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MWEA Presentation FOG Control & Prevention Programs October 24, 2007. FOG Control & Prevention Programs. Detroit Wastewater System 840 Sq. Mile Service Region 350 Significant Industrial Users +15,000 Minor Commercial/Industrial Users
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MWEA PresentationFOG Control & Prevention Programs October 24, 2007
FOG 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 Programs • 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 ProgramsWhat is FOG? FOG Mineral Vegetable Animal Edible Inedible Petroleum Oils Lard (Pork) Tallow (Beef) Schmaltz (Poultry) Soy, Corn, Sunflower, Peanut, Cotton Seed Linseed Tung Gasoline, Lubricating oils
FOG Control & Prevention ProgramsThe Problem(s) • WWTP Interference & Pass-through • Blockages/Obstructions • Spills • Contained • Uncontained
FOG 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 • $32k for 250 gals
FOG Control & Prevention Programs • Problems with Animal & Vegetable FOG • Creates Obstructions - act as Cement-like matrix, e.g. Forms Hard Deposits • Involves Commonly Used Material • Restaurant Clustering • Difficult to Identify Responsible Source • Existing Controls - Not Well Regulated • Health Department • Plumbing Code • Water & Sewerage
FOG Control & Prevention Programs What Can WE DO?
FOG Control & Prevention ProgramsOptions: • Regulatory Approaches (Command & Control) • Industrial Pretreatment • Surcharge a.k.a. User Charge System • Non-Regulatory Approaches • Voluntary • Education
FOG Control & Prevention Programs • Command & Control Programs: • Work Well -- • Regulating Large Industrial/Manufacturing Operations • Operations are Sophisticated • Control Group is Small • Don’t Work as Well -- • Problem is Occasional • Control Group is Large
FOG Control & Prevention Programs • Command & Control Options • Local Pollutant Discharge Limitations • Limit = 1,500 mg/l • Headworks allocation: 48,000 lbs Domestic / 350,000 Available • General Prohibitions • Nuisance prohibition • Interference and pass-through prohibitions • Floating-oil prohibition • Economic = +$ 27 M/yr • User Charge Program FOG Rate = $ 0.284/lb (2007/08) • Excludes Restaurants
Costs of FOGWho should bear the cost? Source User Pays Transport/Conveyance Local Maintenance Public Pays Treatment Plant/Pump Station Destination
FOG Control & Prevention Programs • 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 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 Programs • 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)
FOG Control & Prevention Programs • Decided to “Fill the Regulatory Gap” • Found “LAPSE” in Regulation • Need for Partnering Among Agencies • Decided to Regulate - Differently • Decided on Key Focus Group - Restaurants • Facilities Need to “KNOW” • Facilities Need - Methods for Success
FOG 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 ProgramsResults • 2-Year Results: 848 Facilities Visited • Review Operations • Provide Basic Materials • Identify Disposal Methods Used • No-effect on Blockage Reports -- YET • Survey/Feedback Measures • Positive & Well Received • Acceptance by Franchise Operators
FOG Control & Prevention ProgramsConclusions • 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