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
impacts of FOG FOG Program Success
Sanitary Sewer Overflows are Prohibited
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
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:
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.
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?
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
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
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”
a brochure or information sheet or letter is critical
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.
Leave copy of inspection sheet with FSE
Contact Person – owner, manager Facility Address, Mailing Address Phone Number Kitchen Equipment (What‟s on their menu?) • • • • • •
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”
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
Interceptor maintaining structural integrity?
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
Food Service Establishments Floor Traps- Indoor & …
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
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
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
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
Passed FOG ordinance Sept. 2004
5 year permits issued to all food prep facilities (120 restaurants/30 hotels)
O&G limits, grease interceptors required w/maintenance and record keeping
No FOG related SSOs since 2005
Won National Clean Water Act Recognition Award – 2008 – National Pretreatment Program Category