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ECAR Fact Sheet for Michigan
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 you have
an inspection.
Floor
drains in many industrial facilities have been found to empty into
surface waters, or into septic fields. In either case, the discharge
of wastewater from the shop floor into this kind of system is illegal.
If the floor drain discharges into a city sewer system, it will
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
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?
It is very important to know where all your floor drains
lead, and that you are aware of Michigan MDEQ’s regulations that
apply to your discharge activities. If you do not know where your
drains lead, or if you using floor drains improperly, you could
be contaminating nearby surface waters or drinking waters.
Wastes entering floor drains may only be legally disposed
of if the discharge goes to the following:
- Publicly
Owned Treatment Works (POTWs) or municipal wastewater treatment
plants, with prior approval by the local sewer authority. You
may be required to treat the wastewater before discharging (e.g.
oil/water separation, removing solids, chemicals, etc.)
- Holding
tanks that are then pumped out and the wastewater and sludge is
hauled to an approved facility. See the ECAR Wastewater fact
sheet.
NOTE: Any floor drains that do not discharge to either of the above must be
closed off. This is often done by plugging the drain with concrete.
Any company that wants to discharge an industrial wastewater
to waters of the state needs to get a permit (NPDES permit) from
MDEQ. Examples of waters of the state include streams, rivers, lakes,
ponds, marshes, waterways, wells and springs. If your floor drains
lead to any water of the state, you must have a discharge permit
for this activity. The DEQ will not usually issue a groundwater
discharge permit for floor drains connected to septic systems.
Links to the Regulations. Use the following links to view the
regulations and permit forms pertaining to floor drains.
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 Motor Vehicle Waste
Disposal Wells
Michigan’s Natural Resources and
Environmental Protection (Act 451), Part 111 regarding Hazardous
Waste Management and administrative rules
Michigan’s Natural Resources and
Environmental Protection (Act 451), Part 121 regarding Liquid Industrial
Waste
Self-Audit
Checklist
When an inspector comes to your facility, there are certain
things he or she checks 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 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 or into septic systems. 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 National Pollutant Discharge Elimination
System (NPDES) Permit. This includes discharges into storm sewers.
- Do
your floor drains discharge to a city sewer system? Are the discharges
authorized by prior approval? 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 also need to get a permit or written notification for
the discharge.
- Is
oil or solvent discharged to floor drains? These are federally
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
wastewater collected in holding tanks properly characterized and
managed as liquid industrial waste or hazardous waste? Are
registered haulers used to ship waste off-site? Are manifests
submitted as required? Are copies of manifests and characterization
documentation kept for at least 3 years from waste shipment?
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.
- Don’t
hose down your work area. This practice generates large quantities
of contaminated wash water.
- Consider
sealing your shop floor with epoxy or other suitable sealant.
Contacts
- For
questions regarding the Industrial Pretreatment Program, contact
your local wastewater treatment plant or MDEQ Water Bureau District
Office.
- For
more information, contact MDEQ’s Environmental Assistance Center
at 1-800-662-9278.
- For
reporting spills/releases and pollution emergencies, contact:
1-800-292-4706.
Related
ECAR Fact Sheets
- Wastewater
- Septic
Tanks and Disposal Wells
- Stormwater
Other
Relevant Resources
- Managing
Floor Drains and Flammable Traps, Minnesota Pollution Control
Agency
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