MWEA PresentationFOG Control & Prevention

Programs October 24, 2007

FOG Control & Prevention ProgramsFOG Control & Prevention Programs

Detroit Wastewater System 840 Sq. Mile Service Region

• 350 Significant Industrial Users• +15,000 Minor Commercial/Industrial Users• +10,000 Food Establishments (Restaurants,

Institutions, other) 78 Communities (Municipalities, Townships,

Counties, Authorities) Population = +3.9 million

FOG Control & Prevention ProgramsFOG Control & Prevention Programs

Fats, Oils & Grease Fats, Oils & Grease Mineral Based Petroleum Based Animal & Vegetable Based

Definitions Fats – Solid at room temperature Oil – Liquid at room temperature Grease – Viscous semi-solids at room

temperature

FOG Control & Prevention ProgramsFOG Control & Prevention ProgramsWhat is FOG?What is FOG?

FOG

Animal Vegetable Mineral

Lard (Pork)

Tallow (Beef)

Schmaltz (Poultry)

Petroleum OilsSoy, Corn, Sunflower,

Peanut, Cotton Seed

LinseedTung

Edible Inedible

Gasoline,

Lubricating oils

FOG Control & Prevention FOG Control & Prevention ProgramsProgramsThe Problem(s)The Problem(s)

WWTP Interference & Pass-throughBlockages/ObstructionsSpills

Contained Uncontained

FOG Control & Prevention ProgramsFOG Control & Prevention Programs Consideration of DWSD Facilities

Impacted by FOG Meter Station Downstream of a Snack-

Food Manufacturer Sewer Blockages & Similar Nuisances Grease Trap Cleaners Discharge

• Restaurants• Food Establishments

Oil Spills• $320k for 50,000 gals• $32k for 250 gals

FOG Control & Prevention ProgramsFOG Control & Prevention Programs

Problems with Animal & Vegetable FOG Creates Obstructions - act as Cement-like

matrix, e.g. Forms Hard Deposits Involves Commonly Used Material

• Restaurant Clustering

• Difficult to Identify Responsible Source Existing Controls - Not Well Regulated

• Health Department

• Plumbing Code

• Water & Sewerage

What Can WE DO?

FOG Control & Prevention FOG Control & Prevention ProgramsPrograms

FOG Control & Prevention ProgramsFOG Control & Prevention Programs

FOG Control & Prevention FOG Control & Prevention ProgramsProgramsOptions:Options:

Regulatory Approaches (Command & Control) Industrial Pretreatment Surcharge a.k.a. User Charge System

Non-Regulatory Approaches Voluntary Education

Command & Control Programs: Work Well --

• Regulating Large Industrial/Manufacturing Operations

• Operations are Sophisticated • Control Group is Small

Don’t Work as Well -- • Problem is Occasional• Control Group is Large

FOG Control & Prevention FOG Control & Prevention ProgramsPrograms

FOG Control & Prevention FOG Control & Prevention ProgramsPrograms

Command & Control Options Local Pollutant Discharge Limitations

• Limit = 1,500 mg/l• Headworks allocation: 48,000 lbs Domestic / 350,000 Available

General Prohibitions• Nuisance prohibition• Interference and pass-through prohibitions• Floating-oil prohibition

Economic = +$ 27 M/yr User Charge Program FOG Rate = $ 0.284/lb (2007/08)

• Excludes Restaurants

Costs of FOGWho should bear the cost?

Source

Transport/Conveyance

Destination

Local Maintenance

Treatment Plant/Pump Station

User Pays

Public Pays

What Kinds of “Problems” Lend Themselves to Non-Command & Control Strategies? Ubiquitous Pollutants

• Mercury• Fats, Oils & Grease

Numerous Small Sources (Examples)• Dental Offices• Restaurants

FOG Control & Prevention ProgramsFOG Control & Prevention Programs

FOG Control & Prevention FOG Control & Prevention Programs Programs

Voluntary Methods Focus on Restaurants (Franchises, Institutions,

Grills)• Establishments often cluster, impacting local sewers

• Difficulty in identifying “sole”source

• Grease Controls – mixed– Grease Trap Requirements – sizing & maintenance

– Garbage disposers, Dishwashers – effectiveness of traps

FOG Control & Prevention FOG Control & Prevention ProgramsPrograms

Education Pollution Prevention Approach

• Provide notice of problem

• Transfer duty to prevent

• Development of maintenance plans and responses to “Manage” FOGs

Identifies “problem” for restaurant industry to focus upon

• Video/CD (5 minute information)

• Posters (Do and Don’ts)

Decided to “Fill the Regulatory Gap” Found “LAPSE” in Regulation Need for Partnering Among Agencies

Decided to Regulate - DifferentlyDecided on Key Focus Group - Restaurants

Facilities Need to “KNOW” Facilities Need - Methods for Success

FOG Control & Prevention ProgramsFOG Control & Prevention Programs

FOG Control & Prevention ProgramsFOG Control & Prevention Programs

Developed Response of Pollution Prevention Program Information about Grease Trap Maintenance Information about Instructing on Proper &

Improper Disposal Alternatives Informational Material (Posters) and Video

Involves Visiting & Distributing Materials to Large and Small Operations

FOG Control & Prevention ProgramsFOG Control & Prevention Programs ResultsResults

2-Year Results: 848 Facilities Visited Review Operations Provide Basic Materials Identify Disposal Methods Used

No-effect on Blockage Reports -- YETSurvey/Feedback Measures

Positive & Well Received Acceptance by Franchise Operators

FOG Control & Prevention FOG Control & Prevention ProgramsPrograms

ConclusionsConclusions

Efforts have Demonstrated Good Alternative to C&C

BMP Approaches Provide Maximum Flexibility for Users

Codify Use of BMP into Local SUO Expanding Application to Other Pollutants Include Both “Voluntary” and “Required”

Participants