Knowledge is often divided into “need to know” and “nice to know” categories. “Need to know” knowledge can be looked upon as the critical must have information, while “nice to know” knowledge is often the information that is quite useful, but not necessarily vital or critical.When it comes to environmental, health and safety issues, make sure you obtain and understand what you “need to know” first and foremost, and then complement that knowledge with the “nice to know” information.
You should take this approach to all of your environmental, health and safety issues at your facility – regardless of complexity. For one client we worked with in the Mid-West, the location and discharge point of several floor drains throughout their facility definitely became “need to know”.
We were at this site investigating possible causes of contamination in several different areas of the property, which primarily consisted of oil impact to soil, groundwater, and surface water in an onsite pond. The client was willing to accept that some of the soil contamination was attributable to their onsite operations; however, they strongly believed that the groundwater and pond were possibly being impacted from offsite activities being conducted by their neighbors.
When looking at contamination issues, you need to look for potential source areas of the contamination, and then identify the potential pathways for any released materials to impact the environment. One such pathway that almost every facility has, are floor drains. Our client said there was no way that their floor drains were potential pathways contributing to the contamination identified at the site. According to the facility personnel, all the drains in the entire facility discharged to the public sewer system.
Our experience has shown that you cannot assume that your floor drains discharge to the sewer system. Floor drain locations and where they discharge must be confirmed – in other words, this is “need to know” information.
We decided to take a closer look at this facility’s floor drains. Digging through the property history, we discovered that the facility had actually been built in multiple stages over time. As the business grew, they’d expand the building.
The very first building section had been built before there were any public sewer systems available in the area. As a result, all of the facility’s wastewater (from bathrooms and also from process areas) had discharged to an onsite septic system. Now, when the public sewer system was installed in the area, the facility discontinued use of the septic system and connected to the public sewer system – or so they thought! The facility forgot about the floor drains located in the first building section of the facility. It turns out that these floor drains also discharged to the septic system. These floor drains, which handled oily discharges from processing equipment, continued to discharge to the septic system for decades after the facility connected to the public sewer system. Overtime, the facility forgot about the septic system, and it unknowingly continued to discharge oily wastewater to the septic system through these floor drains, where the oily material leached into the soil and groundwater. (By the way, this is a great example of what we call “Invisible Environmental Gorillas.” You can get a free checklist of the top 10 here.)
In the second building section, we found that most of the floor drains were connected to the public sewer system. However, we did find that the drains at the loading docks discharged to the onsite pond. Now, this setup makes sense because the loading dock drains were installed to capture and drain away any stormwater that entered the loading dock area to keep it from flooding. However, what we also found was that due to their proximity to the loading dock drains, the facility had connected the air compressor blowdown lines from the processing area to the loading dock drains. Again, the facility thought all of their drains discharged to the public sewer system. Unfortunately, due to this setup, all of the compressor blowdown, which is known to contain lubricating oil and other contaminants, ended up being discharged to the onsite pond.
As a result, the pond water – and the sediment at the bottom – were impacted by the facility, not by any of their neighbors.
In the last section of the building that was constructed, the most recently built, we found that all of the floor drains did indeed discharge to the public sewer system. Third time’s a charm.
I must stress that this wasn’t the client’s fault. Each section of that facility had been built to the standards of that time.
If you’re faced with a similar situation – an older facility that was constructed in various stages over time – you “need to know” its history and how things used to be done.
In any case, you should be taking a close look at your floor drains to make sure you know where they discharge. Don’t assume.
Researching property history through records and old blueprints, as well as speaking with long-time employees, is a good start.
But if you’re still not sure where your floor drains go, or are concerned that you’re unaware of other “hidden” environmental, health and safety issues at your facility, let’s talk.
Call Envision Environmental, Inc. now at (609) 208-1885 or email markroman@envisionenvironmental.com to schedule a phone consultation about conducting an Invisible Gorilla Evaluation.
We’ll help identify risks and exposures that exist at your facility - you just don’t see them because you’re so involved in the day-to-day operations. That’s just human nature.
As consultants with 20+ years of experience – not to mention outsiders to your facility, we see things you miss. We will most likely find issues, but not to create work for ourselves, but to help you reduce your potential exposures and help manage your environmental, health and safety risks at your facility.
We’ll always suggest ways to mitigate these issues in-house with your own facility team. My goal is to reduce your exposure, risk, and liabilities. I’m helping you eliminate future invoices from me. Because you can either eliminate these problems now, or it’ll more than likely cost a lot more money down the road.
