IDENTIFYING AND STRENGTHENING WEAK LINKS IN THE FOG MANAGEMENT CHAIN

Carrie R. Mero, PE, URS Corporation North Carolina Jessica L. Wilkerson, EI, URS Corporation North Carolina

ABSTRACT Recently, EPA presented statistics that cited grease accumulation in sewers as the leading cause of sewer blockages resulting in sanitary sewer overflows (SSOs). Such blockages can be attributed to fats, oils, and grease (FOG) discharged from food preparation and manufacturing facilities, concentrated residential areas, and even single family homes. North Carolina municipalities and wastewater system managers have responded to this problem by implementing FOG management programs, often successfully reducing FOG blockages and subsequent SSOs. However, many programs are not as strong as they could be in important areas of education, treatment, and enforcement. These weaknesses may ultimately result in FOG management program failures. North Carolina municipalities, governmental agencies, and wastewater system managers should anticipate potential weak links while addressing the typical aspects of a FOG management program. Common weak links include ambiguous or vague ordinances that do not clearly delineate roles and responsibilities, poorly trained kitchen staff, inappropriate grease interceptor (GI) sizing methods, and weak enforcement of FOG management regulations. By adequately reinforcing weak links in the FOG management chain, responsible officials and agencies can create a FOG management program that will save money, time and resources, and protect the health of the public and the environment, by reducing FOG accumulation in the sewer system. This presentation will present common FOG management options and guidelines used in North Carolina, and discuss areas that can easily become weak links if not diligently and thoroughly addressed in the FOG management program.

KEYWORDS Fats, oils, and grease (FOG); wastewater collection system; grease trap; grease interceptor; sanitary sewer overflow (SSO); wastewater pretreatment.

INTRODUCTION For the past several decades, municipalities and government agencies have recognized the importance of addressing excessive fats, oils, and grease (FOG) discharges into the sanitary sewer system. FOG discharged from food preparation facilities, food manufacturing facilities, and residential areas, if not properly pretreated, enters the wastewater collection system. In the typical sewer environment, FOG can solidify and accumulate in sanitary sewer pipes and lift stations, potentially leading to sanitary sewer overflows (SSOs). Additionally, excessive FOG can disrupt lift stations and wastewater treatment plant (WWTP) operations. To mitigate the expensive and potentially hazardous impacts of FOG, most municipalities and wastewater collection system managers have implemented FOG management programs, with much success. However, these programs are often not as strong as they could be in important areas of education, treatment, and enforcement. These weaknesses may undermine an otherwise successful and comprehensive FOG management program. This paper presents common FOG management options and guidelines, and discusses areas that can easily become weak links if not properly addressed in the FOG management program. BACKGROUND Fats, oils, and grease Vegetable oils and animal fats from food and food preparation activities (e.g., frying, grilling) are commonly referred to as FOG, an umbrella term for all edible fats, oils, and grease. FOG can be either liquid (oils) or solid (fats and grease), has a lighter density than water, and is not readily water-soluble. These characteristics allow FOG to

Identifying and Strengthening Weak Links in the FOG Management Chain

float on the surface of water, unless influenced by physical and/or chemical factors that can lead to emulsification or mixing, such as high temperatures, high turbulence, mechanical mixing (i.e., pumping) and cleaning products or additives containing surfactants. Sources. Any facility that prepares, processes, manufactures, or serves food has the potential to contribute FOG to the wastewater collection system. These include food service establishments (FSEs), such as restaurants, schools, and grocery stores; food manufacturing or processing facilities; concentrated residential areas, such as multifamily/apartment complexes; and even single family homes. Food manufacturing and processing facilities can vary greatly and should be included in the municipal industrial discharger program. Grease interceptor (GI) and FOG management programs for such facilities should be developed on a site by site basis. The remainder of this discussion is focused on more typical FOG contributors, such as FSEs and residential areas. Most often, FOG enters the wastewater stream as a liquid during cookware and dinnerware washing activities. Both hand washing and automatic dishwashers use high temperature water and emulsifying detergents, which by design ensure that the FOG is liquefied. Another common pathway for FOG discharge is direct disposal in kitchen drains. Often, improperly trained kitchen staff and residential dischargers dispose of used frying grease and cooking oils in kitchen sink drains, garbage disposals and/or floor drains because they have never been informed of the potential implications of discharging grease and oil into the sanitary sewer system. Commercial or institutional kitchens have other unique FOG discharge sources because of the large quantities of food prepared at these facilities. Commercial food preparation equipment contributes a significant amount of grease and solids because the wastewater from cleaning them and, often, any remaining food contents are emptied into floor sinks. Garbage disposals or pulpers are commonly found at large kitchens, which also present a significant source of FOG and food solids. Impacts of fats, oils, and grease. FOG-laden wastewater can cause problems in the collection system when lower temperatures and decreased turbulence allow liquefied FOG to re-solidify and accumulate on sanitary sewer walls and in lift stations and WWTP headworks. This can result in hazardous impacts on public and environmental health, as well as large financial impacts on municipal utility budgets. Pipe blockages caused by FOG accumulations and combination FOG-debris aggregates lead to SSOs, which discharge raw sewage into the environment and waterways and have the potential to expose the public to harmful pathogens. Cleaning and repairing the damages caused by SSOs is costly, and the required monetary investment can vary considerably depending upon the extent of the damage and the volume of the release. In a 2004 Report to Congress, EPA presented SSO characteristics gathered from reportable SSO data from 25 states, recorded during the years of 2001 through 2003 (EPA, 2004). The most commonly cited cause of reported SSOs in sewer lines was identified as blockages, with nearly half of those attributed to grease accumulation. The report further stated that grease-related SSOs during this time period resulted in the discharge of approximately 30 million gallons of raw sewage, which introduced harmful pollutants into the environment and exposed the public to potentially hazardous pathogens. In addition to these environmental and public health implications, SSOs are also a significant financial burden for municipalities and collection systems. Depending on the extent of the damages caused by an SSO, these costs can vary from approximately $5,000 for a typical SSO event (NCDENR DPPEA, 2005) to more than $100,000 for overflows that result in sewage backups into multiple private homes (Moyer, 2006). Sewer back-ups into homes due to downstream grease blockages are quite common and usually occur as a result of a combination of FOG and structural and maintenance issues, including undersized pipes, root infiltration, and damaged or poorly maintained collection system infrastructure. FOG-laden wastewater discharges exacerbate these structural and maintenance problems, as grease tends to collect in areas of pipe irregularities and low velocity. Even if FOG accumulation does not escalate into blockages and SSOs, it can disrupt lift station and treatment plant operations, sometimes necessitating costly repairs, by-pass pumping, or service disruptions. Lift stations are particularly vulnerable to FOG accumulation because they provide a stable environment with low temperatures and decreased turbulence, which allows FOG to separate and accumulate on the walls and equipment. If not properly managed, grease accumulation in lift stations can damage and foul equipment, increasing the necessary frequency of inspections, maintenance activities, and repair or replacement of parts. Dealing with FOG in the collection system significantly increases routine and emergency operation and maintenance costs for all components of the wastewater system. Additionally, high FOG concentrations in wastewater can disrupt WWTP biological processes and

Identifying and Strengthening Weak Links in the FOG Management Chain

contribute to FOG accumulation on tanks and equipment, increasing operation and maintenance requirements and costs at the treatment facility. Grease pretreatment units Grease pretreatment units are typically installed at FSEs in order to reduce the amount of FOG discharged to the wastewater collection system. These units, depending upon the type, remove FOG either passively, by allowing it to float to the surface where it is retained until physically removed, or actively, by employing oleophilic (oil loving) moving parts that attract FOG and deposit it into a separate collection bin. If properly sized, installed, and maintained, these systems can provide effective pretreatment for oily and greasy wastewater discharges, therefore minimizing the FOG contributed to the collection system from an FSE. Grease pretreatment units can be organized into three main categories: Exterior Underground Grease Interceptors (GIs), Under-the-Sink Grease Traps (either in-floor or on top of floor), and Automatic Grease Removal Systems.

Exterior underground grease interceptors. Large underground GIs are typically installed outside of a food service facility and receive flow from all the drains within the kitchen that may have FOG-laden discharges. Underground GIs can be constructed of concrete, steel, or fiberglass and have tees and/or baffles that retain the floating oil and grease inside the tank. They can vary in size from 300 to over 20,000 gallons in capacity. Underground GIs are typically located at the rear of the building near the loading dock and/or dumpster areas, so that they are easily accessible to a vacuum truck for pumping and cleaning. Manhole-type covers are usually installed at the ground surface to provide access for inspection, cleaning, and maintenance. Figure 1 provides a diagram of a typical exterior underground GI. Figure 1 Diagram of Typical Exterior Underground Grease Interceptor

(Bay Area Pollution Prevention Group, 2004)

Identifying and Strengthening Weak Links in the FOG Management Chain

Under-the-sink grease traps. Under-the sink grease traps are often installed at small FSEs that do not generate large FOG-laden wastewater flows, such as a small deli or bakery. These point-of-use units are installed at each FOG generating drain in the kitchen, usually dedicated dishwashing sinks, and can be installed either above or under the floor. Grease traps are significantly smaller than GIs, ranging in size from 10 to 500 gallons, and can be constructed of steel, fiberglass, or plastic. The smaller size is possible because grease traps are designed with specialized internal baffle arrangements and an external vented flow control device, which allows air entrainment to accelerate the separation process and increase separation efficiency. Solids strainers or interceptors are usually installed upstream of these units to prevent fouling from excessive food solids. Figure 2 provides a diagram of a typical grease trap. Figure 2 Diagram of Typical Under-the-Sink Grease Trap

(PDI, 1998) Automatic grease removal/skimmer systems. Another form of FOG control is the automatic grease removal or skimmer system. Like grease trap units, these automatic systems are often installed at facilities that do not generate a significant amount of FOG-laden wastewater and may only have one or two sources of grease (e.g., wash sink and/or dishwasher only). These point-of-use automatic grease removal systems are installed under the sink and above the floor at each dishwashing drain. Also like grease trap units, solids strainers or interceptors are usually installed upstream of these units to prevent fouling from excessive food solids. Figure 3 provides a diagram of a typical automatic grease removal system. Figure 3 Diagram of Typical Automatic Grease Removal System

(PDI, 1998)

WEAK LINKS IN THE FOG MANAGEMENT CHAIN Many municipalities implement FOG management programs in an attempt to reduce the discharge of FOG into the sewer system and, subsequently, mitigate its impact on the wastewater collection system and public and environmental health. Although FOG management programs have been effectively implemented to reduce grease blockages in wastewater collection systems, there are several areas that, if not given adequate attention and planning, can become weak links and cause a failure in the FOG management chain.

Identifying and Strengthening Weak Links in the FOG Management Chain

Determining the authority having jurisdiction One of the first obstacles facing a successful FOG management program may be determining under whose jurisdiction it falls. FOG management involves public utilities, plumbing and building codes, public health, environmental health, and law enforcement; each of these areas could have its own agency and regulations. According to an article published in 2005, the State of Ohio discovered several obstacles and regulatory gray areas when trying to determine the appropriate agency to enforce rules relating to FOG management and GI pretreatment devices (Dexter, 2005). Confusion as to which governing agency had jurisdiction over exterior GI pretreatment units ultimately lead to the determination that neither the existing plumbing code nor the existing building code adequately addressed GIs or had the authority to do so. In the opinion of the author, several changes in administrative codes and increased cooperation among the parties involved are required to eliminate FOG contamination/pollution from entering the environment and adequately manage GI installation and operation (Dexter, 2005). The following recommendations were made regarding the delineation of roles: The State environmental agency should regulate and establish limits for discharges to the environment from WWTPs; Wastewater collection system managers and/or WWTP operators should regulate individual dischargers to their system and establish rules for discharge limits, monitoring, and/or sampling; Design and manufacturing organizations should be responsible for developing grease pretreatment unit designs and equipment that will meet or exceed discharge limits; and Wastewater collection system managers and WWTP operators should work in cooperation with the food service division of the public health department to monitor and develop best management practices and record keeping requirements (Dexter, 2006).

Coordinating and delegating FOG management responsibilities among appropriate governmental and regulatory agencies may be a challenge, but it is essential to implementing an effective and cohesive FOG management program. Public education Wastewater system managers can reduce FOG discharge by educating their customers about the potential problems it can cause and providing instruction on how to dispose of kitchen food wastes, grease, and used cooking oil properly. FOG education programs are geared towards both residential and commercial users. Residential education programs. Public education campaigns usually make use of catchy slogans, mascots, wellplaced posters, advertisements on local television channels, informational websites, and bill stuffers to attract their customers attention while teaching them about FOG management. Residential users are instructed to avoid pouring oil and grease down the drains and to collect food wastes for composting or landfill disposal, rather than using the kitchen sink and garbage disposal. Often, blanket public education campaigns are effective for the majority of residential areas, but for various reasons they may not be adequately or appropriately communicating the message to all neighborhoods or populations. If particular residential areas are identified to be contributing a noticeably high level of FOG to the collection system, it may be necessary to develop and implement a more targeted approach. Wastewater collection system managers should utilize their mapping capabilities to identify the areas of concern. Plotting locations of SSOs, sewer back-up calls, and line blockages may reveal a pattern of problems in or downstream of particular neighborhoods. Excessive accumulation of grease in lift stations provides evidence of upstream violators. When a residential area is identified as a problem, collection system managers should instigate an education campaign targeted toward those residents. The targeted campaign should inform residents that there have been grease problems in their neighborhood, remind them of the proper FOG management procedures, and inform them that the discharge of FOG into the sewer system is strictly prohibited. Rather than a flyer or commercial sent to all customers or residents of the municipality, this message should be delivered only to the residents of the problem area, possibly by way of hand delivered notices or door tags. This approach may cause frequent violators to feel more accountable for their actions, and they may change their behavior to avoid a punitive action.

Identifying and Strengthening Weak Links in the FOG Management Chain

Most importantly, public education campaigns should be persistent. Current residents may need frequent reminders of the proper procedures, and new residents arrive on a regular basis. It may be useful to develop education materials targeted towards particular groups of new residents, such as college students or military installation personnel. Student-specific information should be distributed near campuses or on campus television and radio stations at the start of each semester. At military installations, FOG education information can be provided in welcome packets. Commercial education programs. It is essential that restaurant and other commercial kitchen managers and staff are adequately trained on the location and operation procedures of the GI(s) installed at their facilities; especially if they will be required to perform regular maintenance, such as discarding the grease accumulated by under-the-sink grease removal systems. A common cause of GI failure is improper operation and neglect. Kitchen staff should be educated on how a unit works and trained to follow operating procedures, including: Minimizing discharge of wastewater containing oil and grease; Minimizing the use of excessive detergents and cleaners containing emulsifying agents; Reducing the introduction of food solids and other kitchen wastes into the drains, GIs, or the sewer system; Placing used oil and accumulated grease in grease collection containers to be recycled, and taking precautions to minimize spills around these containers; and Recognizing signs that the GI is not operating properly (e.g., excessive odor, plumbing back-ups, surcharging) and contacting the appropriate person(s).

Kitchen managers should also be informed that common kitchen practices and appliances, such as garbage disposals and high temperature dishwashers, can compromise GI performance and have substantial impacts on the downstream sewer lines, potentially effecting their own establishments. The North Carolina Department of Environment and Natural Resources (NCDENR) Division of Pollution Prevention and Environmental Assistance (DPPEA) offers a free kitchen staff training presentation for interested municipalities in the State. This presentation includes a discussion of the sources and impacts of FOG, the methods that kitchen staff can employ to reduce FOG contributions to the wastewater stream, and the basic principles and operation and maintenance requirements of GIs. The manager of the Environmental Stewardship Initiative, a program within NCDENR DPPEA, recommends that all kitchen staff receive training upon being hired and on a routine schedule after that, possibly corresponding with performance evaluations (Murphy, 2006). It is also suggested that training presentations geared towards kitchen staff be limited to 15 minutes and rely heavily on visual aid support. It is also important to provide FOG training materials in area-specific languages to help ensure that all members of the staff will understand and, hopefully, implement the recommended procedures. When training kitchen managers and FSE owners, NCDENR DPPEA recommends utilizing a 30 minute presentation stressing how FOG accumulation in the wastewater stream can negatively affect them and their establishments (Murphy, 2006). It is best to illustrate these negative effects by incorporating photos of SSOs; providing costs of cleaning clogged pipes, overflows, and back-ups; and describing recent news or statistics of SSOs or grease related problems. NCDENR DPPEA has also created a checklist specifically for helping kitchen managers and FSE owners track their FOG management practices. This checklist can be found at the following website: http://www.p2pays.org/food/Food Service Assessment Checklist.pdf. In addition to owners, kitchen managers, and staff, other individuals who may be discharging FOG-laden wastewater from food preparation facilities should be included in FOG management training. Often, contractors are hired to clean specific equipment or areas within a facility, including grease hoods and meat processing areas and equipment. These personnel should be instructed on the same FOG management procedures as kitchen staff, as well as any instructions specific to their activities. Grease interceptor ordinance Many municipalities have GI ordinances in place that require the installation of a GI or other grease pretreatment unit on the wastewater stream leaving commercial food preparation facilities. Municipal GI ordinances vary widely, but usually incorporate the following areas:

Identifying and Strengthening Weak Links in the FOG Management Chain

GI Design GI Sizing GI Operation and Maintenance GI Ordinance Enforcement and Penalties

Grease interceptor design. GI ordinances typically include specific requirements for GI design, construction, and installation, and they often refer to state or local building and plumbing codes. The Uniform Plumbing Code (UPC) and the International Plumbing Code (IPC) are commonly referenced; both include detailed design and installation requirements for exterior underground GIs. GI ordinances typically specify construction material, wall thickness, location, type and location of baffle and tee placement, type and location of access points (usually manholes) and lids, size of separation chambers, and venting requirements for exterior underground GIs. GI ordinances typically refer to published standards, such as the Plumbing and Drainage Institute (PDI), for design requirements for underthe-sink grease traps and automatic grease removal systems. Most GI ordinances also include design requirements that apply to all FOG pretreatment units, including proximity to discharge source and prohibited discharges. FOG pretreatment units are typically required to be installed as close as possible to the wastewater source, allowing for structural feasibility. Prohibited discharges usually include garbage disposals (food grinders) and high temperature discharges, such as dishwashers. There are conflicting recommendations about the discharge of dishwashers and other high temperature sources to grease interceptors. Dishwashers are generally prohibited from discharging to GI units because they release a large amount of high temperature water containing powerful emulsifying detergents. Conventional wisdom is that such a discharge overwhelms the GI and liquefies and emulsifies accumulated grease, sending it downstream. Conversely, high temperatures can also reduce the formation of grease-food debris aggregates that can pass through the interceptor into the collection system. For this reason, high temperature water sources have been found to improve grease separation in some GIs (PDI, 1998). Additionally, dishwashers are found to be a significant contributor of FOGladen wastewater. To date, the debate on dishwasher discharges has not been resolved. Generally they are prohibited because they increase the retention time and size of GI required. Grease interceptor sizing. To ensure proper function, all grease interceptor, grease trap, and automatic skimmer systems must be sized properly. GI ordinances usually defer the sizing of smaller under-the-sink units, grease traps and automatic grease removal systems, to manufacturer-provided sizing guidelines or established standards. For the more common exterior underground GI units, there are several methods for determining adequate sizing, with varying degrees of complexity. All methods incorporate different aspects of the facility type and waste stream characteristics. A brief discussion of some of the methods is provided below, including the applicability, required inputs, and the reference that contains more detailed information about the engineering basis for each method. EPA Standards for On-Site Wastewater Systems: This approach is geared towards achieving an effluent concentration of less than 100 mg/L of oil & grease (O&G). There are two equations, one for restaurants and one for commercial kitchens with varied seating, both with a minimum of 750 gallons of GI capacity. The restaurant equation incorporates the number of seats or meals served per day, a storage factor, number of hours open, and a loading factor. The commercial kitchen calculation incorporates the number of meals served per day, a storage factor, and loading factors. Loading factors take proximity to highways (restaurants) and presence of automatic dishwashers and/or garbage disposals (commercial kitchens) into consideration. There are several inputs to this method and users are required to make several assumptions. This method results in GIs ranging from 750 to over 20,000 gallons when used to calculate capacity for a typical military dining facility (EPA, 2002). The North Carolina Department of Environmental Health (NCDEH) GI Sizing Table: This approach takes the type of food preparation facility and the number of seats into account. The result is a corresponding range of GI sizes that have been found to be effective. The recommended GI sizes range from 500 to 3,000 gallons (NCDENR DPPEA, 2002). The Uniform Plumbing Code (UPC) Procedure: The method incorporates a relatively simple equation with the following inputs: number of meals per peak hour, waste flow rate, retention time, and storage factor (IAPMO, 2003). Some municipalities have developed their own approach to GI sizing that takes a combination of the above into consideration. The Town of Cary, North Carolina has a spreadsheet that calculates GI size required to

Identifying and Strengthening Weak Links in the FOG Management Chain

achieve a desired retention time using Mannings Formula for the number and size of plumbing fixtures. The resulting spreadsheet is user-friendly and provides a scientifically-based GI size recommendation. The Town of Cary GI sizing spreadsheet is located on the Towns Fats, Oils, and Grease Control website: http://www.townofcary.org/grease/sizingdesign.htm. Providing an appropriate sizing method can be difficult because of the large number of methods available and the infinite combinations of food preparation facility type, size, and equipment used. Different methods can result in significantly different GI sizes for the same facilities. Using the four sizing methods discussed earlier, recommended GI sizes were calculated for a day care cafeteria. The recommendations range from 500 to 3,400 gallons in size. This indicates that a one-size fits all approach to GI sizing may yield results that will work for most facilities, but may result in oversized or undersized GIs for others. A successful GI ordinance should account for facilities that are anomalies so that required sizes can be adjusted if needed. Regardless of the method used, the sizing approach should incorporate the following: adequate volume, sufficient retention time for emulsified FOG to separate and rise to the surface, turbulence control measures, and sufficient storage capacity for grease and solids. Requirements and guidance for GI sizing should be established in the GI ordinance, however FOG management personnel should reserve the right to adjust GI sizing as needed for atypical facilities. Grease interceptor operation and maintenance After an appropriately designed and sized GI has been installed, kitchen managers and staff should be made aware of its location and type, and should be trained on proper operation procedures. Grease interceptos must also be properly maintained, including regular inspections and cleanings. Most successful GI ordinances include required operation and maintenance procedures and schedules. Proper operating procedures often include best management practices for kitchen managers and staff to employ to reduce the amount of FOG discharged to the GI. Common procedures include the use of dry cleaning methods, disposing of food waste and solids from dishes and cookware into the trash or compost, and collecting used oil and grease in collection bins for recycling. These also may include restrictions on the use of strong detergents and degreasers, to reduce potential emulsification of accumulated grease in the GI units. Inspections of grease pretreatment units are typically required to ensure proper operation. If under-the-sink units are installed, they often require frequent attention by kitchen staff, sometimes on a daily basis. Underground GI units are typically inspected by municipal or collection system representatives on a regular basis, often during unannounced inspection visits, to ensure that they are operating properly, appear to be cleaned on a regular basis, have no signs of surcharging, and are not receiving prohibited flows. Cleaning schedules are sometimes provided in GI ordinances, although the need for cleaning can vary dramatically depending on the size of the unit and the wastewater flow characteristics of the facility. Successful GI ordinances provide guidance for determining the frequency of GI inspection and cleaning that takes these variables into consideration. One approach is to require that (1) accumulated grease does not exceed 50 percent of the total grease capacity of the unit and (2) solids accumulation does not exceed 25 percent of the total capacity of the unit. Typically, GI ordinances will require that only qualified and/or properly permitted contractors conduct the pumping and cleaning of underground GIs. In addition to removing the accumulated FOG layer, wastewater phase and accumulated solids, the internal components of the unit should be thoroughly cleaned and inspected for any structural defects. Cleaning can be accomplished by scraping and/or pressure washing. After cleaning and internal inspections are complete, the unit should be filled with clean water prior to receiving wastewater discharges. If not properly recharged, all grease that flows under the baffle or effluent tee will escape the interceptor. Grease interceptor ordinance enforcement and penalties To ensure the success of a comprehensive and clear ordinance, a policy for enforcement and penalties is usually developed. Most successful FOG programs involve several departments within the utility management organization, as well as some staff specifically dedicated to the FOG or pretreatment program, to ensure compliance with GI ordinance rules. Creating an enforcement division dedicated solely to enforcing the FOG management program is one way to consolidate enforcement responsibilities and ensure that GI ordinance requirements are being met. Many municipalities are covering the costs for ordinance enforcement by requiring all FSEs to pay FOG or GI fees and to obtain permits. The collection of fines as a result of permit violations can also provide funding for ordinance enforcement efforts. The biggest source of funding for

Identifying and Strengthening Weak Links in the FOG Management Chain

FOG-related program management and ordinance enforcement is savings in collection system operation and maintenance as a result of decreased FOG discharge into the sewer system. There are many issues involved with enforcing GI ordinances, including: Ensuring that GI installation and operation meets applicable building and plumbing codes, Permitting of GI waste haulers and treatment facilities, Inspecting facilities for compliance, Ensuring that facilities are not discharging inappropriate waste streams or substances to the GI, and Preventing illegal discharge of GI waste into the wastewater collection system.

Preventing illegal discharges of GI waste is often the most challenging aspect of GI ordinance enforcement. Slugs of grease from illegal dumping from FSEs and disposal of GI contents into manholes or lift station wet wells can result in the formation of grease logs. This occurs when the accumulated grease layer is pumped through the force main. This scenario can create problems in the collection system and treatment plant. These grease logs can contribute to pipe blockages and damage bar screens and other lift station and WWTP equipment. Adequate permit requirements using a cradle to grave documentation program for GI waste hauling and treatment is one method to curtail illegal dumping. Wastewater collection systems and municipalities should ensure that grease septage treatment facilities are compliant and accept waste only from properly permitted haulers. Local law enforcement officials can be useful resources for identifying, apprehending, and deterring individuals who illegally dump GI waste into the sewer system. However, few of them know about GI operation or how to detect illegal GI waste dumping activities and should receive training to effectively incorporate them into the FOG management program. The Town of Cary, NC created a training video for local police to educate them on GI operation, suspicious behavior, and the signs of illegal discharge. Clark County Water Reclamation District (CCWRD), which manages the FOG program for the Las Vegas, Nevada area, has encountered an on-going problem of illegal dumping by GI pumping companies (Helal, 2006). In response, CCWRD has installed locking manholes in areas prone to illegal dumping or that are in remote areas in an attempt to deter these activities. They also coordinate with the police, FBI, and Nevada Division of Environmental Protection (NDEP) to monitor the activities of suspected pumping companies using video surveillance. Coordination among different agencies and a clearly written and enforceable GI ordinance can help reduce illegal dumping or discharge of GI waste into the wastewater collection system. Additives Often, GI additives labeled all natural, bio-degradable, and enzyme, marketed to improve GI operation, are added to drains discharging to a GI unit. To date, very little third-party research has been conducted to support the claims of the manufacturers of these products. These products are touted to be an environmentally friendly method to eliminate grease problems by employing bacteria to eat the grease, but usually they contain enzymes and surfactants in addition to microorganisms, and often, they do not include microorganisms or bacteria of any kind. Enzymes are produced by bacteria to aid in digesting FOG particles. The enzymes break the molecules into smaller chains of fatty acids, eventually releasing carbon atoms that can be integrated into the bacterial cells. During this process, the size of the FOG particles decreases to the point that they can become suspended in water. Surfactants are particles with both a hydrophilic (water loving) and hydrophobic (water hating) side, which allows them to be soluble in water and oil. When added to greasy water, surfactants surround grease particles and create an emulsion. When additives containing enzymes and surfactants are introduced into a GI, they emulsify any retained FOG and allow it to pass through the GI into the wastewater collection system, undermining the pretreatment capabilities of the GI unit. Problems arise when the grease comes out of the emulsion and accumulates downstream in the wastewater collection system. However, some enzyme products claim that the grease remains emulsified until treated at the WWTP. NDEP has a strict policy prohibiting the addition of enzymes, emulsifiers, and organic solvents (another chemical that emulsifies FOG) into GI units (Helal, 2006). CCWRD enforces this policy by interviewing kitchen staff during

Identifying and Strengthening Weak Links in the FOG Management Chain

routine GI inspections about the kitchen chemicals that are used on a daily basis and whether or not additives or specific chemicals are added to the floor drains (Helal, 2006). Municipalities and wastewater collection system managers should weigh the advantages and disadvantages of utilizing GI additives before strictly prohibiting them from use. Any additives that contain only surfactants and emulsifiers should not be allowed; these products only circumvent pretreatment units and cause increased FOG problems downstream. Bacterial and enzyme additives may have useful application, especially for older facilities that experience frequent plumbing back-ups due to the size and condition of internal piping. In order to ensure that the FOG management program, especially GI requirements, remains effective, municipalities and wastewater collection systems must adequately address and enforce the prohibition of emulsifying GI additives. CONCLUSIONS Although FOG management programs have been in existence for several decades, there are several aspects of a typical program that can become weak links if not properly addressed. These weak links can undermine an otherwise comprehensive FOG management program, rendering it ineffective or reducing the success it may have otherwise achieved. By adequately anticipating the weak links discussed above, municipalities and wastewater collection system managers can create a FOG management program that will save money, time and resources, and protect the health of the environment and the public by reducing SSOs caused by FOG accumulation in the sewer system.

REFERENCES Bay Area Pollution Prevention Group (2004) Avoid Fines and Health Risks from Grease Overflows. Dexter, D. D. (2005) The State of FOG An Ohio Perspective. PMEngineer, http://www.pmengineer.com/CDA/ArticleInformation/features/BNP_Features_Item/0,2732,152646,00.htm l. Dexter, D. D., PE, CPD, CPI (2006) Personal communication, Korda/Nemeth Engineering, Inc., Consultant for State of Ohio codes. Gary, E.; Sneddon J. (1999) Determination of the Effect of Enzymes in a Grease Trap. Microchemical Journal, 61, 53-57. Helal, E. (2006) Personal communication, Clark County Water Reclamation District, Nevada. Holt, L. (2006) Personal communication, Utility Pretreatment Manager, Department of Public Works and Utilities, Town of Cary, North Carolina. Horne Engineering Services, Inc. (1999) Multiservice Oil/Water Separator Guidance Manual. U.S. Army Environmental Center: Aberdeen Proving Ground, Maryland. International Association of Plumbing and Mechanical Officials (IAPMO) (2003) Uniform Plumbing Code (UPC). 23rd ed. IAPMO: Ontario, CA. Moyer, J. (2006) Personal communication, Former Assistant Director of Public Utilities, City of Raleigh, North Carolina. Murphy, N. (2006) Personal communication, Manager, Environmental Stewardship Initiative, NCDENR DPPEA. North Carolina Department of Environment and Natural Resources (NCDENR) Division of Pollution Prevention and Environmental Assistance (DPPEA) (2002) Considerations for the Management of Discharge of FOG to Sanitary Sewer Systems. http://www.p2pays.org/ref/20/19024.pdf NCDENR DPPEA (2005) Ft. Bragg Food Service Operations: FOG (Fats, Oils, & Grease) Management Considerations. http://www.p2pays.org/webshare/FOG/Ft.BraggFOG_11_3_05.ppt Plumbing and Drainage Institute (PDI) (1998) Guide to Grease Interceptors, Eliminating the Mystery. PDI: South Easton, MA.

Identifying and Strengthening Weak Links in the FOG Management Chain

The Town of Cary, North Carolina (2006) Fats, Oils and Grease Control web site, http://www.townofcary.org/grease/sizingdesign.htm. URS Corporation, Inc. (2005) Grease Interceptor Consolidation and Management Plan, Fort Bragg Army Post, North Carolina. U.S. Army Corps of Engineers, Mobile District: Mobile, AL. U.S. Environmental Protection Agency (EPA) (2002) Onsite Wastewater Treatment Systems Manual; EPA/625/R00/008; Washington, D.C. U.S. EPA (2004) Report to Congress: Impacts and Control of CSOs and SSOs; EPA-833-R-04-01; Washington, D.C.

Identifying and Strengthening Weak Links in the FOG Management Chain