KEVINS. HENNI

Hennessy

SeeingtheCompleteFOGPicture

OG (fats, oils, and grease) is a major com plant equipment. Large amounts of FOG in a treat ponent of discharges from certain food ser ment plant also increase treatment costs for aerobic vice establishments. Homes and large food- treatment processes and stimulate growth of unde F processing facilities can also be significant sirable and harmful filamentous microorganisms in contributors of FOG, the leading cause of public the activated sludge process. sewer system blockages and treatment plant upsets. As the adverse effects of FOG in sewer systems The resulting sewer backups, access-hole overflows, have increased over time and utilities have identi and wastewater spills in turn lead to contamination fied FOG as the culprit in the majority of their and damage to homes, businesses, and the environ spills, overflows, and maintenance costs, some ment. The US Environmental Protection Agency local governments have taken action to protect (USEPA)in a report to Congress (2004) stated that facilities and educate the public about the prob “grease from restaurants, homes and industrial lems caused by FOG. Grease is especially problem sources are the most common cause (47%) of atic because when it is hot, it is liquid and stays reported blockages.” More recent data compiled by dissolved in water; however, as grease cools it USEPAindicated that more than 65% of spills solidifies, reduces conveyance capacity, and can nationwide may be caused by FOG (USEPA,2009). ultimately block the flow of sewer water. The costs However, although the need to stop FOG from clog to perform sewer system maintenance associated ging sewers and treatment plants is certainly an with keeping sewer systems and wastewater treat important challenge for local governments and pub ment plants (WWTPs) clear of FOG can run in the licly owned treatment works (POT’Ws),it is just the hundreds of thousands of dollars per year for an first step in what should be a comprehensive, cradle- average-sized sewer system. to-grave approach to handling FOG. The initial response by local governments on the Historically, FOG control was not a distinct cutting edge of this nationwide FOG dilemma has management activity for POTWs’ collection-system been to enact or modify pretreatment ordinances to operation and maintenance, Collection systems impose and enforce FOG regulatory controls for clogged with FOG often went undetected until an food service establishments in an attempt to reduce overflow actually occurred. Clogs were simply interferences with WWTP operations. Some efforts pushed open to reestablish flow, and the FOG have included establishing numeric pretreatment flowed in a slug to a treatment plant. As a result, limits and/or requiring best management practices, there were severe problems at the plant such as such as the use and proper maintenance of intercep handling FOG, odor from FOG, and clogging of tor or collection devices. CONTROLLINGFOG lenges. Nevertheless, a complete approach to dealing Control strategies are a necessary first step in with FOG cannot be limited to simply keeping FOG addressing the challenges posed by FOG. A local gov out of the sewer system. ernment should at a minimum have in place a well written sewer use and pretreatment ordinance that spe FOGDISPOSALANDRECYCLING cifically addresses FOG. The ordinance should require Some local governments expend great energy in con methods for the capture of FOG by food service estab trolling FOG, but there has been little focus on FOG lishments and other significant FOG generators. It disposal either nationally or locally. This is a liability should also include fees, fines, or other sources of reve for the regulated community. Disposal can be a prob flue that will help offset the cost of inspections, pre lem for waste haulers if facilities that accept FOG are treatment personnel, and clearing FOG from sewer limited. This becomes a back-door way to defeat the lines and equipment. Local governments also need to effectiveness of FOG regulation because without an invest in public outreach and education about sources economical way to dispose of FOG, generators try to of FOG, the issues with FOG, and the purposes of pump traps less frequently and waste haulers look for related ordinances. cheaper disposal methods that include illegal dumping. The collection of FOG solids and semisolids in an The disposal of grease separated before entry into effort to keep FOG out of the sewer system has cre the sewer collection system is a major concern in the ated a secondary issue: What to do with the collected wastewater industry. What do you do with FOG kept FOG material? FOG collected in grease traps and from or removed from the collection system? Grease interceptors is often sent to landfills for disposal. This must be disposed of in an appropriate and environ method of disposal has fallen into disfavor because it mentally sound manner. Current FOG disposal loca uses valuable landfill space, creates a potential source tions and methods are somewhat uncertain and in of groundwater contamination, and fails to take many situations unsustainable. If not handled properly, advantage of more environmentally beneficial options FOG disposal can be a cause of environmental con for collected FOG such as recycling, conversion to tamination or the spread of disease. Sustainable, non- biofuel, or use in generating renewable energy (bio polluting disposal options are an important component gas). Each of these options poses its own unique chal of any complete FOG control program.

Now Fiom Mueller Co.

,‘ ‘\

Enhances Water Quality - Conserves Resources • FLushesduring low demand • Saves water • Cuts annual costs • Reduces crew time • Discharge to ground or drain • Models for year-round flushing - Summer or Winter AHydro-Cuardsystemautomatesthe flushingprocessand is a water qualitymanagementtoolthat can pay foritself. Thissystemflushes dead-endswithouta crewon-site,useslesswater,and enhancesthequalityofdeliveredwaterin your

- distributionsystem.Withminimizedchlorineusage,lesslaborinvolvedand decreasedwaterusage, overallcostsare significantlyreduced.Yourcustomerswillbe happiertoo.Betterwaterquality willresultin fewercomplaintsabouttasteand odors. Learnmoreaboutthisnewproductline fromMuellerCo.and itsbroadrangeof models,includingfrost-resistantand SMART“2-way”(SCADAcompatible).Visit wwwhydro-guard.com,[email protected] call877.864.8500. Hydro-Guard Flushing System - another Smart Mcve by Mueller C

7 With the current thinking, the solution to dealing and financial grants to develop productive FOG use. with a growing amount of separated FOG solids has Similarly, state agencies don’t seem to have identified been to find a way to recycle or reuse FOG. Environ recycling or productive use of FOG as a regulatory mentally beneficial and cost-effective options for priority. This leaves local governments to implement handling collected FOG include use as supplemental innovative uses of FOG and, through trial and error fuel, generating methane-rich digester gas, producing to identify successful approaches in either incorporat biodiesel fuel, and sending FOG to rendering plants ing FOG plants at public facilities or permitting pri to be converted to animal food, cosmetics, soap, and vate FOG plants within their jurisdictions. other products. In either case, a local government would be well FOG can be used as a supplemental fuel for munici served by updating its land use regulations and imple pal solid waste incinerators, sludge incinerators, solid menting coordination among various departments waste burners, and heat recovery systems. This use of (e.g., zoning, pretreatment, stormwater, and public FOG provides an incinerator with an inexpensive fuel works) before issuing the first approval for a FOG source and the POTW receives revenue by charging facility. A FOG dewatering, recycling, or biofuel pro tipping fees for disposal of FOG. Anaerobic digestion duction facility or other facility that handles FOG will is used to treat wastes ranging from high-concentra have a number of siting issues. FOG-handling as an tion industrial wastewater to municipal solids. An industry provides a number of public benefits and also anaerobic digester breaks down the organic content of includes aspects that some members of the public will the feed stream into methane, carbon dioxide, and find objectionable. Truck traffic, odor, the potential water. FOG can be added to the feed stream of an for spills, and concerns about the facility’s effect on existing digester, resulting in significant revenue bene property values make the appropriate siting of a FOG- fits. Finally, there has been success in using grease— handling facility a potentially complicated issue. Local even brown grease—in the production of biodiesel, governments should specifically identify these facilities but to date such production has been suppressed as as requiring attention from all departments in order to economically unprofitable. ensure that the facilities are located in appropriate Municipalities should continue to educate the public commercial- or industrial-zoned districts with suffi about FOG and continue to remove FOG discharges cient screening or buffers from adjacent uses. The from collection systems. Local governments should not most difficult issue for FOG facilities is the likelihood simply try to avoid FOG altogether, however. The next of off-site odors, which can be minimized but not step for local governments is to instead see FOG as an entirely eliminated. This is art issue with which any opportunity rather than only as a problem. An enlight local government with a sewage facility located near a ened approach to dealing with FOG is to identify the retail or residential property is likely familiar. How ways in which a government can generate revenue from ever, with proper coordination and development of the beneficial use of FOG. Such efforts are a good pub local ordinances, FOG facilities can be successfully lic relations opportunity to enhance the reputation of sited, designed, constructed, and operated. the wastewater management industry. Seeing the full FOG picture will allow local govern ments to protect existing sewer systems through appro FOGFACILITIES priate action and develop uses for collected FOG that While regulators are encouraging the creation of will be environmentally and economically beneficial to facilities that can provide these environmentally bene their communities. ficial processes, state and local regulations and gov ernment officials might not be prepared to adequately —Kevin S. Hennessy is an executive shareholder permit or regulate such facilities or advise operators at the Tampa Bay, Fla., office of Lewis, Longman & on the siting, operation, permitting, and regulatory Walker, P.A. His practice focuses on administrative, issues that can be involved in building and operating environmental, governmental, and land use law, a FOG or rendering plant. This appears to be the with particular experience in litigation in those third major challenge in a comprehensive plan to areas of law. He can be contacted at address FOG. khennessy@llw-law. corn. USEPAdoes not have FOG-specific regulations; it addresses FOG in its regulation of sewer systems and REFERENCES treatment works. USEPA makes a priority of ensuring USEPA(USEnvironmentalProtection Agency(,2009.CaliforniaFOG proper capacity, management, operations, and mainte Meeting,USEPARegionS,July 14.Oakland,Calif. nance of collection systems, all of which require spe USEPA,2004.Reportto Congress on the Impacts and Controlof CSOs cific FOG management plans. USEPA also encourages and SSOs.Washington,D.C. alternatives to FOG disposal at landfills but has done little other than to establish some education programs http:f/dx.doi.org/1O.5942/jawwa.2014.106.OO1O