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Every year, the annual production of collected grease trap waste and uncollected grease entering sewage treatment plants from Food Service Establishments (FSEs) ranges from 800 to 17,000 pounds/year/per restaurant.
Since 2004, the EPA and NPDES have worked together to control FOG in POTWs by prohibiting “solid or viscous pollutants in amounts which will cause obstruction in the POTW and its collection system.” But what does this mean for utilities, and how can they better approach this expensive issue?
A naturally occurring byproduct of production, FOG waste is generated by FSEs from food preparation and service. FOG captured on-site is classified as either yellow grease or grease trap waste; yellow grease is derived from cooking oil and grease trap waste is separated and collected at the point of use by the FSE.
This causes major problems, including combined sewer overflows (CSOs) and sanitary sewer overflows (SSOs), and while also contributed to by homes and industrial sources. Once the grease enters the sewers and solidifies, this reduces conveyance capacity and blocks flow in sewer systems.
Controlling FOG discharges will help POTWs present these blockages that contribute to CEOs and SSOs, and ensure proper operations. The National Pretreatment Program already provides the needed regulatory tools and the authority to control interference problems under the provisions of part 403.5(c)(1) & (2). Additionally, pretreatment oversight programs should include the activities designed to pinpoint and prevent the potential interference and violations.
To best manage and prevent FOG violations, the use of an asset management solution, capacity, management, operations and maintenance (CMOM) and GIS systems are effective methods for assessing and identifying problem areas and solutions. This combination of tools provides insight into the sources of FOG, while also establishing a structure to prevent further FOG from entering the system.
Once a utility has implemented an asset management system with GIS, the POTW can work toward establishing a FOG ordinance within the community and establish design requirements for grease traps and other structures that prevent FOG from entering the collection system. Additionally, POTWs should implement an enforcement system to ensure compliance within FSEs and other entities contributing to blockage, consistent inspections to ensure that the necessary equipment is functioning properly, and prioritize cleaning the distribution systems based on discharges.
To reduce FOG discharges, the EPA expects that these blockages will decrease as POTWs incorporate FOG reduction activities into CMOM or asset management software to help enforce regulation.
POTWs should base their FOG treatment programs on the unique knowledge and behavior of their systems while integrating best practices that’ve been successful in reducing FOG discharges and backups, and an asset management solution or a CMOM program gives organizations insight into this process and enhances an organization’s ability to address problems and identify compliance issues.
Importantly, the integration of GIS mapping can locate the specific FSEs and other entities that are contributing the most to FOG and blockage, making compliance easier to achieve with this transparent reporting and insight.
Reducing FOG discharges must be a team effort. It’s up to POTWs, but also FSEs to reduce blockage and control material before entering the collection system. FSEs can adopt a variety of best practices to install collector devices that control FOG material, such as accumulating yellow grease for pick-up by consolidation service companies for resale or re-use in the manufacturing of animal feed supplements, fuels or tallow.
FSEs can also install grease traps to collect grease on-site and prevent this from entering the POTW system, and implement other maintenance procedures to capture FOG. This might be an interceptor device designed to allow FOG to cool and separate in a non-turbulent environment, or ensure that these devices are served at regular intervals and functioning properly.
Aside from FSEs, POTWs can control FOG discharges by using existing authorities (general pretreatment standards or local authorities) to enforce the FOG regulatory controls needed in order to reduce interferences with operations, such as blockages and damages to collection systems.
For example, New York City identified a 73% non-compliance rate with its grease trap ordinance among restaurants and the city instituted a $1,000-per-day fine for FOG violations in order to enforce this strictly and protect its POTWs. Other solutions to FOG compliance might include mandatory measures like inspections, periodic grease pumping, penalties and criminal citations for violators in addition to monthly surcharges added to sewer bills.
Next steps for organizations battling FOG compliance with FSEs and other entities need to first pinpoint the biggest problem areas, including the biggest FOG producers. This requires a technology solution that allows utilities to perform inspections and administer compliance programs within their communities, ideally engaging the FSE community directly.
Consider Utility Cloud –– an intelligent all-in-one utility asset management solution designed for water, wastewater and sewer utilities for industry obstacles like FOG compliance. Not sure how to get started? Contact us today with your questions.