Transcript Document

Fats, Oils and Grease Licensing &
Enforcement in Cork County Council
Alan Costello
A/Scientist
Wastewater Laboratory
Cork County Council
FOG Problems in WWTP’s
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FOG (Now referred to as ‘Oils and Greases’)
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CnH2n+1COOH
50-100mg/l in untreated wastewater, 30–40% of the total chemical oxygen
demand
Clog inlet screens to WWTPs
Increase the COD loading
Micro organisms cannot easily break them down
Grease balls in aeration basins
Odours
Reduces oxygen transfer, increase energy requirement
Filamentous bacteria
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Foaming
Poor settling sludge
Chaos in Membrane Bio-Reactor (MBR) plants- pore blockages, significant cost
issues
Create unsightly films d/s of discharge
EPA have set FOG as an ELV on some WWDLs
Local Government (Water Pollution) Act 1977
Section 16:
A person.. shall not…discharge or cause or permit the discharge of any trade
effluent or other matter (other than domestic sewage or storm water) to a
sewer, except under and in accordance with a licence.
"trade effluent" means effluent from any works, apparatus, plant or drainage
pipe used for the disposal to waters or to a sewer of any liquid (whether treated
or untreated), either with or without particles of matter in suspension therein,
which is discharged from premises used for carrying on any trade or industry
(including mining), but does not include domestic sewage or storm water.
"sewage" includes domestic sewage and a combination of domestic sewage and
storm water” (Domestic sewage not defined).
Urban Wastewater Treatment Regulations 2001:
Domestic waste water" means waste water from residential settlements and
services which originates predominantly from the human metabolism and from
household activities.
Due to “absence of a definition of domestic sewage…lack of uniformity on the
application of licensing requirements to domestic-type wastewater discharges…”
Circular L8/2003 (WSP)
Interpreted Domestic Sewage as: “Including also sewage from a different
source, but which nevertheless is of a composition or concentration produced by
a household” and exempt from licensing.
Recommended licensing restaurants, food preparation establishments, butchers
etc.
Water Services Act 2007
Section 63 (not yet commenced-will replace S16 of the LG(WP)A 1977-1990)
A person…shall not…discharge or cause or permit the discharge, either directly or indirectly,
of any trade effluent or other matter (other than domestic waste water or storm water) to a
sewer.
“trade effluent” means effluent from any works, apparatus, plant or drainage pipe used for
the disposal to a waste water works of any liquid (whether treated or untreated), either with
or without particles of matter in suspension therein, which is discharged from premises used
for carrying on any trade or industry (including mining), but does not include domestic waste
water or storm water.
“domestic waste water” means waste water of a composition and concentration (biological
and chemical) normally discharged by a household, and which originates predominantly
from the human metabolism or from day to day domestic type human activities, including
washing and sanitation, but does not include fats, oils, grease or food particles
discharged from a premises in the course of, or in preparation for, providing a related
service or carrying on a related trade.
Cork County Council FOG Programme
1st FSE FOG License issued in 2005
Number of licenses issued by Cork County Council;
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143 FOG licenses issued
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19 FOG licences issued in Kinsale
15 FOG licenses issued in Midleton
FOG programme currently under review
Licensing Procedure
Local Area Engineers identify significant FOG dischargers in their functional
area to Environment Directorate.
Environment Directorate staff call to premises and explain to operators FOG
control requirements & explain licensing procedure.
or
Environment Directorate write to these premises advising them of their FOG
control requirements, their licensing obligations and set a date for an application
form to be submitted.
Completed Application Form submitted to Environment, who forward a copy to
Area Engineer for comment.
Premises inspected where possible.
Further Information sought, or licence issued to applicant.
FOG Licence Application Information Required
Applicant details, company reg. no. etc.
Details of activity
Usage of premises ( employees, hours of business etc.)
Drawings showing;
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Layout
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Sewer connection
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FOG producing equipment
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Grease removal equipment & service agreement
Chemical analysis of a sample post GRU
Volume of discharge produced (water in/water out sufficient)
Details of materials (detergents etc.) used on premises
FOG License Requirements
Adequately sized GRU
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Passive retention/active grease removal to I.S E.N 1825
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Concentration should not exceed 25mg/l or
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Construction in accordance with specified minimum dimensions.
Regular maintenance of the equipment as per manufacturers recommendations by operator, with
maintenance records to be forwarded to Area Engineer's Office annually.
Regular cleaning of equipment, with records to be maintained.
Proper disposal of separated FOGs by permitted contractor & records
Best management practises re. kitchen waste disposal - sink strainers, plate/pot scraping to bin, recovery
of used cooking oils- i.e. remove FOGs at source
License ELV:
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50mg/l FOG
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1000mg/l BOD
Annual Licence Fee ( €100/year)
Licence charges structured to promote self compliance by licensee in conjunction with L.A.O. Fees increase
if inspection/sampling required.
FOG Licence Application Form issues
Applicant unable to identify sewer connection
 “no idea, assume it’s outside the shop somewhere”
Poor / absent drawings
Sections left completely blank
 “I’m too stupid to fill it in”
Improvised forms used
No analysis of effluent
Who is the owner/operator?
Applicant doesn’t ‘exist’
To whom do we issue the licence?
Cost of analysis
Application fee is €380.42 irrespective of size of operation
FOG Licence Monitoring
FOG licensees not included in routine S4/S16 license monitoring
programme
Monitoring at the request of the Local Area Office if problem in sewer
Licensees are then charged per inspection visit
Exceed ELV enforcement action
Enforcement Options Available:
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Warning letter
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S.16 (1) WPA Prosecution
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S.16(13) WPA Notice
Failure to Apply for a licence
On expiry of prescribed date from initial letter, final warning letter issued advising
that Environment Directorate Staff will call to the premises and conduct dye test
to establish connection to sewer.
Dye test + Caution owner/operator that a prosecution will be initiated unless
application form submitted within given time frame.
Summons issued - Usually sufficient to get them to apply for a license.
Court Appearance
Enforcement Problems Encountered
Access difficult due to hours of operation
Sudden language barrier during inspection. Owners seldom on site even if prior agreement
to meet.
Sewer connections tarred over
Organized resistance from traders
Need to prove a discharge of trade effluent from the premises prior to using S.16(1) or
S.16(13)
Dye test merely confirms they are connected to a sewer, does not prove they actually
discharge to the sewer. “Insufficient evidence” of a discharge.
A sample taken from a pipe does not mean they discharged it as you don’t know what else
is connected to that pipe
Unlikely to obtain a sample given low volumes of discharge
Frequent adjournments
Enforcement Options
Try to have enough circumstantial evidence to persuade an individual to plead include;
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Photographs of dishes in sinks
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Dye test from sink
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Sample if possible
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Camera survey of sewer
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Evidence from local water services staff history of blockages
S.22(6) WSA: Direction to take measures if risk to health or environment
S.70 WSA: Occupier of a premises shall not permit wastewater to be discharged to a sewer
that
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causes/likely to cause a risk to human health/environment S.70(1)
interfere with the free flow of the contents of the sewer S.70(3)
Focus on one of the larger dischargers, usually several smaller ones are waiting to see what
happens.
Is there a need to amend existing legislation? E.g. A premises shall be connected to the
satisfaction of the wastewater services provider’?
-Thank You-