ECAR Fact Sheet for Florida
Floor Drains
Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
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The
following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.
What You Need to Know
Floor
drains, especially those built when designers and contractors were
much less environmentally conscious than they are now, can be full
of surprises. If you do not know what is happening at the
other end of yours, you would be well advised to find out before
an inspector does.
Floor
drains in many industrial facilities have been found to empty into
storm sewers, or into septic fields. In either case, the discharge
of wastewater from the shop floor into this kind of system is almost
certainly illegal. If the floor drain discharges into a city
sewer system, it will almost certainly need a permit, and will need
to be periodically monitored. Floor drains can also leak,
and have been known to cause serious and costly soil and groundwater
contamination problems. This fact sheet will help you determine
if the floor drains in your facility are properly connected and
properly used.
Regulations
This
fact sheet addresses regulatory issues and practices associated
with floor drain systems. A floor drain system commonly includes
a concrete trench, which runs down the center of a shop floor that
may lead to underground pipes and/or tanks. Instead of a trench,
some shops have single or multiple rectangular or round floor drains.
Typically, the shops floor is slightly sloped to allow liquids to
flow into the floor drain.
A floor
drain is a red flag for any inspector from an environmental protection
agency. Their concerns are primarily:
- what
types of materials could potentially enter the floor drain system,
and
- what
ultimately happens to those materials?
Depending
on how your facility answers these two questions, one or more regulations
will apply:
- Some
chemicals found in auto recycling facilities are regulated as
hazardous waste. If these chemicals enter the floor drain system,
it is likely that the material (i.e., liquid and sludge) in the
system is a hazardous waste. When the floor drain system is cleaned
out, those residuals, if hazardous, will have to be handled, stored
and disposed of according to hazardous waste rules. You can perform
a hazardous waste determination to check the status of these residuals.
Even if the residuals are non-hazardous, they must be handled
and disposed of properly. Generally, this means having the residuals
transported to a licensed treatment/disposal facility.
- Floor
drains that collect wastewater and discharge to a city sewer system
are regulated by federal and state "pretreatment" regulations.
You must have a permit or written authorization for this kind
of discharge. You may also need to install an oil/water separator
or other treatment equipment to comply with discharge standards.
- Floor
drains that discharge to a septic system are regulated by federal
and state Underground Injection Control (UIC) regulations and
require a permit. Florida UIC rules also require that such systems
are operated in a manner that they do not present a hazard to
an underground source of drinking water. Therefore, it is essentially
impossible to have a floor drain in an auto recycling shop connected
(legally) to a septic tank or similar structure. New federal regulations
specifically covering "motor vehicle waste disposal wells"
tighten the UIC rules even more.
Links
to the Regulations and Forms. Use
the following links to view the regulations and permit forms pertaining
to floor drains.
Florida
Hazardous Waste Regulations
Federal
Hazardous Waste regulations Part 261 - Identification and Listing
of Hazardous Waste
Federal
Hazardous Waste regulations Part 262 - Standards Applicable to Generators
of Hazardous Waste
Federal
Rules for Class V Wells
Federal
Rules for Motor Vehicle Waste Disposal Wells
Underground
Injection Control Rules
Pretreatment
Requirements for Industrial Discharges
Self-Audit
Checklist
When
an inspector comes to your facility, there are certain things they
check to see if you are in compliance with environmental regulations.
It makes good sense for you to perform a "self-audit"
and catch and correct problems before they result in penalties.
Also, there are some compliance incentives associated with self-audits
(see Audit
Policy Page).
Use
the following list to audit your floor drain system.
- Do
your floor drains discharge to a septic tank or other well system?
Are the discharges authorized by a permit?
If you are using floor drains to discharge industrial wastewater
into an injection well system such as a dry well or septic tank,
you must obtain a UIC permit and you must not contaminate drinking
water supplies.
- Do
your floor drains discharge to the ground, a water body or storm
sewer? Are the discharges authorized by a permit? Make sure
your floor drains DO NOT discharge industrial wastewater onto
the ground. This discharge activity is illegal and you must find
another way to manage the wastewater. If you are using floor drains
to discharge industrial wastewater to a water body you must have
a NPDES permit. This includes discharges into storm sewers.
- Do
your floor drains discharge to a city sewer system? Are the discharges
authorized by a permit? If you are using floor drains to discharge
wastewater to a local wastewater treatment plant, make sure the
treatment plant knows about this activity. You may be required
to conduct treatment on the wastewater before discharging it.
You may also need to get a permit or written notification for
the discharge.
- Is
oil or solvent discharged to floor drains? These are RCRA
regulated wastes and must be removed and properly disposed of.
If the floor drain system is connected to the city sewer system,
Federal and state laws prohibit the discharge of oil or flammable
solvents.
- Is
material removed from floor drain systems properly managed and
disposed of? Perform a determination to establish if the materials
are hazardous waste. If the materials are hazardous, follow the
rules for hazardous waste storage and disposal.
Best
Management Practices (BMPs)
Most
regulations tell you what you have to do to be in compliance, but
they don't explain how to do it. That's where "best management
practices" come into play. BMPs are proven methods that
help you to get into compliance and stay there. The following BMPs
are recommended for floor drains.
- Check
all of your floor drains and make sure you know where they drain.
- Cap
or plug floor drains that are not serving a useful and lawful
purpose.
- Use
drip pans or similar devices to collect vehicle fluids before
they reach the floor drain system.
- Do
not put fluids like oil, solvents, paints or chemicals into a
floor drain.
- Install
berms in the shop around areas where chemicals are stored to prevent
their entry into the floor drain system.
- Install
screens in drains to prevent solids from entering the floor drain
system.
- Develop
and implement a maintenance schedule for inspecting and cleaning
the floor drain system.
- Prepare
and train for emergencies. Have a plan in place to quickly cleanup
a spill before it escapes.
- Use
dry cleaning methods such as sweeping instead of water cleanup,
whenever possible.
Contacts
- Industrial
Wastewater Contacts at DEP.
Related
ECAR Fact Sheets
- Wastewater
- Septic
Tanks and Disposal Wells
Other
Relevant Resources
- Floor
Drain Management, Maine Department of Environmental Protection
- Managing
Floor Drains and Flammable Traps, Minnesota Pollution Control
Agency
- DEP
Underground Injection Control (UIC) Program
- What
Should I Know About Motor Vehicle Waste Disposal Wells?
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