Do You Know Where Your Drains Go
It’s important to know where your facility’s indoor and outdoor drains lead to, which determines what can go down them. Discharging the wrong materials down certain drains violates federal, state and/or local regulations in addition to harming the environment and potentially causing public health problems.
The three most common end points that your drains could lead to include:
1. Sanitary Sewers
Wastewater and other liquids that pass from drains to sanitary sewers separate into a scum layer, water layer and sludge layer. The water layer moves to a drain field where the water is either channeled back into the ground or sent to a publicly owned treatment works (POTW) to be sanitized and reused.
POTW’s are not designed to treat industrial waste, so check with your local authority to discuss the waste your facility produces that could end up in a sanitary sewer.
2. Onsite Treatment Facilities
Wastewater treated at or near its point of generation is either channeled to a nearby waterway after treatment or pumped back to the facility to be reused.
Flushing pollutants, such as pathogens, nitrogen and phosphorus to an onsite treatment facility can affect treatment and potentially pass through some treatment systems, polluting water. Test your wastewater for those and other pollutants before discharging processed waters.
If your facility is close to a waterway, there’s a good chance your drains lead directly there. You’ll need a National Pollutant Discharge Elimination System (NPDES) permit if your facility discharges pollutants, such as oil, sediment or other hazardous waste.
Even with a NPDES permit, you can’t dump whatever you want down drains. All NPDES permits have conditions that limit the amounts of a pollutant that may be discharged based on EPA Water Quality Standards.
Changes that Might Affect Your Protection Efforts
The Environmental Protection Agency (EPA) and U.S. Army Corps of Engineers published a rule in 2015 that clarified the scope of “Waters of the United States” (WOTUS) under the new Clean Water Rule. The new rule places an emphasis on tributaries, as well as waters next to rivers and lakes, that feed and impact downstream waters.
Although several states and organizations are contesting the rule, the clarifications still help facilities better determine whether they are subject to Clean Water Act regulations.
Read what your peers and industry experts are saying about the EPA’s new definition of WOTUS.
Much of the water that flows into navigable waterways comes from industry drains, which is why it’s important to protect drains and prevent discharges.
Protect Your Drains
It’s important to protect your drains no matter where they go to stay in compliance with the Clean Water Act as well as applicable local and state regulations.
Contained spills can’t get to drains. Hazardous liquids must have secondary containment should their primary container fail to prevent a discharge to navigable waters or adjoining shorelines. Common methods include berms, decks, pallets and portable pools. Secondary containment isn’t the solution to spills, but it will buy responders time to figure out a solution.
Secondary containers, like primary containers, can fail. When one does, you’ll be glad to have a spill kit with the appropriate absorbents nearby as a backup. Keep spill kits and other response supplies in spill-prone locations and near vulnerable drains.
Drain covers can be used proactively before fluid transfers and in areas that will be unmanned. They can also be used reactively after a spill has happened but before liquid gets to the drain. Some drain covers are a one-time use while others can be cleaned and stored for future incidents.
Whether it’s one big spill or trace amounts of sediment and hazardous material that enter a drain on a daily basis, water pollution destroys one of our most valuable natural resources. Protecting drains should be a key component in every facility’s environmental compliance efforts. Being aware of what can enter a storm drain and prepared to prevent incidents preserves this vital resource.