United States Office of Ground Water EPA/816-R-99-014d

Environmental and Drinking Water (4601) September 1999

Protection Agency 

The Class V Underground Injection

Control Study

Volume 4

Wells That Inject Fluids From Carwashes 

Without Engine or Undercarriage

Cleaning
September 30, 1999

Table of Contents

Page

1. Summary ............................................................... 1

2. Introduction ............................................................. 3

3. Prevalence of Wells ....................................................... 4

4. Wastewater Characteristics and Injection Practices ................................ 6

4.1 Injectate Characteristics .............................................. 7

4.2 Well Characteristics ................................................ 10

5. Potential and Documented Damage to USDWs ................................. 18

5.1 Injectate Constituent Properties ....................................... 18

5.2 Observed Impacts ................................................. 18

6. Best Management Practices ................................................ 19

7. Current Regulatory Requirements ............................................ 20

7.1 Federal Programs .................................................. 20

7.1.1 SDWA .................................................... 20

7.1.2 CWA ..................................................... 22

7.2 State and Local Programs ........................................... 22

Attachment A: Injectate Quality Data For Wells That Inject Fluid from Carwashes Without Engine or

Undercarriage Cleaning ............................................. 24

Attachment B: State and Local Program Descriptions .................................. 35

References ................................................................... 45
1

 Class V wells used to inject fluids from carwashes where engine or undercarriage washing is

performed were classified as industrial wells and wells that receive both carwash wastewater and waste

fluids from vehicle maintenance activities were classified as motor vehicle waste disposal wells in the July

29, 1998 proposed revisions to the USEPA Class V UIC regulations.

September 30, 1999 1

WELLS AT CARWASHES WITHOUT ENGINE OR

UNDERCARRIAGE CLEANING

The U.S. Environmental Protection Agency (USEPA) conducted a study of Class V

underground injection wells to develop background information the Agency can use to evaluate the risk

that these wells pose to underground sources of drinking water (USDWs) and to determine whether

additional federal regulation is warranted. The final report for this study, which is called the Class V

Underground Injection Control (UIC) Study, consists of 23 volumes and five supporting appendices. 

Volume 1 provides an overview of the study methods, the USEPA UIC Program, and general findings. 

Volumes 2 through 23 present information summaries for each of the 23 categories of wells that were

studied (Volume 21 covers 2 well categories). This volume, which is Volume 4, covers Class V wells

at carwashes without engine or undercarriage cleaning.

1. SUMMARY

Wells used to dispose of washwater that was used to wash only the exterior of vehicles

(sometimes called “wand washes”) are the only carwash wells within the scope of this volume of the

Class V UIC Study.

1

 These are typically located at coin-operated, manual carwashes where people

use hand-held hoses to wash vehicles. Even though the term “carwash” is used, the category includes

wells that receive used washwater at facilities designed for washing all kinds of vehicles, including cars,

vans, trucks, buses, boats on trailers, etc. 

The cleaning solutions used at these carwashes generally consist of soap solutions, rinsewater,

and wax, and are not expected to contain significant amounts of degreasing agents or solvents such as

methylene chloride or trichloroethylene (because these wells, as defined, are not supposed to be

receiving engine or undercarriage washwater, which is more likely to contain such substances). As a

result, the spent washwater disposed in a carwash well (as defined in this report) primarily contains

detergents, road salts, sediments, and incidental contaminants that may be washed from a vehicle’s

exterior, comparable to typical storm water runoff. Although there are no data on the issue, there is

also concern that de-icing agents may be rinsed from cars and enter ground water. The data available

on the quality of fluids entering carwash wells indicate that the concentrations of antimony, arsenic,

beryllium, cadmium, lead, and thallium in the injectate typically exceed primary drinking water maximum

contaminant levels (MCLs) and health advisory levels (HALs). Some samples show that ethylene

glycol, methylene chloride, naphthalene, and tetrachloroethene also have exceeded primary MCLs or

HALs, indicating that degreasers may in fact be working their way into the washwater at some facilities. 

Injectate pH and aluminum, iron, and manganese concentrations exceed secondary MCLs.
September 30, 1999 2

Two possible contamination incidents involving carwash wells were reported in Hawaii in the

early 1990s. The nature and extent of contamination are unknown, but both wells were closed.

Although there are only these two reported contamination incidents associated with carwash

wells, there is concern over the potential for such wells to be vulnerable to spills or illicit discharges. 

Because the facilities are usually unsupervised (meaning an attendant is not onsite), individuals may in

fact wash their engines or undercarriages using degreasers, wash the exterior of their vehicles with

chemicals other than common soap solutions, or may pour used oil, antifreeze, or other hazardous

materials down these drains. No actual contamination incidents associated with this kind of illicit

discharge, however, were discovered during the course of this study. Industry representatives also

assert that illegal dumping of unauthorized materials into drains at self-service carwashes is less of a

problem now than in the past, due to increased environmental awareness and the greater availability of

hazardous material collection centers.

The inventory results for these wells are very uncertain because most responses to the state and

USEPA Regional survey conducted for this study did not distinguish carwash wells from other kinds of

commercial or industrial wells. These survey results suggest that there are up to 4,651 documented

carwash wells and approximately 7,192 estimated carwash wells in the U.S. Although the wells are

documented in 14 states, 99 percent of the documented wells and 98 percent of the estimated wells are

located in nine states: Alabama, Mississippi, New York, Washington, Maryland, Iowa, West Virginia,

California, and Maine. Many states estimate that more than the documented number of wells exist,

although these estimates are typically based only on best professional judgment and the true number of

wells is unknown. As sewer system hookups become increasingly available to carwash owners, it is

expected that the number of Class V carwash wells will decrease. Many states close carwash wells

when they find them. 

Although West Virginia permits carwash wells by rule (in accordance with the existing federal

UIC program), other states with the majority of documented and estimated carwash wells are

developing and implementing more extensive regulatory programs to address these wells. Specifically:

C Alabama, Maryland, Mississippi, New Hampshire, New York, and Washington (when the well

meets best management practice requirements) issue individual permits.

C California requires reporting of discharges from carwash wells.

C Iowa bans carwash wells.

C Maine issues discharge licenses for new wells and permits for existing wells.
September 30, 1999 3

2. INTRODUCTION

Wells that inject wastewater from carwashes qualify as Class V injection wells as long as the

wastewater is not a hazardous waste as defined under the Resource Conservation and Recovery Act

(RCRA) and implementing regulations. Using the existing list of Class V well types in 40 CFR

§146.5(e), carwash disposal wells are either “dry wells used for the injection of wastes into a

subsurface formation” (per §146.5(e)(5)), or if the wastewater is disposed via a septic system, “septic

system wells used to inject the waste or effluent from ... a business establishment” (per §146.5(e)(9)). 

In the 1987 Class V UIC Report to Congress, carwash wastewater disposal wells were considered to

be industrial process water and waste disposal (5W20) wells (USEPA, 1987). 

Carwashes are commonly divided into three types: tunnel, rollover, and wand. These different

types of carwashes are characterized in the following way in USEPA’s development document for

effluent limitations guidelines and standards for the “auto laundries” point source category (USEPA,

1980):

C Tunnel wash: This is the most common type of carwash in the U.S. and is usually housed in a

long building. The vehicle is pulled by a conveyer or driven through the length of the building,

passing through separate washing, rinsing, waxing, and drying areas. In the washing area,

detergents and water are applied and dirt is mechanically removed either by brushes or highpressure streams of water. The vehicle is then rinsed with clean water to remove the dirt and

soap. Finally, the vehicle is dried, usually by a blower. All of the used wash and rinse water is

collected in a floor trench. In many tunnel washes, the wash and rinse waters are kept separate

by a dam placed in the trench.

C Rollover wash: In a rollover wash, the vehicle remains stationary while the washing equipment

passes over the vehicle. This is similar in design to exterior pressure washes that utilize highpressure streams of water in lieu of brushes. At both of these types of carwashes, all of the

wastewater is collected in a single trench, usually situated beneath the vehicle.

C Wand wash: In this type of wash, the car remains stationary in a garage-type structure (called

a bay) while the customer washes the vehicle using a high-pressure stream of soap and water

from a hand-held wand. The wash and rinse waters are typically collected in a single trench or

sump.

On July 29, 1998 (63 FR 40586), USEPA proposed revisions to the Class V UIC regulations. 

This notice proposed to put wells used to inject fluids from carwashes into two different well categories

depending on whether the carwashes perform engine or undercarriage washing (see 63 FR 40599). 

Wells at carwashes “that are specifically set up to perform engine or undercarriage washing” would be

included in the “industrial well” category. By contrast, wells at coin-operated, manual carwashes where

people use hand-held hoses to wash only the exterior of vehicles would be classified as “other industrial
2

 The wells in the proposed “other industrial well” category are: (1) wells used to inject fluids from

carwashes that are not specifically set up to perform engine or undercarriage washing; (2) wells used to

inject noncontact cooling water that contains no additives and has not been chemically altered; (3) wells

used to inject fluids from laundromats where no onsite dry cleaning is performed or where no organic

solvents are used for laundering; and (4) wells used to inject wastewater from food processing operations. 

The other three kinds of wells included in the other industrial well category are addressed in separate

volumes of the Class V Study.

September 30, 1999 4

wells,”2 as would those at any other vehicle washing facility not set up to perform engine or

undercarriage washing.

Following this proposed distinction, this volume of the Class V UIC study focuses only on wells

that inject fluids from carwashes where no engine or undercarriage washing is performed. These are

primarily wand wash facilities described above, although USEPA recognizes that engine or

undercarriage washing can and does occur at some wand washes.

3. PREVALENCE OF WELLS

For this study, data on the number of Class V carwash wells were collected through a survey of

state and USEPA Regional UIC Programs. The survey methods are summarized in Section 4 of

Volume 1 of the Class V Study. Table 1 lists the numbers of Class V carwash wells in each state, as

determined from this survey. The table includes the documented number and estimated number of wells

in each state, along with the source and basis for any estimate, when noted by the survey respondents. 

If a state is not listed in Table 1, it means that the UIC Program responsible for that state indicated in its

survey response that it did not have any Class V carwash wells.

Many states and USEPA Regions administering the UIC program acknowledge that wells at

carwashes without engine or undercarriage cleaning probably exist, but they have not been able to

determine exactly how many exist for a variety of reasons. Chief among these reasons is that many

states do not permit or inventory these wells. Other states group carwash wells with wells at

laundromats or with other industrial wells. 

Ninety-nine percent of the documented wells and 98 percent of the estimated wells are located

in nine states: Alabama, California, Iowa, Maine, Maryland, Mississippi, New York, Washington, and

West Virginia. Washington reports the largest number of wells, 3,900. However, this number is an

estimate based on the number of registered non-contact cooling water wells and carwash wells (both

with and without engine or undercarriage cleaning) in the state. These wells are grouped together in one

category and, according to state staff, cannot be differentiated in the state’s records. Several other

states also group carwash wells with other well categories and report a single documented number

based on the total number of registered wells in those categories: New York (<174), West Virginia

(<223), Alabama (<162), and New Jersey (<28). Only three other states document more than 10

carwash wells: New Hampshire (as many
September 30, 1999 5

Table 1. Inventory of Wells at Carwashes Without Undercarriage

or Engine Cleaning in the U.S.

State

Documented 

Number of

Wells

Estimated Number of Wells

Number Source of Estimate and Methodology1

USEPA Region 1

MA 6 >6 No estimate provided, but state suspects more than 6 exist.

M E 63 <63 Best professional judgement. No estimate provided, but state suspects

that fewer wells exist than documented. 

NH

11 (response)

14(inventory)

11 (response)

14(inventory

)

The documented number of wells is inaccurate because they are found

only when inspections are performed. 

USEPA Region 2

NJ <28 <28 Permits database documents 28 “other industrial” wells, of which carwash

wells are a subset.

NY <174 1,000 Estimate of 1,000 “other industrial” wells based on best professional

judgement. 

VI 0 50 Region 2 estimate based on review of inspection reports and business

directory.

USEPA Region 3

MD 38 >38 No estimate provided, but state suspects more than 38 exist. 

WV <223 >223 Based on best professional judgement, state estimates that more than 223

other industrial wells exist.

USEPA Region 4

AL <162 >162 162 represents the number of permitted other industrial wells. State

estimates that more than 162 other industrial wells exist.

MS 9 410 Estimate based on best professional judgement; 5 carwashes in each of 82

counties.

USEPA Region 5

MI $8 $8 N/A

USEPA Region 6 -- None

USEPA Region 7

IA NR >1,000 Best professional judgement based on ten years of Iowa experience and

discussions with trade organizations and county sanitarians.
Table 1. Inventory of Wells at Carwashes Without Undercarriage

or Engine Cleaning in the U.S. (Continued)

State

Documented 

Number of

Wells

Estimated Number of Wells

Number Source of Estimate and Methodology1

September 30, 1999 6

USEPA Region 8

WY 0 3 Estimate provided by Robert Lucht, Wyoming Department of

Environmental Quality, Water Quality Division.

USEPA Region 9

CA 20 220 Best professional judgement.

HI 5 5 N/A

NV 0 30 Best professional judgement and gross estimates.

USEPA Region 10

AK 1 10 Best professional judgement.

OR 0 25 Wells are closed when found; the number of existing wells is not

documented.

WA <3,900 >3,900 No estimate provided, but state expects that more wells exist. 

All USEPA Regions

All

States 4,651 +/- 7,195 +/-

As indicated above, many of these documented and estimated numbers are

for all types of “other industrial” wells, of which carwash wells are a

subset.

1

 Unless otherwise noted, the best professional judgement is that of the state or USEPA Regional staff completing the survey

questionnaire.

N/A Not available.

NR Not reported.

as 14), Maryland (38), and California (20). Many states estimate that more than the documented

number of wells exist.

4. WASTEWATER CHARACTERISTICS AND INJECTION

PRACTICES

Very little information is available on the characteristics of carwash well injectate. There are

several reasons for this lack of data. First, these wells are often not a high priority for state programs. 

Instead of requesting sampling and analysis of injectate, states may simply close the wells when they are

discovered. Second, wells that receive carwash water often receive wastes from car maintenance

areas or from carwashes that also clean engines or undercarriages, qualifying the wells as motor vehicle
September 30, 1999 7

waste disposal wells or industrial wells. The injectate going into these wells is not representative of that

entering carwash wells as defined for the purpose of this study.

The information that is available for carwash injectate is presented in Section 4.1 below. This is

followed by a summary of the limited information available on carwash well design characteristics

(Section 4.2) and operational practices (Section 4.3).

4.1 Injectate Characteristics

Injectate from carwashes has been shown by limited data to contain detergents, dissolved solids

(salts), elevated biochemical oxygen demand levels, and elevated levels of suspended solids (sand and

grit) (NC DEHNR, 1997 and USEPA, 1994). Some detergents may contain metals such as arsenic

and nutrients such as phosphorus and nitrogen (ECOL, 1995). The injectate also often contains metals

(lead and chromium, among others), volatile organic compounds (VOCs), and oils and grease. 

However, metals are not expected in appreciable concentrations at carwashes that do not perform

engine or undercarriage washing. 

The injectate characteristics information presented in this section is based on data from 16

carwash facilities in New York, one sampling event each in 1997 at two carwashes in Montana,

sampling events at 17 carwash facilities in Maryland, and three sampling events at a combined carwash

and laundromat facility in Montana in the 1997 to 1998 time period. The quality of the background or

feed (i.e., source) water was not measured in any of these events, even though it could affect the quality

of the injectate samples.

The New York Department of Environmental Conservation sampled 16 wells at carwashes

without engine or undercarriage cleaning in Suffolk and Nassau counties, New York. The complete

data set is included as Table A-1 in Attachment A to this volume. The injectate was sampled and

analyzed following any type of water treatment that may have occurred, which is indicated on the table. 

State officials explained that, although these facilities are not set up to perform undercarriage or engine

washing, it is possible that these activities could occur at the two self-service facilities. Table 2 presents

a summary of the parameters for which there are MCLs and/or HALs. 

The most common inorganic constituents present in the New York carwash well injectate are

total Kjeldahl nitrogen (TKN), chloride, methylene blue active substance (MBAS), oil and grease, total

dissolved solids (TDS), and total suspended solids (TSS). Of the detected inorganic constituents, only

chloride and TDS exceeded the secondary MCLs. In addition, several metals were detected above

the MCLs: aluminum, antimony, beryllium, cadmium, iron, lead, and thallium. Of these, the following

metals also exceeded the HALs: antimony, arsenic, beryllium, cadmium, and thallium. Of the detected

organic constituents, methylene chloride and tetrachloroethene were present above the primary MCLs.
September 30, 1999 8

Table 2. Summary of Data from Car Wash Samples in New York

Parameter Number of 

Observations

Range of

Concentrations

(mg/l)

Drinking Water

Standards*

Health Advisory

Levels**

mg/l P/S mg/l N/C

Chloride 14 10.8 - 302 250 S -

Nitrite 8 <.05 - 0.931 1 P -

Nitrate 8 <.05 - 3.71 10 P -

TDS 7 230 - 546.0 500 S -

Chloroform 5 0.001 - 0.057 0.1/0.08† P 0.6 C

Ethylbenzene 3 0.001 - 0.017 0.7 P 0.7 N

Methylene Chloride 3 0.0017 - 0.016 0.005 P -

Tetrachloroethene 1 0.079 0.005 P -

Toluene 4 0.0012 - 0.038 1 P 1 N

Xylene 1 0.017 10 P 10 N

m+p-Xylene 3 0.0045 - 0.060 10 P 10 N

o-Xylene 3 0.002 - 0.013 10 P 10 N

Aluminum 15 0.295 - 13.100 0.05 - 0.2 S -

Antimony 15 0.0066 - 0.123 0.006 P 0.003 N

Arsenic 1 0.0032 0.05 P 0.002 C

Beryllium 2 0.0014 - 0.026 0.004 P 0.0008 C

Cadmium 16 0.001 - 0.009 0.005 P 0.005 N

Chromium 15 0.001 - 0.0278 0.1 P 0.1 N

Copper 16 0.0139 - 0.460 1.3 S -

Iron 15 2.120 - 19.700 0.3 S -

Lead 16 0.0044 - 0.0598 0.015 P -

Nickel 16 0.0118 - 0.0682 0.1 P 0.1 N

Selenium 1 0.0026 0.05 P -

Silver 3 0.0011 - 0.007 0.1 S 0.1 N

Thallium 4 0.0024 - 0.0068 0.002 P 0.0005 N

Zinc 16 0.0895 - 0.482 5 S 2 N

Source: New York Department of Environmental Conservation, 1999

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

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

-No standards or advisory levels available.

†0.1 is the current MCL, 0.08 is the proposed rule for Disinfectants and Disinfection By-products: Total for all THMs combined

cannot exceed the 0.08.
September 30, 1999 9

Table 3 summarizes quality data for injectate sampled at Dano’s Carwash and Libby Auto, two

carwash facilities in Libby, Montana, in 1997. The complete data set is included as Table A-2 in

Attachment A to this volume. The samples were analyzed for the presence of several metals. Iron,

lead, and manganese exceeded the MCLs. In addition, the concentration of total cadmium at Libby

Auto equaled the primary MCL, and antimony exceeded the noncancer HAL. The Montana carwash

well samples were not analyzed for the presence of organic constituents. 

Table 3. Summary of Data from Carwash Samples in Montana

Parameter

Concentrations

(mg/l)

Drinking Water

Standards*

Health Advisory

Levels**

LibAuto Dano mg/l P/S mg/l N/C

Aluminum, Total 0.105 3.22 0.05-0.2 S -

Antimony, Total <0.003 0.004 0.006 P 0.003 N

Arsenic, Total <0.025 <0.025 0.05 P 0.002 C

Barium, Total <1 <1 2 P 2 N

Benzene NA NA 0.005 P 0.1 C

Beryllium, Total <0.002 <0.002 0.004 P 0.0008 C

Cadmium, Total 0.0050 <0.0025 0.005 P 0.005 N

Chromium, Total <0.05 <0.05 0.1 P 0.1 N

Chromium, Dissolved <0.05 <0.05 0.1 P 0.1 N

Copper, Total <0.5 <0.5 1.3 P -

Iron, Total 0.91 3.90 0.3 S -

Lead, Total 0.0096 0.0172 0.015 P -

Manganese, Total 0.077 0.243 0.05 S -

Mercury, Total <0.001 <0.001 0.002 P 0.002 N

Nickel, Total <0.05 <0.05 0.1 P 0.1 N

Selenium, Total <0.025 <0.025 0.05 P -

Selenium, Dissolved <0.025 <0.025 0.05 P -

Silver, Total <0.025 <0.005 0.1 S 0.1

Thallium, Total <0.001 <0.001 0.002 P 0.0005 N

Zinc, Total <2.5 <2.5 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.

-No standards or advisory levels available.
September 30, 1999 10

Table 4 displays a summary of water quality data for one sampling event at each of 17 car

dealerships and car washes in Maryland. Thirteen of these facilities are new and used car dealerships

or automotive sales and service facilities. Also included is one truck and construction equipment repair

facility; one vehicle repair, servicing, and cleaning facility; one geotechnical construction company; and

one maintenance facility for transportation vehicles. These data are for samples taken from wells

receiving exterior vehicle washwater. If a parameter is not included in the table, it was either not

detected or the sample was not analyzed for that parameter. The complete data set is included as

Table A-3 in Attachment A to this volume. Measurements of pH exceeded the upper end of the

secondary MCL range, with two of five samples above the range. Two metals, cadmium and iron,

exceeded MCLs. Cadmium was the only inorganic constituent reported above the HALs. A large

number of organic constituents were reported above detection limits in the Maryland carwash samples. 

Three of these organic constituents were reported at levels above the MCLs and HALs: ethylene

glycol, naphthalene, and tetrachloroethene.

On March 19, 1992, the Jackson Hole Airport Rental Carwash septic system in Jackson,

Wyoming was sampled. Table 5 presents the water quality data from this sampling event. None of the

organic or inorganic constituents were reported above the MCLs or HALs.

A&J Suds and Scrub in Libby, Montana, submitted the results of three sampling events as part

of the requirements for a UIC permit. The facility’s well receives a combination of carwash and

laundromat effluent. As a result, the injectate data are not entirely representative of carwash well

injectate. Table 6 summarizes these data; the complete data set is included as Table A-4 in Attachment

A to this volume. Several of the metals were reported above the MCLs: aluminum, cadmium, iron,

lead, and manganese. The cadmium concentration also exceeded the noncancer HAL. None of the

organic constituents were present in concentrations above the MCLs or HALs.

4.2 Well Characteristics

Figures 1 and 2 display standard treatment systems for wand wash carwash facilities in

Tennessee. Based on these diagrams, some wells consist of septic systems and/or sand filters. Others

may simply be dry wells. 

Arkansas strongly suggests that car and truck washing facilities include a grit chamber and

grease trap in the design of their injection wells; however, this is not a requirement (ADPC&E, 1996). 

In Wyoming, carwash septic systems are designed to accommodate 200 gallons per vehicle unless they

can show that they use a lesser amount based on the design of an automatic system (WYDEQ/WQD,

1999). No additional information is available on the design, construction, or siting of carwash wells. 
September 30, 1999 11

Table 4. Summary of Data from Carwash Samples in Maryland

Parameter Number of

Detections

Range of

Concentrations

(mg/l)

Drinking Water

Standards*

Health Advisory

Levels**

mg/l P/S mg/l N/C

pH 7 3.5 - 9.5 6.5 - 8.5 S -

Benzene 1 0.004 0.005 P 0.1 C

Chloride 1 26 250 S -

1,2-Dichlorobenzene 1 0.009 0.6 P 0.6 N

1,4-Dichlorobenzene 1 0.0065 0.075 P 0.075 N

Diethyl Phthalate 3 0.012 - 0.019 - 5 N

Ethylene Glycol 9 <.01% - 9.6 - 7 N

Ethylbenzene 3 0.025 - 0.182 0.7 P 0.7 N

Methylene Chloride 1 0.004 0.005 P -

Naphthalene 4 0.0074 - 4.620 - 0.02 N

Tetrachloroethene 2 0.002 - 0.022 0.005 P -

Toluene 6 0.016 - 0.077 1 P 1 N

Xylene 1 0.057 10 P 10 N

Cadmium 1 0.016 0.005 P 0.005 N

Chromium 1 0.008 0.1 P 0.1 N

Iron 1 2.4 0.3 S -

Lead 1 0.013 0.015 P -

Magnesium 1 14 - -

Nickel 1 0.055 0.1 P 0.1 N

Zinc 1 0.24 5 S 2 N

Source: Maryland Department of the Environment, 1999

-No standards or advisory levels available.

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

** Health Advisory Levels: N= Noncancer Lifetime; C= Cancer Risk.
September 30, 1999 12

Table 5. Data from Carwash Samples Taken at Jackson Hole Airport Carwash Facility

Parameter Concentration

(mg/l)

Drinking Water

Standards*

Health Advisory

Levels**

mg/l P/S mg/l N/C

Ammonia (as N) 0.55 - 30 N

Benzene 0.0006 0.005 P 0.1 C

Chloride 12 250 S -

Ethylbenzene 1.0 0.7 P 0.7 N

Methylene Chloride <1 0.005 P -

Nitrate 0.25 10 P -

TDS 372 500 S -

Total Phenols <0.05 - 4 N

1,2-Dichlorobenzene <0.001 0.6 P 0.6 N

1,4-Dichlorobenzene <0.001 0.075 P 0.075 N

1,1-Dichloroethane <0.001 - -

1,2-Dichloroethane <0.001 0.005 P 0.04 C

1,2-Dichloroethene <0.001 - -

1,2-Dichloropropane 0.0026 0.005 P 0.06 C

Tetrachloroethene <0.001 0.005 P -

Trichloroethene <0.001 0.005 P 0.3 C

1,1,1-Trichloroethane <0.001 0.2 P 0.2 N

Toluene <0.0005 1 P 1 N

Total Xylenes 0.0075 10 P 10 N

Arsenic <0.05 0.05 P 0.002 C

Barium 1.23 2 P 2 N

Cadmium <0.001 0.005 P 0.005 N

Chromium <0.05 0.1 P 0.1 N

Lead <0.005 0.015 P -

Mercury <0.001 0.002 P 0.002 N

Selenium <0.005 0.05 P -

Silver <0.05 - 0.1 N
Table 5. Data from Carwash Samples Taken at Jackson Hole Airport Carwash Facility

Parameter Concentration

(mg/l)

Drinking Water

Standards*

Health Advisory

Levels**

mg/l P/S mg/l N/C

September 30, 1999 13

Source: WDEQ/WQD, 1999

-No standards or advisory levels available.

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

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

Table 6. Summary of Water Quality Data from

A&J Suds & Scrub Libby, Montana

Parameter

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
Table 6. Summary of Water 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 14

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

Iron, Total 12.5 NA NA 0.3 S -

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 .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 .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
Table 6. Summary of Water 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 15

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.

NA = Not analyzed for that constituent.

- No standards or advisory levels available.

† J = Estimated value. Present, but less than the limit of quantitation.

‡ 0.1 is the current MCL, 0.08 is the proposed rule for Disinfectants and Disinfection By-products: Total for all THMs

combined cannot exceed the 0.08.
September 30, 1999 16

Figure 1. Carwash Designed with Sand Filter Oil/Water Separator
September 30, 1999 17

Figure 2. Sand Filter Oil/Water Separator Design
September 30, 1999 18

5. POTENTIAL AND DOCUMENTED DAMAGE TO USDWs

5.1 Injectate Constituent Properties

The primary constituent properties of concern when assessing the potential for Class V carwash

wells to adversely affect USDWs are toxicity, persistence, and mobility. The toxicity of a constituent is

the potential of that contaminant to cause adverse health effects if consumed by humans. Appendix D

of the Class V Study provides information on the health effects associated with contaminants found

above drinking water standards or health advisory limits in the injectate of carwash wells and other

Class V wells. As discussed in Section 4.1, the contaminants that have been observed above drinking

water standards (i.e., MCLs) or HALs in carwash well injectate are aluminum, antimony, arsenic,

beryllium, cadmium, iron, lead, thallium, manganese, chloride, pH, TDS, ethylene glycol, methylene

chloride, naphthalene, and tetrachloroethene.

Persistence is the ability of a chemical to remain unchanged in composition, chemical state, and

physical state over time. Appendix E of the Class V Study presents published half-lives of common

constituents in fluids released in carwash wells and other Class V wells. All of the values reported in

Appendix E are for ground water. Caution is advised in interpreting these values because ambient

conditions have a significant impact on the persistence of both inorganic and organic compounds. 

Appendix E also provides a discussion of mobility of certain constituents found in the injectate of

carwash wells and other Class V wells.

5.2 Observed Impacts

Hawaii state officials report that two possible contamination incidents resulted from the injection

of carwash water into a Class V well. First, Budget Rent-A-Car near the Hilo, Hawaii, airport owned

and operated a dry well to which they discharged carwash water. Although the nature and extent of

contamination were unknown, USEPA issued an administrative order in 1991 for the facility to install a

system that recycled the carwash water, and the facility complied. Second, the McKinley Carwash in

Honolulu, Hawaii, disposed of carwash water into an oil/water separator with an injection well a few

blocks from a lagoon. Although the nature and extent of contamination were unknown, the well was

closed (Cadmus, 1999). 

Five public commenters on the July 29, 1998 Class V proposed rule (63 FR 40586) described

incidents observed at self-service carwashes, where solvents have been used and engine cleaning

activities have occurred, resulting in potentially dangerous fluids being disposed in floor drains at these

facilities. Some commenters added that VOC contamination of ground water might have been caused

by the misuse of solvents at carwashes without engine or undercarriage cleaning. However, none of

these commenters provided documentation of any contamination incidents (USEPA, 1998). 
September 30, 1999 19

6. BEST MANAGEMENT PRACTICES

When possible, effluent from carwashes should be discharged to sewer systems or holding

tanks, thus reducing the amount of injected wastewater. When discharge to a sewer system or holding

tank is not possible, the amount of effluent entering the injection well can be reduced by capturing and

recycling as much water as possible, using filters, oil/water separators with recyclable absorbents,

reclamation systems, and other appropriate technologies. Using these practices, some carwashes

currently recycle 100 percent of their captured waste water (USEPA, 1992).

The State of Washington has published a best management practices (BMP) manual for

carwashes entitled “Vehicle and Equipment Washwater Discharges: Best Management Practices

Manual.” The manual states that an acceptable treatment system should be constructed with a gravity

separation unit (e.g., an API Separator, Coalescing Plate Separator, or a containment sump with a

gravity separation overflow and positive control valve). Also, the effluent should be treated after gravity

separation to further remove residual oil and metals. The manual recommends that a 4 to 5 foot deep

multimedia filter (e.g., a multimedia peat sand filter) be used to remove heavy metals. Sampling ports

should be installed to facilitate sampling of the influent and effluent of the treatment system and gravity

separation unit. With proper operation and maintenance of the system, the average total suspended

solids should be less than 75 ppm, while oil and gas should be less than 10 ppm. The treatment system

should not be located above the frost line and it should not produce an effluent that will exceed the state

ground water quality standards. Sanitary wastes should not be discharged in to the treatment system

(ECOL, 1995). The manual also outlines a maintenance program for the carwash well treatment

system, which should include the following steps:

C Daily inspection and weekly cleaning of grit traps.

C Maintenance of gravity separation units according to manufacturer’s recommended

maintenance procedures.

C Regular monitoring of treated effluent is recommended. Oil and grease should be monitored

every six months and metals should be monitored annually.

C Multimedia filters should be replaced as necessary.

C Solids removed from the treatment system should be disposed of in a manner that does not

cause pollution to waters of the state (disposal methods may include sanitary landfill disposal).

C A log of all maintenance activities should be kept at the site and made available to the

Washington State Department of Ecology and/or local authorities when requested. 

In 1996, the New York State Department of Environmental Conservation (NYDEC) issued a

guidance memorandum on vehicle washing with plain water. According to the memorandum, any

facility should conduct all vehicle maintenance operations in a dedicated area that ensures proper

disposal of any incidental or accidental spillage of fluids. The facility should use only clean water, as

opposed to water that has already been used for cleaning, when washing vehicles and washing should

be done in a manner to minimize runoff. Runoff should be directed away from surface waters to the

extent practicable. The facility also should take measures to reduce water usage (e.g., the use of high

pressure wands which make cleaning more effective in a shorter period of time) (NYDEC, 1996). 
September 30, 1999 20

The Southwest Carwash Association provides carwash operators with large signs to be placed

in public view that outline USEPA regulations and the harmful effects of illegal dumping (Space, 1998).

Finally, the contaminant load of the injectate can be reduced by regularly inspecting treatment

equipment, tanks, and chemical containers for leaks; calibrating treatment and application equipment

regularly; and using biodegradable soaps and chemicals instead of solvent-based solutions. 

Accumulated pit dirt should be processed to separate solids, contaminants, and wastewater. Dried pit

dirt and residual liquid waste should then be hauled to waste disposal sites in accordance with federal,

state, and local waste disposal regulations (USEPA, 1992).

7. CURRENT REGULATORY REQUIREMENTS

Several federal, state, and local programs exist that either directly manage or regulate Class V

carwash wells. On the federal level, management and regulation of these wells falls primarily under the

UIC program authorized by the Safe Drinking Water Act (SDWA). Some states and localities have

used these authorities, as well as their own authorities, to extend the controls in their areas to address

concerns associated with carwash wells.

7.1 Federal Programs

7.1.1 SDWA

Class V wells are regulated under the authority of Part C of SDWA. Congress enacted the

SDWA to ensure protection of the quality of drinking water in the United States, and Part C specifically

mandates the regulation of underground injection of fluids through wells. USEPA has promulgated a

series of UIC regulations under this authority. USEPA directly implements these regulations for Class

V wells in 19 states or territories (Alaska, American Samoa, Arizona, California, Colorado, Hawaii,

Indiana, Iowa, Kentucky, Michigan, Minnesota, Montana, New 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.

Carwash wells currently are not subject to any specific regulations tailored just for them, but

rather are subject to the UIC regulations that exist for all Class V wells. Under 40 CFR 144.12(a),

owners or operators of all injection wells, including carwash wells, are prohibited from engaging in any

injection activity that allows the movement of fluids containing any contaminant into USDWs, “if the

presence of that contaminant may cause a violation of any primary drinking water regulation . . . or may

otherwise adversely affect the health of persons.” 

Owners or operators of Class V wells are required to submit basic inventory information under

40 CFR 144.26. When the owner or operator submits inventory information and is operating the well

such that a USDW is not endangered, the operation of the Class V well is authorized by rule. 

Moreover, under section 144.27, USEPA may require owners or operators of any Class V well, in
3

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

September 30, 1999 21

USEPA-administered programs, to submit additional information deemed necessary to protect

USDWs. Owners or operators who fail to submit the information required under sections 144.26 and

144.27 are prohibited from using their wells.

Sections 144.12(c) and (d) prescribe mandatory and discretionary actions to be taken by the

UIC Program Director if a Class V well is not in compliance with section 144.12(a). Specifically, the

Director must choose between requiring the injector to apply for an individual permit, ordering such

action as closure of the well to prevent endangerment, or taking an enforcement action. Because

carwash wells (like other kinds of Class V wells) are authorized by rule, they do not have to obtain a

permit unless required to do so by the UIC Program Director under 40 CFR 144.25. Authorization by

rule terminates upon the effective date of a permit issued or upon proper closure of the well. 

USEPA Region 2 requires operators of manned carwash facilities to submit additional

information, including: explanations of the facility’s operating practices, materials safety data sheets for

chemicals used at the facility, sampling results from sludge in the well, and a site maintenance plan. 

Additionally, operators must post a sign in the washing bay indicating that only the top and side of a

vehicle should be washed, and that only environmentally sound soaps and waxes (i.e., those that are

biodegradable and nontoxic) should be used. If a carwash is unmanned, Region 2 requires the facility

to apply for a Class V UIC permit (Cadmus, 1999).

Separate from the UIC program, the SDWA Amendments of 1996 establish a requirement for

source water assessments. USEPA published guidance describing how the states should carry out a

source water assessment program within the state’s boundaries. The final guidance, entitled Source

Water Assessment and Programs Guidance (USEPA 816-R-97-009), was released in August

1997.

State staff must conduct source water assessments that are comprised of three steps. First,

state staff must delineate the boundaries of the assessment areas in the state from which one or more

public drinking water systems receive supplies of drinking water. In delineating these areas, state staff

must use “all reasonably available hydrogeologic information on the sources of the supply of drinking

water in the state and the water flow, recharge, and discharge and any other reliable information as the

state deems necessary to adequately determine such areas.” Second, the state staff must identify

contaminants of concern, and for those contaminants, they must inventory significant potential sources

of contamination in delineated source water protection areas. Class V wells, including carwash wells,

should be considered as part of this source inventory, if present in a given area. Third, the state staff

must “determine the susceptibility of the public water systems in the delineated area to such

contaminants.” State staff should complete all of these steps by May 2003 according to the final

guidance.3
September 30, 1999 22

7.1.2 CWA

Pursuant to a 1976 settlement agreement and subsequently the 1977 Clean Water Act (CWA)

Amendments, USEPA was required to develop a program and adhere to a schedule in promulgating

effluent limitations guidelines and pretreatment standards for 65 toxic pollutants and classes of pollutants

for 21 major industries. The “Auto and Other Laundries Point Source Category” was one of the

categories mandated for study and possible effluent limitations guidelines and standards development by

the 1976 Settlement Agreement. However, in 1982, the auto and other laundries category, which

included carwashes, was excluded from regulation. As a result, the only federal program that address

special carwash wells are those under the SDWA. 

7.2 State and Local Programs

As discussed in Section 3 above, 99 percent of the documented and 98 percent of the

estimated carwash wells in the nation exist in nine states: Alabama, California, Iowa, Maine, Maryland,

Mississippi, New York, Washington, and West Virginia. Attachment B to this volume describes how

each of these states, in addition to New Hampshire and Wyoming, currently control carwash wells. 

The statutory and regulatory frameworks for injection wells associated with carwash facilities in

the states that report having the most carwash wells fall into two major groups.

C In the three states in which the Class V UIC program is directly implemented by USEPA--

California, Iowa, and New York--the states have additional requirements for Class V wells

above and beyond the existing federal program. In California, Regional Water Quality Control

Boards can prescribe requirements for discharges to injection wells. In Iowa, unless carwash

wastewater can be shown to be sanitary waste, it is banned from disposal in onsite wastewater

treatment and disposal systems. Finally, New York requires State Pollution Discharge

Elimination System (SPDES) permits for discharges to ground water.

C Primacy states for Class V wells apply a range of requirements to carwash wells. Alabama,

Mississippi, Maryland, Wyoming, and New Hampshire issue individual permits. Washington

also issues individual permits to existing wells as long as carwash wells meet BMP

requirements. However, Washington prohibits all new Class V injection wells that inject

industrial, municipal, or commercial waste fluids into or above a USDW. 
September 30, 1999 23

C New Hampshire and Maryland require sampling and testing of effluent, and New

Hampshire also requires ground water sampling and testing. Carwash wells in West

Virginia are authorized by rule unless the Office of Water Resources requires an

individual permit. Maine requires a waste discharge license for Class V injection wells.
September 30, 1999 24

ATTACHMENT A

INJECTATE QUALITY DATA FOR WELLS THAT INJECT FLUID 

FROM CARWASHES WITHOUT ENGINE OR UNDERCARRIAGE CLEANING

Table A-1. Results of 16 Car Wash Samplings in New York

Parameter

Type of Treatment

None SET SET F F &

SET

F &

SET

/SS

SET SET SET SET SET SET SET SET SET SET/SS

Chloride (mg/l) 63.8 85.1 30.1 8.86 10.8 48.2 103 47.9 302 NA NA 83.3 108 53.2 78 230

MBAS (mg/l) .135 .165 .204 <.025 20.5 6.2 <.025 <.025 45.8 <.025 <.025 <.025 47.8 2.77 3.44 2.17

TKN (mg/l) 5.6 3.22 2.8 NA NA NA NA NA 7.8 .56 .56 NA NA .28 .56 1.54

Nitrite (mg/l) <.05 <.05 <.05 NA NA NA NA NA NA .106 <.05 NA NA .931 <.05 <.05

Nitrate (mg/l) <.05 <.05 <.05 NA NA NA NA NA NA <.05 ..268 NA NA 3.71 <.05 <.05

Oil&Grease (mg/l) <.05 21.2 16.4 6.0 <5.0 6.8 13.8 18.8 30.4 51.8 79.2 5.4 <5.0 3.4 15.9 34.4

TDS (mg/l) NA NA NA NA NA NA NA NA NA 353 383 253 353 230 433 546

TSS (mg/l) 26 25.0 44.0 14.0 21 39 31.0 20.0 126 42.0 86.0 44.0 <10 60 14 58

Chloroform (mg/l) .057 .001 .012 .0053 .001

Ethylbenzene (mg/l) .003 .017 .001

Methylene Chloride

(mg/l)

.016 .0017 .0052

Tetrachloroethene

(mg/l)

.079

Toluene (mg/l) .038 .002 .0026 .0012

Xylene (mg/l) .017

m+p-Xylene (mg/l) .060 .058 .0045

o-Xylene (mg/l) .031 .013 .002

Aluminum (mg/l) .563 .769 1.83

0

NA .365 8.730 1.65 2.95 1.350 .421 .480 .310 .559 13.100 1.010 2.510
Table A-1. Results of 16 Car Wash Samplings in New York (Continued)

Parameter

Type of Treatment

None SET SET F F &

SET

F &

SET

/SS

SET SET SET SET SET SET SET SET SET SET/SS

September 30, 1999 25

Antimony (mg/l) .0197 .030

1

.022

7

.0129 .0122 .0066 .0633 .0132 .123 .0090 .0176 .0127 .018 .0094 .0129

Arsenic (mg/l) .0032

Beryllium (mg/l) .0014 .026

Cadmium (mg/l) .0036 .003

4

.005

7

.0016 .0039 .0009

5

.0054 .0011 .0013 .0021 .0027 .0010 .0050 .0012 .0010 .0090

Chromium (mg/l) .0095 .014

8

.010

5

.0107 .0010 .0250 .0055 .0227 .0052 .0063 .0073 .0192 .0278 .0176 .0112

Copper (mg/l) .214 .183 .195 .0234 .0139 .0167 .285 .0807 .460 .111 .118 .0492 .0924 .168 .126 .119

Iron (mg/l) 2.380 3.58

0

4.72

0

NA 3.240 2.940 6.540 2.120 12.20 2.660 4.350 3.040 2.910 19.700 2.190 4.490

Lead (mg/l) .0212 .030

5

.027

8

.028 .0182 .0044 .0382 .0107 .0598 .0130 .0140 .0079 .0320 .0265 .0174 .0258

Nickel (mg/l) .0216 .020

3

.034

7

.0129 .0195 .0682 .0331 .0132 .0318 .017 .0155 .0168 .0177 .0192 .0118 .0327

Selenium (mg/l) .0026

Silver (mg/l) .0016 .001

1

.0070

Thallium (mg/l) .0024 .0068 .0056 .0059

Zinc (mg/l) .253 .295 .435 .0895 .264 .257 .396 .160 .464 .268 .364 .139 .369 .280 .250 .482

Source: NYDEC, 1999

SET: Settling Tanks

F: Filter

S/S: Self Service Facility

NA: Not Analyzed 
September 30, 1999 26

Table A-2. Data from Carwash Samplings in Montana

Parameter Concentrations

(mg/l)

Drinking Water

Standards

Health Advisory

Levels

LibAuto Dano mg/l P/S mg/l N/C

Aluminum, Total 0.105 3.22 0.05-0.2 S -

Aluminum, Dissolved 0.031 0.289 - -

Antimony, Total <0.003 0.004 0.006 P 0.003 N

Antimony, Dissolved <0.003 <0.003 - -

Arsenic, Total <0.025 <0.025 0.05 P 0.002 C

Arsenic, Dissolved <0.025 <0.025 - -

Barium, Total <1 <1 2 P 2 N

Barium, Dissolved <1 <1 - -

Beryllium, Total <0.002 <0.002 0.004 P 0.0008 C

Beryllium, Dissolved <0.002 <0.002 - -

Cadmium, Total 0.0050 <0.0025 0.005 P 0.005 N

Cadmium, Dissolved 0.0044 <0.0025 - -

Chromium, Total <0.05 <0.05 0.1 P 0.1 N

Chromium, Dissolved <0.05 <0.05 0.1 P 0.1 N

Copper, Total <0.5 <0.5 1.3 P -

Copper, Dissolved <0.5 <0.5 -- -

Iron, Total 0.91 3.90 0.3 S -

Iron, Dissolved 0.44 0.53 - -

Lead, Total 0.0096 0.0172 0.015 P -

Lead, Dissolved <0.0075 <0.0075 - -

Manganese, Total 0.077 0.243 0.05 S -

Manganese, Dissolved 0.072 0.202 - -

Mercury, Total <0.001 <0.001 0.002 P 0.002 N

Mercury, Dissolved <0.001 <0.001 - -

Nickel, Total <0.05 <0.05 0.1 P 0.1 N

Nickel, Dissolved <0.05 <0.05 - -

Selenium, Total <0.025 <0.025 0.05 P -
Table A-2. Data from Carwash Samplings in Montana (Continued)

Parameter Concentrations

(mg/l)

Drinking Water

Standards

Health Advisory

Levels

LibAuto Dano mg/l P/S mg/l N/C

September 30, 1999 27

Selenium, Dissolved <0.025 <0.025 0.05 P -

Silver, Total <0.025 <0.005 0.1 S 0.1

Silver, Dissolved <0.025 <0.005 - -

Thallium, Total <0.001 <0.001 0.002 P 0.0005 N

Thallium, Dissolved <0.001 <0.001 - -

Zinc, Total <2.5 <2.5 5 S 2 N

Zinc, Dissolved <2.5 <2.5 - -

Source: USEPA Region 8, 1999

*J = Estimated value. Present, but less than the limit of quantitation.

**0.1 Current MCL, 0.08 is the proposed rule for Disinfectants and Disinfection By-products: Total for all THMs combined

cannot exceed the 0.08.

-No standards or advisory levels available.
September 30, 1999 28

Table A-3. Results of Car Wash Samplings in Maryland

Parameter

Presto

n

Ford*

Grimes

Truck Center†

Village

Volvo*

Fuller

*

Gambacorta*Neviaser*McCoy

*

Attention

to

Detail Auto

Salon, Inc.‡

Barrett

*

Carlto

n

Massey

Inc.* County*

Dave

Wilson*

Frostrom

&

Sons, Inc.*

Good

News

Salisbury*

Hayward

Baker

Inc**

Preston

*

Shipley

Transpor

t***

Chloride (mg/l) 26

pH (SU) 7.0 6.3 5.9 3.5 9.5 9.3 6.82

TPH (mg/l) 134 1.4-

186

3.9 4.3 ND ND 26.1 13.1-

14.1

280 8 ND

Ethylene Glycol (mg/l) ND ND <.01% .108 9.6 -- ND ND ND

Oil&Grease (mg/l) 6.4 57 24 120

Antimony (mg/l) ND

Arsenic (mg/l) ND

Beryllium (mg/l) ND

Cadmium (mg/l) 0.01

6

Chromium (mg/l) 0.00

8

Cyanide (mg/l) ND

Copper (mg/l)

Iron (mg/l) 2.4

Lead (mg/l) 0.01

3

Magnesium (mg/l) 14

Mercury (mg/l) ND

Nickel (mg/l) 0.05

5

Selenium (mg/l) ND

Silver (mg/l) ND

Sodium (mg/l) 36
Table A-3. Results of Car Wash Samplings in Maryland (Continued)

Parameter

Presto

n

Ford*

Grimes

Truck Center†

Village

Volvo*

Fuller

*

Gambacorta*Neviaser*McCoy

*

Attention

to

Detail Auto

Salon, Inc.‡

Barrett

*

Carlto

n

Massey

Inc.* County*

Dave

Wilson*

Frostrom

&

Sons, Inc.*

Good

News

Salisbury*

Hayward

Baker

Inc**

Preston

*

Shipley

Transpor

t***

September 30, 1999 29

Thallium (mg/l) ND

Zinc (mg/l) 0.24

USEPA Method 624 All ND All

ND

All ND All

ND

All

ND

All ND

Acetone (mg/l) 1.6 14.000

Benzene (mg/l) 0.004

1,4-Dichlorobenzene

(mg/l)

0.023

Ethylbenzene (mg/l) 0.025 0.182 0.12

0

Methylene Chloride

(mg/l)

0.004

2-Propanol (mg/l) 1

Tetrachloroethene

(mg/l)

0.022 0.002

Toluene (mg/l) 0.06

1

0.046 0.077 0.016 0.06

7

0.027

USEPA Method 625 All ND All

ND

Benzo(b)fluor-anthene

(mg/l)

0.008

5

Bis(2-

ethylhexyl)phthalate

(mg/l)

0.00

9

0.056 0.025 0.14

1

0.086

Butylbenzylphthalate

(mg/l)

0.019

1,2-Dichlorobenzene

(mg/l)

0.00

9
Table A-3. Results of Car Wash Samplings in Maryland (Continued)

Parameter

Presto

n

Ford*

Grimes

Truck Center†

Village

Volvo*

Fuller

*

Gambacorta*Neviaser*McCoy

*

Attention

to

Detail Auto

Salon, Inc.‡

Barrett

*

Carlto

n

Massey

Inc.* County*

Dave

Wilson*

Frostrom

&

Sons, Inc.*

Good

News

Salisbury*

Hayward

Baker

Inc**

Preston

*

Shipley

Transpor

t***

September 30, 1999 30

1,4-Dichlorobenzene

(mg/l)

0.00

65

Diethylphthalate 0.019 0.019 0.012

Di-n-butylphthalate 0.008 0.004

1

0.021

Di-n-octylphthalate

(mg/l)

0.140

Naphthalene (mg/l) 0.00

74

1.6 4.62

0

0.068

2-Methylnaphthalene

(mg/l)

0.072

Pheneanthrene (mg/l) 0.012

1,2,4-

Trimethylbenzene

(mg/l)

0.130

Total Xylenes (mg/l) 0.057

Note: For most of these constituents, a blank cell indicates the sample was not analyzed for that parameter. Samples that were reported as having some USEPA Method 624 or 625 constituents

present were analyzed for all constituents in that series. A blank cell under these Methods indicates a ND value for all constituents other than those with values greater than detection limits. If all

parameters in the series were reported as “ND,” that is indicated in the main row for each method.

ND = Not detected

*Car dealership and service facilities †Truck and construction equipment repair facility

**Geotechnical Construction Company ‡Vehicle repair, servicing, and cleaning facility

***Maintenance facility for transportation vehicles
September 30, 1999 31

Table A-4. 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 -

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-4. 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 32

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 - -
Table A-4. 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 33

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 -

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 - -
Table A-4. 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 34

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

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

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

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

NA = Not anlayzed.

-No standards or advisory levels available.

†

J = Estimated value. Present, but less than the limit of quantitation.

‡0.1 Current MCL, 0.08 is the proposed rule for Disinfectants and Disinfection By-products: Total for all THMs combined

cannot exceed the 0.08.
September 30, 1999 35

ATTACHMENT B

STATE AND LOCAL PROGRAM DESCRIPTIONS

This section describes the programs of the following nine states that report having 99 percent of

documented wells and 98 percent of estimated wells associated with carwash facilities: Alabama,

California, Iowa, Maine, Maryland, Mississippi, New York, Washington, and West Virginia. In

addition, the New Hampshire and Wyoming programs are described to provide additional examples of

how states control these wells. These 11 states, which have substantially different regulatory structures,

provide a sample of the ways in which carwash wells are controlled. Several are Direct Implementation

states or have incorporated the federal UIC rules by reference. California, New York, and Iowa, all

Direct Implementation states, have state requirements that may supplement USEPA’s implementation of

the UIC program with requirements arising from the states’ wastewater management program or

pollution discharge elimination program. In addition, Washington has a strong antidegradation policy

that stringently limits injection wells. 

Alabama

Alabama is a UIC Primacy state for Class V wells. The Alabama Department of

Environmental Management (ADEM) has promulgated requirements for Class V UIC wells under

Chapter 335 of the Alabama Administrative Code (AAC). 

Permitting

The operator of an existing or proposed Class V well must submit a permit application to

ADEM including the following information (335-6-8-.14(a) through (e) AAC):

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 impact on a USDW posed

by the well, and to determine any special construction and operation requirements which may be

required to protect a USDW (335-6-8-.15(1) AAC). If the ADEM determines that the proposed

action may have an adverse impact on a USDW, the applicant may be required to submit a permit

application in the manner prescribed for Class I and Class III wells. The state requires such

applications to be made on USEPA’s Consolidated Permit Application Form 1 and Form 4, which

require the submission of extensive and detailed information. ADEM also has specified the information

required to be submitted in its UIC regulations (335-6-8-.09 (1) through (7) AAC). When those

permit application requirements are applied, as they apparently have been in at least two situations

involving lead contamination from a car wash facility and lead and chromium contamination from an

external truck wash facility, the permit application processing and issuance procedures follow the rules
September 30, 1999 36

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). At present, an unknown number of wells, including car wash wells, in

the state are not permitted.

 

Siting and Construction Requirements 

Class V wells are specifically exempted from the siting and construction requirements (found in

335-6-8-.20 through 335-6-8-.24) pertaining to Class I and III wells (335-6-8-.25 AAC). The wells

are required to be constructed in such a manner that they may not cause a violation in USDWS of

primary drinking water regulations (defined as 40 CFR Part 142). When required by ADEM, new

Class V wells must be constructed by a well driller licensed by ADEM (335-6-8-.25 AAC). The state

requires facilities seeking permits for industrial wells to submit construction plans and well specifications

prior to permit approval, but construction requirements may differ depending on the proposed injectate. 

Operating Requirements

Class V wells must be operated in a manner that may not cause violation of primary drinking

water regulations under 40 CFR 142. ADEM may order the operator to take necessary actions to

prevent violation, including closure of the well (335-6-8-.16 AAC).

A method of obtaining grab and composite samples of pollutants after all pretreatment and prior

to injection must be provided at all sites. Spill prevention and control measures sufficient to protect

surface and ground water from pollution must be taken at all sites (335-6-8-.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). Two car wash wells that have

had known contamination incidents are required to conduct monthly monitoring. 

Plugging and Abandonment

A plugging and abandonment plan may be required by permit or administrative order. If

necessary it may be required to include aquifer cleanup procedures. If pollution of a USDW is

suspected, ground water monitoring may be required after well abandonment (335-6-8-.27 AAC). 

California

USEPA Region 9 directly implements the UIC program for Class V injection wells in

California. The California Water Quality Control Act (WQCA), however, establishes broad

requirements for the coordination and control of water quality in the state, sets up a State Water Quality

Control Board, and divides the state into nine regions, with a Regional Water Quality Control Board

that is delegated responsibilities and authorities to coordinate and advance water quality in each region

(Chapter 4 Article 2 WQCA). A Regional Water Quality Control Board can prescribe requirements
September 30, 1999 37

for discharges (waste discharge requirements or WDRs) into the waters of the state (13263 WQCA). 

These WDRs can apply to injection wells (13263.5 and 13264(b)(3) WQCA). In addition, the

WQCA specifies that no provision of the Act or ruling of the state board or a regional board is a

limitation on the power of a city or county to adopt and enforce additional regulations imposing further

conditions, restrictions, or limitations with respect to the disposal of waste or any other activity which

might degrade the quality of the waters of the state (13002 WQCA).

Permitting

Although the Regional Water Quality Control Boards do not permit injection wells, the WQCA

provides that any person operating, or proposing to operate an injection well (as defined in §13051

WQCA) must file a report of the discharge, containing the information required by the regional board,

with the appropriate regional board (13260(a)(3) WQCA). Furthermore, the regional board, after

any necessary hearing, may prescribe requirements concerning the nature of any proposed discharge,

existing discharge, or material change in an existing discharge to implement any relevant regional water

quality control plans. The requirements also must take into account the beneficial uses to be protected,

the water quality objectives reasonably required for that purpose, other waste discharges, and the

factors that the WQCA requires the regional boards to take into account in developing water quality

objectives, which are specified in §13241 of the WQCA ((13263(a) WQCA). However, a regional

board may waive the requirements in 13260(a) and 13253(a) as to a specific discharge or a specific

type of discharge where the waiver is not against the public interest (13269(a) WQCA).

California counties take a variety of approaches to regulation of carwash and similar types of

wells. Some counties prohibit these wells. For example, Merced County prohibits the construction of

“dry/drainage” wells, defined as a well constructed for the purpose of disposing of waste water,

hazardous material, or drainage water unless it can be shown that the quality of the water being

introduced into the well will not have an undesirable impact on ground water and/or the well’s

construction will not permit the intermixing of aquifers or provide a conduit for the vertical movement of

known or potential contaminants (Merced County Code, 9.28.060B.1). This authority has generally

prohibited such wells in Merced County. Santa Clara County prohibits “sewer wells, cesspools,

seepage pits, and similar excavations” as a public nuisance (Santa Clara County Health and Safety

Code B11-20). Other counties regulate such wells under their County Water Quality Ordinances. 

Yolo County, for example, defines industrial liquid waste treatment system as wastes, excluding human

wastes, from any producing, manufacturing, or processing operation of whatever nature (Yolo County

Code 6-8.409) and provides that all industrial waste discharges must be carried out according to

standards and conditions established by the County Board of Supervisors (Code 6-8.604). Riverside

County addresses the topic in its Plumbing Code.

Iowa

USEPA Region 7 directly implements the UIC program for Class V injection wells in Iowa. In

addition, the state has enacted regulations addressing on-site wastewater treatment and disposal

systems that collect, store, treat, and dispose of wastewater from four or fewer dwelling units or other
September 30, 1999 38

facilities (e.g., commercial facilities) serving the equivalent of 15 persons (1,500 gallons per day (gpd)

or less) (Chapter 567-69 Iowa Administrative Code (IAC)). An on-site wastewater treatment and

disposal system is defined in these rules as a system that includes domestic waste whether residential or

nonresidential, “but does not include industrial waste of any flow rate” (567-69.1(2) IAC). Generally,

therefore, unless it can be shown clearly to be only sanitary waste, car wash wastewater would be

banned from disposal in these systems. 

Mississippi

Mississippi is a UIC Primacy state for Class V wells. The state’s wastewater permit

regulations provide that unless otherwise required, owners or operators of Class V wells and all

applicants for UIC permits shall comply with 40 CFR 144, 146, 147.1250 subpart Z, and 148, which

are incorporated and adopted by reference (Wastewater Permit Regulations IV.K.2.e. and IV.K.3). 

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

enacted. Therefore, the requirements in 40 CFR apply.

New 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 water), specify that such

discharges must comply with the standards in Part 703, and provide for monitoring in Part 756. 

Permitting 

Applications for a SPDES permit, which are required for discharges to ground water, must

describe the proposed discharge, supply other requested information, and are subject to public notice. 

SPDES permits must ensure compliance with effluent limitations and standards, and will include

schedules of compliance, monitoring requirements, and records and reports of activities (Parts 751 -

756).

Operating Requirements

Effluent limits (Part 703) in the SPDES permit must be met. Monitoring and reporting

requirements in the SPDES permit must be met.

Washington

Washington is a UIC Primacy state for Class V UIC wells. Chapter 173-218 of the

Washington Administrative Code (WAC) establishes the underground injection control program. 
September 30, 1999 39

Under the program, the policy of the Department of Ecology is to maintain the highest possible

standards to prevent the injection of fluids that may endanger ground waters which are available for

beneficial uses or which may contain fewer than 10,000 mg/l TDS. Consistent with that policy, all new

Class V injection wells that inject industrial, municipal, or commercial waste fluids into or above a

USDW are prohibited (172-218-090(1) WAC ). Existing wells must obtain a permit to operate. 

Permitting

A permit must specify conditions necessary to prevent and control injection of fluids into the

waters of the state, including all known, available, and reasonable methods of prevention, control, and

treatment. It also must specify conditions to satisfy applicable requirements in 40 CFR Parts 124, 144,

146 and any other conditions necessary to preserve and protect USDWS. Any injection well that

causes or allows the movement of fluid into a USDW that may result in a violation of any primary

drinking water standard under 40 CFR Part 141 or that may otherwise adversely affect the beneficial

use of a USDW is prohibited (173-218-100 WAC).

Siting and Construction

The state has promulgated minimum standards for construction and maintenance of wells (173-

160-010 through -560 WAC). However, injection wells regulated under Chapter 173-218 are

specifically exempted from these constructions standards (173-160-010(3)(e) WAC).

Operating Requirements

The water quality standards for ground waters establish an antidegradation policy. The

injectate must meet the state ground water standards at the point of compliance (173-200-030 WAC).

Plugging and Abandonment

All wells not in use must be securely capped so that no contamination can enter the well

(173-160-085 WAC).

West Virginia

West Virginia is a UIC Primacy state for Class V wells. Regulations establishing the UIC

program are found in Title 47-13 West Virginia Code of state Regulations. The state does not identify

a separate category of Class V industrial wells, but does specify that Class V includes injection wells

not included in Classes I, II, III, or IV (47-13-3.4.5. WVAC).
September 30, 1999 40

Permitting

Class V injection wells are authorized by rule unless the Office of Water Resources of the

Division of Environmental Protection requires an individual permit (47-13-12.4.a. and 47-13-13.2 

WVAC). Injection is authorized initially for five years under the permit by rule provisions.

Operating Requirements 

Owners or operators of Class V wells are required to submit inventory information describing

the well, including its construction features, the nature and volume of injected fluids, alternative means of

disposal, the environmental and economic consequences of well disposal and its alternatives, operation

status, and location and ownership information (47-13-12.2 WVAC). 

Rule-authorized wells must meet the requirements for monitoring and records (requiring

retention of records pursuant to 47-13-13.6.b. WVAC concerning the nature and composition of

injected fluids until 3 years after completion of plugging and abandonment); immediate reporting of

information indicating that any contaminant may cause an endangerment to USDWS or any malfunction

of the injection system that might cause fluid migration into or between USDWS; and prior notice of

abandonment.

The rules enact a general prohibition against any underground injection activity that causes or

allows the movement of fluid containing any contaminant into a USDW, if the presence of that

contaminant may cause a violation of any primary drinking water regulations under 40 CFR Part 142 or

promulgated under the West Virginia Code, or may adversely affect the health of persons. If at any

time a Class V well may cause a violation of the primary drinking water rules the well may be required

to obtain a permit or take such other action, including closure, that will prevent the violation (47-13-

13.1 WVAC). Inventory requirements for Class V wells include information regarding pollutant loads

and schedules for attaining compliance with water quality standards (47-13-13.2.d.1 WVAC).

For protection of a USDW, the injection operation may be required to satisfy requirements,

such as for corrective action, monitoring and reporting, or operation, that are not contained in the UIC

rules (47-13-13.2.c.1.C. WVAC).

Mechanical Integrity 

Only a Class V well required to obtain an individual permit will be required to demonstrate that

the well exhibits mechanical integrity.

Plugging and Abandonment 

A Class V well required to obtain an individual permit will be subject to permit conditions

pertaining to plugging and abandonment to ensure that the plugging and abandonment of the well will
September 30, 1999 41

not allow the movement of fluids either into a USDW or from one USDW to another. A plan for

plugging and abandonment will be required.

Maryland

Maryland is a UIC Primacy state for Class V wells. Business inquiries to discharge vehicle

wash water to surface waters are often referred to the Maryland Department of Environment’s Ground

Water Permits Division by the National Pollutant Discharge Elimination System (NPDES) program. 

This action is taken because vehicle wash water has historically failed the biomonitoring testing required

by the NPDES program. The failure is thought to be caused by surfactants in the wash water (Eisner,

1999). 

Permitting

Under the Code of Maryland Regulations (COMAR 26.08.02) any discharge or disposal of

waters or wastewaters into the underground waters of the state requires a discharge permit (COMAR

26.08.02.09A.(1)). The Code also provides that dischargers or potential dischargers to ground waters

may be required to monitor ground or surface waters in a manner and frequency and at locations

specified by the Maryland Department of the Environment (COMAR 26.08.02.09.D(4)). The Code

defines three aquifer types, and specifies discharge quality criteria for each type (COMAR

26.08.02.09C). Discharges to ground water may not result in degradation of ground waters below the

criteria established, nor may discharges to an aquifer of specific classification result in pollution of an

aquifer possessing higher quality criteria. For Type I aquifers, discharges may not exceed Maryland’s

primary or secondary standards for drinking water, and for Type II aquifers the constituents may not,

after treatment, exceed primary or secondary drinking water standards, except for TDS (COMAR

26.08.02.09C). The underground injection of hazardous wastes is prohibited (COMAR 26.13.05.18). 

A separate ground water discharge permit is not required if an underground injection permit has been

issued under COMAR 26.08.07 or if the subsurface disposal system is covered by a general permit

under COMAR 26.08.04.07 (COMAR 26.08.02.09A(3)(d) and (4)). Maryland has adopted by

reference the federal UIC regulations (COMAR 26.08.07.01), and does not require a UIC permit for

Class V wells (COMAR 26.08.07.01B).

Under these authorities, the Maryland Department of the Environment’s Wastewater Permits

Program issues Ground Water Discharge Permits for exterior vehicle washing if the wastewater is

discharged to the ground surface or to the subsurface via disposal systems such as drainfields or

drywells. Effluent testing is required to support the permit application and is required throughout the life

of the permit. Testing for total petroleum hydrocarbons (TPH) is required, typically on a monthly or

quarterly basis. The sampling point is typically located at the point of discharge, after treatment and

prior to discharge to a drainfield or dry well. In some cases, vehicle wash water may mix with domestic

wastewater in the facility’s septic tank prior to discharge. Permits issued for self-service washing

facilities have historically required quarterly VOC testing and posting of signs in the wash bays to

educate the public (Eisner, 1999).
September 30, 1999 42

Operating Requirements

Monthly or quarterly testing for TPH is required, with a technology-based effluent limit of 15

mg/l. Treatment is typically an oil/water separator, for which there are maintenance requirements in the

facility’s permit. Engine and undercarriage cleaning and the use of solvents are strictly prohibited. The

permits encourage pollution prevention by using hot water without detergents for washing. Finally, all

material safety data sheets are reviewed for any detergents or additives used (Eisner, 1999).

Maine

Maine is a UIC Primacy state for Class V wells. The Maine Department of Environmental

Protection administers the UIC program, with support from USEPA Region 1. Title 38 of the Maine

Revised Statutes Annotated (MRSA) establishes, among other programs, the state’s ground water

protection program (38 MRSA §§ 401-404), pollution control program, including waste discharge

licensing provisions (38 MRSA §413), and ground water classification standards (38 MRSA §465-C). 

Rules controlling the subsurface discharge of pollutants by well injection implemented by the

Department of Environmental Protection are found in 06 Code of Maine Regulations (CMR) Chapter

543.

Licensing

The rules controlling subsurface discharge of pollutants by well injection provide that all

subsurface discharges of fluids into or through a well are prohibited except as authorized in accordance

with the rules. The state recognizes five classes of wells, reflecting the definitions adopted by the

federal UIC program. Any subsurface discharge into or through a Class V well that would cause or

allow the movement of fluid into a USDW that may result in a violation of any Maine Primary Drinking

Water Standard, or which could otherwise adversely affect human health, is prohibited (06-

096.543.3.D CMR). The state designates ground water as either Class GW-A (for use as public

drinking water supplies) or Class GW-B (for uses other than drinking water supplies). However, no

ground water to date has been classified as GW-B. The Primary Drinking Water Standards are set

forth in Department of Human Services rules in 10-144A CMR 231. Class V wells must obtain a

waste discharge license issued under 38 MRSA §413 (1-B) prior to the commencement of the

discharge. Wells that are already discharging may be permitted, depending on the characteristics of the

injectate.

Class V wells also can be redesignated or subject to additional regulatory requirements. Any

Class V well receiving toxic or hazardous compounds is redesignated as a Class IV well and, as such,

is prohibited. The rules controlling the subsurface discharge of pollutants also note that the Maine

Hazardous Waste, Septage, and Solid Waste Management Act (38 MRSA § 1301 et seq.) or the Site

Location of Development Act (38 MRSA § 481 et seq.) could apply to certain Class V wells. 
September 30, 1999 43

New Hampshire

New Hampshire is a UIC Primacy state for Class V wells.

Operating Requirements

New Hampshire requires that Ambient Ground Water Quality Standards be met and

maintained. Facilities are required to comply with the state’s Best Management Rule (Env-Ws 421). 

Owners and operators may register or permit their wells and are required to sample and test effluent

and ground water (Locker, 1999).

Carwashes in New Hampshire have four options to assist in protecting ground water:

C Operate a closed-loop system with wastewater recycling. Discharges must be disposed of at

an approved disposal facility (i.e., a wastewater treatment plant or hazardous waste facility,

depending upon the nature of the recycled water).

C Discharge wastewater to a sanitary sewer. The owner of the facility must contact the local

sewer authority to obtain approval.

C Obtain a ground water discharge permit. The ground water discharge well must be permitted in

accordance with Env-Ws 1504, and wastewater is treated to ambient ground water standards.

C If the facility washes fewer than 30 cars per week, the facility can indirectly discharge water to

ground water through surface discharge. Facilities can only dispose of wastewater in this

manner if their wastewater meets very strict criteria (e.g., does not contain hazardous

contaminants; has been treated with an oil-water separator; is not from power washing, steam

cleaning, engine cleaning or undercarriage cleaning; etc.).

Wyoming

Wyoming is a UIC Primacy state for Class V wells. Chapter 16, Wyoming Water Quality

Rules and Regulations, requires an individual UIC permit for all carwash wells (WYDEQ/WQD). 

Permitting

Carwash permits issued in Wyoming include the following sections:

C Discharge zone and area of review, specifying the aquifer into which injection is allowed to take

place.

C Ground water classification, describing the classification, under state regulations, of the

receiving aquifer and nondegradation requirements.

C Authorized operations, describing the volume and pressure of the injection activities.

C Environmental monitoring program for ground waters of the state, describing the monitoring

activities that the UIC well owner/operator must perform.

C Requirements for monitoring the discharge, describing the monitoring and reporting schedule.
September 30, 1999 44

C Records and reports, describing the timeframe for keeping records and annual reporting

requirements.

C General permit conditions, describing the review period for permits and specifying what actions

constitute permit violations.

C Duties of the permittee, describing actions the owner or operator should take to comply with

the permit conditions.

C Signatories requirement, describing who must sign the permit.
September 30, 1999 45

REFERENCES

Arkansas Department of Pollution Control and Ecology (ADPC&E). 1996. Application Procedures

for a No-Discharge Water Pollution Control Permit. June 21, 1996.

The Cadmus Group. 1999. State-by-State Notebooks Compiling Results from the Class V

Underground Injection Control Study. February 1, 1999.

Locker, M. 1999. New Hampshire Department of Environmental Services. Telephone conversation

with Stephanie Barrett, ICF Consulting. July 27, 1999.

Maryland Department of the Environment (MDOE). 1999. Memorandum from Michael Eisner,

Maryland Department of the Environment, to Anhar Karimjee, Office of Water, transmitting comments

on Class V Study reviews. June 21, 1999.

New York State Department of Environmental Conservation (NYDEC). 1996. Guidance

Memorandum on Vehicle Washing with Plain Water to Regional Water Engineers from Warren Lavery,

Director, Bureau of Permits. November 4, 1996.

New York State Department of Environmental Conservation (NYDEC). 1999. Email from William

Spitz, New York State Department of Environmental Conservation, to Robyn Delehanty, USEPA

Office of Water, transmitting injectate data for carwashes and laundromats. March 10, 1999.

North Carolina Department of Environment, Health, and Natural Resources. 1997. “Waste

Minimization.” February 1997.

Space, C. 1998. Southwest Carwash Association. Telephone Conversation with Scott Hines, ICF

Consulting. September 1, 1998.

State of Tennessee Department of Environment and Conservation (TDEC). 1995. Letter from Robin

J. Bell to Rhudy Johnson approving Class V Authorization application for discharge of car wash waste

water from Buggy Bath Car Wash, Roan Mountain, Tennessee. August 29, 1995.

USEPA. 1980. Development Document for Effluent Limitations Guidelines and Standards for

the Auto and Other Laundries Point Source Category. Washington, D.C. OMB 0704-0188. 

October 1980.

USEPA. 1987. Report to Congress: Class V Injection Wells. Office of Water. Washington, D.C. 

EPA570/9-87-006. September 1987.

USEPA. 1992. Class V BMP Fact Sheet Number 3. Office of Water. Washington, D.C. USEPA

570/9-91-036L. January 1992.
September 30, 1999 46

USEPA. 1994. Underground Injection Control Inspector Training Manual. Washington, D.C. 

September 1994.

USEPA. 1998. Public Comments on the July 29, 1998 Proposed Revisions to the Class V UIC

Regulations: Comment Excerpts Sorted by Issue Category. December 9, 1998.

USEPA Region 8. 1999. Correspondence from Douglas Minter, USEPA Region 8, to Robyn

Delehanty, USEPA Office Water, transmitting sampling data for automotive and industrial Class V

wells. March 3, 1999.

Washington State Department of Ecology (ECOL). 1995. Vehicle and Equipment Washwater

Discharges: Best Management Practices Manual. Publication Number WQ-R-95-56. Olympia,

Washington: Washington State Department of Ecology. June 1995.

Wyoming Department of Environmental Quality/Water Quality Division (WYDEQ/WQD). 1999. 

Memorandum from Robert Lucht, Wyoming DEQ/WQD, to Amber Moreen, USEPA Office of

Water, on Review of Class V Study documents. July 12, 1999.