WSSC FOG Abatement Program Update: Current Initiatives and Regulations

1. Fats, Oils & Grease (FOG) Abatement Program Update • June 28, 2010

2. WSSC FOG PROGRAM HISTORY • 1990’s - 2005 • WSSC had an active FOG Program with various procedures • 2005 Consent Decree, Article 3 – FOG Program Milestones • June 2006 • Established and submitted database of all FSEs in the sanitary District • Prepared and submitted a Modified FOG Program Plan for EPA approval • September 2006 • Prepared and submitted Draft FSE Wastewater Discharge Permit • May 2007 • Received EPA approvals and began formal permitting and initial inspections of FSEs • Update database with new or out of business FSEs • 2007 – 2009 • Proposed and adopted WSSC Code changes to better define formal FOG Program basics • Completed 100 inspections per month, majority of systems in non-compliance with permit/Code • Scheduling and witnessing pump-downs at flow-based units

3. WSSC FOG Abatement Program • Enhancements to FOG Abatement Program as part of SSO Consent Decree • Plumbing & Fuel Gas (P&FG) Code • Waste Haulers are required to obtain Permits • Applicable Food Service Establishments (FSEs) are required to obtain Discharge Permit • Applicable FSEs are required to install Grease Abatement Systems • Increased cleaning and inspection requirements

4. Waste Hauler Discharge Permits • Types of Permits • Waste Hauler Discharge Permit • Discharge Permit required for each truck discharging at disposal sites designated by the Commission • Zero Discharge Permit • Required for trucks cleaning grease interceptors within WSSC service area, but disposing outside Commission’s service area • Fees • WSSC Permit Fee • Annual fee based on vehicle capacity • Allows unlimited dumping during permitted hours • County Health Department Permit Fee

5. FSE Discharge Permits • Section 818 of WSSC P&FG Code • Applies to all establishments (FSEs) where food is served to the public with or without charge including, but not limited to: • Restaurants • Cafeterias • Hotel kitchens • Church kitchens • Hospital cafeterias • Bars • All FSEs must apply for Permit • FSE Discharge Permit Contains: • Best Management Practices for controlling FOG • On-site Recordkeeping Requirements • Grease Abatement System Installation and O&M Standards, if applicable • Other general conditions or procedures

6. FSE Grease Abatement Systems • Installation Requirements • Section 302 of WSSC P&FG Code provides: • Design, location, sizing, and piping installation requirements for • Flow-Based Grease Interceptors • Volume-Based Grease Interceptors • Maintenance Requirements • Section 818 of WSSC P&FG Code requires: • Maintenance of efficient operations by owner/operator at their expense • 25% Rule • Owner/operator shall ensure accumulation of FOG/solids does not exceed 25% of liquid retention capacity • Maintenance Interval • Volume Based Grease Interceptors – Monthly, Quarterly or by the “25% Rule” • Flow Based Grease Interceptors – Manufacturer’s recommendations (weekly or bi-weekly) or by the “25% Rule”

7. WSSC FOG Handling • Impacts of FOG Abatement Program Enhancements • Increased discharge volume to grease receiving station • Muddy Branch Wastewater Pump Station • No pretreatment of waste stream • Discharges to Blue Plains AWWTP • Removed in screenings or primary clarifier scum, and landfilled • No sample collection or volume measurement features • July 1, 2010 – WSSC initiating Manifest System at Muddy Branch Site • Site cannot accommodate anticipated upgrades

8. Current FOG Handling Practices Muddy Branch Disposal Site

9. WSSC FOG Receiving &Treatment • Septage/FOG Study Schedule • March 29, 2007 • Study Kick-off • March 14, 2008 • Presentation of Recommendations Stakeholder Workshop • November 26, 2008 • Study Expanded to Include Evaluation of FOG Handling and Treatment Processes • November 2, 2009 • Study Expanded to Address Montgomery County Concerns • Completion of FOG Study – To be determined

10. WSSC FOG Receiving &Treatment • Evaluation of FOG Receiving/Treatment Approach • Grease Interceptor Waste Volume Estimates • Characterization of Grease Interceptor Waste • Grease Receiving/Treatment Process Alternatives • Grease Receiving/Treatment Site Alternatives

11. Grease interceptor waste volume estimates • Results of WSSC initial inspections of FSEs to date (June 2010) • Estimated # of FSEs requiring grease abatement • Total for Montgomery and Prince George’s Counties = 4,600 • Breakdown of Grease Interceptors • 20% (900 -950) have volume-based (outside) interceptors serviced by a contractor • 40% (1800-1900) have flow-based (inside) interceptors serviced by a contractor • 40% (1800-1900) have flow-based (inside) interceptors serviced by owner, have a non-working interceptor, or have no interceptor *Estimate from known FSEs in Montgomery and PG Counties. Does not include grease from outside jurisdictions.

12. Grease interceptor waste CHARACTERISTICS Sampling at Muddy Branch Disposal Site

13. GOALS FOR GREASE RECEIVING/TREATMENT FACILITY • Primary Goals • Prevent accumulation of grease in collection system and reduce SSOs • Optimize WSSC’s capital investment • Address operations and maintenance challenges • Provide safe, secure system for haulers that protects the environment • Provide system that considers impact on neighborhoods and citizens • Secondary Goals • Minimize operation costs • Provide a source of revenue • Focus on sustainability – greenhouse gas reduction, renewable energy, sustainable design • Provide local system that allows haulers to provide cost competitive services

14. GREASE RECEIVING/TREATMENT process alternatives • Benchmarking of FOG Facilities • City of Baltimore, MD – Direct Discharge/Anaerobic Digestion • Derry Township Municipal Authority, PA – Aerobic Digestion • Kline’s Services, Salunga, PA – Fuel Oil Production • EcoSolve, Charlotte, NC – Dewatering Technology • Valley Proteins, Baltimore, MD – Fuel Oil Production

15. GREASE RECEIVING/TREATMENT process alternatives • Pretreatment Process Alternatives • Screening • SV-2 System • Removes trash and debris using steam to heat grease flow • Standard Wastewater Influent Screen • Screen and washing compactor • Requires larger bar spacing and high temperature pressure washer • Grease Concentration • Fractionation Tank (with or without heat) • Batch separation process with multiple withdrawal ports for debris, aqueous layer and grease • Scum Concentrator • Continuous flow separation process with mechanical removal of grease from surface SV-2 Unit Screenings Fractionation Tank

16. GREASE RECEIVING/TREATMENT process alternatives • Primary Treatment/Disposal Alternatives • Municipal Solid Waste • Mix with screenings and dispose at landfill • Mixing with Dewatered Solids • Mix with sludge, lime stabilize and land apply • Incineration • Mix with sludge and incinerate at Western Branch WWTP • Land Treatment • Direct application of grease interceptor waste to farmland • Aerobic Digestion • Aerobic digestion of grease and dewatering

17. GREASE RECEIVING/TREATMENT process alternatives • Primary Treatment/Disposal Alternatives • Anaerobic Digestion • Anaerobic digestion and production of methane gas • Biodiesel Production • Conversion of grease interceptor waste to biodiesel with intermediate processing • Fuel Oil Production • Conversion of grease interceptor waste to fuel oil • Dewatering • Screw press cake product to be incinerated, land applied or landfilled

18. Selected alternative Separation Tank 90 to 100 oF • Fuel Oil Production – Burt Waste System Unload at 175 gpm, 10-15 min/truck Cook Tank 165 oF Facility Requirements • (2) SV-2 Separation Units • (2) Separation Tanks • (1) Cook Tank • Finished Oil Tank • Fuel Oil Tank • Boiler - Fuel Oil • Process Piping • Building • Odor Control System • Video Monitoring System • Fence/Gate Access System • Auto Sampler

19. Selected alternatives • Financial Considerations • Planning Level Construction Cost Estimate for Facility • $2,200,000 to $2,800,000 per site • Planning Level O&M Cost Estimate for Facility • $300,000 annually (includes staff, power, equipment maintenance/replacement, etc.) • Value of Product • Potentially 5,250,000 – 5,550,000* gallons of grease interceptor waste generated from known FSEs annually • 111,000 gallons of product annually (20 gallons of product per 1,000 gallons of interceptor waste) • Process Requirements (16 to 20 gallons of product per hour) = 37,500 gallons annually • Residual of 73,500 gallons annually = 607,000 lbs annually • At $0.15/lb, revenue = $91,000 • Reduction in collection system maintenance costs by keeping FOG out of system *Estimate from known FSEs in Montgomery and PG Counties. Does not include grease from outside jurisdictions.

20. GREASE RECEIVING/TREATMENT site alternatives • Site Selection Evaluation Criteria • System Reliability • Hauler Impacts • Constructability • Ease of Operation • Public Acceptance • Community/Environmental Impacts • Construction Cost • Operations and Maintenance Cost

21. GREASE RECEIVING/TREATMENT site • Alternative Sites Considered Montgomery county prince george’s county 1 1 – Crystal Rock PS 2 – Clopper Road PS 3 – Seneca WWTP 4 – Seneca I&II PS 5 – Rock Creek WWTP 6 – Muddy Branch Disposal Site 1 – Parkway WWTP 2 – Tanglewood PS 3 – Anacostia I&II PS 4 – Ritchie Road PS 5 – Western Branch WWTP 6 – Piscataway WWTP 1 2 3 2 5 3 4 4 6 5 6 Food Service Establishment Current Waste Discharge Sites

22. Preliminary site recommendation Prince George’s County • Anacostia I&II PS • Advantages • Located in the commercial corridor of Prince George’s County • Space on site for construction of new facilities • Surrounded by wooded area and other industrial facilities

23. Preliminary site recommendation Montgomery County • Abandoned Rock Creek WWTP • Advantages • Centrally located to FSEs in Montgomery County • Existing facilities on-site could possibly be utilized (building, fencing) • Surrounded by wooded area and other industrial facilities • Access to site is convenient for haulers

24. Anaerobic digestion & combined heat & Power study • Scope • Evaluate feasibility of viable economic alternatives for adding anaerobic digestion and combined heat and power and/or biosolids gasification and drying facilities for the biosolids generated at the Seneca and Piscataway Wastewater Treatment Plants • Goal • Reduce fossil fuel derived energy use, biosolids volume and land application disposal costs • Impact • Fuel oil product could be utilized as a feedstock for anaerobic digestion • Schedule • Kick-off Meeting: July 2010 • Project Duration: 10 months

25. summary • Enhancements to FOG Abatement Program via Updates to the WSSC P&FG Code • Current FOG handling facility at Muddy Branch is inadequate and will be abandoned • P&FG updates could result in an estimated 5,250,000 – 5,550,000 gallons* of grease interceptor waste from Montgomery and Prince George’s Counties • Grease interceptor waste has high solids, BOD and COD content and is highly variable • SV-2 screening with Fuel Oil Production Process is the recommended approach for grease receiving/treatment • Preliminary Receiving/Processing Site Recommendations • Prince George’s County – Anacostia I&II Pump Station • Montgomery County – Rock Creek WWTP • Modify hauler tipping fee program *Estimate from known FSEs in Montgomery and PG Counties. Does not include grease from outside jurisdictions.

26. WSSC FOG PROGRAM SCHEDULE • December 2010 (Consent Decree Deadline) • All known “qualifying” FSEs must be permitted • Updated and detailed list of permitted FSEs • December 2011 (Internal WSSC Deadline) • Complete initial inspections of all known FSEs • Basis for the Consent Decree Report • May 2012 (Consent Decree Deadline) • Complete initial inspections of all known FSEs • Submit updated and detailed Report