Floor Drains

ECAR Fact Sheet for New York
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 surface waters, 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 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.
It is illegal to discharge directly to surface waters without a State Pollutant Discharge Elimination System (SPDES) permit. Industrial discharges to septic systems are also illegal.
Auto recyclers should be aware that floor drains should not have a direct discharge to the ground or groundwater.
Floor drains must be connected to a public sewer system. Refer to the Local Codes Enforcement Officer and the Sewer Use Ordinance before making any new connections. Some municipalities restrict floor drains from being connected to the sewer system, depending on the type of operation. Floor drains not connected to a publicly owned treatment works (POTW) could be considered an underground injection and would constitute a violation of federal laws unless authorized by a permit. Floor drains connected to a POTW must adhere to the requirements of the sewer authority.
You may be required by your sewer operators to connect an oil/water separator between the between the floor drains and the sewer system. Oil/water separators should be checked on a monthly basis to make sure they are working properly. This includes cleaning out the sludge annually, testing it for toxicity and then disposing of it properly.

Links to the Regulations and Forms. 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 Class V Wells

Federal Rules for Motor Vehicle Waste Disposal Wells

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. 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 State Pollutant Discharge Elimination System (SPDES) 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.
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 information about water discharge permits, contact Angus Eaton at 518- 402-8123.
To report a chemical or petroleum spill, contact 1-800-457-7362. (24 hour number)

Related ECAR Fact Sheets

Other Relevant Resources

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