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
September 30, 1999

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 1

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 greywater 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 coinoperated 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
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 2

Virginia, New York, 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 York 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 1987 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.

1

 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 watersoluble 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.
September 30, 1999 3

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 selfservice 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 drycleaning 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 4

Table 1. Inventory of Wells at Laundromats Without Drycleaning in the U.S.

State Documented 

Number of Wells

Estimated Number of Wells

Number Source of Estimate and Methodology1

USEPA Region 1

MA 9 >9 State staff suspect more wells exist in MA than documented.

M E 80 <80 State staff suspect fewer wells exist in ME than documented. 

USEPA Region 2

NJ <28 <28 N/A

NY <174 1,000 Best professional judgement. 

VI 0 50 Region estimate based on review of inspection reports and

business directory.

USEPA Region 3

WV <223 >223 Best professional judgement.

USEPA Region 4

AL <162 >162 State staff estimate that more than the documented number of

other industrial wells exist.

FL 4 >4 State staff suspect more wells exist, but no statewide

inventory is available.

MS 6 820 Best professional judgement, based on 10 laundromats without

dry cleaning per county times 82 counties.

TN 2 >2 State staff suspect more wells exist in TN than documented.

USEPA Region 5

MI 4 4 N/A

WI 4 >4 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

M T 0 10 Estimate based on USEPA Region 8 records.
Table 1. Inventory of Wells at Laundromats Without Drycleaning in the U.S.

(Continued)

State Documented 

Number of Wells

Estimated Number of Wells

Number Source of Estimate and Methodology1

September 30, 1999 5

USEPA Region 9

CA 0 50 Best professional judgement.

HI 4 4 N/A

NV 0 10-20 Best professional judgement and gross estimates.

USEPA Region 10

AK 0 10 Best professional judgement.

OR 0 15 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 6

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 York

Paramete

r

Treatment Type

Drinking

Water

Standards

(*)

Health

Advisory

Levels

(**)

F&C F&C F & DAF

Non

e

Non

e M/C

Non

e C&R C&R

mg/

l

P/

S

mg/

l N/C

pH (SU) 9 NA 7 NA NA NA 9.1 NA NA 6.5-

8.5

S -

TSS (mg/l) 4 27 28 40 42 <5 8 21 30 - -

TDS (mg/l) 167 604 1130 NA 382 NA 726 NA NA 500 S -

Oil &

Grease

(mg/l)

3 <5 <5 <5 <5 <5 <10 <5 6.3 - -

MBAS

(mg/l)

0.31 16.4 50.1 50.1 47 0.92 75 22.9 2 - -

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-1 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 7

Table 3. Summary of Injectate Quality Data from A&J Suds & Scrub, Libby, Montana

Parameter

Concentrations

(mg/l)

Drinking Water

Standards (*)

Health Advisory

Levels (**)

11/05/97 1/12/98 7/27/98 mg/l P/S mg/l N/C

Aluminum, Total 13 NA NA 0.05-0.2 S -

Antimony, Total <0.003 NA NA 0.006 P 0.003 N

Arsenic, Total <0.025 NA NA 0.05 P 0.002 C

Barium, Total <1 NA NA 2 P 2 N

Benzene NA <0.0005 <0.0005 0.005 P 0.1 C

Beryllium, Total <0.002 NA NA 0.004 P 0.0008 C

Bromodichloromethane NA <0.0005J † <0.0005 0.1/0.08 ‡ P 0.06 C

Bromoform NA <0.0005 <0.0005 0.1/0.08 ‡ P 0.4 C

Bromomethane NA <0.0005 <0.0005 - 0.01 N

Cadmium, Total 0.0064 NA NA 0.005 P 0.005 N

Carbon Tetrachloride NA <0.0005 <0.0005 0.005 P 0.03 C

Chlorodibromomethane NA <0.0005 <0.0005 0.1/0.08 ‡ P 0.06 N

Chloroform NA 0.015 0.009 0.1/0.08 ‡ P 0.6 C

Chloromethane NA <0.0005 <0.0005 - 0.003 N

2-Chlorotoluene NA <0.0005 <0.0005 - 0.1 N

4-Chlorotoluene NA <0.0005 <0.0005 - 0.1 N

Chromium, Total <0.05 NA NA 0.1 P 0.1 N

Copper, Total <0.5 NA NA 1.3 P -

1,2-Dichlorobenzene NA <0.0005 <0.0005 0.6 P 0.6 N

1,3-Dichlorobenzene NA <0.0005 <0.0005 - 0.6 N

1,4-Dichlorobenzene NA <0.0005 <0.0005 0.075 P 0.075 N

Dichlorodifluoromethane NA <0.0005 <0.0005 - 1.0 N

1,2-Dicholoroethane NA <0.0005 <0.0005 0.005 P 0.04 C

1,1-Dichloroethene NA <0.0005 <0.0005 0.007 P 0.007 N

cis-1,2-Dichloroethene NA <0.0005 <0.0005 0.07 P 0.07 N

trans-1,2-Dichloroethene NA <0.0005 <0.0005 0.1 P 0.1 N

1,2-Dichloropropane NA <0.0005 <0.0005 0.005 P 0.06 C

Ethylbenzene NA <0.0005 <0.0005 0.7 P 0.7 N

Fluorotrichloromethane NA <0.0005 <0.0005 - 2 N

Hexachlorobutadiene NA <0.0005 <0.0005 - 0.001 N
Table 3. Summary of Injectate Quality Data from A&J Suds & Scrub, Libby, Montana

(Continued)

Parameter

Concentrations

(mg/l)

Drinking Water

Standards (*)

Health Advisory

Levels (**)

11/05/97 1/12/98 7/27/98 mg/l P/S mg/l N/C

September 30, 1999 8

Iron, Total 12.5 NA NA 0.3 S -

p-Isopropyltoluene NA 0.0012 <0.0005J † - -

Lead, Total 0.0453 NA NA 0.015 P -

Manganese, Total 0.474 NA NA 0.05 S -

Mercury, Total <0.001 NA NA 0.002 P 0.002 N

Methylene chloride NA <.0005 0.00081 0.005 P -

Naphthalene NA <0.0005J † 0.00056 - 0.02 N

Nickel, Total <0.05 NA NA 0.1 P 0.1 N

Selenium, Total <0.025 NA NA 0.05 P -

Silver, Total <0.005 NA NA 0.1 S 0.1 N

Styrene NA <0.0005 <0.0005 0.1 P 0.1 N

1,1,1,2-Tetrachloroethane NA <0.0005 <0.0005 - 0.07 N

1,2,3-Trichloropropane NA <0.0005 <0.0005 - 0.04/0.5 N/C

Tetrachloroethene NA 0.00085 0.00085 0.005 P -

Thallium, Total <0.001 NA NA 0.002 P 0.0005 N

Toluene NA <0.0005J † 0.0021 1 P 1 N

1,2,4-Trichlorobenzene NA <0.0005 <0.0005 0.07 P 0.07 N

1,1,1-Trichloroethane NA <0.0005 <0.0005 0.2 P 0.2 N

1,1,2-Trichloroethane NA <0.0005 <0.0005 0.005 P 0.003 N

Vinyl Chloride NA <0.0005 <0.0005 0.002 P 0.0015 C

Xylenes NA <0.0005J † 0.00059 10 P 10 N

m+p Xylene NA <0.0005J † 0.00059 10 P 10 N

o Xylene NA <0.0005 <0.0005 10 P 10 N

Zinc, Total <2.5 NA NA 5 S 2 N

Source: USEPA Region 8, 1999.

* Drinking Water Standards: P= Primary; S= Secondary.

** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.

† 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 0.08.

- No standards or advisory levels available.
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 Volume 4 of the Class V UIC Study for a

summary of carwash wells).

September 30, 1999 9

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.
September 30, 1999 10

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

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 York, 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
3

 May 2003 is the deadline including an 18-month extension.

September 30, 1999 11

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
September 30, 1999 12

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. 

C 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. 

C 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 13

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 14

ATTACHMENT A

INJECTATE QUALITY DATA FOR

WELLS THAT INJECT FLUID FROM LAUNDROMATS WITHOUT DRY CLEANING

Table A-1. Injectate Quality Data from A&J Suds & Scrub, Libby, Montanaa

Parameter

Concentrations

(mg/l)

Drinking Water

Standards (*)

Health Advisory

Levels (**)

11/05/97 1/12/98 7/27/98 mg/l P/S mg/l N/C

Aluminum, Total 13 NA NA 0.05-0.2 S - -

Aluminum, Dissolved 0.494 NA NA - - - -

Antimony, Total <0.003 NA NA 0.006 P 0.003 N

Antimony, Dissolved <0.003 NA NA - - - -

Arsenic, Total <0.025 NA NA 0.05 P 0.002 C

Arsenic, Dissolved <0.025 NA NA - - - -

Barium, Total <1 NA NA 2 P 2 N

Barium, Dissolved <1 NA NA - - - -

Benzene NA <0.0005 <0.0005 0.005 P 0.1 C

Beryllium, Total <0.002 NA NA 0.004 P 0.0008 C

Beryllium, Dissolved <0.002 NA NA - - - -

Bromobenzene NA <0.0005 <0.0005 - - - -

Bromochloromethane NA <0.0005 <0.0005 - - 0.01 N

Bromodichloromethane NA <0.0005J † <0.0005 0.1/0.08 ‡ P 0.06 C

Bromoform NA <0.0005 <0.0005 0.1/0.08 ‡ P 0.4 C

Bromomethane NA <0.0005 <0.0005 - - 0.01 N

n-Butylbenzene NA <0.0005 <0.0005 - - - -

sec-Butylbenzene NA <0.0005 <0.0005 - - - -

tert-Butylbenzene NA <0.0005 <0.0005 - - - -

Cadmium, Total 0.0064 NA NA 0.005 P 0.005 N

Cadmium, Dissolved 0.0064 NA NA - - - -

Carbon Tetrachloride NA <0.0005 <0.0005 0.005 P 0.03 C

Chlorobenzene NA <0.0005 <0.0005 - - - -

Chlorodibromomethane NA <0.0005 <0.0005 0.1/0.08 ‡ P 0.06 N

Chloroethane NA <0.0005 <0.0005 - - - -

Chloroform†† NA 0.015 0.009 0.1/0.08 ‡ P 0.6 C
Table A-1. Injectate Quality Data from A&J Suds & Scrub, Libby, Montanaa

(Continued)

Parameter

Concentrations

(mg/l)

Drinking Water

Standards (*)

Health Advisory

Levels (**)

11/05/97 1/12/98 7/27/98 mg/l P/S mg/l N/C

September 30, 1999 15

Chloromethane NA <0.0005 <0.0005 - - 0.003 N

2-Chlorotoluene NA <0.0005 <0.0005 - - 0.1 N

4-Chlorotoluene NA <0.0005 <0.0005 - - 0.1 N

Chromium, Total <0.05 NA NA 0.1 P 0.1 N

Chromium, Dissolved <0.05 NA NA - - - -

Copper, Total <0.5 NA NA 1.3 P - -

Copper, Dissolved <0.5 NA NA - - - -

1,2-Dibromo-3-chloropropane NA <0.001 <0.001 - - - -

1,2-Dibromoethane NA <0.0005 <0.0005 - - - -

Dibromomethane NA <0.0005 <0.0005 - - - -

1,2-Dichlorobenzene NA <0.0005 <0.0005 0.6 P 0.6 N

1,3-Dichlorobenzene NA <0.0005 <0.0005 - - 0.6 N

1,4-Dichlorobenzene NA <0.0005 <0.0005 0.075 P 0.075 N

Dichlorodifluoromethane NA <0.0005 <0.0005 - - 1.0 N

1,1-Dichloroethane NA <0.0005 <0.0005 - - - -

1,2-Dicholoroethane NA <0.0005 <0.0005 0.005 P 0.04 C

1,1-Dichloroethene NA <0.0005 <0.0005 0.007 P 0.007 N

cis-1,2-Dichloroethene NA <0.0005 <0.0005 0.07 P 0.07 N

trans-1,2-Dichloroethene NA <0.0005 <0.0005 0.1 P 0.1 N

1,1-Dichloropropene NA <0.0005 <0.0005 - - - -

1,2-Dichloropropane NA <0.0005 <0.0005 0.005 P 0.06 C

1,3-Dichloropropane NA <0.0005 <0.0005 - - - -

cis-1,3-Dichloropropene NA <0.0005 <0.0005 - - - -

trans-1,3-Dichloropropene NA <0.0005 <0.0005 - - - -

2,2-Dichloropropane NA <0.0005 <0.0005 - - - -

Ethylbenzene NA <0.0005 <0.0005 0.7 P 0.7 N

Fluorotrichloromethane NA <0.0005 <0.0005 - - 2 N

Hexachlorobutadiene NA <0.0005 <0.0005 - - 0.001 N

Iron, Total 12.5 NA NA 0.3 S - -
Table A-1. Injectate Quality Data from A&J Suds & Scrub, Libby, Montanaa

(Continued)

Parameter

Concentrations

(mg/l)

Drinking Water

Standards (*)

Health Advisory

Levels (**)

11/05/97 1/12/98 7/27/98 mg/l P/S mg/l N/C

September 30, 1999 16

Iron, Dissolved 0.44 NA NA - - - -

Isopropylbenzene NA <0.0005 <0.0005 - - - -

p-Isopropyltoluene NA 0.0012 <0.0005J † - - - -

Lead, Total 0.0453 NA NA 0.015 P - -

Lead, Dissolved 0.0084 NA NA - - - -

Manganese, Total 0.474 NA NA 0.05 S - -

Manganese, Dissolved 0.216 NA NA - - - -

Mercury, Total <0.001 NA NA 0.002 P 0.002 N

Mercury, Dissolved <0.001 NA NA - - - -

Methylene chloride NA <.0005 0.00081 .005 P - -

Naphthalene NA <0.0005J † 0.00056 - - 0.02 N

Nickel, Total <0.05 NA NA 0.1 P 0.1 N

Nickel, Dissolved <0.05 NA NA - - - -

n-Propylbenzene NA <0.0005 <0.0005 - - - -

Selenium, Total <0.025 NA NA 0.05 P - -

Selenium, Dissolved <0.025 NA NA - - - -

Silver, Total <0.005 NA NA 0.1 S 0.1 N

Silver, Dissolved <0.005 NA NA - - - -

Styrene NA <0.0005 <0.0005 0.1 P 0.1 N

1,1,1,2-Tetrachloroethane NA <0.0005 <0.0005 - - 0.07 N

1,1,2,2-Tetrachloroethane NA <0.0005 <0.0005 - - - -

1,2,3-Tetrachlorobenzene NA <0.0005 <0.0005 - - - -

1,2,3-Trichloropropane NA <0.0005 <0.0005 - - 0.04/0.5 N/C

1,2,4-Trimethylbenzene NA <0.0005J † <0.0005 - - - -

1,3,5-Trimethylbenzene NA <0.0005 <0.0005 - - - -

Tetrachloroethene NA 0.00085 0.00085 .005 P - -

Thallium, Total <0.001 NA NA 0.002 P 0.0005 N

Thallium, Dissolved <0.001 NA NA - - - -

Toluene NA <0.0005J † 0.0021 1 P 1 N
Table A-1. Injectate Quality Data from A&J Suds & Scrub, Libby, Montanaa

(Continued)

Parameter

Concentrations

(mg/l)

Drinking Water

Standards (*)

Health Advisory

Levels (**)

11/05/97 1/12/98 7/27/98 mg/l P/S mg/l N/C

September 30, 1999 17

1,2,4-Trichlorobenzene NA <0.0005 <0.0005 0.07 P 0.07 N

1,1,1-Trichloroethane NA <0.0005 <0.0005 0.2 P 0.2 N

1,1,2-Trichloroethane NA <0.0005 <0.0005 0.005 P 0.003 N

Trichloroethene NA <0.0005 <0.0005 - - - -

Vinyl Chloride NA <0.0005 <0.0005 0.002 P 0.0015 C

Xylenes NA <0.0005J † 0.00059 10 P 10 N

m+p Xylene NA <0.0005J † 0.00059 10 P 10 N

o Xylene NA <0.0005 <0.0005 10 P 10 N

Zinc, Total <2.5 NA NA 5 S 2 N

Zinc, Dissolved <2.5 NA NA - - - -

Source: USEPA Region 8, 1999.

aThe 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.

† 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.

†† Chloroform is a disinfection byproduct.
September 30, 1999 18

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):

C facility name and location;

C name of owner and operator;

C legal contact;

C depth, general description, and use of the injection well; and

C 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 III 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 III 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 (335-6-8-.25 AAC).

Construction requirements also are specified for all injection wells. However, Class V wells are

specifically exempted (335-6-8-.25 AAC). They are required to be constructed in such a manner that
September 30, 1999 19

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

(335-6-8-.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-.28 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 (335-6-8-.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 IV.K.2.e. and IV.K.3.). 
September 30, 1999 20

For Class V wells associated with laundromats, no additional requirements or exceptions have been

enacted. Therefore, only the requirements in 40 CFR apply.

New York

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 21

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.1

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’s UIC 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 22

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.

Wyoming

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).
September 30, 1999 23

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 24

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.html#Define (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.