In the midst of massive capital improvement expenditures to address infiltration and inflow in compliance with EPA Capacity, Management, Operation and Maintenance (CMOM) regulations, William Armes saw that he was staring down a bigger problem.
Armes is pretreatment manager for ReWa (Renewable Water Resources), formerly known as the Western Carolina Regional Sewer Authority. He couldn’t ignore the effects of increasing development and population growth on his grease control program. He needed a plan.
From 1990 to 2000, the eight-county area referred to as upstate South Carolina, which includes the authority’s five-county service territory, saw a 160 percent increase in developed acres, from 222,745 to 576,336. That year, the authority began a self-assessment of compliance under CMOM requirements.
“When we were going through our CMOM program, one of the pieces of information we were asked to provide was about places where we had experienced sewer overflow problems,” says Armes’ colleague, collection department manager Tony Walton. “We immediately began researching those areas and found that 10 of them are grease-related. Contributing factors may be poor grade or improper installation of a line, but the main culprit is grease.”
Grease control is a major initiative in a system with 300 miles of trunk sewer, 1,750 miles of collector sewer, 60 miles of force main, 7,000 manholes and 63 pump stations. ReWa attacks the problem with a comprehensive approach that includes education, inspection, data management and proactive maintenance.
Staying out in front
The authority’s largest municipality is the city of Greenville, but it is also responsible for 17 sewer subdistricts. Armes’ pretreatment division covers more than 100 industries, from bagel makers to auto parts suppliers. Enforcement is divided between a commercial group, which includes light manufacturing and food service, and an industrial group.
Armes was fairly certain that the more than 1,000 food service establishments in his area were the major grease contributors. Growth predictions told him that even though grease wasn’t as large a problem as I&I, it soon would be. He got his team together to develop a cohesive strategy to head off a grease-related crisis.
“We’d had in place some elements of it beforehand based on previous grease buildup, but the CMOM program gave rise to our current grease control strategy,” Armes says. “There were a lot of negotiations with the EPA about what was going to go into it.”
Still, though outcomes are EPA-mandated, means are not. Armes knew he must be proactive, so he led ReWa in developing a comprehensive fat, oil and grease (FOG) strategy.
Making a plan
The strategy covers FOG collection, transportation and disposal. It calls for commercial grease interceptors and provides guidelines on their sizing and maintenance. It prohibits chemical additives to any streams moving through the interceptors. It also contains guidelines for waivers, permitting, inspections, monitoring, reporting and documentation, as well as fines up to $2,000 for offenses.
“The strategy focuses heavily on education as a means of bringing structure to informing food service establishments of the need to capture and transport waste from their locations,” says Armes. “The second layer is inspection. We make sure they’re aware of requirements and have proper equipment installed.
“Once that initial inspection is done, the establishment is directed to put a regular inspection process in place and gets an inspection schedule. They get information from us on how to maintain their interceptors and implement other parts of the program.”
The third element is enforcement. “The CMOM regulations have certain elements that require us to have a municipal-level grease control strategy, but it’s up to the manager to make sure it stays current,” Armes says. “It’s not static by any means. In fact, it’s pretty dynamic. We’re reviewing that right now, how you keep the program consistent, given the turnover of people we deal with in food service.”
Staffing and management
The first real challenge was staffing. “We really didn’t have any staff to spare, so we had to justify in the budget a full-time, hauled-waste inspector and a part-time one, plus a data control technician (DCT) to sample transporters and maintain documents for hauled waste and grease control programs,” Armes says.
The DCT enters data for and from inspections. For grease control, that’s mainly establishing new businesses’ contact and compliance information. This accounts for roughly 40 percent of the position’s workload. The remaining 60 percent of data entry deals with industrial hauled waste pretreatment.
This industrial data can be more elaborate. Reporting covers more than 136 parameters, and regulations require that it be tracked. A separate group of three regional inspectors, divided between a number of industries, takes care of industrial inspections. These inspec-tors are responsible for everything from permitting to inspecting to billing, and they provide data to the DCT.
The last duty of the DCT is to issue quarterly reports to the South Carolina Department of Health and Environmental Control, the state agency delegated by the EPA to carry out environmental policy.
Armes’ plan was detailed enough to justify hiring for these positions, so the program moved forward. An intensive promotional campaign began to create awareness among the public and affected businesses of the FOG initiative. The fiscal 2009 budget for the campaign was $18,400. Besides the commercial and industrial com-ponents of promotion, a hauling inspector visits schools during career days or science days, handing out grease collection cans and coloring books and talking about the importance of keeping FOG out of the sewer system.
Inspection and enforcement
“Our first inspection was pretty low-key, as in ‘How are you doing? Here’s what you need,’” says Armes. “But now that everyone except new food service establishments has been visited and should know what they’re supposed to do, it’s time to make sure they step up to the plate to meet their obligations.”
About a third of food service establishments inspected end up in noncompliance. The authority first ordered property owners to install grease interceptors and then allowed time for installation. “But that window is coming to a close, and now we have to find a way to bring stragglers into compliance,” Armes says. “We’re now seeing a lot of noncompliance that’s not being remedied in the two to three years typically allowed. We may have to go to a permitting process to address that.”
A sampling crew from the authority’s laboratory monitors compliance. At least annually, they sample transporters’ heavy metals, grease, hydrocarbons and other parameters. “This process is more for commercial transporters hauling grease and septage,” Armes says.
Proactive maintenance
Keeping a firm grip on the grease situation means staying proactive. After the CMOM self-assessment, ReWa formulated a predictive cleaning program to mitigate further overflows in problem areas. “We keep them on our scheduled cleaning list on a quarterly basis,” says Walton. “Others on the list get cleaned every six months. We also remove grease from the surface of about 30 of our pump station wet wells at least annually, some semi-annually.”
His department performs cleanouts with a Vac-Con Inc. combination truck with a 15-cubic-yard debris tank. GIS mapping of all system assets makes the job easier. “We have GPS data on all 7,000 manholes,” Walton reports. “We’ve also performed an above- and below-ground inventory of their characteristics. The department also GPS located all permitted industries and large users, and all 63 pump stations.
This information resides in a CityWorks Asset Maintenance Management System software package database by Azteca Systems Inc. The authority is upgrading from the Desktop package to the Anywhere package, which allows for mobile access.
The ReWa system includes 10 wastewater treatment plants also affected by FOG. The collection department services those plants, cleaning scum tanks and grit pits as needed.
For cleaning cast iron lines, the crews use a Ford F-800 diesel truck with a 5,000-psi jetter from Harben Inc. They use a 1987 International 5070 four-wheel-drive truck with a SRECO-Flexible jetter for regular cleaning and stoppage response. To access remote areas, they use an Extend-A-Jet and Model EMSP-6 jetter from SRECO-Flexible.
Resource consolidation
At present, ReWa is working to consolidate treatment into seven regional plants for efficiency. “It’s an economy of scale,” says Armes. “We’re narrowing down to three basins: the Saluda River, Reedy River and Enoree River. We’re at the headwaters of all these waterways, so our permit regulations are tight.”
The Mauldin Road site that handles grease offloads is getting a major upgrade. To keep FOG out of the plant, ReWa is replacing a trench drain with a system that will separate solids, grit and grease right where the transporters discharge their loads. “For several years, we’ve depended on clarifiers and bar screens to collect floatables and settleables at the head of the treatment plant,” says Armes. “But now, to address grease waste, we need something more sophisticated.”
The authority is installing a Septage Acceptance Plant from Lakeside Equipment Corp. “With the Lakeside system, we’re hoping to eliminate that grease buildup in the plant,” Armes says. “But in the collection lines, we still have to keep a proactive process.”
The approach seems to be catching on. “A lot of the subdistricts have adopted our grease strategy as part of their own programs, and are proactive about working with us to address these issues,” Armes observes. It’s a promising scenario, and ReWa hopes it is the start of a trend: Municipalities work together preemptively to keep grease problems from turning into crises.
