A Local Regulatory Perspective

Transcription

1 FOG Fats, Oil & Grease A Local Regulatory Perspective Industrial Pretreatment t t Program Warwick Sewer Authority Warwick, Rhode Island BettyAnne Rossi, Pretreatment Coordinator

2 Local Historical Perspective The Warwick Sewer Authority s (WSA) Industrial Pretreatment Program (IPP) was established in early 1984 Program history demonstrates, both verbal accounts and documents, a strong emphasis on those Users with toxic wastestreams (CN, heavy metals, toxic organics) Shortly following the inception of our Program Shortly following the inception of our Program there was a substantial effort to identify and characterize sources of FOG within our city

3 Local Historical Perspective Presently we have 285 permitted FOG Users A very diverse group of permittees including restaurants, delis, meat & fish markets, buffets, supermarkets, catering businesses, fast-food joints, pizza & ice cream parlors, etc. Their abundance and unique characteristics makes for a constant challenge for our IPP personnel. Our permitting and inspection efforts provide evidence of significant reductions in blockages and SSO related to FOG

4 Components of our FOG Source Control Program Identification and Characterization ti of FOG Sources FOG Source Control Wastewater Discharge Permit Inspection Enforcement Action Legal Authority Outreach Efforts

5 FOG Source Identification The WSA continuously strives to update our industrial and commercial user inventory including restaurants and other FOG producing facilities. Identification of new Users, as well as, changes in and/or modifications to existing User processes, is achieved via multiple l mechanisms.

6 FOG Source Identification: Media Pretreatment t t personnel routinely track local newspaper and television announcements advertisements business phone directory listings in an effort to maintain current in an effort to maintain current FOG User information.

7 FOG Source Identification: Pretreatment Field Exercises Field exercises provide for an excellent opportunity to identify changes, additions and or modifications to our FOG User Base Inspectors are swift to recognize and report new construction activities changes in business signs or marquees new company vehicles

8 FOG Source Identification: WSA and City Personnel - An Extension of Pretreatment The WSA Collective WSA personnel, aside from Pretreatment staff, have proven time and again to be an invaluable resource to our Pretreatment Program. Sewer Inspectors Billing Personnel Photo above and left courtesy Donna Conde Conde Photo as in MSW Magazine 2008

9 FOG Source Identification: WSA and City Personnel - An Extension of Pretreatment City CtyResources esouces Our staff also work very closely other City Departments to identify and update our list of non-domestic Users. Building Tax T Collection Police

10 FOG Source Characterization: The Wastewater Discharge Permit Application Once identified as new or undergoing modification the facility is required to complete a Food Preparers & Processors permit application form. This application form, unlike our industrial and commercial user applications, is customized to obtain information for the characterization of FOG Sources as well as sources of other conventional pollutants (i.e., BOD, COD & TSS). Interested in obtaining a copy of our Pretreatment Program s Food Preparers & Processors permit application form? Visit

11 FOG Source Characterization: The Wastewater Discharge Permit Application The 5-page application form includes several sections of questions geared to characterize: The processes conducted on site kitchen design available appliances/equipment p menu & food preparation (scratch vs. pre-packaged) The flow/wastestream hours of business seating capacity anticipated flow The grease/solids removal system trap vs. interceptor size of system pumping and cleaning frequency biodegradation products

12 FOG Source Characterization: The Wastewater Discharge Permit Application Fees & Penalties Facilities are provided 30 days to complete and submit the form along with a one-time application fee. Late applications are subject to a $50.00 penalty for each day the forms remain delinquent. Application Fee Annual Permit Fee Category - Description $ $ R-1: Seating capacity of 1-25 persons $ $ R-2: Seating capacity of persons $ $ R-3: Seating capacity of persons $ $ R-4: Seating capacity of persons and/or 50% or more gross receipts from takeout or drive-up $ $ R-5: Seating capacity of >125 persons

13 FOG Source Characterization: The Wastewater Discharge Permit Application Application Submittals A site inspection is conducted following a rigorous review of the application submittal in order to confirm the information provided. Confirmation of the information supplied is essential in assessing the facility s potential to impact our collection system and/or the environment (SSO). Solid characterization of the facility and wastestream allows for our Pretreatment personnel to: evaluate the suitability of the proposed pretreatment equipment/system t (grease trap vs. grease interceptor, t size of unit) as well as, properly categorize the facility for our permitting purposes.

14 FOG Source Control: The Wastewater Discharge Permit The Control Mechanism Having confirmed the information as supplied in the application form, a site specific wastewater discharge permit is issued. As previously demonstrated permit categories are established relative to the seating capacity of the facility and/or percentage of gross receipts derived from drive-up or take out food. Category Description R-1 Seating capacity of 1-25 persons R-2 Seating capacity of persons R-3 Seating capacity of persons R-4 Seating capacity of persons and/or 50% or more gross receipts from take-out or drive-up R-5 Seating capacity of >125 persons

15 FOG Source Control: The Wastewater t Discharge Permit Categories R-1 and R-2 Small (1-50 seating capacity), low flow businesses Basic menu with limited offerings requiring minimal preparation Installation of an appropriately sized grease trap is required. These locations typically do not have high volume water usage in their kitchens (pre-rinse & dishwashers) therefore grease traps are adequate ate if they are: properly installed AND properly maintained (typically y weekly, semi-weekly)

16 FOG Source Control: The Wastewater t Discharge Permit Category R-3 Medium ( seating capacity), moderate flow businesses More diverse menu with several offerings requiring additional preparation operations Installation of an appropriately sized grease trap is required. However, R-3 s may be required to install a grease interceptor if warranted by their anticipated: flow business volume Again, grease traps are typically adequate for FOG removal if they are: properly installed AND properly maintained (typically semi-weekly or daily)

17 FOG Source Control: The Wastewater t Discharge Permit Categories R-4 and R-5 Large (100 - >125 seating capacity), high flow businesses Elaborate, eclectic menu with numerous offerings requiring i advanced preparation, typically from scratch Installation of an external, in-ground appropriately sized grease interceptor OR interceptors is required. Sized for minimum of 24-hours detention time Adequate detention time is required for cooling and separation of the wastestream pollutants Grease floats to surface of tank, while solids will settle out along the bottom Internal baffles will facilitate better separation Important to note: Tanks which employ baffles must have adequate access points to ensure proper cleaning of the unit

18 FOG Source Control: The Wastewater Discharge Permit Categories R-4 and R-5 Additionally a sampling/observation manhole must be installed for the separate exiting sanitary and process flow lines. The purpose of the manhole is multifold allowing for: discreet inspection and/or sampling of the process wastewater line 24 hours/day the discharge of excess pollutants to be readily detected at the process invert, prior to dilution from other wastestreams ease in access for preventative cleaning & maintenance ease in access to free a blockage Separate are equally as important lines readily allowing for upgrades to the existing grease removal system if warranted

19 FOG Source Control: The Wastewater t Discharge Permit Categories R-4 and R-5 Permittees with grease interceptors are required to perform quarterly effluent monitoring for TSS, BOD, COD and O&G. The monitoring months of January, April, July and October have been chosen to demonstrate seasonal influences (if any) on effluent quality. As with our industrial and commercial permittees, our Program will accept only those data generated by a laboratory licensed with the RIDOH to perform and report (for regulatory purposes) the analyses as set forth in the Permittee's permit. Monitoring results must demonstrate compliance with the WSA s discharge limits for conventional pollutants.

20 FOG Source Control: The Wastewater t Discharge Permit Categories R-4 and R-5 Levels above the maximum discharge limits identified are subject to enforcement action. Levels of pollutants t which h exceed their respective surcharge limit are subject to annual surcharge fees which are included in the permittees annual bill. Pollutant Maximum Discharge Limit (mg/l) Surcharge Limit (mg/l) Surcharge Value (price/lb) BOD 1, $0.30/lb COD 5, $0.30/lb TSS 1, $0.30/lb O&G $0.24/lb

21 FOG Source Control: Inspections Purpose To foster a positive, cooperative working relationship with permittees Presence demonstrates commitment to the relationship and to environmental protection To ensure the Permittee's compliance with their wastewater discharge permit To identify incidences of noncompliance and provide immediate corrective action(s) and time table for implementation

22 FOG Source Control: Inspections What if the permittee is uncooperative, denying entry or access (i.e., manhole covered by vehicle) for inspection?

23 FOG Source Control: Inspections Frequency FOG locations (restaurants) are generally inspected 1-2 times per year. Larger restaurants (R-4 s and R-5 s-seating capacity of > 100) may be inspected more frequently. Restaurants known to have historical oil and grease problems are inspected more often to: ensure proper maintenance of the grease removal system review grease rendering activities review permit requirements (frequent changes in personnel)

24 FOG Source Control: Inspections Elements of the inspection include, but are not limited to: A tour of the facility including chemical/cleaning product storage areas to ensure that enzyme products are not being used (enzymes are prohibited from use within our City), Inspectors are required to look for the installation of garbage grinders which are also strictly prohibited from use within the City, Inspection of the observation manhole and invert (if present/accessible),

25 FOG Source Control: Inspections Inspection of the grease/solids removal system to ensure proper installation (flow restrictors, inlet/outlet T location), maintenance and cleaning, Permittees are required to post a grease trap/grease interceptor cleaning log in a conspicuous location in their kitchen/process area so it is readily available during an IPP inspection.

26 FOG Source Control: Inspections - Reports Information gathered during an inspection must be: Well documented in a report prepared by the inspector, a hard copy of which is stored in the Permittee's file for future reference. A camera is an absolute for documenting inspections! A picture is worth a thousand words especially when administering an enforcement action!

27 FOG Source Control: Inspections - Reports Information gathered during an inspection must be: Entered into an electronic database which can then be referenced or queried via plat/lot, address, or other pertinent information for use in tracking hot spots or problematic locations provides for mechanism to track and log corrective actions

28 FOG Source Control: Inspections Deficiencies and/or non-compliance noted at an inspection event are always: immediately brought to the facility manager s attention (or equivalent) addressed with corrective actions and a time table for implementation followed-up with additional activities including: subsequent inspection(s) to ensure that corrective actions have been implemented; line cleaning/flushing exercises as warranted Official Enforcement Action: including but not limited to Fine, Administrative Order (AO) with Fine, Show Cause Order, Civil Action.

29 Legal Authority The Rules and Regulations of the Warwick Sewer Authority or Sewer Use Ordinance (SUO) grants authority to the WSA to regulate discharges to the sewer system, including those that contain grease. Our SUO prohibits discharges to the collection system containing more than 100 mg/l (ppm) of O&G, or those discharges that, at lesser levels, interfere with the operation of the collection system. The ordinance also authorizes inspection of FOG producing facilities, and the administration of enforcement action in the form of notices, orders and/or fines where non-compliance is observed. The WSA s IPP has administered fines where facilities have discharged excessive amounts of grease resulting in a blockage in the collection system. The WSA has also back-charged facilities where extensive flushing and cleaning of the collection system was required to remove a FOG blockage caused by their discharge. The WSA has aggressively pursued reimbursement for damage claims where the source of the FOG blockage was clearly identified.

30 Legal Authority The Pretreatment t t Coordinator, Superintendent, t Executive Director and WSA Board have varying levels of involvement in the execution of enforcement actions taken in response to permitted user non-compliance. Our IPP s Enforcement Response Plan (ERP) clearly identifies those individuals responsible for executing enforcement actions as they pertain to specific events of non-compliance. The ERP is identified in Regulation 54 of the WSA s SUO as an important guidance document in the administration of enforcement actions where non-compliance is observed.

31 Outreach Efforts and Program Effectiveness The WSA s Pretreatment FOG Program has been very effective in reducing blockages due to grease. Although our personnel may identify sporadic grease blockages in our system, they are frequently identified as aggravated blockages or those blockages associated with roots, structural deficiencies and construction debris.

32 FOG Outreach Efforts and Program Effectiveness Factors contributing to enhanced compliance/decline in blockages include, but are not limited to the following: Our IPP s permitting, monitoring and inspection efforts have undoubtedly accounted for the decline in grease blockages observed in recent years. The WSA s flushing equipment and newly purchased robotic camera/video equipment have been instrumental in identifying potential blockages and aiding in blockage prevention. Informational materials including our IPP s Quick Guide to Restaurant Discharge Maintenance ( also available on our website) which provides answers to commonly asked questions regarding grease/solids removal have also been helpful. Future efforts: develop and distribute other informational brochures on FOG, including one for residential locations to assist the home owner in making wise/compliant decisions for their FOG/solids disposal.