Fats, Oils & Grease Discharges and their Impact on SSOs

Operator Training Committee of Ohio Columbus, Ohio May 10, 2011 Jodie Opie U.S. EPA Region 5

Objectives  SSOs  FOG

Programs  Food Service Establishments   

Grease control equipment Inspections BMPs

 Residential

impacts of FOG  FOG Program Success

Sanitary Sewer Overflows are Prohibited   

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Why are they prohibited? Protect public health Prevent public and private property damage Prevent resource damage Surface Waters Fish/shellfish beds Groundwater Lost recreational value of waterways Lost tourism and sport fishing dollars

What Causes SSOs 50 45 40 35 30 25 20 15 10 5 0

Inadequate base flow capacity

Power Failures

Pipe Breaks

Excessive Pipe Infiltration Blockages and inflow

How Serious is the Problem?  20,000+

municipal sanitary sewer systems in the U.S.  23,000-75,000 SSOs occur in the US per year  3 -10 billion gallons of untreated wastewater released in the US per year  Reporting of SSOs (number and volume) is incomplete

SSOs Related to FOG 

Discharge of grease into collection systems can: 

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Solidify in sewer pipes Block wastewater flow Reduce sewer conveyance capacity Cause equipment failures Lead to SSO discharges and basement flooding Impacts to businesses, residences, waters of the US

City of Grand Rapids, Michigan 

2003-2007 experienced at least 23 SSOs related to FOG  No official FOG program in Grand Rapids.

http://www.deq.state.mi.us/csosso/events

City of Green Bay, Wisconsin  May

2009 -1.2 million gallons sewage released to Baird Creek due to plugged pipe (and broken bulkhead) due to FOG.  No official FOG program in Green Bay.

Why Not Develop a FOG Program? 

Decrease: 

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Sewer line cleaning, repair & replacement costs Sewer Pumping Station equipment & maintenance impacts WWTP equipment & maintenance impacts WWTP treatment costs Odors & contribution to hydrogen sulfide generation Estimated that a full service restaurant will cost a POTW at least $500 per year for BOD5, TSS and FOG treatment at the WWTP

Key Elements of FOG Program   

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Legal Authority SUO Enforcement Plan Review & Design Standards Inspections Permitting / Control Mechanisms Certification Performance Measures Public Education

Legal Authority • SUO Many POTWs use the General and Specific Prohibitions in the SUO…but this does not provide detail on facility requirements or enforcement • FOG Ordinance

• FOG Management Policy • Enforcement Response Guide • Does your POTW need to update its SUO, or add FOG policy guidance to have legal authority for FOG program?

FOG Ordinance or FOG Mgt. Policy contents ►Facilities covered – Restaurants, mobile food units, nursing homes, hospitals, schools, prisons, etc… ►Requirements for grease control equipment – Sizing criteria – Maintenance (pumping) – Proper materials ►Concrete, fiberglass, plastic? – Proper components/configuration ►Inlet T, Outlet T, baffle sweep or T, etc..

FOG Ordinance or FOG Mgt. Policy contents

►Certifications, reporting, recordkeeping – Grease Interceptor, Grease Trap certification – Records of pumping, maintenance ►Enforcement – Food Service Establishment Enforcement Response Guide

Plans Review / Approval of FSE Grease Control Equipment 

Are there standard operating procedures for Grease Control Equipment approval at new FSEs, or upgrades to existing FSEs? – Communication with Codes Dept, Health Dept, Stormwater Dept? 

Has the POTW adopted interceptor and trap specifications with schematic/drawing provided? Approval process documented? COMMUNICATION with other City Departments is critical.

Design Standards Grease Interceptors

Grease Layer

Food Solids

Influent T

Effluent T

Effluent T

Food Service Establishments Grease Control Equipment Grease Interceptor or

“Outside, underground tank” –Normally Concrete but some are fiberglass or plastic. Minimum capacity of 500-750 gallons

Grease Trap or “Inside, underthe-sink units”, “floor traps”, and “outdoor floor traps”

Inspections  Providing

a brochure or information sheet or letter is critical 

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Save time on explanation and have picture (worth a 1000 words) of interceptor and trap, BMPs, contact information and other info Allows the FSE something to refer to after you leave.

 Inspection 

Sheet

Leave copy of inspection sheet with FSE

Inspection Checklist 

Facility Information   

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Contact Person – owner, manager Facility Address, Mailing Address Phone Number Kitchen Equipment (What‟s on their menu?) • • • • • •

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Deep Fryer Wok Grill Stove Dishwasher Floor drains, 3 compartment sinks, other sinks

Location Info • Sewer Plat ID • Handy Map ID • GPS

Remember that most FSE mgrs will say “We don’t really have any grease”

Inspection Checklist 

Grease Control Equipment 

Interceptor • • • •

Location of Interceptor Size (estimated gallons, check waste manifest) MH access Are Inlet and Outlet T „s Visible, proper material? 

• • • • • • •

Outlet T working properly

Sample location available Depth of Grease Layer, food solids bottom layer Any other mechanical or physical problems noted Cleaning/Pumping frequency Records of cleaning available Grease Hauler Used Additives Used

Grease Control Equipment Inspections Do Not assume that because you have 2 MHs you will be able to see the Inlet and Outlet T s.

Hopefully there is access to the middle compartment for a 2 baffle wall interceptor. If the middle compartment does not have MH access then the grease haulers cannot pump middle chamber and grease & solids will build up

Food Service Establishments Grease Control Equipment Inspections

Single Manhole access does not allow inspection of the outlet or inlet T.

Food Service Establishments Poorly Located Interceptors

Food Service Establishments Downstream sewer line impact…

Identify FOG impact in sewer line. Note: Major impact may be 2 or 3 manholes downstream of FSE due to cooling of FOG Communicate with Sewer System Cleaning and CCTV personnel Identify Enforcement need, track Hotspots

Food Service Establishments Housekeeping Problems

FSEs pour “yellow” grease or recycle grease into mop sinks or floor drains, or grease spills are washed into kitchen drains, or do not pump and maintain their interceptor

Food Service Establishments Grease Control Equipment Inspections

for grease recycle bin – if FSE does not have one…what are they doing with fryer oils or other “yellow” grease? – Stormwater impacts at grease recycle bin?  Check

If recycle bin is next to a dumpster, advise the FSE mgr to either move the recycle bin or separate the bin from the dumpster with poles or curb to prevent a spill when the dumpster is emptied. Garbage trucks have caused the bins to turn over.

Food Service Establishments

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Interceptor maintaining structural integrity? 

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Possible parking lot collapse Half of concrete gone

Food Service Establishments GREASE TRAPS Under the Sink” Units

Recommend only to use traps for FSEs that do very limited cooking (i.e. deli’s, mobile food units), and make sure that proper components installed…

Grease Trap Components Estimated that only 33% installed correctly, plumbers need to be made aware of proper installation Critical: FLOW RESTRICTOR DEVICE And… Grease Trap is Vented Flow restrictor

Vent

Food Service Establishments Floor Traps- Indoor & …

Outdoor

Certification Program Prevent interceptor malfunction and deterioration problems. One answer is interceptor certification program. ftp://ftp.nashville.gov/web/ws/mws_grease_interceptor_certification_A.pdf

Enforcement is Necessary 

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Adopt a FSE Enforcement Response Guide, or SOP for enforcement of FSEs  Consistency  Efficiency Implement on-site noncompliance notifications, or notice of deficiency to the FSE. Issue these during “routine” inspections. Track enforcement on FSEs, conduct follow-ups as necessary. Escalate enforcement if necessary. NYC identified a 73% noncompliance rate with grease trap ordinance – instituted $1,000/day fine for FOG violations

Best Management Practices  Encourage   

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FSEs to utilize BMPs:

Train all staff Post “no grease” signs at sinks/dishwashers Routine checks of interceptor/grease trap cleaning “Dry wiping” of pots, pans before cleaning “Dry cleaning” of spills; adsorbent wipes/kitty litter before mopping

http://www.cityoflakeport.com/docs/FOG---BMPs,-Food-Service-Est716200891921PM.pdf

Nashville, TN

Nashville, TN

Residential FOG Control Public Education       

Door-hangers Website information Notification phone calls or letters Newspaper articles TV/Cable commercials Bill inserts POTW Sewer Jet Trucks and CCTV trucks with FOG discharge prevention decals  “Can the Grease” program  Handouts, fridge magnets, coloring books with residential FOG control – packets given to 3rd graders to take home  Grease Recycling Program for residents to bring used cooking oil

St. Johns County Utility Department, St. Augustine, FL 

Developed Oil and Grease Management Program

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Passed FOG ordinance Sept. 2004

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5 year permits issued to all food prep facilities (120 restaurants/30 hotels)

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O&G limits, grease interceptors required w/maintenance and record keeping

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No FOG related SSOs since 2005

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Won National Clean Water Act Recognition Award – 2008 – National Pretreatment Program Category

http://www.co.st-johns.fl.us/BCC/Utility_Department/media/Oil_Grease_Ord_2008.pdf