What the State of N.C. Wants You to Know About FOG: Permits, SSO Reporting and Other Requirements
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1 What the State of N.C. Wants You to Know About FOG: Permits, SSO Reporting and Other Requirements Wednesday, December 12 th, 2012 Deborah Gore NC DENR PERCS Unit Supervisor Michael Leggett, PE NC DENR PERCS Unit
2 WAY PROGRESS N A E WAY PROGRESS L C 1 end 3 end 5 end 7 end HIGH HIGH HIGH HIGH HIGH
3 CMOM Capacity, Management, Operation & Maintenance [ (F)] 1/4/2001 Notice of Proposed Rulemaking 1/20/ NPRM withdrawn 11/8/2001 Go ahead given for CMOM NPRM Continued delays
![42 (F)] 1/4/2001 Notice of Proposed Rulemaking](/docs-images/47/20818083/images/page_3.jpg "1/20/2001 - NPRM withdrawn 11/8/2001 Go ahead")
4 Causes of SSOs # 1 Cause Grease (29%) Inflow / Infiltration (15.9%) Debris (13.9%) Roots (11.2%) Other (9.7%) Pipe failure, break (6.7%)
5 Causes of SSOs Severe natural conditions (6.6%) Pump station equipment failure (4.0%) Vandalism (1.9%) Power outage (1.5%)
6 Fecal Fountain
7 Cooking Oil and Grease Recycling Easy to set up Lots of benefits Revenue Jobs Less SSOs Biodiesel production Need less virgin materials Less dependent on petroleum
8 DEAO FOG Webpage Web address: Market information for Waste Vegetable Oil Information setting up WVO Collection Case studies Documents, presentations, outreach material Sample ordinances
9 Contact DEAO Keyes McGee Jamie Ragan
10 How re we doing? EPA estimates 23,000 75,000 SSOs per year nationwide Last year (2011) in NC 1,315 SSOs to surface waters 865 less than 1,000 gallons
11 # of Spills Gallons to Waters Gallons/Spill ,833 18,742,311 10, ,918 35,109,354 20, ,884 93,578,529 32, ,064 42,163,692 20, ,759 33,210,963 18, ,107 33,676,489 15, ,598 14,114,763 8, ,655 26,931,212 16, ,601 24,465,627 15, ,672 15,341,103 9, ,315 7,655,416 5, ,591,936 6,946
12 ,659,330 gallons spilled 10,819 spills 20,211 gallons/spill ,574,633 gallons spilled 8,992 spills 14,966 gallons/spill
13 What RO Inspectors Want You to Know Insufficient grease trap control ID all grease traps and develop good management program Good grease trap control program most effective way to control FOG More frequent cleaning of grease traps Under sink grease traps are basically non-functional Annual grease trap inspections High density housing are a problem with little control More education FOG not just grease
14 Federal Pretreatment Regulations 40 CFR (b)(3) Prohibits solid or viscous pollutants in amounts which will cause obstruction in the POTW resulting in Interference 40 CFR (c)(1&2) POTWs with a Pretreatment Program shall develop and enforce specific limits to implement the prohibitions listed All other POTWs shall develop and enforce specific effluent limits for Industrial User(s), and all other users, as appropriate
15 North Carolina Clean Water Act G.S B - Systemwide municipal and domestic wastewater collection system permit program The EMC shall develop and implement a permit program for municipal and domestic wastewater collection systems The collection system permit program shall provide for performance standards, minimum design and construction requirements, a capital improvement plan, operation and maintenance requirements, and minimum reporting requirements
16 System-Wide Collection System Permitting 15A NCAC 02T.0400 Collection Systems having actual or permitted average daily flow greater than or equal to 200,000 gallons per day Individual Permit Required (Operation and Maintenance) Establish Performance Standards Requires effective management, maintenance, & operation FOG Program, Capital Improvement Plan, Contingency Plans Operation and Maintenance Requirements System Classification & ORC designation Testing, Inspection, & Maintenance Programs Cleaning Schedule Response Action Plan
17 System-Wide Collection System Permitting 15A NCAC 02T.0400 (continued) Records Maintain Record for a minimum of three years SSO records requirements (regardless of size) Comprehensive System Map Monitoring and Reporting Requirements SSO Notification Requirements Annual Reporting Requirement Inspections Permittee Requirements High Priority Line Inspections (Bi-Annual) General Conditions
18 Fats, Oils and Grease (FOG) Requirements for System-Wide Collection Systems Condition I(3) Establishment of legal authority (by Permittee) Condition I(4) Implementation of Educational Program Implementation of Enforcement Program Condition III(1) & III(2) Records Retention for a minimum of three years For Compliance and SSOs / Incidents
19 FOG Legal Authority Requirement Condition I(3) The Permittee shall establish by ordinance its legal authority to require new sewers be properly constructed; to ensure proper inspection and testing of sewer mains and service laterals; to address flows from satellite systems and to take enforcement action as required by Condition I(4) Establishes legal authority over FSE discharges by: Modifying the Sewer Use Ordinance (SUO) Creating stand alone SUO dealing with FOG Permitting program for FOG sources
20 General Outlines for Legal Authority I(3) Scope / Purpose / Introduction Defines what FOG is 40 CFR 403.5(b)(3) Problems associated with FOG discharges into sewers Blockages SSOs Public Health Environmental Health Disruptions (Residential & Commercial) Maintenance Costs Goals / Benefits of the Permittee s FOG Program
21 General Outlines for Legal Authority I(3) Authority & Definitions Defined Authority Clarify where requirements originated (Federal & State) When adopted and by what governing authority Approval / Enforcement Structure Definitions Clear terminology to prevent future issues Grease Interceptor vs. Grease Trap Grease/Solids Depth (other Design Constraints) Best Management Practices Requirements for FSE to establish BMPs Training, Dry-Cleanup, Spill Prevention Utilize Recycle Programs, etc.
22 General Outlines for Legal Authority I(3) General Requirements Which FSEs are required to install grease handling facilities Specific Limits New FSEs vs. Older FSEs Space constraints for existing establishments Variance/Exemption Process Snack Bars, Bed-and-Breakfast, etc. Review, Evaluation, & Pre-Inspection Process
23 General Outlines for Legal Authority I(3) Design Standards Installation of adequate sized grease interceptors Minimum volume requirements (1,000 gallons) and detention times Retention of As-Built Drawings Registered Professional Engineer responsible for sizing? Interceptor meet sizing requirements per NC Plumbing Code? Section Indoor Grease Trap Guidelines (Variance required?) Testing Requirements (Watertight and properly sealed joints) Design achieves compliance with the appropriate discharge limit Ultimate approval structure (i.e. Town Engineer)
24 General Outlines for Legal Authority I(3) Maintenance Requirements Requirement to clean in order to meet FOG concentration limits Requirements for regularly scheduled maintenance of grease handling facilities Minimum service (pumping ) frequency (30 days, 60 days, 90 days) Grease/Solids Depths Define usage of enzymes, chemical, or biological additives
25 General Outlines for Legal Authority I(3) Reporting Requirements FSE should maintain written records, onsite of maintenance Require FSE to complete and send in frequency schedule Quarterly, Monthly, Bi-Annual, etc. Minimum service (pumping ) frequency (30 days, 60 days, 90 days) Include receipt, signed by the contractor for the work performed Includes Date and Name of Contractor Retention time period for cleanings/pumps and maintenance Typically 3 years
26 General Outlines for Legal Authority I(3) Inspection & Sampling Requirements Clearly defined inspection and sampling frequency Inspection Checklist Quantity / Clarity of Grease, Pumping / Hauling Records Grease/Solids Depth Violations When sampling will be required provided not mandated Sampling locations (effluent tee) Analysis and reporting
27 FOG Education Requirement Condition I(4) The Permittee shall develop and implement an educational fats, oils and grease program that shall include at least bi-annual distribution of educational material targeted at both residential and non-residential users Traditionally, compliance with this condition involves the Permittee distributing hardcopy information twice a year Pamphlets Door Hangers Bill Stuffers
28 FOG Education Requirement - I(4) FSE Educational Issues Non-Residential High Turnover Rate Training Limited Limited Resources Unaware Residential Communication / Cultural Connection Barriers Traditional Delivery Changes Unaware
29 FOG Education Requirement - I(4) Strengthening Traditional Methods Emphasize Connection between FOG and Negatives Repair costs (higher utility bills) Public / environmental health risks (SSOs in / around home) Enforcement Potential (FSEs) Include web links to receive more information Alternative Delivery Means Insure materials reach audience (Multifamily / Apartments) Mobile displays, public access television, etc. Presentations at schools, apartment management groups, etc.
30 FOG Enforcement Requirement Condition I(4) The Permittee shall also develop and implement an enforceable fats, oils, and grease program for non-residential users under which the Permittee can take enforcement against users who have not properly installed, operated, and maintained grease traps or grease interceptors as directed or otherwise violated the terms of the local ordinance pertaining to fats, oils, and grease Enforcement element should be established within legal authority Modifying the Sewer Use Ordinance Creating stand alone ordinance dealing with FOG Permitting program for FOG sources
31 General Outlines for FOG Enforcement I(4) Primary Reasons for Enforcement Failure to install grease handling facility (interceptor) Failure to maintain grease handling facility Failure to repair in a reasonable time period Failure to maintain maintenance records on site Failure to provide records to the Permittee according to schedule Failure to pay fee(s) Denied /Delayed authorized inspectors access to facility
32 Example FOG Enforcement Schedule I(4)
33 General Outlines for FOG Enforcement I(4) Sewer Blockage Cost of Repair / Cleaning, Mediation Costs Sanitary Sewer Overflow Legal Fees Equipment repair / replacement Cost of Repair / Cleanup Sampling / Monitoring Costs Enforcement Discontinuance of Water and Sewer Services
34 Records Requirements for FOG Enforcement Condition III(1) & (2) Condition III(1) Records shall be maintained to document compliance with Conditions I(4), II(2) - II(4), II(7) - II(8), IV(3) and V(1) -V(4). Records shall be kept on file for a minimum of three years. Condition III(2) The Permittee shall maintain adequate records pertaining to SSOs, and complaints for a minimum of three years.
35 Records Requirements for FOG Enforcement Condition III(1) & (2) Records must include: Date of SSO or complaint; Volume of wastewater released as a result of the SSO and/or nature of complaint; Location of the SSO and/or complaint; Estimated duration of the SSO; Individual from the Division who was informed about the SSO and/or complaint, when applicable; Final destination of the SSO; Corrective actions; Known environmental/human health impacts resulting from the SSO; and How the SSO was discovered.
36 Permitting by Regulation - 15A NCAC 02T.0403 Collection Systems having actual or permitted average daily flow less than 200,000 gallons per day For Publicly Owned Biannual distribution of educational materials for commercial / residential Legal authority to require grease interceptors for new / retrofit Legal authority to inspect and enforce For Privately Owned Biannual distribution of grease education materials to users Education materials shall be distributed more often if necessary
37 Fats, Oils and Grease (FOG) Requirements for System-Wide Collection Systems (Recap) Conditions I(3) Establishment of legal authority (by Permittee) Conditions I(4) Implementation of Educational Program Implementation of Enforcement Program Condition III(1) & III(2) Records Retention for a minimum of three years For Compliance and SSOs / Incidents
38 WAY PROGRESS STEPPETSPETS
39 Contact Information Deborah Gore PERCS Unit Supervisor Michael Leggett, PE PERCS Collection Systems
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