Hauler training 2015 Wayne H. Ludwig, Jr. FOG Unit Coordinator George Clay Industrial Investigations Supervisor Philip Rindge Industrial Investigations Supervisor I-Hsin McConnell IDC Unit Coordinator
Hauler training 2015 This session will discuss the Industrial Discharge and FOG (Fats, Oils and Grease) Programs in relation to the grease hauling/disposal industry and WSSC officials. We will review the challenges facing both sides of the regulatory picture. Productive past practices and processes will be highlighted for review along with input from attendees. This will be an annual process for all haulers within the WSSD.
Hauler training 2015 AGENDA Introduction/ Overview General comments and updates IDC Presentation (haulers permits and septage manifesting) IDC Q&A Break if needed FOG Presentation FOG Q&A Wrap-up
Important note about this presentation The manufacturers, contractors, suppliers or any other vendors or commercial entities seen in this presentation are for illustrative purposes only and are not to be interpreted as recommended, allowable or otherwise approved equipment or vendor by the presenter of this training. (i.e. they just happened to be in the action when the photo was taken )
General References IDC: Industrial Discharge Control Sanitary Sewer Overflow (SSO) Any unpermitted spill, release, or discharge from the Collection System (overflowing manholes, pumping stations, stream crossings, etc ) Building Backup (BBK) The release from the Collection System through a lateral to a building or structure (usually basement backups) Food Service Establishment (FSE) The business, usually defined by Code, that prepares food that may contain FOG. Grease Abatement/Recovery Device (GAD/GRD) Any device designed to physically remove FOG within given specifications.
NOTE: WSSC is able to regulates/control FOG, IDC and Plumbing Codes THIS OFFERS AN ADVANTAGE OVER MANY TYPES OF FOG PROGRAMS
WSSC: Regulatory Services Group Functions Inspection Services: performs plumbing and gas-fitting inspections Licensing and Inspection Support: Issue licenses to plumbers and schedules plumbing inspections Plans Review: reviews plumbing plans for commercial and residential work Industrial Discharge Control: regulates the discharge of wastewater to the sanitary sewer from industrial sources (Industrial Pretreatment Program) and waste haulers FOG: regulates the discharge of FOG-laden wastewater from Food Service Establishments (FSEs) to the sanitary sewer; investigates many FOG-related incidents.
WSSC Regulator perspective: The hauling industry is generally both business and environmentally oriented
WSSC Regulator perspective: The business goal is to get from Point A (pickup) to Point B (discharge) in the least amount of time, at the least amount of expense, and emptying the vehicle in the safest and fastest manner without undue delay to get to Point C (new pickup) to start the process over again.
WSSC Regulator perspective: Assure each law, regulation, rule, procedure or permit has a basis for implementation and be ready to communicate the reasoning
WSSC Regulator perspective: Sometimes, you need to speak the nontechnical language to get your point across XX
WSSC Regulator perspective: The hauling industry comprises a very diverse group of personalities and agendas
WSSC Regulator perspective: Some septage and most FOG-related materials are usually readily biodegradable and re-use, alternate use disposal methods should be explored.
WSSC Regulator perspective: The hauling industry should understand the nature of their waste material
WSSC Regulator perspective: Although being aware of the haulers bottom line, environmental regulations, checks and balances are critical
WSSC Regulator perspective: Hauler vehicles usually need inspections/ requirements beyond DOT; usually Health Department based
WSSC Regulator perspective: We really try to understand driver s and other first line personnel s priorities and agendas-and we ll work with you within the allowable limits.
WSSC Regulator perspective: We always try to anticipate feedback (sometime push back ) when adopting new or more stringent regulations. Allow stakeholder input.
WSSC Regulator perspective: We try to assure the hauler regulatory program is communicated with all types of hauler businesses and their employees from top to bottom.
WSSC Regulator perspective: haulers are a diverse group of businesses ranging in size, capital, equipment and trained personnel
Industrial Discharge Control Program And Waste Haulers July/August 2015
Program Mission We are experts in the pretreatment field entrusted by our community to protect our wastewater treatment plants & collection system, the integrity of out sludge, and the health and safety of our co-workers. We are dedicated to ensuring that our receiving waters are environmentally safe for humans, fish, and future generations.
Program Objectives To control pollutants from industrial/commercial sources which: pass through the wastewater treatment plant process; interfere with the operations of the treatment plant contaminate sewage sludge; damage the collection system; and are harmful to the workers at the treatment plants or in the collection system.
Program Personnel Unit Coordinator I-Hsin McConnell Permit Agent Bellamie Nelson 301-206-8841 Industrial Investigations Supervisor George Clay Industrial Investigations Supervisor Philip Rindge Industrial Investigator Robin Forte Tanglewood Drive 301-206-8590 Industrial Investigator John Matthews Muddy Branch Road 301-206-8592 Industrial Investigator Devora Wilkinson Temple Hills Road 301-206-8566 Industrial Investigator Todd Gentry Ritchie Road 301-206-8506 Industrial Investigator Tonya Penn-Huff Temple Hills Road 301-206-8566 Industrial Investigator Peter Holland 301-206-8629
Permit Agent Responsibilities related to Waste Haulers / Others Issue hauler permits Collect permit fees Review and verify manifests Process civil citations, fines and court papers Enter information into database. Answer general questions related to hauled waste Permitting Agent: 301-206-8841
Industrial Investigator Responsibilities Related to Waste Haulers/Others Enforce waste hauler requirements Collect manifests at disposal sites Randomly collect samples from waste haulers Attend court proceedings related to violations. Answer questions related to sites, disposal practices, and prohibited discharges, etc.
Applying for a Waste Hauler Permit A hauler permit is effective July 1 st - June 30 th (our fiscal year). If purchased after January, permit is pro-rated for onehalf of the annual fee. Haulers are required to re-apply for a hauler permit annually Applications can be found: Online www.wsscwater.com In person 14501 Sweitzer Lane, Laurel, MD By mail by calling - 301-206-8841 (Permit Agent) New customers, renewals, and zero dischargers may apply by mail or at the RGH building.
Items Needed to Obtain a Hauler Permit Complete permit application Montgomery and/or Prince George s County Health Department Permit Vehicle Registration card(s) Material Safety Data Sheet Formaldehyde or 1,4 dichlorobenzene are prohibited Check or Money Order payable to WSSC
2012 DC Water Blue Plains Inter- Municipal Requirements Septic or Greasy waste accepted at WSSC that originated from: Montgomery County Prince George s County Arlington County Fairfax County Loudoun County District of Columbia
2012 DC Water Blue Plains Inter- Municipal Requirements Greasy waste must be disposed of at Muddy Branch in Montgomery County. Manifests are required for all hauled waste discharges Random sample collection of hauled waste
FY 2016 Changes to the General Conditions Arlington County VA wastes Submittal of manifests Sidenote: a word about Muddy Branch grease manifests Temple Hills Disposal Site
How to Complete a Septage Manifest Or trailer number Don t forget to sign here
Manifesting Septic Waste All highlighted information required for manifest to be considered complete. LEGIBLE!
Most Common Violations in FY15 No and/or Suspended Permit Required to provide renewed County Health Permit/Licenses Unsanitary Conditions Required to notify WSSC of Spills and Cleanups Outside Service Area Waste Sidenote: COLVIN RUN, VA notice
Most Prevalent Violations Committed by Waste Haulers/Others Discharging after hours Discharging without a hose and creating an unsanitary condition through spillage of waste Failure to submit manifest Failure to complete manifest Discharging without a waste hauler permit Disposing of hauled waste from outside the service area
Enforcement Actions A Notice of Violation (NOV) and a Civil Citation are the enforcement actions that WSSC will issue to the waste hauler. Citations start at (per violation type) - $ 250 for the first offense - $ 500 for the second offense - $ 750 for the third offense - $ 1,000 for any subsequent offenses
Where to get Additional Information about Disposal at Existing Sites Contact the IDC Permit Agent at 301-206-8841. Or Contact the Industrial Investigator associated with individual disposal site. (see phone numbers in the Program Personnel slide or in the Waste Hauler Permit Conditions)
Updates on Waste Hauler Program Two potential sites have been identified in Prince George s County as disposal sites: Anacostia II Pump Station septic only Piscataway WWTP- septic and grease One potential site has been identified in Montgomery County as a disposal site: Abandoned Gude Drive WWTP- septic and grease Design phase is 30% complete for possible sites. Grease and septage waste to be accepted, may be processed and treated differently
Updates on Waste Hauler Program Scope of Design: Locations of sites; Architectural; Security/Access (keycards); Vehicle maneuvering; Receiving Station with Pretreatment; Hours of sites not evaluated at this time.
Questions???
FOG Stakeholders FOOD SERVICE ESTABLISHMENTS PLUMBERS / PLUMBING INSP. WASTE DISPOSAL / HAULERS HARDWARE / CHEMICAL VENDORS FOG PROGRAM STAFF EPA / STATE REGULATORS
WSSC FOG Program by the numbers 6500 FSEs registered with region health departments; 4600 active FOG regulated FSEs in a 900 square mile area; 3050 total inspections per year; 575 FSEs per Investigator with staff of 8 FOG Investigators >2000 outdoor interceptors 33 licensed grease haulers 1 grease dumping site within the WSSC service district (WSSD)
FOG Unit Goals and Objectives WSSC s plan to effectively balance the needs of the customers, regulators, mandates, environmental groups, and FSE organizations: Education Enforcement Response Plan Experienced staff
MAIN CONTACTS: Tom Brown: 301-206-8575 Wayne Ludwig: 301-206-8719
A FOG program s primary objective is SSO (or CSO) PREVENTION SSO s in a service area have the potential to discharge thousands of gallons of raw or partially treated sewage into the storm drain system and ultimately to the local water bodies; In addition, BBK s can cause additional damages to property and the environment. It has been estimated that 40-60% of all SSOs and basement backups nation wide are grease related. What s your utility s record? Pollution prevention (FOG control) is often the first line of defense.
GREASE BUILD UP SEWER PIPE CLOGGED WITH GREASE
SEWAGE OVERFLOW IN PARKING LOT
Wastewater Treatment Plants also are a repository of FOGrelayed materials
Sewage Pumping Station FOG Accumulations
Manual cleaning of smaller station reservoirs is common Common technique, especially for smaller, easily accessible wetwells; Inexpensive in relation to use of Vac truck; Technique requires bringing wetwell below low-level cutoff to the point of almost breaking suction in pumps; Material is moved to the next downstream site or utility; Assumes downstream sewer capacity for hydraulics and solids; Use of high pressure hose to coax blanket (move/emulsify/break-up) usually accomplished; May require confined space procedures (dependent on depth/accessibility of wetwell)
Vacuum truck assistance and waste product handling
Contractual cleaning
Pumping Station wetwell cleaning at National Harbor (MD) January 2010
Key aspect of grease/fog abatement CONTROLLING THE SOURCE OF FOG
EDUCATION Public / Industry
Grease Management Brown Grease ) Brown Grease: Grease that goes down the drain into a volume or flow-based grease interceptor (WSSC regulates this) A WSSC Septage & FOG disposal study recommends upgrades to system. Separate septage and brown grease disposal streams. Grease treatment options may include dewatering and conversion to bio-fuel. Other local utilities also looking at a more formal program of regulation. Yellow Grease Yellow Grease: Used fryer oil or any other used cooking oil (various contractors exist for this service There is a national and local interest to convert Yellow Grease to Biodiesel FSE owners must comply with local requirements for proper handling and disposal of grease
From the website http://www.wsscwater.com/home/jsp/content/cleaninggrease.faces http://www.wsscwater.com/home/jsp/content/fog-training.faces
General FOG Program Enforcement Specific limitations for prohibiting discharges to the sanitary sewer; Investigative and Enforcement authority over FSE s; including how they operate and maintain grease removal/abatement devices. May have Investigative Authority for Grease Disposal (e.g. septic or grease haulers); Permitting Authority; Sometimes able to enforce other portions of the utility Code such as plumbing design, fixtures, drainage, interceptors and traps.
Most common FOG program violations GRD not being maintained properly. Improper tail pieces from sinks / potential for overloading the flow rating of a GRD* One or more kitchen fixtures not connected to GRD inside or out (flow or volume based) Floor drains not connected to interceptor Floor mop sink not connected to GRD inside or out No interceptor / passive GRD for amount of wastewater that can potentially be discharged Wrong / unapproved device for grease removal Garbage disposal to GRD *GRD-Grease Removal Device: can be categorized as flow or volume based via utility code-it is NOT just a small kitchen based unit of 50 gal. or less.
An effective formal FOG Program Proactive inspections Increased Enforcement abilities Record keeping Best Management Practices (BMPs) Customer Outreach (partnering) Restaurant Associations Permitting (FOG Discharge Permit) Contains requirements for control and management of FOG, many with grease interceptor/recovery device operation and maintenance FOG related fees and funding sources to assure proper administration.
WHY FOG CONTROL THROUGH A FORMAL PROGRAM? THE GREEN THING TO DO
Idea from N.C. Dept of Environment and Natural Resources (DENR) THE GREEN PLAN-waste reduction, recycling, pollution prevention. OVERVIEW-the why s and how to s FATS, OIL AND GREASE (FOG)-management FOOD WASTE-guidelines and recommendations SOLID WASTE-recycling
FOG tracking and control Administration and Management Regulatory Requirements General FSE Hauler Recordkeeping Manifest program Operation and Maintenance tracking Spill control Enforcement Response Plans FOG Education Programs Fees and fee structures
ENFORCEMENT FOG Management should follow the cradle to grave environmental mentality of various E.P.A. Laws
Important References 1) Code Section for FOG control Contains administrative requirements for FSEs Mainly used by Food Service Operators 2) Regulations usually found in local Plumbing Codes Contains Technical Requirements for the design, sizing, and installation of grease interceptors. Mainly used by plumbers and grease interceptor manufacturers 3) Typical Code Example Waste Haulers Contains requirements for companies that pump grease interceptors May be overseen by Pretreatment Group and /or Health Department 4) Food Service Establishment Discharge Permit-HIGHLY RECOMMENDED Permit issued by to FSEs that contains more detailed requirements than is in the Code.
Code language: INTRODUCTION Applicability. The regulations in this Section shall apply to establishments where food is served to or provided for the public, with or without charge, including, but not limited to restaurants, cafeterias, hotel kitchens, church kitchens, school kitchens, hospital cafeterias, bars, or any other commercial operation that has the potential to discharge grease laden (of a measurable quantity) wastewater; hereafter referred to as Food Service Establishments (FSE).
Code Language: Requirements for a Permit Permit Required All FSEs shall apply to the Commission for a FSE Wastewater Discharge Permit. Existing FSEs shall apply for a Discharge Permit within 30 days of receiving an application. New FSEs shall obtain a Discharge Permit prior to discharging.
Code Language: Permit Requirements FSE Wastewater Discharge Permit Requirements EPA Minimum Permit Requirements: (1) Best Management Practices (BMPs) for controlling FOG discharges (2) Grease abatement system operations and maintenance standards, when applicable. (3) On-site record keeping requirements. (4) Statement of non-transferability. (5) Other conditions as deemed appropriate by the WSSC.
Code Language: Permit Conditions Section I. General Conditions Contains Necessary Legal Language Section II. Special Conditions Grease Abatement System Management, Operations, and Maintenance Best Management Practices (simple kitchen practices that minimize the amount of FOG going to the drain.)
Code Language: Assuring cross-compliance Other Permits. Haulers and FSEs must maintain the required County Health Department permits at all times. Haulers and FSEs must comply with any and all permits issued by Local, State or Federal Regulatory agencies.
Code Language: Inspections Inspections All Haulers and FSEs are subject to routine inspections as determined by the utility. Right of Entry/Inspect clause. Inspections can be prioritized based on risk of causing SSOs. Priority based on proximity to a sewer hot spot, FSE menu, type of grease interceptor, and/or compliance history.
2013 WSSC PLUMBING & FUEL GAS CODE 157 SECTION 807 RIGHT OF ENTRY 807.1 Investigation Authority 807.1 Investigation Authority 807.1.1 Scope of Duties. Employees or agents of the Commission shall have the right to enter and inspect any properties, buildings and premises in the WSSD or in those portions of Montgomery and Prince George s Counties outside of the WSSD, while in the pursuit of their official duties cited in this code including but not limited to: Inspecting, monitoring, reviewing records, copying records, setting up monitoring or measuring equipment or any other actions necessary to determine compliance with this Code. Commission personnel shall have the right to document locations, processes, conditions or equipment, at an Industrial User s facility through the use of photographs or video cameras or at the discretion of the Commission, require the Industrial User to supply such documentation. 807.1.2 Inspections. Inspections of facilities shall be performed by the code official, employees of the Commission, or its agents as deemed necessary by the Commission. Inspections may be performed anytime the facility is in operation, discharging or has a potential to discharge. 807.1.3 Identification and Entry. Where an Industrial User has security measures or safety procedures in force that require proper identification and clearance or special protective equipment before entry can be gained into the premises, the Industrial User shall make necessary arrangements at its own expense, to enable Commission employees, their agents, the State or EPA entry without delay for the purposes of performing their official duties. 807.1.6 Intimidation or Obstruction. Industrial Users shall not initiate or permit any action which harasses, intimidates, obstructs or threatens Commission employees or their agents in the performance of their official duties.
SECTION 814 HAULED WASTES 814.1 Applicability. The regulations in this subsection shall pertain to companies, individuals or partnerships hereinafter referred to as Waste Haulers, engaged in the business of transportation and disposal of domestic wastes or grease from food service establishments. These regulations shall also apply to businesses as deemed appropriate by the Commission including, but not limited to, grease interceptor cleaning, buses, carpet cleaning and mobile food service companies. 814.1.1 Waste Hauler Permits. 814.1.1.1 Waste Hauler Discharge Permit. Individuals, partnerships, or corporations engaged in the cleaning of septic tanks, holding tanks or grease interceptors shall apply for a Waste Hauler Discharge Permit for each truck used in discharging wastes at the waste disposal sites designated by the Commission. 814.1.1.2 Zero Discharge Permit. Individuals, partnerships, or corporations engaged in the cleaning of grease interceptors within the WSSC service area shall apply for a Zero Discharge Permit if they elect to dispose of this waste at a waste disposal site outside of the Commission s jurisdiction. A Zero Discharge Permit is not an authorization to discharge at the Commission s disposal sites.
Example Code Language: GAD references Grease Abatement System Installation and Maintenance Requirements, General. When directed by the utility, FSEs shall install and maintain an approved grease abatement system that meets or exceeds minimum requirements cited in. Basic types of grease abatement systems may be listed, such as: Flow-Based Volume-Based
Treatment alternatives PHYSICAL treatment for initial capture ULTIMATE DISPOSAL has various options
Types of Grease Abatement (from WSSC Code) FLOW BASED (usually indoor) Manual Grease Trap - a passive interceptor that has a rated flow of 50 gpm (50 gal volume) or less. (IPC) Automatic Grease Recovery Device (GRD) An electrical/mechanical device designed to automatically remove grease; still requires manual cleaning of residuals caught. VOLUME BASED (usually outdoor) Outside Grease Interceptor an interceptor that has a rated flow greater than 50 gpm (50 gal volume) or generally no flow restriction requirements. (IPC) Requires certified contractor (hauler) cleaning.
Example Code Language: Assigning Responsibility Permittee/Property Owner's Responsibility. Grease Abatement Systems shall be maintained in efficient operation at all times by the owner/operator at the owner's/operator's expense. Shared interceptors maintained by property owner.
FLOW BASED (usually indoor) Grease Abatement Devices (GADs) will have instruction manuals and references. Hold onto the manual and any other written directions about the care and maintenance of any GAD. Many have daily and weekly requirements, including frequency of cleaning.
GAD operation and maintenance Always keep any and all labeling, safety precaution, and manufacturer labels in good care and on the equipment as provided. In addition, keep a copy of the exact info in a separate maintenance book. Learn the proper flow rate that is allowable through the unit and do not exceed it. Ask your plumber or FOG Investigator to confirm.
Maintenance Directives
Maintenance Directives
Maintenance Directives
GAD inspection and cleaning Cleaning frequency depends on the following (any/all): The capacity of the device. The amount of grease the facility generates. Best Management Practices (BMPs) the facility has implemented to reduce the fats, oils and grease discharged. The degree to which the facility has contributed to system blockages in the past. Your specific permit or FOG Investigator written requirements
NOT A GOOD SIGN
MECHANICAL GAD with skimmer drum
Internal GAD s-the devices that are flow based and can be manual or mechanical in their abilities to separate grease from kitchen liquids. Usually-when they re used as a shelf, they re not being maintained
GAD Cleaning Baffles Fixture for food debris
GAD Cleaning Clean out the grease trap ENTIRELY. Remove the baffle. Scrape the baffle and inside walls of the tank to remove FOG buildup. Dry wipe the trap rather than using water and cleaning chemicals.
GAD Cleaning Trap should be placed so that it is easy to open and clean. The grease that is cleaned out should be placed into a container and disposed of in the trash. Frequent skimming of the trap makes it easier to clean later.
GAD Cleaning A grease trap should be cleaned out completely when about a quarter of its volume is FOG and solids. The grease trap should be checked every day to make sure it does not need to be cleaned, and it must be cleaned a minimum of once per week.
FSE Maintenance Logs After cleaning out a GAD, remember to enter the information into the maintenance log. If a grease hauler cleaned out the trap or interceptor, put the grease hauler s manifest into the maintenance log. The date and approximate volume of FOG waste removed should be recorded. Maintenance documents are to be kept on site at the FSE for at least three (3) years.
Referenced from a Connecticut haulers website: http://www.sanitrol.net/grease_trap_cleaning.html The following illustrations depict a typical service visit for an internal grease trap. Proper grease trap maintenance is very crucial in order to have an efficiently operating grease trap. Many problems can occur if the levels of collected FOG and solids are not monitored. Problems such as drain line blockages and back-ups, foul odors and even worse, too much FOG being deposited into the city sewer lines, which can lead to fines
Continuing from-- http://www.sanitrol.net/grease_trap_cleaning.html Sanitrol can service the most remote internal grease traps with our Portable Conde grease trap cleaning unit. This device can be transported inside buildings without disruption to your day-today business operations. The portable Conde system provides all the power of a larger tank system with a compact arrangement of components in a completely portable unit. The 60 gallon tank size is ideal for many small pumping applications including: grease trap service, boat holding tanks, machine sumps, and other liquid waste applications.
VOLUME BASED INTERCEPTORS
OUTSIDE GREASE INTERCEPTOR
Interceptor inspection Learn to visually inspect the interceptor The influent (or entry) side usually has the heavier amounts of grease (top photo here). A baffle or elbow should be showing. You should be able to see an outlet arrangement to gauge efficiency on the other end (bottom photo).
WSSC general Interceptor maintenance guidelines (may vary by utility) There should be an adequate number of access manholes to provide access for cleaning all areas of an interceptor. All grease interceptors should be cleaned at regular intervals. This varies with regulatory requirements and experience and usually varies from bi-weekly to quarterly. When cleaning, the entire tank should be cleaned, including solids from the bottom. Definition of clean varies with regulatory requirements Always deal with a reliable company for grease trap cleaning service. Many utilities require ones that are both licensed and permitted.
Example project set-up Assure your contractor specifications are clear and concise, pinpointing all details of your cleaning expectations. Usually the hired help has many years of experience but different expectations from a diverse group of customers. Never assume they know your requirements. Let them know your specifications and witness their work.
Interceptor cleaning operations-typical The outdoor Interceptor usually has at least one, and can have up to three access manholes for inspection and cleaning. It is advisable for you to have the prints or as-builts so you know what the Interceptor cross-section looks like. The operation begins with an inspection of the top grease layer and using truck suction hose(s) to vacuum up the heavier FOG. This may be followed by highpressure water scrubbing or mixing.
CLOCKWISE FROM UPPER LEFT: preparing jetter machine for use; use of rigid threaded rod to stabilize jetter hose/nozzle; tech preparing to use jetter pressure with suction hose; use of high pressure water and suction hose.
Assuring pump-outs or cleanings are proper A coordinated effort is needed to assure all solids are removed and the tank is left clean. Sometimes using all access ports are necessary to coax the solids out to the suction hoses. Assure what is left behind is reasonable and satisfactory for the situation. Frequency of cleanings, FSE planned operations and contractor availability all contribute to definition of clean.
25% Rule Some Codes specify what satisfactory is in an Interceptor: It shall be the owner s responsibility to ensure that the accumulation of solids, grease, and oils does not exceed 25% of the liquid retention capacity of the interceptor, trap, or separator.
The 25% Rule Definition: The combined depth of the FOG layer and solids layer cannot exceed 25% of the total liquid depth of the grease interceptor
Example Code Language: Waste (Grease) Haulers Waste Hauler Waste Hauler Permit is required for all Waste Haulers cleaning interceptors. Pumping and disposal of the contents shall be performed in accordance with conditions of the waste hauler discharge permit cited in Section..
Manifesting advantages Identifies responsible parties Helps quantify the waste Helps quantify the interceptor usage, characteristics Helps track compliance Can help determine interceptor condition Documents maintenance Tracks the waste Protects the hauler
MUST BE LEGIBLE (to WSSC)!!!
Grease manifests
Code language related to pumping less frequently than Maintenance Directive requirements 818.4.3 Maintenance Interval. The minimum maintenance and cleaning frequency for Volume-Based Grease Interceptors shall be quarterly or by the "25% rule", whichever is more stringent. The maintenance and cleaning for Flow-Based Grease Interceptors shall be conducted pursuant to manufacturers' recommendations or by the "25% rule," whichever is more stringent. Deviation from required maintenance intervals less frequent than minimums determined by the Commission shall be approved by the Commission in writing. 818.4.3.1 FSEs who deviate from the frequency of pumping or maintenance requirements of their WSSC issued Maintenance Directive, without prior WSSC approval, will be in violation and are subject to a civil citation at the discretion of the code official.
Requests for GAD pumping frequency reduction Request must be in writing and must be from the authorized representative of the FSE. FSE will be responsible for coordinating licensed hauler and WSSC representative to be present at applicable pumpouts. First pumpout noting interceptor characteristics Second pumpout at Maintenance Directive (MD) interval noting interceptor characteristics Third pumpout at proposed interval noting interceptor characteristics. WSSC updates MD if necessary.
Haulers need to ensure that they dispose of and/or recycle all grease in a safe and legal manner (i.e. certified and possibly provide a manifest)
LATE COULD EQUAL CIVIL CITATION
UPDATED MANIFEST: KEY CHANGES
MISSING/POOR DATA COULD EQUAL CIVIL CITATION
GREASE MANIFEST REPORT CARD JUNE-JULY 2015 SNAPSHOT HAULER TTL.MANIFESTS CORRECT AVG. CORRECT A 2 2 1.000 B 221 210 0.950 C 39 37 0.949 D 65 61 0.938 E 11 10 0.909 F 9 8 0.889 G 7 6 0.857 H 22 16 0.727 I 52 30 0.577 J 54 31 0.574 K 11 6 0.545 L 8 4 0.500 M 3 0 0.000 N 1 0 0.000 O 1 0 0.000 P 2 0 0.000 Q 84 0 0.000
A new program.. - PREFERRED PUMPER PREFERRED HAULER CERTIFIED PUMPER CERTIFIED HAULER HAULER EXTRAORDINAIRE
TYPICAL CRITERIA PHP Criteria Submit list of facilities pumped out on a regular basis for baseline data collection of grease trap pump outs. Attend waste hauler education meeting. Accurately completes the FOG Pump-Out Reports and submits them to JEA in a timely manner (unless FOG generator wishes to retain this responsibility). Submit manifests for disposal of all trap contents generated in JEA s service area on a quarterly basis. Satisfactory results from grease traps inspections indicate acceptable pump outs. PHP Benefits PHP list provided to all FOG Generators. Preferred haulers will assume responsibility for completing and submitting PO reports (and consequences for discrepancies). Restaurants know that PHP trap inspections will be hauler focused, not restaurant focused.
Northern Florida-JEA (and Pacific Northwest) general experience Key participants in JEA s Fats, Oils and Greases (FOG) Program are the vendors that pump out and dispose of grease trap/interceptor contents. It is essential that waste haulers adequately maintain traps/interceptors and dispose of their contents in an acceptable manner. The Preferred Hauler Program (PHP) is for grease trap pump out vendors that meet certain JEA established criteria. FOG generators in the JEA FOG Program are encouraged to use vendors in the PHP. When generators use a vendor in the PHP, the hauler will assume responsibility for submitting completed pump out reports. Also, grease trap inspections will be focused on the haulers performance in maintaining the trap and most discrepancies could be addressed to the hauler not the generator.
WSSC Certified Hauler? Some criteria suggestions In good standing with IDC (DCWATER, other applicable jurisdictions?) NOV, Civil Citation history (period of time to review?) Signs certification statement Manifest completeness % Manifest accuracy % Spot / follow-up check confirmation history (x/yr; time period) Annual training attendance Driver or company training in house or other Recommendation(s) / satisfaction surveys by FSE
Possible ideas--- WSSC Certified Hauler perks Assigned a simpler manifest Listed on WSSC website with the definition of Certified Can advertise on business site Qualifies for self-training programs vs. mandatory attendance for most employees Participate in WSSC review processes dealing with grease recycling and disposal May appear in public service/fse education infomercials
Reducing FOG from FSEs Kitchen BMPs Installed and properly maintained GRDs Prevent SSOs, maintain function of sanitary sewer system, and protect stormwater system and surrounding habitat. City owned Stormwater Sewer System Food Service Establishment City owned Sanitary Sewer System
New/modified FOG programs Anticipating the whys? EDUCATING THE STAKEHOLDERS FOG CODE / STATUTORY POLICIES AND PROCEDURES IPC, OTHER RELATED CODES OR REFERENCES FOG CONTACTS FOG WEBSITE & LITERATURE FAQ S DOCUMENTATION USE OF I.T. PROGRAMS OR JUST MANUAL PERMIT STRUCTURE STAKEHOLDERS MAY INCLUDE OTHER DEPTS. THAT REGULATE THE PLUMBER ORGANIZATIONS THE HAULER ORGANIZATIONS THE RESTAURANT ASSOCIATIONS
Effective management practices for FOG programs ENFORCEABLE CODIFIED REGULATIONS. FSE EDUCATION AND TRAINING. COMMITTED, KNOWLEDGABLE INSPECTORS ENFORCEABLE AND FOLLOWED-THROUGH FSE PERMIT LANGUAGE. Unit cleaning/maintenance requirements. 25% rule or other descriptive parameter FSE RECORD-KEEPING PROGRAM. FOG WASTE HAULER PERMITS AND CONDITIONS. Unit maintenance requirements-defining what is clean Interceptor cleaning efficiency Usually qualitative (procedure) vs. quantitative (post sampling) CONVENIENT, EFFICIENT DISPOSAL/RECYCLING SITE(S) TIMELY AND THOROUGH INSPECTIONS. CERTIFICATION PROGRAMS (annual reviews, training offers).
WSSC Regulator perspective: Appreciate and respect the service provided
Hauler Training 2015 CERTIFICATE OF COMPLETION Presented to: Wayne H. Ludwig, Jr.; Moderator Date SEPTAGE F.O.G.
Thank you! Wayne H. Ludwig, Jr. FOG Unit Coordinator, WSSC wayne.ludwig@wsscwater.com