Facilities Planning has recently become aware of a new enforcement initiative by the U.S. Environmental Protection Agency (EPA). Floor drains connected to underground dry wells, typical in School District maintenance garage service bays, are no longer allowed by the Federal Underground Injection Control Program under the Safe Drinking Water Act. EPA requires a cleanup and closure plan within 30 days or penalties up to $25,000 a day and 3 years imprisonment may be assessed.
Floor drains must be re-routed to a collection tank or acceptable sanitary sewer system that is connected to a sewage treatment plant.
The New York State Department of Environmental Conservation (DEC) has in the past allowed service area floor drains connected to dry wells under the State Pollution Discharge Elimination System (SPDES) permit program. Also instructions related to the State Environmental Audit Law have not previously emphasized these floor drains as potentially unique sources of pollution. However, since the EPA enforcement initiative has been implemented, the DEC is directing that all service bay floor drains connected to subsurface disposal systems be eliminated.
Facilities Planning will no longer approve service bay floor drains shown discharging to dry wells for new construction or reconstruction projects. For existing buildings, school districts should plan to disconnect and close all such existing drains as part of their ongoing capital construction planning.
For further information, districts should contact their regional DEC office.