Enforcement of the Grease Control Program Narragansett Bay Commission Kerry M. Britt

1. Enforcement of the Grease Control Program Narragansett Bay Commission Kerry M. Britt Pretreatment Manager

2. Narragansett Bay Commission Field’s Point in Providence 45 MGD Bucklin Point in East Providence 22 MGD

3. NBC Pretreatment Program • 1,691 discharge permits in effect • On average conduct 2,000 inspections/year • Conduct approximately 30 investigations/year • 10% - 20% regarding grease issues

4. NBC Grease Control Program • Been in place since the late 1980s • 1,060 Permitted companies with the potential to discharge grease laden wastewater • Restaurants • Schools • Nursing Homes • Hospitals • Hotels • Supermarkets • Food Processors

5. Grease Removal Requirements • Meet NBC discharge limitation of 125.0 ppm • Submit plans detailing kitchen layout, plumbing and grease removal equipment • Install grease removal equipment with sample port • Automatic Electro/Mechanical • Outdoor In-ground Passive • Maintain all pretreatment equipment to ensure continuous operation

6. Grease Removal Equipment • Automatic Electro/Mechanical • Outdoor In-ground Passive • Sized properly • Sample port • Solids Retention • Accessible • Fixtures required to be connected • Prohibited Discharges

7. Grease Removal Equipment • Log Books • Maintenance • Emptying Strainer Basket • Cleaning Wiper Blades • Cleaning Trough • Wet Vacuuming of GRU • Amount of Grease Removed from unit • Date and time of inspection • Person conducting inspection

8. Inspection Program • Conduct inspections of 75% of restaurants annually • Inspect all other companies with the potential to discharge grease laden wastewater bi-annually

9. Inspection Program (cont’d) Automatic Electro/Mechanical GRU Outlet Strainer Basket Skimmer Wheel Wiper Blades Inlet Sample Port Grease Container Timer Unit

10. Inspection Program (cont’d)Outdoor Inground Passive Interceptor

11. Poorly Operating Automatic GRU

12. Blockage due to poor maintenance onPassive In-Ground Grease Traps

13. Grease from food preparation facilities caused blockages in a sewer line

14. No Power to Automatic GRU

15. Mazey’s Restaurants • Two locations in North Providence, RI • We found them in August 2006 • Required to apply for permits and install GRUs • Required applications and plans not submitted • Legal Letters sent out in February 2007 resulted in applications being submitted • He requested a meeting to discuss GRU requirements in August 2007 • As a result the companies were given the option to sample until GRUs could be purchased • First 5 days while washing operations are being conducted • Every April and October • Permits were issued in September 2007

16. Mazey’sRestaurants • Sampling was not conducted – NOVs issued and calls to the owner were made • The owner stated that samples were at the lab and he would send the results when he received them • Legal Letters were issued • The owner stopped taking our calls • Inspections were conducted outstanding requirements were discussed

17. Mazey’s Restaurants • An Administrative Order was prepared and issued in October 2009 • Failure to install a sample port • Failure to conduct sampling • Ordered Mazey • Install the sample port • Conduct sampling and submit analyses for all outstanding samples • Comply with the permits • Submit plans for GRUs and install • Assessed a total fine of $18,500

18. Mazey’s Restaurants • Consent Order (CO) was issued in May 2010 • Required • Satisfy the outstanding sampling requirements • Install the sample port • Install GRUs by June 2011 • Stipulated Penalties if any of the samples exceeded 125 ppm the GRU would have to be installed within 30 days • Assessed a $5,000 penalty • Met with the owner again in June 2010 – result GRUs would be installed • July 2010 the owner stated he would conduct the sampling • The CO was reissued and signed in September 2010

19. Mazey’s Restaurants • June 2011 still hadn’t complied with the CO • Owner was notified that the matter would be brought to court • Met with the owner again • Didn’t want to conduct the sampling because it wouldn’t mean anything • Couldn’t afford the GRUs • Shouldn’t have signed the CO so he didn’t think he should have to pay the fine • He was ill • The compliance schedule was revised • Didn’t comply with revised schedule so we proceeded to court and awarded a default judgment to cut and cap the discharge line • Notified the Town of North Providence and Department of Health • Permits expired and were held in abeyance

20. Mazey’s Restaurant • Finally GRUs were installed in early 2013 • The permits were reissued • A fine of $500 was paid • One of the locations is now closed

21. Restaurant in Lincoln, RI • Received a call from the Lincoln, RI police • Restaurant discovered a septage hauler was dumping in the grease interceptor • Called in to determine where the sewer lines were and if the hauler was permitted • Investigated the property • Called the RI Department of Environmental Management • Worked with DEM Criminal Section and the RI Attorney General’s Office

23. Contact Information Email: Kerry.Britt@narrabay.com Telephone: 401.461.8848 ext. 490 NBC Website: www.narrabay.com Pretreatment Information: http://www.narrabay.com/pretreatment.asp