United States Office of Ground Water EPA/816-R-99-014h
Environmental and Drinking Water (4601) September 1999
Protection Agency
The Class V Underground Injection
Control Study
Volume 8
Wells That Inject Fluids From
Laundromats Without Dry Cleaning
-------
Table of Contents
Page
1. Summary 1
2. Introduction 2
3. Prevalence of Wells 3
4. Wastewater Characteristics and Injection Practices 5
4.1 Injectate Characteristics 5
4.2 Well Characteristics 9
4.3 Operational Practices 9
5. Potential and Documented Damage to USDWs 9
5.1 Injectate Constituent Properties 9
5.2 Observed Impacts 10
6. Best Management Practices 10
7. Current Regulatory Requirements 10
7.1 Federal Programs 10
7.1.1 SDWA 10
7.1.2 CWA 11
7.2 State and Local Programs 12
Attachment A: Injectate Quality Data for Wells That Inject Fluid from Laundromats Without Dry
Cleaning 14
Attachment B: State and Local Program Descriptions 18
References 24
September 30, 1999
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WELLS THAT INJECT FLUIDS FROM LAUNDROMATS
WITHOUT DRY 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 8, covers Class V wells
that inject fluids from laundromats without dry cleaning.
1. SUMMARY
Wells used to inject fluids from laundromats where no onsite dry cleaning is performed or
where no organic solvents are used for laundering are classified as "laundromat wells" for the purpose
of this study. These wells are located throughout the U.S. and can be found at coin-operated
laundromats.
The characteristics of the fluids drained into these wells are similar to those of grey water from
household washing machines. The limited data that are available from coin-operated washers indicate
that none of the primary drinking water maximum contaminant levels (MCLs) or health advisory levels
(HALs) are exceeded by laundromat washwater injectate. However, the injectate has exceeded the
secondary MCLs for pH and total dissolved solids (TDS).
It is not a typical practice to locate laundromat wells in injection zones with specific geologic
characteristics (laundromat wells do not tend to be located in areas with karst, fractured bedrock, or
any other particular kind of subsurface feature).
Although there are no reported contamination incidents associated with laundromat wells, some
wells may to be vulnerable to spills or illicit discharges. For instance, the unsupervised nature of coin-
operated laundromats may make Class V wells at those facilities susceptible to contamination due to
laundering of contaminated articles. For instance, an individual may wash highly contaminated articles,
such as solvent-soaked or oily rags, that may result in increased contaminant concentrations in the wash
water. As another example, it is reasonable to expect that any sinks or floor drains at the facility, which
also may receive minor spills, would be hooked into the same plumbing system that collects and
transfers wash water to the injection well.
The inventory results for laundromat wells are very uncertain because most responses to the
state and USEPA Regional survey conducted for this study did not distinguish laundromat wells from
other kinds of commercial or industrial wells. These results suggest that there are less than 700
documented laundromat wells in the U.S. The wells are documented in 12 states, with Alabama, West
September 30, 1999
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Virginia, New %rk, Mississippi, and Iowa providing the highest estimates (collectively, these five
states account for more than 90 percent of the estimated national inventory). Although many states
estimate numbers of wells much higher than the numbers documented, most are unsure of the exact
number of wells.
States with the majority of documented or estimated laundromat wells are implementing various
kinds of regulatory programs to address these wells. Alabama and New "fork issue individual permits.
Individual permits are also sometimes required in West Virginia. However, in Iowa, Mississippi, and
West Virginia, the wells are permitted by rule; that is, as long as owners and operators meet certain
requirements, they are allowed to operate a laundromat well.
2. INTRODUCTION
Using the existing list of Class V well types in 40 CFR §146.5(e), laundromat wells could be
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,
laundromat wells were considered to be industrial process water and waste disposal (5W20) wells
(USEPA, 1987).
On July 29, 1998 (63 FR 40586), USEPA proposed revisions to the Class V UIC regulations
that would add new requirements for the following three types of wells that, based on available
information, were believed to pose a high risk to USDWs when located in ground water-based source
water protection areas: motor vehicle waste disposal wells, industrial wells, and large-capacity
cesspools. All other types of Class V wells are to be studied further to determine whether they warrant
additional UIC regulation.
In the July 29, 1998 notice, USEPA proposed to include "wells used to inject fluids from
laundromats where no dry cleaning is performed or where no organic solvents are used for laundering"
within the "other industrial" well category. * Such wells would be excluded from the more stringent
regulations proposed for high-risk industrial wells. This approach was proposed because USEPA
believed that laundromat wells, when defined in this narrow way, pose a lower risk than the wells that
would be regulated under the proposal, because they inject wastewaters containing primarily water-
soluble cleaners and normal laundry dirt, similar to domestic washing machines. This volume examines
laundromat wells excluded from the July 29, 1998 proposal to help USEPA make more informed
decisions about this type of Class V well.
1 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 UIC Study.
September 30, 1999
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Wells used to inject wastewater from laundries 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). Because most dry cleaners generate hazardous waste, by virtue of the perchloroethylene that
is commonly used as a solvent, disposal of wastewater from dry cleaners in Class V wells is generally
prohibited by the existing UIC regulations.
Facilities of interest for this study are coin-operated laundromats, which are typically self-
service facilities that anyone can use. For the most part, the washing machines used, the detergents
used, and the items washed in such "coin-ops" are the same as in a typical private home scenario,
resulting in wastewater that is essentially identical to that from a household washing machine. However,
there is a potential for people to use coin-ops to wash small loads of commercial items or unusually
contaminated household items (e.g., towels or rugs soaked by spills), which are more typically washed
at industrial laundries.
3. PREVALENCE OF WELLS
For this study, data on the number of Class V laundromat 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 laundromat 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 laundromat wells.
As indicated in the table, the documented number of wells at laundromats without dry cleaning in
the U.S. is relatively low (less than 700); however, states and USEPA Regions estimate that many
more of these wells actually exist. The largest numbers are thought to exist in Mississippi and Iowa,
which estimate 820 and 1,000 wells, respectively. (The estimated number in New York is 1,000, but
includes not only laundromat wells, but also the three other kinds of wells included in the "other
industrial" well category.) Although many other states also estimate numbers of wells much higher than
the numbers documented, most are unsure of the exact number of wells. In many cases, all of the
"other industrial" wells are inventoried and laundromat wells are a subset of this category, yet state staff
are unable to differentiate the laundromat wells from others in the inventory.
September 30, 1999
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Table 1. Inventory of Wells at Laundromats Without Dry cleaning in the U.S.
State
Documented
Number of \\fells
Estimated Number of \\fells
Number
Source of Estimate and Methodology1
USEPA Region 1
MA
ME
9
80
>9
<80
State staff suspect more wells exist in MA than documented.
State staff suspect fewer wells exist in ME than documented.
USEPA Region 2
NJ
NY
VI
<28
<174
0
<28
1,000
50
N/A
Best professional judgement.
Region estimate based on review of inspection reports and
business directory.
USEPA Region 3
WV
<223
>223
Best professional judgement.
USEPA Region 4
AL
FL
MS
TN
<162
4
6
2
>162
>4
820
>2
State staff estimate that more than the documented number of
other industrial wells exist.
State staff suspect more wells exist, but no statewide
inventory is available.
Best professional judgement, based on 10 laundromats without
dry cleaning per county times 82 counties.
State staff suspect more wells exist in TN than documented.
USEPA Region 5
MI
WI
4
4
4
>4
N/A
State staff suspect more wells exist in WI than documented.
USEPA Region 6 - None
USEPA Region 7
IA
N/A
1,000
Best professional judgement, based on ten years of IA
experience and discussions with trade organizations and
county sanitarians.
USEPA Region 8
MT
0
10
Estimate based on USEPA Region 8 records.
September 30, 1999
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Table 1. Inventory of Wells at Laundromats Without Dry cleaning in the U.S.
(Continued)
State
Documented
Number of \\fells
Estimated Number of \\fells
Number
Source of Estimate and Methodology1
USEPA Region 9
CA
HI
NV
0
4
0
50
4
10-20
Best professional judgement.
N/A
Best professional judgement and gross estimates.
USEPA Region 10
AK
OR
0
0
10
15
Best professional judgement.
N/A
All USEPA Regions
All States
<700
> 3,495
Many of the estimated numbers are for all types of "other
industrial" wells, of which laundromat wells are only a subset.
Total estimated number counts the documented number when
the estimate is NR.
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.
A representative of the Coin Laundry Association estimates that there are approximately
30,000 coin-operated laundromats nationwide. Most of these laundromats discharge their wastewater
directly to the local sewer system. In fact, the Coin Laundry Association estimates that only about 100
laundromats discharge to a septic system, which is considered a Class V well (Vassalydes, 1998).
4. WASTEWATER CHARACTERISTICS AND INJECTION
PRACTICES
4.1 Injectate Characteristics
Given that coin-operated laundries are used by most customers to launder their household items
and clothing, the wastewater from these sites is expected to be very similar to the "greywater" resulting
from washing machines in homes. Greywater is defined as the wastewater produced from baths and
showers, clothes washers, and lavatory sinks (as opposed to the wastewater generated by toilets,
kitchen sinks, and dishwashers, which is called "blackwater") (Agriboard Industries, 1998).
Very little quantitative information is available on the characteristics of laundromat well injectate.
States often do not request sampling and analysis of injectate at these establishments. The limited
September 30, 1999
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information and injectate data available on laundromat wells is discussed below It includes analytical
data from nine coin-operated laundromats in New York and data from three sampling events at a
combination carwash and laundromat in Libby, Montana. The data from New York were received by
USEPA in 1999, and the Montana sampling events took place in 1997 and 1998.
In New York, many of the laundromats engage in self sampling and analysis. However, the
New York State Department of Environmental Conservation sampled several coin-operated
laundromats in Suffolk and Nassau counties. Table 2 displays the discharge data for these
laundromats, compared to applicable drinking water MCLs and HALs.
Table 2. Discharge Data for Coin-Operated Laundromats in New \brk
Paramete
r
pH (SU)
TSS (mg/1)
TDS (mg/1)
Oil&
Grease
(mg/1)
MB AS
(mg/1)
Treatment Type
F&C
9
4
167
3
0.31
F&C
NA
27
604
<5
16.4
F&DAF
7
28
1130
<5
50.1
Non
e
NA
40
NA
<5
50.1
Non
e
NA
42
382
<5
47
M/C
NA
<5
NA
<5
0.92
Non
e
9.1
8
726
<10
75
C&R
NA
21
NA
<5
22.9
C&R
NA
30
NA
6.3
2
Drinking
Vtoter
Standards
mg/
1
6.5-
8.5
-
500
_
_
P/
S
S
s
Health
Advisory
Levels
mg/
1
-
-
-
_
_
N/C
Source: New York Department of Environmental Conservation, 1999.
Treatment Types: F&C: Filters and Carbon F&DAF: Flocculation and Dissolved Air Flotation
M/C: Membrane/Carbon C&R: Chemical and Resin
* Drinking Water Standards: P= Primary; S= Secondary.
** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.
- No standards or advisory levels available.
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 laundromat well
injectate. Table 3 summarizes the water quality data for injectate sampled at A&J Suds and Scrub.
The complete data set is included as Table A-l in Attachment A of this volume.
The data shown in Table 2 indicate that, even after treatment, fluids injected into laundromat
wells have exceeded secondary MCLs for pH and TDS. In particular, two pH levels were 9 and 9.1,
September 30, 1999
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Table 3. Summary of Injectate 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
Dichlorodifluoromethane
1 ,2-Dicholoroethane
1 , 1 -Dichloroethene
cis-1 ,2-Dichloroethene
trans- 1 ,2 -Dichloroethene
1 ,2-Dichloropropane
Ethylbenzene
Fluorotrichloromethane
Hexachlorobutadiene
Concentrations
(mg/1)
11/05/97
13
<0.003
<0.025
<1
NA
<0.002
NA
NA
NA
0.0064
NA
NA
NA
NA
NA
NA
0.05
0.5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1/12/98
NA
NA
NA
NA
0.0005
NA
O.OOOSJf
O.0005
0.0005
NA
0.0005
O.0005
0.015
O.0005
0.0005
O.0005
NA
NA
O.0005
O.0005
O.0005
0.0005
O.0005
O.0005
O.0005
0.0005
0.0005
O.0005
O.0005
O.0005
7/27/98
NA
NA
NA
NA
0.0005
NA
O.0005
O.0005
0.0005
NA
0.0005
O.0005
0.009
O.0005
0.0005
O.0005
NA
NA
O.0005
O.0005
O.0005
0.0005
O.0005
O.0005
O.0005
0.0005
0.0005
O.0005
O.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 J
0.1/0.08 J
-
0.005
0.005
0.1/0.08 J
0.1/0.08 J
-
-
-
0.1
1.3
0.6
-
0.075
-
0.005
0.007
0.07
0.1
0.005
0.7
-
-
P/S
s
p
p
p
p
p
p
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
1.0
0.04
0.007
0.07
0.1
0.06
0.7
2
0.001
N/C
N
C
N
C
C
C
C
N
N
C
N
C
N
N
N
N
N
N
N
N
C
N
N
N
C
N
N
N
September 30, 1999
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Table 3. Summary of Injectate Quality Data from A&J Suds & Scrub, Libby, Montana
(Continued)
Parameter
Iron, Total
p-Isopropyltoluene
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
Xylenes
m+p Xylene
o Xylene
Zinc, Total
Concentrations
(mg/1)
11/05/97
12.5
NA
0.0453
0.474
O.001
NA
NA
<0.05
<0.025
0.005
NA
NA
NA
NA
0.001
NA
NA
NA
NA
NA
NA
NA
NA
<2.5
1/12/98
NA
0.0012
NA
NA
NA
<0005
O.OOOSJf
NA
NA
NA
0.0005
O.0005
O.0005
0.00085
NA
O.OOOSJf
O.0005
O.0005
0.0005
O.0005
O.OOOSJf
O.OOOSJf
0.0005
NA
7/27/98
NA
0.0005J f
NA
NA
NA
0.00081
0.00056
NA
NA
NA
0.0005
O.0005
O.0005
0.00085
NA
0.0021
O.0005
O.0005
0.0005
O.0005
0.00059
0.00059
0.0005
NA
Drinking Water
Standards (*)
mg/1
0.3
-
0.015
0.05
0.002
0.005
-
0.1
0.05
0.1
0.1
-
-
0.005
0.002
1
0.07
0.2
0.005
0.002
10
10
10
5
P/S
s
p
s
p
p
p
p
s
p
p
p
p
p
p
p
p
p
p
p
s
Health Advisory
Levels (**)
mg/1
-
-
-
-
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
10
10
10
2
N/C
N
N
N
N
N
N
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.
f Estimated value. Present, but less than the limit of quantitation.
J 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 0.08.
- No standards or advisory levels available.
September 30, 1999
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compared to the upper end of 8.5 for the secondary MCL. Three measurements of TDS levels
exceeded the secondary MCL.
At the A&J Suds and Scrub facilty, several of the metals were reported above the MCLs:
aluminum, cadmium, iron, lead, and manganese (see Table 3). 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
No information on the design characteristics of laundromat wells is available.
4.3 Operational Practices
Laundromat wells are generally owned and operated by small laundromats. The only other
information available on operational practices is that lint filters may be commonly used. For example,
the Arkansas Department of Pollution Control and Ecology recommends that lint filters be included in
the design of laundromat facilities (ADPC&E, 1996).
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
laundromat 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 UIC Study provides information on the health effects associated with
contaminants found above drinking water standards or health advisory limits in the injectate of
laundromat wells and other Class V wells. As discussed in Section 4.1, the contaminants that have
been observed above drinking water MCLs or HALs in laundromat well injectate are pH and TDS.2
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 UIC Study presents published half-lives of
common constituents in fluids released in laundromat 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 laundromat wells and other Class V wells.
2 The injectate quality data for the combination laundromat/carwash well at A&J Suds & Scrub
indicated the presence of several metals above the MCLs. Because of the similarity of these results to
other carwash injectate data, the metals are presumed to be a result of the car washing operations at the
facility and not related to the laundromat operation (see Wume 4 of the Class V UIC Study for a
summary of carwash wells).
September 30, 1999
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5.2 Observed Impacts
No contamination incidents involving laundromat wells were reported in responses to the survey
of state and USEPA Regional UIC programs. In addition, no contamination incidents involving
laundromat wells were found in the literature.
6. BEST MANAGEMENT PRACTICES
One alternative to laundry wastewater injection is wastewater reuse. Laundries are motivated
to save water to reduce water costs. However, laundries are often small facilities lacking the space to
install complete wastewater treatment facilities. Smaller laundries also may find many recycling
alternatives unaffordable. The best water recycling systems for laundries may be small, relatively
advanced treatment systems such as coagulation, flocculation, or a combination of the two processes
(California Water Resources Commission, 1989).
7. CURRENT REGULATORY REQUIREMENTS
Several federal, state, and local programs exist that either directly manage or regulate Class V
laundromat 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 laundromat wells. Discharges from industrial laundries are also being
evaluated under the Clean Water Act (CWA), but these efforts do not include coin-operated laundries.
7.1 Federal Programs
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.
Laundromat 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 laundromat wells, are prohibited from engaging in
any injection activity that allows the movement of fluids containing any contaminant into USDWs, "if the
September 30, 1999 10
-------
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
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
laundromat 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.
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 laundromat
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
7.1.2 CWA
In the late 1970s and early 1980s, USEPA considered the development of effluent limitations
guidelines and standards for the "Auto and Other Laundries Point Source Category," which included
3 May 2003 is the deadline including an 18-month extension.
September 30, 1999 11
-------
coin-operated laundries (USEPA, 1980). This point source category was mandated for study and
possible regulation pursuant to a 1976 settlement agreement and the 1977 Clean Water Act
Amendments. However, in 1982, the auto and other laundries category was excluded from regulation.
Among other reasons, this decision was made because assessments had determined that 95 percent of
the industry-charged pollutants could be treated by publicly owned treatment works (POTWs), and did
not pass through, interfere with, or otherwise prove incompatible with the operation of POTWs. Since
1987, USEPA has been focusing on industrial laundry effluent limitations guidelines and pretreatment
standards; however, coin-operated laundries are not covered under these efforts.
7.2 State and Local Programs
As presented in Section 3 above, more than more than 80% of the documented and more than
90% of the estimated laundromat wells in the nation exist in five states: Alabama, Iowa, Mississippi,
New York, and West Virginia. Attachment B of this volume describes how each of these states
currently regulate laundromat wells. The attachment also describes the Wyoming program to provide
an additional examples of existing state controls.
The statutory and regulatory framework for injection wells associated with laundromat facilities
(without dry cleaning) in the states that current records indicate contain the largest numbers of such
injection wells fall into two major groups.
In states in which the UIC Class V program is directly implemented by USEPA -including
Iowa and New York- the USEPA Region applies inventory requirements and a permit by rule
program to ensure non-endangerment of USDWs. In some cases, the state has no other
statutory or regulatory authorities that apply directly to laundromat injection wells, but it may
have requirements that indirectly apply. For example, Iowa does not have regulations that
specifically address industrial wells, including injection wells used at laundromats without dry
cleaning. If such wells discharge into septic tanks, however, the septic tanks will be classified
as industrial wells and Iowa's requirements for on-site wastewater systems will apply to them.
New York also does not have regulations that apply specifically to laundromat wells. If such
wells discharge in such a way that they violate New York's water quality standards and ground
water effluent limitations, however, the state can require the well to obtain a State Pollution
Discharge Elimination System (SPDES) permit. Detailed information about the discharge must
be supplied and the permit sets both effluent limits and monitoring and reporting requirements.
All laundromat wells in New York, however, have not been permitted under the SPDES
program.
Primacy states for Class V wells also apply a range of requirements to laundromat wells.
Mississippi, for example, has incorporated the USEPA's Class V UIC requirements by
reference. The state applies inventory requirements and a permit by rule program. West
Virginia, on the other hand, has issued individual permits to approximately six laundromat wells
under its state UIC program, while the majority of laundromat wells in the state are authorized
by rule. Alabama requires sufficient information to be submitted under its Class V UIC
requirements to determine whether or not to require an individual permit for the well (based on
September 30, 1999 12
-------
its likelihood of adversely impacting a USDW). Wyoming plans to issue individual permits to
large-scale commercial laundromat operations under its Class V UIC rules that are currently in
the planning stage.
September 30, 1999 13
-------
ATTACHMENT A
INJECTATE QUALITY DATA FOR
WELLS THAT INJECT FLUID FROM LAUNDROMATS WITHOUT DRY CLEANING
Table A-l. Injectate Quality Data from A&J Suds & Scrub, Libby, Montana3
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
Chloroformn
Concentrations
(mg/1)
11/05/97
13
0.494
0.003
O.003
<0.025
0.025
<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
O.0005
NA
NA
O.0005
O.0005
O.OOOSJf
0.0005
O.0005
O.0005
O.0005
0.0005
NA
NA
O.0005
0.0005
0.0005
O.0005
0.015
7/27/98
NA
NA
NA
NA
NA
NA
NA
NA
O.0005
NA
NA
O.0005
O.0005
0.0005
0.0005
O.0005
O.0005
O.0005
0.0005
NA
NA
O.0005
0.0005
0.0005
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 J
0.1/0.08 J
-
-
-
-
0.005
-
0.005
-
0.1/0.08 J
-
0.1/0.08 J
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
14
-------
Table A-l. Injectate Quality Data from A&J Suds & Scrub, Libby, Montana3
(Continued)
Parameter
Chloromethane
2-Chlorotoluene
4-Chlorotoluene
Chromium, Total
Chromium, Dissolved
Copper, Total
Copper, Dissolved
1 ,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
Ethylbenzene
Fluorotrichloromethane
Hexachlorobutadiene
Iron, Total
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
NA
NA
NA
12.5
1/12/98
<0.0005
0.0005
<0.0005
NA
NA
NA
NA
0.001
O.0005
0.0005
0.0005
O.0005
O.0005
O.0005
0.0005
O.0005
O.0005
O.0005
0.0005
O.0005
O.0005
O.0005
0.0005
0.0005
O.0005
0.0005
O.0005
0.0005
NA
7/27/98
0.0005
0.0005
0.0005
NA
NA
NA
NA
0.001
O.0005
0.0005
0.0005
O.0005
O.0005
O.0005
0.0005
O.0005
O.0005
O.0005
0.0005
O.0005
O.0005
O.0005
0.0005
0.0005
O.0005
0.0005
O.0005
0.0005
NA
Drinking Water
Standards (*)
mg/1
-
-
-
0.1
-
1.3
-
-
-
-
0.6
-
0.075
-
-
0.005
0.007
0.07
0.1
-
0.005
-
-
-
-
0.7
-
-
0.3
P/S
-
-
-
P
-
P
-
-
-
-
P
-
P
-
-
P
P
P
P
-
P
-
-
-
-
P
-
-
s
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
-
-
-
-
0.7
2
0.001
-
N/C
N
N
N
N
-
-
-
-
-
-
N
N
N
N
-
C
N
N
N
-
C
-
-
-
-
N
N
N
-
September 30, 1999
15
-------
Table A-l. Injectate Quality Data from A&J Suds & Scrub, Libby, Montana3
(Continued)
Parameter
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
1 ,2,3-Trichloropropane
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
Tetrachloroethene
Thallium, Total
Thallium, Dissolved
Toluene
Concentrations
(mg/1)
11/05/97
0.44
NA
NA
0.0453
0.0084
0.474
0.216
<0.001
<0.001
NA
NA
<0.05
O.05
NA
0.025
O.025
<0.005
<0.005
NA
NA
NA
NA
NA
NA
NA
NA
<0.001
0.001
NA
1/12/98
NA
0.0005
0.0012
NA
NA
NA
NA
NA
NA
<0005
O.OOOSJf
NA
NA
O.0005
NA
NA
NA
NA
0.0005
O.0005
O.0005
O.0005
0.0005
O.OOOSJf
O.0005
0.00085
NA
NA
O.OOOSJf
7/27/98
NA
0.0005
0.0005J f
NA
NA
NA
NA
NA
NA
0.00081
0.00056
NA
NA
O.0005
NA
NA
NA
NA
0.0005
O.0005
O.0005
O.0005
0.0005
0.0005
O.0005
0.00085
NA
NA
0.0021
Drinking Water
Standards (*)
mg/1
-
-
-
0.015
-
0.05
-
0.002
-
.005
-
0.1
-
-
0.05
-
0.1
-
0.1
-
-
-
-
-
-
.005
0.002
-
1
P/S
-
-
-
p
-
s
-
p
-
p
-
p
-
-
p
-
s
-
p
-
-
-
-
-
-
p
p
-
p
Health Advisory
Levels (**)
mg/1
-
-
-
-
-
-
-
0.002
-
-
0.02
0.1
-
-
-
-
0.1
-
0.1
0.07
-
-
0.04/0.5
-
-
-
0.0005
-
1
N/C
-
-
-
-
-
-
-
N
-
-
N
N
-
-
-
-
N
-
N
N
-
-
N/C
-
-
-
N
-
N
September 30, 1999
16
-------
Table A-l. Injectate Quality Data from A&J Suds & Scrub, Libby, Montana3
(Continued)
Parameter
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
NA
NA
NA
NA
<2.5
<2.5
1/12/98
<0.0005
0.0005
<0.0005
<0.0005
<0.0005
<0.0005Jf
<0.0005Jf
<0.0005
NA
NA
7/27/98
<0.0005
<0.0005
<0.0005
<0.0005
O.0005
0.00059
0.00059
<0.0005
NA
NA
Drinking Water
Standards (*)
mg/1
0.07
0.2
0.005
-
0.002
10
10
10
5
-
P/S
P
P
P
-
P
P
P
P
s
-
Health Advisory
Levels (**)
mg/1
0.07
0.2
0.003
-
0.0015
10
10
10
2
-
N/C
N
N
N
-
C
N
N
N
N
-
Source: USEPA Region 8,1999.
The well receives a combination of laundromat and carwash effluent.
* Drinking Water Standards: P= Primary; S= Secondary.
** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.
f Estimated value. Present, but less than the limit of quantitation.
J 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.
n Chloroform is a disinfection byproduct.
September 30, 1999
17
-------
ATTACHMENT B
STATE AND LOCAL PROGRAM DESCRIPTIONS
This section describes the controls for injection wells associated with laundromat facilities
(without dry cleaning) in the five states that current records indicate contain the largest number of such
wells. Altogether, these states are estimated to contain approximately 92 percent of the estimated
national inventory of laundromat wells. The Wyoming program is also described to provide an
additional example of existing state controls.
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 impacts 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 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. When those permit application requirements
are applied, the permit application processing and issuance procedures will follow the rules set forth for
Class I and HI 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).
Siting and Construction Requirements
The AAC specifies that injection wells shall be sited so that they inject into a formation that is
beneath the lowermost USDW located within five miles of the well (335-6-8-.20 AAC). However,
Class V wells are specifically exempted (335-6-S-.25 AAC).
Construction requirements also are specified for all injection wells. However, Class V wells are
specifically exempted (335-6-S-.25 AAC). They are required to be constructed in such a manner that
September 30, 1999 18
-------
they may not cause a violation in USDWs of primary drinking water regulations under 40 CFR Part
142, and when required by ADEM must be constructed by a well driller licensed by ADEM (335-6-8-
.25 AAC).
Operating Requirements
Class V wells are required to 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 (335-6-8-. 16 AAC).
Before operation of the well can begin, 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).
Plugging and Abandonment
A plugging and abandonment plan may be required by permit or administrative order. If
necessary, aquifer cleanup procedures may be included. If pollution of a USDW is suspected, ground
water monitoring may be required after well abandonment (335-6-S-.27 AAC).
Iowa
USEPA Region 7 directly implements the UIC program for Class V injection wells in Iowa. In
addition, the state has enacted regulations addressing onsite wastewater treatment and disposal systems
that collect, store, treat, and dispose of wastewater from four or fewer dwelling units or other facilities
serving the equivalent of 15 persons (1,500 gallons per day (gpd) or less) (Chapter 567-69 Iowa
Administrative Code (IAC)). Onsite 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). Estimates of flow rate appended to the rule
include an estimate for laundromats. If wastewater from laundromats without dry cleaning can be
shown clearly to be only sanitary waste it is not banned from such systems. Similarly, under the rules
pertaining to large capacity septic systems (i.e., 567-60 to 567-64 IAC), waste that does not meet the
definition of industrial waste could be placed in such 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.).
September 30, 1999 19
-------
For Class V wells associated with laundromats, no additional requirements or exceptions have been
enacted. Therefore, only 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 waters), specify that such
discharges must comply with the standards in Part 703, and provide for monitoring in Part 756.
Part 703 of New York's water quality regulations sets both surface and ground water quality
standards and ground water effluent standards. They include narrative standards for taste, color and
odor-producing toxic and other deleterious substances for all three of the state's classes of ground
water and narrative standards for thermal discharges to ground water. They also include standards for
pH, dissolved solids, odor, color, turbidity, and total coliform for class GA ground water (potable
ground water). Finally, Part 703 includes water quality standards for class GA ground water for
numerous listed contaminants. Section 703.6 establishes ground water effluent limitations applying to
discharges from a point source to waters of the state. These are the maximum allowable concentrations
for over 100 contaminants (including foaming agents and oil and grease). Part 756 provides for such
monitoring requirements as may be "reasonable required," as well as recording and monthly reporting
of monitoring results, unless otherwise specified in a SPDES permit.
Permitting
Applications for a SPDES permit must be submitted on a required form, describe the proposed
discharge, supply such other information as the DWR requests, 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
Both effluent limits (Part 703) and monitoring and reporting requirements (Part 756) in an
SPDES permit for releases to ground water must be met.
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 or laundromat wells (47-13-3.4.5. WVAC).
September 30, 1999 20
-------
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. DEP has
lacked sufficient resources to individually permit all categories of Class V wells. The state has
individually permitted six laundromat wells in the industrial or commercial well category but other
laundromat wells are currently permitted by rule (WVDEP/OWR, 1999).
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 recordkeeping (requiring
retention of records pursuant to 47-13-13.6.b. WVAC concerning the nature and composition of
injected fluids until three 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 USDWs, 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 on operating factors such as
pollutant loads and schedules for attaining compliance with water quality standards (47-13-13.2.d.l
WVAC).
If it is deemed necessary to protect a USDW, the owner or operator may be required to satisfy
corrective action, monitoring, reporting, or operation requirements that are not contained in the
regulations outlining the West Virginia'sUIC program (47-13-13.2.C.1.C. WVAC).
Mechanical Integrity
A Class V well required to obtain an individual permit may be required to demonstrate that the
well has mechanical integrity (47-13-13.7.g WVAC). The need for such a demonstration is
determined in a case-by-case basis, depending on whether, for example, the well is located in karst
terrain or passes through certain formations. Based on their construction and use, mechanical integrity
September 30, 1999 21
-------
testing is not considered necessary for laundromat wells that are individually permitted or permitted by
rule (WVDEP/OWR, 1999).
Plugging and Abandonment
A Class V well required to obtain an individual permit is subject to permit conditions pertaining
to plugging and abandonment to ensure that the plugging and abandonment of the well will not allow the
movement of fluids either into a USDW or from one USDW to another. A plan for plugging and
abandonment is required.
Financial Responsibility
A Class V well required to obtain an individual permit will be required to demonstrate financial
responsibility for plugging and abandonment.
Although state staff in Wyoming did not report the presence of any laundromat wells in the
Class V study survey, presented below is a brief summary of some of the state's regulatory
requirements for laundromat wells if they were to exist.
Wyoming is a UIC Primacy State for Class V wells. Chapter 16, Water Quality Rules and
Regulations, defines all laundromat facilities as Class 5C3 commercial and industrial discharges and
requires individual UIC permits (WYDEQ/WQD, 1999).
Permitting
To date, no facility in Wyoming has submitted a commercial laundromat application, and the
State of Wyoming has not attempted any specific outreach to this industrial group. Laundromat wells
are required to operate under individual permits, and there is no grandfather clause for existing facilities.
Each individual permit specifies monitoring requirements and operating limits based on the information
provided in the facility's application (WYDEQ/WQD, 1999).
Construction Requirements
The State of Wyoming has standards for construction of septic systems serving laundromats.
The standards for self-service facilities include design flows of 600 gpd per machine or 50 gpd per
cycle. Typically, 600 gpd is used as a standard for self-service laundromats open to the public.
Laundries built in conjunction with other facilities, such as motels, are subject to the 50 gpd per cycle
standard, with the Wyoming Department of Environmental Quality estimating the number of cycles for
the facility (WYDEQ/WQD, 1999).
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Plugging and Abandonment
Plugging and abandonment are allowed in place if the owner or operators can show that no
hazardous waste was discharged through the system (WYDEQ/WQD, 1999).
September 30, 1999 23
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REFERENCES
Arkansas Department of Pollution Control and Ecology (ADPC&E). 1996. Application Procedures
for a No-Discharge Water Pollution Control Permit. June 21, 1996.
Agriboard Industries, L.C. 1998. Sustainable Building Sourcebook
http://www.greenbuilder.com/sourcebook/Greywater.htmWDefine (28 August 1998).
The Cadmus Group. 1999. State-by-State Notebooks Compiling Results from the Class V
Underground Injection Control Study. February 1, 1999.
California Water Resources Commission. 1989. Industrial Water Conservation References of
Industrial Laundries. The Resources Agency, Department of Water Resources. State of California.
Cerra, F.J., and J.W. Maisel, eds. 1979. Wastewater Engineering: Treatment, Disposal, Reuse.
Boston: Metcalf and Eddy. pp. 11-58.
New York State Department of Environmental Conservation (NYDEC). 1999. Email from William
Spitz, New York Department of Environmental Conservation, to Robyn Delehanty, USEPA Office of
Water, transmitting injectate data for carwashes and laundromats. March 10, 1999.
USEPA. 1980. Development Document for Effluent Limitations Guidelines and Standards for the
Auto and Other Laundries Point Source Category. Washington, D.C. OMB0704-0188. October
1980.
USEPA. 1987. Report to Congress: Class V Injection Wells. Office of Water. Washington, D.C.
EPA 570/9-87-006. September 1987.
USEPA Region 8. 1999. Correspondence from Douglas Minter, USEPA Region 8, to Robyn
Delehanty, USEPA Office Water, transmitting sampling data for automotive and industrial Class V
wells. March 3, 1999.
Vassalydes, J. 1998. Coin Laundry Association. Telephone Communication with Scott Hines, ICF
Consulting. August 27, 1998.
West Virginia Department of Environmental Protection Office of Water Resources (WVDEP/OWR).
1999. Telephone conversation between Tina Parsons, WDEP/OWR, and Craig Dean, ICF
Consulting. August 19, 1999.
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.
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