Issue: Fleets must take responsibility for making sure their shop floor drains meet the new EPA regulations
The Environmental Protection Agency (EPA) last fall issued a new rule that effectively closes all Underground Injection Control (UIC) wells - aka dry wells, sumps, and septic systems - that receive waste from motor vehicle maintenance bays.
Most fleet maintenance shops install floor drains to comply with plumbing codes and OSHA regulations to help reduce slip-and-fall hazards. As long as the drains discharge into public sanitation sewers, there's no environmental hazard. Unfortunately, many of them were built to discharge into holes in the ground. Drainage holes were often set up either as dry wells located off the side of the building, or as gravel beds situated directly under the shop. In some cases, however, bay drains were connected to the septic tank and leach field, a setup that is still required by many states.
Concerns arose when these UIC-well discharge options led to groundwater contamination, so EPA created a rule banning new and existing UIC wells.
The deadline for the prohibition of new wells hits first. Starting April 5, 2000, no new motor vehicle wells may be built under any circumstances.
Existing wells are next. Individual states must assess their groundwater supplies by January 1, 2004. The countdown for facility managers begins as soon as a state completes its assessment. Fleets have one year from the time the state finishes its assessment to close the wells.
Closing a well will usually mean either stopping the operation that creates the discharge (vehicle maintenance, for example) or installing a new discharge system such as a sanitary sewer or "pump and haul" operation.
Wells located in states that don't complete groundwater assessments by the deadline will by default be banned, and must be closed down by January 1, 2007.
If your bay drains are discharging into your septic tank and leach field along with your bathroom wastes, then that septic system will be considered a motor vehicle waste well. As such, it will be subject to the requirements of the new rule and could be closed. While EPA will allow fleets to convert these systems, keep in mind that your septic system (and therefore your bathrooms) could be closed for months while cleaning and testing takes place.
Since EPA and the state agencies are not required to inform individual facilities about results of the groundwater assessments or the prohibited areas, fleets must take responsibility for finding out whether their maintenance shops are affected.
EPA plans active inspection and enforcement efforts. So it's important to keep in contact with state agencies, look for posted material in public libraries, or visit agency Web sites. EPA warns, however, that since Web site postings could be a month to a month-and-a-half old, fleets should make sure they have the correct compliance date for their state.
After the initial assessments of actual drinking water sources and the UIC well closures to protect them are completed, states must assess other groundwater sources and apply the ban to those areas as well. The final deadline for closure is January 1, 2008. These other areas will probably spread the ban across all other regions of each state and effectively blanket the country in a ban on UIC wells.
EPA offers a permit option that enables fleets to keep some of their waste wells open, but it's prohibitively expensive. The permit stipulates that all discharge to the wells must meet drinking water standards, which means extensive treatment before discharge. Costly and repeated monitoring will also be required to ensure the quality of the discharge.
If you want to get a jump on the process, check your state's Wellhead Protection Program map. If your facility falls within a Wellhead Protection area, then the UIC well ban applies to you.