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Illinois Mutual Benefits Agreement Project: A Joint State & Federal Effort

Project Overview

groundwater contamination caused by shallow disposal system This project is a joint effort of Illinois EPA and EPA to find and close Motor Vehicle Waste Disposal Wells (MVWDWs) in Illinois. The project is innovative in nature and seeks to effectively leverage resources to fill current resource gaps. Under the project, EPA agreed to act as a designated agent of Illinois EPA. In this capacity, EPA will perform inventory collection, review closure plans, and oversee the closures of MVWDWs in Illinois. The project will use innovation through establishing partnerships, encouraging voluntary compliance, promoting self-certification, developing and using various compliance assistance tools, and providing education and outreach.

Project Focus

Initial work will focus on Source Water Protection Areas (SWPAs). Exit from EPA pages EPA is particularly interested in those areas where public water supplies show high contaminant levels of Trichloroethylene (TCE), Volatile Organic Compounds (VOCs), and Methyl Tertiary Butyl Ether (MTBE). These contaminants are commonly found in automotive fluids and MVWDWs serve as a potential route for these fluids to enter ground water. Agreements have been sought and reached with the Source Water Protection Program (SWPP) and with the Underground Storage Tanks (UST) Program which is administered, in conjunction with the EPA, by the Illinois Fire Marshall. Exit from EPA pages These programs have committed support and resources to the project. EPA is also beginning to work closely with other State Agencies, such as the Illinois Department of Transportation and is seeking to work closely with local governments, including, the county departments of public health and the county sanitarians.

Project Cornerstones

The cornerstones of the project are voluntary compliance and self-certification. In order to achieve this, EPA and Illinois EPA are working with trade associations, providing education and outreach and also providing compliance assistance to the regulated community. EPA will work through such organizations as the Illinois Petroleum Marketers Association - Illinois Association of C-Stores Exit from EPA pages and the Illinois Petroleum Council to increase awareness of UIC requirements and the risks associated with underground disposal of motor vehicle waste.

The project welcomes cooperation from members of the regulated community. EPA’s Voluntary Environmental Self-Policing and Self-Disclosure Policy Statement will help provide the basis for incentives to regulated businesses. EPA is interested in working with businesses that are willing to act responsibly by detecting, disclosing, and correcting violations and potential problems. Through voluntary compliance, EPA can help businesses inventory and close their wells in exchange for safer, alternative methods of waste management and disposal. In the process, businesses can also minimize waste, recycle more, help safeguard community health and the environment, and protect the value of their business. If you have a well, click here to find out what you need to do to meet UIC program requirements.

Project Background

EPA found MVWDWs to be a danger to ground water resources nationwide and required that they be controlled under the UIC program’s Class V rule. Illinois EPA, who maintains primacy for the UIC program, had been unsuccessful with implementing an effective program for controlling high risk Class V waste disposal wells such as this type. Illinois EPA attributed their lack of success to inadequate resources. Illinois EPA attempted to return the UIC program in 1992 but later negotiated to retain primacy with the resource issue being left largely unresolved. The situation was further compounded when EPA promulgated new requirements for MVWDWs which became a national priority based on environmental risk. The new requirements placed additional burden on the state to regulate with no additional resources. Illinois EPA informed Region 5 EPA that it was unable to meet the new requirements. In an effort to help build state capacity and increase the state’s ability to retain primacy, EPA and Illinois EPA entered into two consecutive innovation agreements. The first, which was scheduled to end January 1, 2004, ended with limited results but with great optimism that the two agencies could work in partnership to leverage available resources and achieve environmental results. Thus, EPA and Illinois EPA entered into a second agreement under which the Illinois UIC Class V Mutual Benefits Agreement Project was established.

Summarized Project Workplan

The work plan included project goals, several strategies for achieving results, and measures of success as summarized below.

Primary Environmental Goal

Control or eliminate the threat of potential drinking water contamination posed by the existence of endangering Class V wells within Illinois Source Water Protection Areas (SWPAs).

Programmatic Goal

Close or permit all Class V Motor Vehicle Waste Disposal Wells identified.


Coordinate with the Illinois Fire Marshall on Underground Storage Tanks program inspections to identify wells with focus on SWPAs. Develop and use return postage paid survey postcard. Create and share electronic database of inspected facilities.


Target outreach and education efforts to groups representing the types of businesses that are most likely to operate MVWDWs such as state and county DOTs and trade associations. Target the types of facilities that are most likely to have MVWDWs with focus on unsewered areas. Use sources of business information and databases. Have other EPA program and other governmental agencies assist with outreach and follow-up efforts such as county health departments, county extension services, county sanitarians, regional planning commissions, associations of cities and towns, and other forms of local government. Provide outreach and education to them also. Develop lists of potential facilities and use mass mailings and field visits to identify MVWDWs. Target the facilities that are most likely to have MVWDWs. Create Geographic Information System (GIS) maps of facilities and locations in relation to SWPAs. Develop outreach packages and compliance guidance. Hire and use student interns to help with follow-up activities.


Publish articles in automotive trade journals. Work with the UST program to do this. Stress how business owners can comply and seek technical assistance.


Promote voluntary compliance through expedited self-disclosure process and through a recognition program for those that comply in the form of a letter or certificate and recognition on EPA’s Web site. Provide compliance tools such as closure guidelines, a closure checklist, a self-certification form, and a schedule for compliance. Conduct random closure inspections to spot check and to ensure compliance with requirements.


Enter into an informal memorandum of agreement with Illinois EPA that establishes roles and responsibilities and that sets protocols for the project.


Send letters and compliance guidance to operators who opt for voluntary and early compliance with Class V rules. Establish closure deadlines. Permit or close wells as appropriate giving priority to wells in SWPAs. Develop an environmental stewardship incentives program based on EPA’s Voluntary Environmental Self-Policing and Self-Disclosure Policy Statement.


Enforce the provisions of 40 CFR 144.12 to achieve compliance at endangering facilities and those facilities that do not voluntarily comply. Send notifications and enforce compliance deadlines.

Measures of Success>

Supporting Agency Goals

This project supports the following agency goals.

Contact Information

For more detailed project information, see the summarized project work plan or contact Valoria Robinson by phone at (312) 886-4281 or by email to Valoria Robinson (robinson.valoria@epa.gov).

State of Illinois Web Pages: Exit from EPA pages

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