or processing operation of whatever nature (Yolo County
Code 6-8.409) and provides that all industrial waste discharges must be carried out according to
standards and conditions established by the County Board of Supervisors (Code 6-8.604). Riverside
County addresses the topic in its Plumbing Code.
Iowa
USEPA Region 7 directly implements the UIC program for Class V injection wells in Iowa. In
addition, the state has enacted regulations addressing on-site wastewater treatment and disposal
systems that collect, store, treat, and dispose of wastewater from four or fewer dwelling units or other
September 30, 1999 37
-------
facilities (e.g., commercial facilities) serving the equivalent of 15 persons (1,500 gallons per day (gpd)
or less) (Chapter 567-69 Iowa Administrative Code (IAC)). An on-site wastewater treatment and
disposal system is defined in these rules as a system that includes domestic waste whether residential or
nonresidential, "but does not include industrial waste of any flow rate" (567-69.1(2) IAC). Generally,
therefore, unless it can be shown clearly to be only sanitary waste, car wash wastewater would be
banned from disposal in these systems.
Mississippi
Mississippi is a UIC Primacy state for Class V wells. The state's wastewater permit
regulations provide that unless otherwise required, owners or operators of Class V wells and all
applicants for UIC permits shall comply with 40 CFR 144, 146, 147.1250 subpart Z, and 148, which
are incorporated and adopted by reference (Wastewater Permit Regulations IVK.2.e. and IV.K.3).
For Class V wells associated with carwashes, no additional requirements or exceptions have been
enacted. Therefore, the requirements in 40 CFR apply.
New \brk
USEPA Region 2 directly implements the UIC program for Class V injection wells in New
York. However, under the state's Environmental Conservation Law, the Department of Environmental
Conservation, Division of Water Resources (DWR) has promulgated regulations in the State Code
Rules and Regulations, Title 6, Chapter X, Parts 703, 750, 754, and 756. These regulations establish
water quality standards and effluent limitations, create a state pollutant discharge elimination system
requiring permits for discharges into the waters of the state (including ground water), specify that such
discharges must comply with the standards in Part 703, and provide for monitoring in Part 756.
Permitting
Applications for a SPDES permit, which are required for discharges to ground water, must
describe the proposed discharge, supply other requested information, and are subject to public notice.
SPDES permits must ensure compliance with effluent limitations and standards, and will include
schedules of compliance, monitoring requirements, and records and reports of activities (Parts 751 -
756).
Operating Requirements
Effluent limits (Part 703) in the SPDES permit must be met. Monitoring and reporting
requirements in the SPDES permit must be met.
Washington
Washington is a UIC Primacy state for Class V UIC wells. Chapter 173-218 of the
Washington Administrative Code (WAC) establishes the underground injection control program.
September 30, 1999 38
-------
Under the program, the policy of the Department of Ecology is to maintain the highest possible
standards to prevent the injection of fluids that may endanger ground waters which are available for
beneficial uses or which may contain fewer than 10,000 mg/1 TDS. Consistent with that policy, all new
Class V injection wells that inject industrial, municipal, or commercial waste fluids into or above a
USDW are prohibited (172-218-090( 1) WAC ). Existing wells must obtain a permit to operate.
Permitting
A permit must specify conditions necessary to prevent and control injection of fluids into the
waters of the state, including all known, available, and reasonable methods of prevention, control, and
treatment. It also must specify conditions to satisfy applicable requirements in 40 CFR Parts 124, 144,
146 and any other conditions necessary to preserve and protect USDWS. Any injection well that
causes or allows the movement of fluid into a USDW that may result in a violation of any primary
drinking water standard under 40 CFR Part 141 or that may otherwise adversely affect the beneficial
use of a USDW is prohibited (173-218-100 WAC).
Siting and Construction
The state has promulgated minimum standards for construction and maintenance of wells (173-
160-010 through -560 WAC). However, injection wells regulated under Chapter 173-218 are
specifically exempted from these constructions standards (173-160-010(3)(e) WAC).
Operating Requirements
The water quality standards for ground waters establish an antidegradation policy. The
injectate must meet the state ground water standards at the point of compliance (173-200-030 WAC).
Plugging and Abandonment
All wells not in use must be securely capped so that no contamination can enter the well
(173-160-085 WAC).
West Virginia
West Virginia is a UIC Primacy state for Class V wells. Regulations establishing the UIC
program are found in Title 47-13 West Virginia Code of state Regulations. The state does not identify
a separate category of Class V industrial wells, but does specify that Class V includes injection wells
not included in Classes I, II, III, or IV (47-13-3.4.5. WVAC).
September 30, 1999 39
-------
Permitting
Class V injection wells are authorized by rule unless the Office of Water Resources of the
Division of Environmental Protection requires an individual permit (47'-13-12.4. a. and 47-13-13.2
WVAC). Injection is authorized initially for five years under the permit by rule provisions.
Operating Requirements
Owners or operators of Class V wells are required to submit inventory information describing
the well, including its construction features, the nature and volume of injected fluids, alternative means of
disposal, the environmental and economic consequences of well disposal and its alternatives, operation
status, and location and ownership information (47-13-12.2 WVAC).
Rule-authorized wells must meet the requirements for monitoring and records (requiring
retention of records pursuant to 47-13-13.6.b. WVAC concerning the nature and composition of
injected fluids until 3 years after completion of plugging and abandonment); immediate reporting of
information indicating that any contaminant may cause an endangerment to USDWS or any malfunction
of the injection system that might cause fluid migration into or between USDWS; and prior notice of
abandonment.
The rules enact a general prohibition against any underground injection activity that causes or
allows the movement of fluid containing any contaminant into a USDW, if the presence of that
contaminant may cause a violation of any primary drinking water regulations under 40 CFR Part 142 or
promulgated under the West Virginia Code, or may adversely affect the health of persons. If at any
time a Class V well may cause a violation of the primary drinking water rules the well may be required
to obtain a permit or take such other action, including closure, that will prevent the violation (47-13-
13.1 WVAC). Inventory requirements for Class V wells include information regarding pollutant loads
and schedules for attaining compliance with water quality standards (47-13-13.2.d.l WVAC).
For protection of a USDW, the injection operation may be required to satisfy requirements,
such as for corrective action, monitoring and reporting, or operation, that are not contained in the UIC
rules (47-13-13.2.C.1.C. WVAC).
Mechanical Integrity
Only a Class V well required to obtain an individual permit will be required to demonstrate that
the well exhibits mechanical integrity.
Plugging and Abandonment
A Class V well required to obtain an individual permit will be subject to permit conditions
pertaining to plugging and abandonment to ensure that the plugging and abandonment of the well will
September 30, 1999 40
-------
not allow the movement of fluids either into a USDW or from one USDW to another. A plan for
plugging and abandonment will be required.
Maryland
Maryland is a UIC Primacy state for Class V wells. Business inquiries to discharge vehicle
wash water to surface waters are often referred to the Maryland Department of Environment's Ground
Water Permits Division by the National Pollutant Discharge Elimination System (NPDES) program.
This action is taken because vehicle wash water has historically failed the biomonitoring testing required
by the NPDES program. The failure is thought to be caused by surfactants in the wash water (Eisner,
1999).
Permitting
Under the Code of Maryland Regulations (COMAR 26.08.02) any discharge or disposal of
waters or wastewaters into the underground waters of the state requires a discharge permit (COMAR
26.08.02.09A.(1)). The Code also provides that dischargers or potential dischargers to ground waters
may be required to monitor ground or surface waters in a manner and frequency and at locations
specified by the Maryland Department of the Environment (COMAR 26.08.02.09.D(4)). The Code
defines three aquifer types, and specifies discharge quality criteria for each type (COMAR
26.08.02.09C). Discharges to ground water may not result in degradation of ground waters below the
criteria established, nor may discharges to an aquifer of specific classification result in pollution of an
aquifer possessing higher quality criteria. For Type I aquifers, discharges may not exceed Maryland's
primary or secondary standards for drinking water, and for Type n aquifers the constituents may not,
after treatment, exceed primary or secondary drinking water standards, except for TDS (COMAR
26.08.02.09C). The underground injection of hazardous wastes is prohibited (COMAR 26.13.05.18).
A separate ground water discharge permit is not required if an underground injection permit has been
issued under COMAR 26.08.07 or if the subsurface disposal system is covered by a general permit
under COMAR 26.08.04.07 (COMAR 26.08.02.09A(3)(d) and (4)). Maryland has adopted by
reference the federal UIC regulations (COMAR 26.08.07.01), and does not require a UIC permit for
Class V wells (COMAR 26.08.07.01B).
Under these authorities, the Maryland Department of the Environment's Wastewater Permits
Program issues Ground Water Discharge Permits for exterior vehicle washing if the wastewater is
discharged to the ground surface or to the subsurface via disposal systems such as drainfields or
drywells. Effluent testing is required to support the permit application and is required throughout the life
of the permit. Testing for total petroleum hydrocarbons (TPH) is required, typically on a monthly or
quarterly basis. The sampling point is typically located at the point of discharge, after treatment and
prior to discharge to a drainfield or dry well. In some cases, vehicle wash water may mix with domestic
wastewater in the facility's septic tank prior to discharge. Permits issued for self-service washing
facilities have historically required quarterly VOC testing and posting of signs in the wash bays to
educate the public (Eisner, 1999).
September 30, 1999 41
-------
Operating Requirements
Monthly or quarterly testing for TPH is required, with a technology-based effluent limit of 15
mg/1. Treatment is typically an oil/water separator, for which there are maintenance requirements in the
facility's permit. Engine and undercarriage cleaning and the use of solvents are strictly prohibited. The
permits encourage pollution prevention by using hot water without detergents for washing. Finally, all
material safety data sheets are reviewed for any detergents or additives used (Eisner, 1999).
Maine
Maine is a UIC Primacy state for Class V wells. The Maine Department of Environmental
Protection administers the UIC program, with support from USEPA Region 1. Title 38 of the Maine
Revised Statutes Annotated (MRSA) establishes, among other programs, the state's ground water
protection program (38 MRSA §§ 401-404), pollution control program, including waste discharge
licensing provisions (38 MRSA §413), and ground water classification standards (38 MRSA §465-C).
Rules controlling the subsurface discharge of pollutants by well injection implemented by the
Department of Environmental Protection are found in 06 Code of Maine Regulations (CMR) Chapter
543.
Licensing
The rules controlling subsurface discharge of pollutants by well injection provide that all
subsurface discharges of fluids into or through a well are prohibited except as authorized in accordance
with the rules. The state recognizes five classes of wells, reflecting the definitions adopted by the
federal UIC program. Any subsurface discharge into or through a Class V well that would cause or
allow the movement of fluid into a USDW that may result in a violation of any Maine Primary Drinking
Water Standard, or which could otherwise adversely affect human health, is prohibited (06-
096.543.3.D CMR). The state designates ground water as either Class GW-A (for use as public
drinking water supplies) or Class GW-B (for uses other than drinking water supplies). However, no
ground water to date has been classified as GW-B. The Primary Drinking Water Standards are set
forth in Department of Human Services rules in 10-144 A CMR 231. Class V wells must obtain a
waste discharge license issued under 38 MRSA §413 (1-B) prior to the commencement of the
discharge. Wells that are already discharging may be permitted, depending on the characteristics of the
injectate.
Class V wells also can be redesignated or subject to additional regulatory requirements. Any
Class V well receiving toxic or hazardous compounds is redesignated as a Class IV well and, as such,
is prohibited. The rules controlling the subsurface discharge of pollutants also note that the Maine
Hazardous Waste, Septage, and Solid Waste Management Act (38 MRSA § 1301 et seq.) or the Site
Location of Development Act (38 MRSA § 481 et seq.) could apply to certain Class V wells.
September 30, 1999 42
-------
New Hampshire
New Hampshire is a UIC Primacy state for Class V wells.
Operating Requirements
New Hampshire requires that Ambient Ground Water Quality Standards be met and
maintained. Facilities are required to comply with the state's Best Management Rule (Env-Ws 421).
Owners and operators may register or permit their wells and are required to sample and test effluent
and ground water (Locker, 1999).
Carwashes in New Hampshire have four options to assist in protecting ground water:
Operate a closed-loop system with wastewater recycling. Discharges must be disposed of at
an approved disposal facility (i.e., a wastewater treatment plant or hazardous waste facility,
depending upon the nature of the recycled water).
Discharge wastewater to a sanitary sewer. The owner of the facility must contact the local
sewer authority to obtain approval.
Obtain a ground water discharge permit. The ground water discharge well must be permitted in
accordance with Env-Ws 1504, and wastewater is treated to ambient ground water standards.
If the facility washes fewer than 30 cars per week, the facility can indirectly discharge water to
ground water through surface discharge. Facilities can only dispose of wastewater in this
manner if their wastewater meets very strict criteria (e.g., does not contain hazardous
contaminants; has been treated with an oil-water separator; is not from power washing, steam
cleaning, engine cleaning or undercarriage cleaning; etc.).
Wyoming
Wyoming is a UIC Primacy state for Class V wells. Chapter 16, Wyoming Water Quality
Rules and Regulations, requires an individual UIC permit for all carwash wells (WYDEQ/WQD).
Permitting
Carwash permits issued in Wyoming include the following sections:
Discharge zone and area of review, specifying the aquifer into which injection is allowed to take
place.
Ground water classification, describing the classification, under state regulations, of the
receiving aquifer and nondegradation requirements.
Authorized operations, describing the volume and pressure of the injection activities.
Environmental monitoring program for ground waters of the state, describing the monitoring
activities that the UIC well owner/operator must perform.
Requirements for monitoring the discharge, describing the monitoring and reporting schedule.
September 30, 1999 43
-------
Records and reports, describing the timeframe for keeping records and annual reporting
requirements.
General permit conditions, describing the review period for permits and specifying what actions
constitute permit violations.
Duties of the permittee, describing actions the owner or operator should take to comply with
the permit conditions.
Signatories requirement, describing who must sign the permit.
September 30, 1999 44
-------
REFERENCES
Arkansas Department of Pollution Control and Ecology (ADPC&E). 1996. Application Procedures
for a No-Discharge Water Pollution Control Permit. June 21, 1996.
The Cadmus Group. 1999. State-by-State Notebooks Compiling Results from the Class V
Underground Injection Control Study. February 1, 1999.
Locker, M. 1999. New Hampshire Department of Environmental Services. Telephone conversation
with Stephanie Barrett, ICF Consulting. July 27, 1999.
Maryland Department of the Environment (MDOE). 1999. Memorandum from Michael Eisner,
Maryland Department of the Environment, to Anhar Karimjee, Office of Water, transmitting comments
on Class V Study reviews. June 21, 1999.
New York State Department of Environmental Conservation (NYDEC). 1996. Guidance
Memorandum on "Vehicle Washing with Plain Water to Regional Water Engineers from Warren Lavery,
Director, Bureau of Permits. November 4, 1996.
New York State Department of Environmental Conservation (NYDEC). 1999. Email from William
Spitz, New York State Department of Environmental Conservation, to Robyn Delehanty, USEPA
Office of Water, transmitting injectate data for carwashes and laundromats. March 10, 1999.
North Carolina Department of Environment, Health, and Natural Resources. 1997. "Waste
Minimization." February 1997.
Space, C. 1998. Southwest Carwash Association. Telephone Conversation with Scott Flines, ICF
Consulting. September 1, 1998.
State of Tennessee Department of Environment and Conservation (TDEC). 1995. Letter from Robin
J. Bell to Rhudy Johnson approving Class V Authorization application for discharge of car wash waste
water from Buggy Bath Car Wash, Roan Mountain, Tennessee. August 29, 1995.
USEPA. 1980. Development Document for Effluent Limitations Guidelines and Standards for
the Auto and Other Laundries Point Source Category. Washington, D.C. OMB 0704-0188.
October 1980.
USEPA. 1987. Report to Congress: Class V Injection Wells. Office of Water. Washington, D.C.
EPA570/9-87-006. September 1987.
USEPA. 1992. Class VBMP Fact Sheet Number 3. Office of Water. Washington, D.C. USEPA
570/9-91-036L. January 1992.
September 30, 1999 45
-------
USEPA. 1994. Underground Injection Control Inspector Training Manual. Washington, D.C.
September 1994.
USEPA. 1998. Public Comments on the July 29, 1998 Proposed Revisions to the Class V UIC
Regulations: Comment Excerpts Sorted by Issue Category. December 9, 1998.
USEPA Region 8. 1999. Correspondence from Douglas Mnter, USEPA Region 8, to Robyn
Delehanty, USEPA Office Water, transmitting sampling data for automotive and industrial Class V
wells. March 3, 1999.
Washington State Department of Ecology (ECOL). 1995. Vehicle and Equipment Washwater
Discharges: Best Management Practices Manual. Publication Number WQ-R-95-56. Olympia,
Washington: Washington State Department of Ecology. June 1995.
Wyoming Department of Environmental Quality/Water Quality Division (WYDEQ/WQD). 1999.
Memorandum from Robert Lucht, Wyoming DEQ/WQD, to Amber Moreen, USEPA Office of
Water, on Review of Class V Study documents. July 12, 1999.
September 30, 1999 46
------- |