Conversion of a Motor

Vehicle Waste Disposal Well

-- A UIC Director’s Guide

United States Office of Water EPA 816-R-00-017

Environmental Protection Agency Washington, D.C. 20460 November 2000

"Class V wells at motor vehicle service facilities may not be

subject to the rule, if motor vehicle waste fluids are prevented

from entering the well . . ."

-- Revisions to the Underground Injection Control (UIC) Regulations for Class V

Wells - Final Rule, December 1999
TABLE OF CONTENTS

1. Purpose of this Document . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

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

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

4. What Are the New Requirements for Conversion 

of an Existing Motor Vehicle Waste Disposal Well? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4

5. What Are the Factors to be Considered When Authorizing the 

Conversion of a Motor Vehicle Waste Disposal Well to Another Kind of Class V Well? . . . . . . . . . .5

6. Does the Owner/Operator of an Existing Motor Vehicle Waste 

Disposal Well Need to Provide Notification Prior to Conversion of the Well? . . . . . . . . . . . . . . . . . .9

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

8. Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

9. Need More Information? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

Attachment A:

Pre-Notification Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12

Attachment B: 

Suggested Best Management Practices (BMPs) for Motor

Vehicle-Service Facilities with "Converted" Wells . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14 

Attachment C: 

Common Questions from Owners and Operators Converting Wells in the State of Maine . . . . . . . . . .16

Attachment D:

Special Terms Used in this Guidance Document . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20 
1. Purpose of this Document

This document outlines for Underground Injection Control (UIC) Program Directors and

their staff, the new requirements for allowing the conversion (reclassification) of a motor

vehicle waste disposal well to another type of Class V injection well. The guidance also

discusses other UIC requirements that may affect a conversion and additional factors

that may need to be considered such as Best Management Practices (BMPs).

The Safe Drinking Water Act provisions and Environmental Protection Agency (EPA) regulations described in this document contain legally binding requirements. This document

does not substitute for those provisions or regulations, nor is it a regulation itself. Thus,

it does not impose legally-binding requirements on EPA, States, or the regulated community, and may not apply to a particular situation based upon the circumstances.

The purpose of this document is to specifically address the conversion provision of the

Class V Rule published on December 7, 1999 (40 CFR §144.89(b)). It is optional for

States or Regions to include this provision to allow owners and operators of existing motor

vehicle waste disposal wells to convert their well to another type of Class V well.

Depending on specific conditions and policies in a State, EPA and State decisionmakers

may choose not to allow for the conversion of a motor vehicle waste disposal well to

another type of Class V injection well. For States where conversions will be allowed, any

decisions regarding a particular facility will be made based on the applicable statutes and

regulations. EPA and State decisionmakers retain the discretion to adopt approaches

(e.g., on a case-by-case basis) that differ from this guidance where appropriate.

Therefore, interested parties are free to raise questions and objections about the appropriateness of the application of this guidance to a particular situation, and EPA will consider whether or not the recommendations or interpretations in the guidance are appropriate in that situation. EPA may change this guidance in the future.

EPA published the Class V Rule in the Federal Register on December 7, 1999. The Rule

became effective on April 5, 2000. For additional information on the new requirements of

the Class V Rule and the associated compliance schedules, see 64 Federal Register

68546 and the State Implementation Guidance for the Revisions to the Underground

Injection Control Regulations for Class V Injection Wells (EPA 816-R-00-008).

1

Please Note:

This document was not developed to assist owners or operators to convert their Class

V motor vehicle waste disposal well. Owners and operators should contact their UIC

Program Directors for information on how to complete their conversion.
2. What Does EPA Consider to be a Motor Vehicle Waste 

Disposal Well?

The Class V Rule defines motor vehicle waste disposal wells at 40 CFR §144.81(16) as:

"wells that receive or have received fluids from vehicular repair or maintenance activities, such as an

auto body repair shop, automotive repair shop, new and used car dealership, specialty repair shop

(e.g., transmission and muffler repair shop), or any facility that does any vehicular repair work." 

These wells often take the form of floor drains, work sinks, or washbasins leading to drywells, cesspools, or septic systems.

2

CLARIFICATION: 

In general, waste water from hand washing with regular soap in bathrooms or sanitary

facilities is sanitary wastewater that can be disposed of through septic systems.

However, if a facility has a sink in the service area that discharges to a septic system

or dry well, and employees wash their hands using organic solvents that are typically

used for cleaning parts, it would be considered a motor vehicle waste disposal well.

Specifically, a Class V well receiving floor washing water, parts washing water,

or other waste water containing motor vehicle waste fluid at a motor vehicle

maintenance facility, would be considered a motor vehicle waste disposal well.

Finally, the definition of a well at 40 CFR 144.3 makes no distinction between above

and below grade wastewater disposal systems. A subsurface fluid distribution system

such as a mound or peat biofilter system that meets the definition of a well (see

Attachment D) and is used for the disposal of motor vehicle waste fluids is a Class V

motor vehicle waste disposal well.
3. What Are the New Regulatory Requirements for Motor 

Vehicle Waste Disposal Wells?

The Class V Rule:

• Bans new motor vehicle waste disposal wells nationwide. 

• Bans existing motor vehicle waste disposal wells (with a waiver provision)

in regulated areas designated by the UIC Program Director. 

Owners and operators of existing motor vehicle waste disposal wells in regulated areas

have two options: (1) close their wells;1 and (2) seek a waiver from the ban and obtain a

permit.2 

Some States may adopt the conversion provision of the Class V Rule and allow well

owners and operators to convert their existing motor vehicle waste disposal well to

another kind of Class V well (with permission from the UIC Program Director). The adoption of this conversion provision is at the discretion of the UIC Program Director. Upon

completion of the conversion process, converted wells would not be subject to

the new requirements found in the Class V rule. 

3

1 Before closing a Class V well, the owner or operator must notify the UIC Program

Director of his/her intent to close the well at least 30 days prior to well closure (40

CFR §144.88(b)(1)(vii)). 

2 EPA envisions that UIC Directors will grant waivers through the issuances of permits.

Minimum permit requirements are: (1) fluids released in the wells must meet drinking

water Maximum Contaminant Levels (MCLs) and other health-based standards at

the point of injection, (2) monitoring requirements must be specified to characterize

the quality of the injectate and sludge, both initially and on an ongoing basis, and (3)

best management practices, such as recycling and waste minimization must be

specified (40 CFR §144.88).
4. What are the New Requirements for Conversion of an 

Existing Motor Vehicle Waste Disposal Well? (40 CFR 

§144.89(b))

The UIC Program Director may allow a motor vehicle service facility to convert an existing Class V motor vehicle waste disposal well to another type of Class V well. The converted Class V well would be allowed to receive only other liquids such as stormwater or

snow melt. The following conversion conditions are specified in the regulation: 

• All motor vehicle fluids are segregated by physical barriers and are not

allowed to enter the well. An owner or operator may be allowed to continue

using their well if all motor vehicle fluids stored or generated at the facility (i.e.,

both products and wastes) are segregated from the well by a curb, berm, and/or

other containment structures. 

Note: The use of a semi-permanent plug as a means of segregating waste is not sufficient to convert a motor vehicle waste disposal well to another type of Class V well.

• Injection of motor vehicle waste is unlikely based on a facility’s compliance history and records showing proper waste disposal. The owner or

operator should be able to supply documentation of their past compliance history.

NOTE: A converted well is still subject to the non-endangerment criteria at 40 CFR §144.12, the inventory

requirements found at 40 CFR §144.26, and the closure criteria found at 40 CFR §144.89(a). 

4

Example: 

Owners or operators of existing motor vehicle waste disposal wells may request a conversion under limited circumstances such as: multiple bay garages in which all but one

of the floor drains are closed, and the bay with the open drain only receives wash

water from exterior vehicle wash, or multiple bay garages in which all but one of the

floor drains are closed, and the bay with the open drain receives only snow melt.
5. What Are the Factors to be Considered When 

Authorizing the Conversion of a Motor Vehicle Waste 

Disposal Well to Another Kind of Class V Well?

UIC Program Directors may authorize a conversion in cases where they can ensure that

unintentional or illicit discharge of motor vehicle waste fluids into the well is unlikely,

based on the facility’s compliance history and availability of adequate records showing

proper waste management and disposal. 

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

The definition of motor vehicle waste disposal well includes "wells that receive or have

received" fluids from vehicular repair. When evaluating what an owner or operator

would have to do to convert a well, UIC Program Directors should consider the history

and use of the well. 

A well must be closed in a manner that prevents movement of contaminated fluids into underground sources of drinking water (USDWs), which may cause a violation of Maximum Contaminant Levels (MCLs) or other health-based standards,

or may adversely affect public health (40 CFR §144.89(a)). Additional or more specific closure requirements may be imposed by the UIC Program Directors. 

5

UIC Directors must ensure owners and operators comply with the following:

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

requirements (40 CFR §144.89(a))

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

C. Demonstrate continuous compliance with all appropriate rules and regulations

and proper waste disposal practices (40 CFR §144.89(b))

UIC Program Directors may also:

D. Specify best management practices (BMPs) such as employee training and

sign posting
Closure of a Class V well may include:

• Analysis, disposal and/or management of any soil, gravel, sludge, liquids, or

other materials removed from or adjacent to the well in accordance with all

applicable regulations and requirements. (Note: Based on sampling results of

motor vehicle waste disposal wells, many contaminants such as heavy metals

and volatile organic compounds are found at levels above the MCLs and other

health-based standards in the wells and adjacent to the wells.)

• Proper cleaning of the well and attached conveyances (e.g., wastewater collection

system) to remove contaminants residing in the sludge, fluid, or scum. (Note:

Flushing the well may cause a violation of 40 CFR §144.12 if contaminants are

present.)

• If needed, sampling of the injectate to demonstrate the absence of motor vehicle

fluid related contaminants.

6

Example:

Prior to authorizing a well conversion from an existing motor vehicle waste disposal well

to a vehicle wash well, you may want to consider the effect of large amounts of vehicle

wash water flushing through the converted well. Based on the length of time the well

was used for motor vehicle fluid disposal, and the specific wastes discharged -- you

may want to require the owner or operator to conduct a site evaluation to determine the

impact of continued use of the converted well on USDWs. If the site evaluation shows

contamination of soil and/or ground water you should require the owner/ operator to go

through all the steps of closure (except final plugging of the well) before allowing them

to "re-open" or convert the well. All contaminated sludge, soils, and ground water must

be removed and properly disposed of prior to "re-opening" the converted well (144.82(a)

and 144.82(b)).
B. Segregate motor vehicle fluids from the well (40 CFR §144.89(b))

Owners and operators must use physical barriers to prevent motor vehicle fluids from

entering the converted well, such as:

• Construction of curbs, berms, and/or other containment structures to isolate the

work area and the associated well that is being converted from motor vehicle

waste fluids generated or stored in other areas of the facility.

Note: Curbs, berms, and other containment structures may present a tripping hazard at a facility

and therefore must meet all applicable Occupational Safety and Health Administration (OSHA) or

State equivalent regulations and requirements.

• A semi-permanent plug cannot be used to segregate waste.

Note: The use of semi-permanent plugs (also known as plumber’s plugs) to segregate motor vehicle

waste fluids from other fluids such as snow melt and exterior vehicle wash water cannot be used to

convert motor vehicle waste disposal wells.

• Prohibition of motor vehicle service and maintenance activities that generate

fluid wastes in the areas that drain to the "converted" well. The converted well

may only receive such liquids as snow melt, rain drip, and exterior vehicle wash

water.

• Prohibition of the storage of motor vehicle fluids (e.g., motor oil, antifreeze, and

used motor oil and hydraulic fluids) within the perimeters of the areas that drain

to the "converted" well.

7
C. Demonstrate past history and continuous compliance with all appropriate rules

and regulations and proper waste disposal practices

• Facility has a good history of compliance with appropriate regulations and

requirements (e.g., UIC well inventory information submitted, previous UIC

inspections indicate compliance or corrective actions were taken to return to

compliance, and absence of violations under other Federal or State requirements (such as the Resource Conservation and Recovery Act (RCRA) or

Occupational Safety and Health Act (OSHA)).

• Proper waste disposal practices and recycling, along with appropriate records of

such activities.

UIC Directors may want to:

D. Specify best management practices (BMPs) that should be implemented, such as

employee training and sign posting 

Attachment B lists selected BMPs that may be appropriate for motor vehicle service facilities with converted wells.

Attachment C "Common Questions from Owners and Operators Converting Wells in the

State of Maine" contains specific questions and answers on containment structures, fluid

storage and allowable discharges.

8
6. Does the Owner/Operator of an Existing Motor Vehicle 

Waste Disposal Well Need to Provide Notification Prior 

to Conversion of the Well?

An owner/operator can only convert a motor vehicle waste disposal well to another type

of Class V well with the permission of the UIC Program Director. The rule does not outline the process for obtaining permission. However, 40 CFR144.88(b)(1)(vii) of the Class

V Rule requires owners or operators of existing motor vehicle waste disposal wells to

notify the Director 30 days before closing or converting their wells. This requirement

allows for a more accurate inventory, and provides a mechanism for oversight of well closures and conversions. To collect the closure information from the owner/operator, the

EPA has developed a form entitled "Preclosure Notification for Closure of Injection Wells"

for use by Direct Implementation Programs (See Attachment A). Primacy Programs may

use this form or modify the form to collect the required information from well owners and

operators prior to closing and converting their motor vehicle disposal well.

Note: A State may adopt the Pre-closure Notification form as the mechanism for owners or operators to

request a conversion. However, a conversion cannot take place until it has been authorized by the UIC

Director.

7. Does the UIC Program Director Need to Permit 

Converted Wells?

The Class V Rule does not require site-specific permitting of converted wells and leaves

such decisions to the UIC Program Director’s discretion. However, some States have

suggested that to ensure compliance when authorizing conversions, UIC Programs may

have to increase oversight and/or require owners and operators to obtain a permit or

conduct periodic monitoring of the injectate. 

9
8. Summary 

EPA’s requirements for motor vehicle well conversion are as follows:

• 144.12 and 144.82 Ensure non-endangerment from Class V wells that are

converted from motor vehicle waste disposal wells

• 144.26 and 144.83 Submit inventory

• 144.89(a) Close out well properly (prevent fluid movement and contamination of

USDWs)

• 144.89(b) Conversion must be authorized by the UIC Director and requires the

use of physical barriers, preventing motor vehicle fluids from entering the wells,

and a good compliance history and waste management plans of the facilities. 

Additional factors the UIC Program Director may consider are as follows:

• Site evaluation

• Remediation

• Best Management Practices

• Oversight by UIC Program 

• Monitoring to ensure compliance

10
9. Need More Information?

For additional information on the new requirements of the Class V Rule and the associated compliance schedules, see 64 Federal Register 68546 and the State

Implementation Guidance for the Revisions to the Underground Injection Control

Regulations for Class V Injection Wells. 

• For additional information on State implementation of the rule, see the EPA

State Implementation Guidance for the Revisions to the Underground Injection

Control Regulations for Class V Injection Wells (EPA No. 816-R-00- 008).

• For copies of other guides associated with the Class V Rule, visit the OGWDW

Website: http://www.epa.gov/safewater/uic/c5imp.html.

11
Type or print all information. See reverse for instructions.

Form Approved 12/99

OMB Control No.2040-0214 

CLASS V WELL PRE-CLOSURE NOTIFICATION FORM

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF GROUND WATER AND DRINKING WATER

1. Name of facility: 

 Address of facility: 

 

 City/Town: State: Zip Code: 

 County: Location: 

2. Name of Owner/Operator: 

 Address of Owner/Operator: 

 

 City/Town: State: Zip Code: 

Legal contact: Phone number: 

3. Type of well(s): Number of well(s): 

4. Well construction (check all that apply):

 Drywell Septic tank Cesspool

 Improved sinkhole Drainfield/leachfield Other 

5. Type of discharge: 

 

6. Average flow (gallons/day): 7. Year of well construction: 

8. Type of well closure (check all that apply):

 

 Sample fluids/sediments Clean out well

 Appropriate disposal of remaining fluids/sediments Install permanent plug

 Remove well & any contaminated soil Conversion to other well type

 Other (Describe): 

 

9. Proposed date of well closure: 

10. Name of preparer: Date: 

PAPERWORK REDUCTION ACT NOTICE

The public reporting and recordkeeping burden for this collection of information is estimated to average 1.5 hours per respondent. Burden means the total

time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This

includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and

verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any

previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and

review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required

to respond to, a collection of information unless it displays a currently valid OMB control number. 

Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing

respondent burden, including through the use of automated collection techniques to the Director, Regulatory Information Division, U.S. Environmental

Protection Agency (2137), 401 M St., S.W., Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed

form to this address.

Attachment A
13

INSTRUCTIONS

You must complete this form to notify the U.S. EPA that you intend to close a Underground Injection Control (UIC) Class V

well at your facility. You may complete one form for more than one of the same type of Class V well at each facility. For

example, if you will be closing two drywells that are of similar construction at your facility, you may use one form.

The numbers below correspond to the numbers on the form.

1. Supply the name and street address of the facility where the Class V well(s) is located. Include the City/Town, State

(U.S. Postal Service abbreviation) and Zip Code. If there is no street address for the Class V well, provide the route

number or locate the well(s) on a map. If available, for the "Location" provide the Latitude/Longitude of the well or the

legal description of the facility.

2. Provide the name and mailing address of the owner of the facility or if the facility is operated by lease, the operator of

the facility. Include the name and phone number of the legal contact for any questions regarding the information

provided.

3. Indicate the type of Class V well that you intend to close. For example, motor vehicle waste disposal well or cesspool).

Provide the number of wells of this well type at your location that will be closed.

4. Mark an “x” in the appropriate box to indicate the type of well construction. Mark all that apply to your situation. For

example, for a septic tank that drains into a drywell, mark both the “septic tank” and “drywell” boxes. Please provide a

generalized sketch or schematic of the well construction if available.

5. List or describe the types of fluids that enter the Class V well. If available, attach a copy of the chemical analysis

results and/or the Material Safety Data Sheets for the fluids that enter the well. 

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

7. Provide the year that the Class V well was constructed. If unknown, provide the length of time that your business has

been at this location and using this well.

8. Mark an “x” in the appropriate box(s) to indicate briefly how the well closure is expected to proceed. Mark all that apply

to your situation. For example, all boxes except the “Remove well & any contaminated soil” and “Other” would be

marked if: the connection of an automotive service bay drain leading to a septic tank and drainfield will be closed, but

the septic system will continue to be used for washroom waste disposal only, and the fluids and sludge throughout

the system will be removed for proper disposal, the system cleaned, a cement plug placed in the service bay drain

and the pipe leading to the washroom connection, and the septic tank/drainfield remains open for septic use only. In

this example, the motor vehicle waste disposal well is being converted to another well type (a large capacity septic

system).

9. Self explanatory.

10. Self explanatory.

The purpose of this form is to serve as the means for the Class V well owner or operator’s notice to the UIC Director of

their intent to close the well in accordance with Title 40 of the Code of Federal Regulations (40 CFR) Section 144.12 (a). 

According to 40 CFR §144.86, you must notify the UIC Program Director at least 30 days prior to well closure of you intent

to close and abandon your well. Upon receipt of this form, if the Director determines that more specific information is

required to be submitted to ensure that the well closure will be conducted in a manner that will protect underground

sources of drinking water (as defined in 40 CFR §144.3), the Director can require the owner/operator to prepare, submit

and comply with a closure plan acceptable to, and approved by the Director. 

Please be advised that this form is intended to satisfy federal UIC requirements regarding pre-closure notification only. 

Other state, tribal or local requirements may also apply.
Attachment B

Suggested Best Management Practices (BMPs) for 

Motor Vehicle-Service Facilities with "Converted" Wells

Design/Physical BMPs:

Floor Drains If floor drains must exist in areas performing motor vehicle maintenance and repair activities, they should be connected to a holding

tank (meeting Federal, State, and/or local requirements) or sanitary sewer (with approval from the publicly owned treatment work

or POTW). All holding tank waste should be disposed of properly.

(Note: Floor drains in sanitary facilities (e.g., bathrooms) connected to a septic

system are not motor vehicle waste disposal wells if they receive sanitary waste

only.)

Work Areas Physically separate work areas such as maintenance bays and

chemical storage areas from vehicle wash bays with floor drains

(e.g., using curbs, berms, or other containment structures).

Procedural BMPs:

Training Employees should be trained in the proper operation of equipment;

loading and unloading of materials; spill control and emergency

procedures; and the reuse/recycling of materials.

Employees should be trained prior to working with equipment or

handling of materials, and should be refreshed periodically or

when new regulations or procedures are developed. 

Employees should be made aware of Material Safety Data Sheets

(MSDS) and understand the information contained on them.

14
Develop employee awareness about the environmental and the

economic benefits of waste reduction and pollution prevention, and

the consequences of ignoring environmental rules and regulations.

Communication Post signs reminding employees not to perform motor vehicle repair

and maintenance activities in the areas with converted floor drains;

not to dispose of waste or spills into drains; perform proper spill control procedures; and given emergency response information.

Record Keeping Updated facility plans (to reflect the current configuration) and

copies of associated approvals and permits should be maintained

on file at the facility. 

Maintain waste disposal and recycling records.

Maintain inventory records for materials that would be a RCRA

waste once used and compare them to hazardous waste disposal

records.

15
Attachment C

State of Maine

Common Questions on the Conversion of a Motor Vehicle Waste Disposal Well to

Another Type of Class V Well

In the State of Maine, owners and operators of motor vehicle waste disposal wells have

been allowed to convert their wells to other types of Class V wells. The main reason for

the conversion is to deal with the winter problem of snow melt water from cars and

trucks. The Maine Department of Environmental Protection (MDEP) reviewed a draft of

the EPA Conversion Guide and suggested we include some specific issues/questions

that arise when an owner/operator (O/O) requests a conversion from a State. The following questions and answers reflect some of MDEP’s experience with authorizing conversions and may give UIC Directors a better idea of the issues raised by owners and

operators. The following are responses that the State of Maine provides to these questions. They are included here as useful information to help other States decide how they

might want to address these questions if they arise.

Use of Curbs and Berms:

O/O: If I am going to use curbs, berms, and/or other containment

structures to isolate a converted well, how should I place

them?

MDEP: Curbs, berms, and/or other containment structures should be

placed to isolate the converted well and its associated drainage

area from motor vehicle waste fluids generated or stored in other

areas of the facility.

O/O: If I would like to install berms to isolate a work area for the

converted well, how high should the berms be?

MDEP: We recommend the use of low (1"-2"), rounded-edge berms that

are painted with a bright color such as blaze orange or yellow.

Note: Berms may represent a tripping hazard. While berms are not

covered by the Federal Occupational Safety and Health

Administration (OSHA) Standards, some State’s may have devel16
oped their own, more stringent requirments for the use of berms.

UIC Directors should contact the agency responsible for administering safety and health requirements for State specific information.

Note: Berms do not need to be very high to hold back spills. A

one-inch berm with 100 sq. ft. of floor space behind it will hold

back a spill of about 62 gallons (provided the floor is level).

O/O: What kind of material would be allowed to make up the berms?

MDEP: We recommend concrete berms. Many businesses go to their

nearest pre-cast concrete manufacturer for "speed bumps." Also,

some environmental product supply companies sell pre-fabricated,

six-foot long, plastic sections. Metal "L"s can be fabricated by

local metal shops to make up berms. In general, any material that

will not be degraded by chemicals in the motor vehicle fluids

should work. Adsorbent booms, foam sidewall berms, and flexible

dikes are not appropriate berm materials.

O/O: How should we install the berms? Can we bolt the berms into

the floor?

MDEP: Berms must be permanently adhered to the floor. Without an

adhesive or sealant under the berm, fluids can seep under it and

between sections. Also, berms loosely stuck to the floor can easily

be dislodged, especially if a portion is subject to car or truck traffic

within the service area. Simply bolting berms into the floor is not

an acceptable method of berm installation.

Allowable Fluid Discharge:

O/O: What kinds of fluid can be discharged to the converted wells?

MDEP: Converted wells can receive snow/ice melt, rain drip, and wash

water from exterior washing of cars and light trucks. Cleaning is

restricted to the exterior of the vehicle. Engine, undercarriage,

and transmission washing is prohibited. Cleaning operations

17
should minimize the detachment of paint residues, heavy metals,

or other potentially hazardous materials from vehicle surfaces.

The use of acids, bases, metal brighteners, degreasing agents or

steam is also prohibited. We recommend the use of non-toxic,

phosphate-free cleaners with cold water as cleaning agent. 

Wash water from engine, undercarriage and transmission washing

and from the cleaning of the interior of truck trailers and other

large commodity-carrying containers must be collected and discharged to a municipal sewer system or treated in a closed-loop,

wash water recycling system.

O/O: I have an autobody repair shop. Can I discharge wash water

with a small amount of sanding residues to the converted well?

MDEP: Wash water carrying a small amount of nonhazardous sanding

residues (e.g., catalyzed autobody filler, such as Bondo) from

autobody repairs does not constitute a motor vehicle waste. Wash

water discharging to floor drains in the sanding areas, which carry

a small amount of sanding residues would be allowed to enter the

converted well.

Motor Vehicle Fluid Storage: 

O/O: Can I store motor oil, antifreeze, and hydraulic fluids within

the perimeters of the areas that drain to the converted well?

MDEP: No, you are not allowed to store motor vehicle fluids (e.g., motor

oil, antifreeze, and used motor oil and hydraulic fluids) within the

perimeters of the areas that drain to the converted well. 

O/O: If it is not possible to remove all hazardous materials from the

area that drains to the converted well, can I put up a secondary containment structure to meet the requirement?

MDEP: If it is not possible to remove all hazardous materials from the area

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that drains to the converted well, a secondary containment structure is an acceptable alternative in Maine. Waste oil burners and

275-gallon heating or waste oil tanks are often located within

areas served by the converted wells. In these cases, we require a

secondary containment to be built around the oil tank. This secondary containment can be made out of cinder block and mortar

berm around the base of the tank and its fittings, and must be

large enough to capture the entire contents of the tank should it

rupture. Also, secondary containment is required around aboveground holding tanks that collect wastewater from other part of

your facilities (e.g., vehicle service areas) if these tanks are located in the area served by the converted drain. 

O/O: What should I do if I need to keep small containers of motor

vehicle fluids and other hazardous materials at my facility?

MDEP: You are not allowed to store 55-gallon drums or other smaller containers in the areas that drain to the converted well. You must

move these containers to other areas that are not served by the

converted well, so that the content of these containers will not

accidentally enter the converted well.

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20

Attachment D

Special Terms Used this Guidance Document

Included below are definitions that were added or modified as a result of the Class V

Rule. Readers seeking additional information or clarification are directed to the preamble of the final rule and 40 CFR §§ 144.3 and 146.3.

Cesspool means a "drywell" that receives untreated sanitary waste containing human

excreta, and which sometimes has an open bottom and/or perforated sides.

Drywell means a well, other than an improved sinkhole or subsurface fluid distribution

system, completed above the water table so that its bottom and sides are typically dry

except when receiving fluids.

Improved sinkhole means a naturally occurring karst depression or other natural

crevice found in volcanic terrain and other geologic settings which have been modified

by man for the purpose of directing and emplacing fluids into the subsurface.

Motor Vehicle Waste Disposal Well means a well that receives or has received

fluids from vehicular repair or maintenance activities, such as an auto body repair shop,

automotive repair shop, new and used car dealership, specialty repair shop (e.g., transmission and muffler repair shop), or any facility that does any vehicular repair work.

Point of Injection means the last accessible sampling point prior to waste fluids

being released into the subsurface environment through a Class V injection well. For

example, the point of injection of a Class V septic system might be the distribution box -

the last accessible sampling point before the waste fluids drain into the underlying soils.

For a drywell, it is likely to be the well bore itself.

Sanitary Waste means liquid or solid wastes originating solely from humans and

human activities, such as wastes collected from toilets, showers, wash basins, sinks

used for cleaning domestic areas, sinks used for food preparation, clothes washing operations, and sinks or washing machines where food and beverage serving dishes, glasses, and utensils are cleaned. Sources of these wastes may include single or multiple residences, hotels and motels, restaurants, bunkhouses, schools, ranger stations, crew
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quarters, guard stations, campgrounds, picnic grounds, day-use recreation areas, other

commercial facilities, and industrial facilities provided the waste is not mixed with industrial waste.

Septic system means a "well" that is used to emplace sanitary waste below the surface and is typically comprised of a septic tank and subsurface fluid distribution system

or disposal system.

Subsurface fluid distribution system means an assemblage of perforated pipes,

drain tiles, or other similar mechanisms intended to distribute fluids below the surface of

the ground.

Well means a bored, drilled, or driven shaft whose depth is greater than the largest surface dimension; or, a dug hole whose depth is greater than the largest surface dimension; or, an improved sinkhole; or, a subsurface fluid distribution system.

Well injection means the subsurface emplacement of fluids through a well.