The Drain-and-Stack Walkaround is a short self-check that goes around a site from the floor drains to the rooftop units. The legal background is on the overview and rules and numbers pages.
The Drain-and-Stack Walkaround
- Drains: list every floor drain, storm inlet and wash area, and note whether anything other than rain reaches a storm sewer or stream.
- Ground: before work disturbs 1 or more acres, confirm stormwater coverage is in place; industrial sites confirm ILR00 coverage or a no-exposure certification.
- Tanks: add up aboveground oil containers of 55 gallons or more and compare the total with the 1,320-gallon line for a spill plan.
- Rooftop and coolers: list air conditioning and refrigeration units with their charge sizes and technician certifications; for HFC appliances of 15 pounds or more, record each refrigerant addition and the leak rate.
- Paint and solvent: at auto body shops, check painter training, booth filters and spray guns; at dry cleaners, check the machines, leak checks and the Illinois license.
- Paper: keep permits, notifications, leak records and training proof in one folder.
- Help: note the Illinois small business assistance program and EPA's 21-day disclosure window before a problem appears.
Common mistakes
- Starting grading before construction stormwater coverage is in place.
- Running an industrial site with neither ILR00 coverage nor a no-exposure certification.
- Spraying coatings with uncertified painters, an unfiltered booth or a non-compliant gun.
- Assuming a shop is exempt from the auto body rule without a notification or records of the coatings sprayed.
- Venting refrigerant, or letting uncertified staff open a refrigerant circuit.
- Ignoring leak rates on HFC systems of 15 pounds or more after January 1, 2026.
- Skipping the Illinois dry cleaner license; late payers cannot operate until paid.
- Storing more than 1,320 gallons of oil aboveground with no spill plan.
When to talk to an attorney
A CPA cannot answer these questions. Owners commonly call an attorney when:
- A notice of violation, information request or inspection warrant arrives from EPA, the Army Corps or Illinois EPA.
- Work is planned in wetlands or near streams.
- A site being bought or sold may be contaminated.
- Self-disclosing a violation is under discussion.
- A spill or release may need immediate reporting.
Frequently asked questions
Does every small business need an EPA permit?
No. Permits depend on the activity: acres disturbed, discharges to waters or storm sewers, emissions and refrigerants. In Illinois, construction and industrial stormwater are covered by the state's own general permits, ILR10 and ILR00.
Does the 2026 HFC leak-repair rule cover my office air conditioning?
Residential and light commercial air conditioning and heat pumps are excluded. The rule covers appliances with 15 pounds or more of HFC or certain substitute refrigerant, such as supermarket and walk-in refrigeration and chillers.
Is there penalty relief for small businesses?
EPA's Small Business Compliance Policy applies to businesses with 100 or fewer employees. Penalties can be eliminated or greatly reduced when the business finds a violation, discloses it within 21 days and corrects it. It does not cover criminal conduct, imminent danger or repeat violations. Illinois also offers free, confidential help through its small business environmental assistance program.
Are environmental fines tax deductible?
Fines and penalties paid to a government are not deductible under Internal Revenue Code section 162(f). Restitution or compliance payments can be deductible only if the order or settlement identifies them as such and the taxpayer proves it. See the IRC guide.
A CPA can help with the payroll, tax and accounting side of these issues and works alongside the owner's attorney. Related pages: construction and contractors, restaurants and retail and the OSHA guide.
Official sources
- EPA: Small Businesses and Enforcement
- Illinois DCEO: Small Business Environmental Assistance Program
- EPA: Stationary Refrigeration Leak Repair Requirements
- Illinois EPA: Drycleaners
This page is a plain-language summary. The official source controls if there is any difference.