One of the more ominous aspects of the US Environmental Protection Agency's new and proposed regulations for Class V underground injection wells - leachfields and dry wells used to dispose of wastewater - is that no one is sure how broadly the law will be interpreted or where this first step in regulation will ultimately lead.

New EPA rules, part of the Safe Drinking Water Act's Underground Injection Control program (UIC), are set to become law this fall. They would require washes that perform undercarriage cleaning, fast lube and detail shop operators to purify their wastewater to minimum drinking water standards before disposing of it by putting it into a leachfield or dry well.

While this round of regulations will have an immediate impact on only a select group of operators - principally those in more rural areas where dry wells are common and sanitary sewers are scarce - many believe this is just the beginning of an effort to regulate all carwash wastewater.

A second phase of this EPA study - addressing self-service carwashes, among other industries - is under way. These findings, which are due to be reviewed this fall, could expand the requirement for purifying wastewater to virtually all operators who dispose of any wastewater by putting it in the ground.

As it stands, wastewater that goes into municipal sewers will not face additional regulations on the federal level.

However, the fear is once regulating agencies put carwash wastewater under a microscope, operators will have to treat wastewater to some degree before allowing it to enter even a municipal sewer.

"There is a general push that cities are saying you can't let just anything go down the sewer," says Coy Lindblom, president of the Western Carwash Association.

Making businesses treat wastewater before discharging it into a sanitary sewer is a natural result of the cost of treatment. The EPA and environmentalists are putting pressure on municipalities to better treat sanitary sewer water before releasing it into the environment.

Combine that with the fact municipalities have limited budgets and it may be only a matter of time before municipalities begin to put pressure on carwashes to treat their wastewater before disposal, shifting the clean-up cost away from the taxpayer.

Dick Dreher, owner of GTO Car Wash in Yakima, WA, is already facing problems caused by the city's refusal to accept his pit waste in the municipal landfill. He uses a sanitary sewer to get rid of some reclaim and wax water and is worried about the future.

"Sometime down the road, they're going to come and say they don't want that water down the sewer anymore," Dreher predicts.

EPA mandates under the 1996 Safe Drinking Water Act require the agency to make protecting drinking water sources a national priority. Operators are predicting the current round of new lawmaking is just the tip of the iceberg.

"The regulators have found the larger polluters and slapped them with all kinds of controls and regs," says Hugh Oldham, technical service manager for Frank's Car Wash Equipment & Supply Co. Inc. in Lexington, SC. "They are now looking for smaller fish to fry. As the regulators have realized carwashes exist, they are starting to realize how big a source of water pollution our industry really is."

Operators know wash wastewater is often more than just soap and water. There are chemicals, solvents, salt, metals, oils, grease and wax.

"The carwash industry has been a major source of pollution for many years," says Oldham. "Operators have paid very little attention to the use of some very strong chemicals and have allowed those chemicals to enter the environment in an almost nonchalant manner."

Self serves, although they often use less chemicals, are not safe from regulation. The EPA has documented cases where self-serve customers brought engine solvents and degreasers to use at the wash. Those cleaning agents dramatically raised the level of pollutants in the wastewater.

That the public can and does dump all manner of toxic fluids down the floor drain should make self-serve operators nervous at potentially having to take responsibility for making their wastewater drinking-water pure.

The Class V injection well is a fancy name for the common leachfield or dry well, which gets rid of wastewater by putting it just below ground level. Gravity and evaporation take the water away. Class I through Class IV injection wells are more sophisticated and run deeper underground. Used for waste fluids, brine, steam or industrial water, they have been previously regulated or banned.

Because it has been a relatively inexpensive method of disposal for a host of businesses from auto repair shops with floor drains to retail stores with restrooms, there is no good count of how many Class V wells exist.

Many tunnel carwashes may not believe they employ a Class V well system for their wastewater. Most washes use sanitary sewers or have reclaim systems where waste is picked up and removed from the site.

However, there are situations where tunnel operations may unwittingly use dry wells - as lube bay floor drains, as outlets for towel laundry wastewater or for wax and rinse water that does not go through the reclaim system.

These disposal systems will be scrutinized by the EPA.

"The number of Class V wells is unclear, because states report them differently," says Robin Delehanty, an environmental protection specialist with the EPA. "In many places, the well owners must report them to the state. And there has been no real push to count them."

Dry well and leachfields could have been approved by localities years ago, installed and forgotten. Some were put in on the sly by businesses wanting to cut sewer costs.

The EPA's best guess is there are at least 4,500 dry well and leachfields used by self serves nationwide. The wells used by tunnel washes are not broken out of the estimated 1 million Class V wells nationwide.

Kirk Moline, a hydrologist with C.T. Male Associates P.C., an engineering firm in Latham, NY, is working with automotive businesses to bring them into compliance with the new laws. It is not just rural businesses that will be affected.

"Businesses have dry wells even in locations were there is a municipal sewer," he says. "A lot of municipalities don't want that [automotive waste] water in their sewers."

Moline says the scope of the new regulations is coming as a surprise to a lot of people - "a big surprise."

According to Bob Kline, president of Acquatech International Contractors, a carwash contractor in Fort Meyers, FL, wash operators who installed dry wells and leachfields in the 1970s as a way to reduce sewer costs may now find that decision an expensive one.

"If you want to be a carwasher in the new millennium, you have to realize that Uncle Sam's not going to let you dump [wastewater] in the backyard any more," Kline says. "There's going to be a lot tighter monitoring on our discharge of water."

It is not spelled out in the new regulations whether a dry well constructed not as primary disposal system but as an adjunct to a motor vehicle service facility will be covered under the first set of regulations.

Douglas Minter, environmental health scientist with EPA's Denver office says, "If there is a possibility that motor vehicle waste could escape, or if chemicals are stored on site and a potential for contamination of water exists, that's more than just a carwash in my mind. It's fair to say that if there is a potential for motor vehicle waste to escape, we want to oversee it."

One unanswered question is how aggressively the EPA and state environmental agencies will pursue the dry well issue. The belief is they will gear up for an enforcement blitz.

The EPA is not just targeting the carwashing industry.

The set of regulations which become law this fall with a one-year compliance deadline, will deal with underground injection wells used by a variety of businesses: chemical, electrical and tool-and-die manufacturers; dry cleaners, asphalt manufacturers; commercial printers and large-capacity private cesspools and septic tanks.

On the automotive side, carwashes that do undercarriage washing, gasoline stations, new and used car dealers, motor vehicle repair, auto body, muffler and transmission shops will all come under the first set of regulations.

The first round of laws will address dry wells and leachfields located in areas that serve as drinking water sources. This could be a slippery slope for operators.

The determination of what constitutes a drinking water source will be left up to the states. The EPA's Minter says the area covered by the new regulations could amount to half the state of Colorado.

The law mandates businesses using these injection wells either shut them down or meet drinking water standards at the point where the wastewater is introduced into the ground - an extraordinarily expensive proposition.

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