An Overview of the City of Palo Alto’s FOG Program and its Results Ryan Harrison Industrial Waste Investigator Ryan.Harrison@cityofpaloalto.org (650) 617-3165
City of Palo Alto’s FOG Program • Implementation of a Fats, Oils & Grease (FOG) Program • Current Ordinance Requirements • Proposed Ordinance Revisions • Hotspot Identification • Importance of Best Management Practices (BMPs) • Plan Review of Newly Constructed & Remodeled FSEs • Development & Implementation of Inspection Tablet PC & Database Program • Inspection Overview • Green Business Compliance Inspections
City of Palo Alto’s FOG Program (continued)
• Elevated Enforcement Actions vs. Proactive Upgrades & Changes • Preventative Maintenance Plus FOG Program Pays Off • Helping FSEs • Grease Waste Hauler Service Contract • Palo Alto’s FSE GCD Loads • Maximizing Energy Recovery • Goals • Inspection Overview (in depth if time permits)
Implementation of a FOG Program • The FOG Program’s main goals: – Increase the number of FSEs in compliance – FOG discharge prevention to the sanitary sewer and storm drain systems – Storm drain pollution prevention from poor FSE cleaning practices and FOG related sanitary sewer overflows (SSOs)
• In 1996, a food service program included ordinance provisions, site inspections & BMP distribution • In 2006, the program was expanded to include the hiring of a full time employee • The dedicated position allows for more frequent and rigorous inspections, follow-up inspections, enforcement actions and program development
Current Ordinance Requirements • Grease disposal prohibited • Grease control devices (GCDs) required in grease generating FSEs • Maintaining GCDs properly • Maintenance log onsite for 3 years • Food waste disposers (grinders) prohibited • Storm drain discharges prohibited • Zinc containing floor finishes prohibited in large FSEs
Proposed Ordinance Revisions • The City is revising its Sewer Use Ordinance and creating Rules and Regulations for FSEs that were not previously codified • Directly inputted sizing calculation not referring to any plumbing code, based off 2007 CPC • GCD maintenance requirements including the 25% Rule and FSE staff not allowed to clean GCDs • Grease & tallow hauler requirements plus City’s right to utilize Grease Waste Hauler Service Contract • Drainage fixture discharge location requirements, GCD vs. SS • Implementation of kitchen BMPs and routine training for purposes of stormwater pollution prevention and FOG discharge prevention • Management of waste cooking oil and tallow bins • Record keeping requirements for GCD maintenance, plumbing activities, tallow bin & BMP training
Hotspot Identification • Generally high density and high volume restaurant areas • Discovered by wastewater division or during inspections • Hotspots lines result from FSEs having improperly plumbed drainage fixtures, inadequately sized GCDs due to the limited space and their failure to maintain the GCDs properly
• Mapping hotspots is very useful • The red indicates main lines with heavier FOG build-up and where SSOs have occurred • These areas are hydro-flushed quarterly as preventative maintenance • Also areas where inspections and enforcement actions have become more frequent
Hotspot Areas have Priority • Conduct inspections at FSEs associated with FOG built up lines to confirm compliance with GCD maintenance and record keeping • Check to ensure all grease generating drainage fixtures are connected to GCDs and hot lines and non grease generating drainage fixtures are connected to sanitary sewer • Dye test if needed and or require a plumber to follow-up • Measure GCDs to ensure GCDs are pumped frequent enough to prevent FOG from escaping into the sanitary sewer, apply 25% Rule
City of Palo Alto’s Proposed definition of the 25% Rule: • Requirement for grease control devices to be maintained such that the combined FOG and solids accumulation does not exceed 25% of the design hydraulic depth in any location of the grease control device. This is to ensure that the minimum hydraulic retention time and required available hydraulic volume is maintained to effectively intercept and retain FOG discharged to the sewer system.
Some have more FOG
Some have more bottom solids
“7 Layer Dip� this measurement was 2 months after the last pump out. Too thick to obtain true measurement due to the thickness, mostly food waste on bottom.
BMPs • Play a major role in FSEs defense against FOG and solids building up in their pipes and GCDs • If good BMPs are applied, the GCDs can generally have a longer cleaning frequency and there are less plumbing issues which all equate to cost savings
Proposed BMP Requirements •
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Install screens in all drains. The screens shall be installed to all sinks, drains, floor drains, floor sinks, dishwashers, etc. The screens shall be cleaned frequently by disposing waste to the trash or food scrap container if available. Regular inspections shall be conducted by Lead Managers and or Executive Chefs to ensure screens are functioning properly and are present. Dispose of all food waste. Food waste shall not be disposed to sinks or drains. FSE staff shall dispose of all food waste directly into the trash, garbage, compost or food waste collection bins by scraping with scrapers, towels, paper towels and/or rubber spatulas prior to using water to rinse off plates, dishes, pots, pans, containers, etc.
Plan Review of Newly Constructed & Remodeled FSEs • Review process for maximizing FOG discharge prevention and storm drain pollution prevention • Ensuring proper connections of all drainage fixtures to GCDs or sanitary sewer • Visible access of GCD piping and all cambers in interceptors • Covered recycling, trash and tallow bin storage areas
Site visits are helpful during plan check • Inspect FSEs planning to utilize the existing GCDs • Have a professional also inspect • We discovered this 1,500 gallon GCD had no baffle wall and had to be replaced
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A tenant improvement project changing FSE operations included converting from minimum food service to a steak house and wanted to utilize the existing 50 gallon GCD The owner stated he would monitor every week… we couldn’t trust him We required something bigger and compromised with this 300 gallon in place of the old unit Even though we would have liked to have seen a larger unit, they had issues with costs
FOG Program Inspection Tablet PC & Database • Began developing inspection format design in 2006 • Data uploads to existing database by wireless at office • Features: FSE lists, contacts, previous FOG & storm drain system inspections, enforcement documents, maps and directions to FSEs from office, and generates Follow-up Letters and reports
Inspection Overview • • • • • • • • •
Rate the FSE Condition of grease control devices (GCDs) Maintenance log Best Management Practices (BMPs) Stormwater issues Condition of tallow bins Drainage fixtures Cooking equipment Distribute BMP outreach material
Green Business Compliance Review for the Santa Clara County • Benefits to the applicant FSEs • Also benefits the City by having more FSEs in compliance and trying to reach compliance • The approval requires a very thorough inspection and generally follow-up occurs • Knowledge of and complying with all requirements • Preventative maintenance pays off
Green Business Inspections • In 2008, 13 Green Business Compliance inspections were conducted • 9 were approved, the remaining 4 are improving procedures and or are properly plumbing drainage fixtures • We will return to follow-up and ensure tasks were completed and compliance is achieved
Elevated Enforcement Actions vs. Proactive Upgrades & Changes • Case by Case • Improperly Maintained 4,000 gallon Interceptor • Cowper Street FOG Issues
The effects of an Improperly Maintained 4,000 Gallon Interceptor • Massive block of material from years of failing to properly maintain • This photo is from the baffle wall looking towards the inlet
• This guy went in with proper confined space entry procedures to remove all solid material • He only made a dent • The FSE did not hire them to return because they thought they could do it in a day • Days later the FSE sent their own staff down in with out proper procedures to ensure their staff’s safety • It is 10 feet from the surface to the top of the grease
• They would not admit to sending their staff in to clean without confined space entry procedures • Was that a ladder you pulled out? • How did that shovel get there?
• CAL OSHA was notified and paid them a visit • And then they paid CAL OSHA
• We only issued a Notice of Noncompliance due to their willingness to cooperate • After three months we measured the GCD and set the cleaning frequency to be at least every 3 months or more frequent to prevent FOG from entering into the sanitary sewer
Cowper Street • Reoccurring FOG related SSOs • Wastewater division was hydro-flushing main quarterly • 5 FSEs contributing FOG to the sanitary sewer system
Cowper Street (cont.)
• City hydro-flushing preventative maintenance increased to monthly until SSOs were eliminated and FSEs made changes
FSE #1 • Proactive changes after City staff recommended and explained severity – Their pasta cooker with a continuous drip was connected to the GCD and the pre-rinse sink to the sanitary sewer, the first chamber of the 3,000 gallon GCD measured to be greater than 110 degrees, FOG melts around 106 – After rerouting the these drainage fixtures the GCD, we dye tested to confirm and the temperature lowered to about 70 degrees
FSE #2 • Proactive changes again after City staff recommended and explained severity – Shared the 3,000 gallon GCD with FSE #1 although their kitchen was not as active – Rerouted the dishwasher directly to the sanitary sewer system – Helped lower temperature in the shared GCD
FSE #3 & #4 • • •
Both are small FSEs with little room which required enforcement actions Shared their building’s lateral feeding the top of the Cowper line #3: Notice of Noncompliance and Compliance Agreement Issued – GCD was not installed correctly and it was not maintained properly – Replaced with Big Dipper, Successfully maintained •
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#4: Notice of Noncompliance Issued – Replaced 15 gal GCD that was not maintained properly with a 50 gal unit which we recommended to clean at minimum of every 3 weeks We also worked with their property manager to ensure the building’s lateral is frequently cleaned every 6 months
FSE #5 • Many follow-up inspections • Two Big Dippers not maintained properly by staff to go along with many storm drain system violations: tallow bin issues/spills • Elevated enforcement actions: several Notices of Noncompliance and fines to compound the existing Compliance Agreement in effect
Preventative Maintenance Plus the FOG Program Pays Off • Now this Cowper line is cleaned quarterly by City wastewater division as preventative maintenance similar to most historical FOG hotspot areas even though there has been a dramatic decrease in FOG build up • Proving our combined efforts are paying off for the City
Helping FSEs • We try to help owners and managers • In one case, we discovered a FSE contracting a plumbing company to flush lines and pump out 6,000 gallon GCD quarterly and every 6 months they claimed to have been doing confined space entry of the GCD to clean it out entirely – This is what we found after their last visit…
First chamber, with huge chunks!
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Only the second chamber was truly cleaned or was it? • They were paying for what we are not sure. • The plumber is even trying to increase the frequency of all tasks. • We will return soon to measure to ensure the proper cleaning frequency is achieved.
Give Options vs. Recommendations • Giving options will hold you less liable • Recommend obtaining at least two to three quotes • List many types and manufacturers of GCDs
Grease Waste Hauler Service Contract • Work Plan: – Program Description – Ordinance Modifications – Request for Proposals (RFP) – Agreement (Draft) – Council Meeting Report (CMR) – Plus all related information and attachments to RFP and Agreement
Program Description: City of Palo Alto Grease Waste Hauler Services Goals and Objectives (from RFP) •
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The City is interested in receiving proposals from companies that have demonstrated experience providing grease control device (GCD) waste collection, disposal, processing, record keeping and manifesting services comparable to those described in the RFP. The City seeks one or more contractor who place a high priority on maintaining GCDs, disposing waste properly, have demonstrated significant results and innovation through its program development, implementation, customer education, and on-going operations. The City’s goals and objectives for future services include: Minimize the carbon footprint and other adverse environmental impacts from the provision of service. (The Service Contractor(s) (SCs) can efficiently target sections of the City or more specifically, target streets to be serviced.) Maximize energy recovery. Ensure that GCD waste is collected and transported from customers within the City of Palo Alto to a legally-authorized disposal or treatment facility. Baseline services include disposing GCD waste contents at the RWQCP, although there is a limited amount of capacity. Facilitate efficient and economical food service GCD cleaning and disposal services that are in full compliance with environmental laws and regulations. Identify and minimize sewer blockages, sanitary sewer overflows (SSOs), and stormwater pollution sources created by FOG generated at FSEs.
Program Description: City of Palo Alto Grease Waste Hauler Services Goals and Objectives (from RFP) (continued) • • • • • • • • • • •
Maintain a high level of service (timely, courteous, and responsive) to customers. Ensure the cost effectiveness of the services provided. Maintain an effective reporting system of all collection and disposal activities which is up to date and available to City of Palo Alto staff, possibly as an electronic database. Ensure a fair Agreement for the SCs, customers, and City. Maintain positive communications with the City and the customer. Fulfill community needs by providing increased outreach and awareness on FOG control issues to the general public and FSEs. Ensure the efficient use of City resources. The SCs with input from the City’s FOG Program Manager will determine the frequency at which each FSE’s GCD will be cleaned out. The SCs will bill the FSEs directly similar to their current procedures. The City will conduct follow-up and enforcement for problem FSEs refusing service. The SCs will furnish and maintain all equipment to be functional, presentable and professional in appearance and service. All vehicles shall be subject to City’s approval. The SCs shall employ and manage its staff.
This contract should lessen the potential for major problems • We hope to prevent the type of disaster that occurred in December of 2001 • A FSE whose 3,500 gallon GCD was not maintained properly for years decided to have the unit pumped out • The grease hauler chosen to pump it out decided to release the material into the sanitary sewer downstream of the GCD • This is what occurred as it flowed down hill from the FSE…
Then it entered a creek
Palo Alto FSE’s GCD Loads • •
Investigating whether or not the PA Regional Water Quality Control Plant (RWQCP) can receive all of the City’s and possibly the service area’s GCD loads. How much is generated now with existing GCD maintenance requirements? – – – –
Data is still be obtained and refined So far, approximately 80,000 gallons/month or <1 million gallons/year RWQCP can accept roughly 1.5 million gallons/year The City is aware of 163 traps at 133 FSEs, 83 interceptors at 81 FSEs and 20 Big Dippers at 15 FSEs. – Contribution to the City’s load • Traps: 7.2% • Interceptors: 92.7% • Big Dippers: 0.14%
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With ordinance revisions and Grease Hauler Contract, there is potential to increase the amount generated by PA FSEs.
Looking into converting GCD waste loads into biodiesel or other forms to maximize energy recovery â&#x20AC;˘ We are investigating FOG acceptance procedures at the RWQCP to see if there is potential to receive all hauler loads associated with the Grease Waste Hauler Contract in the City of Palo Alto and possibly the other Cities in the RWQCPâ&#x20AC;&#x2122;s service area even non contracted haulers. â&#x20AC;˘ Currently there is limited capacity for FOG acceptance and it is used as a fuel source in the incinerator
Goals • Adoption of revised ordinance revisions • Grease Waste Hauler Service Contract: – RFP release – Effective Agreement
• Inspect all FSE with tablet and database system • Ensure all FSE drainage fixtures are properly plumbed
Inspection Overview • • • • • • • • •
Rate the FSE Condition of grease control devices (GCDs) Maintenance log Best Management Practices (BMPs) Stormwater issues Condition of tallow bins Drainage fixtures Cooking equipment Distribute BMP outreach material
Rating FSEs â&#x20AC;˘ The FSEs are categorized by their potential to contribute FOG to the collection system or cause other problems such as storm water violations. 1.Problem FSEs in hot spots 2.Problem FSEs 3.FSEs in hot spots 4.FSEs that have only had minor issues in the past 5.FSEs with potential to generate FOG 6.FSEs without significant potential to generate FOG (juice bars, coffee shops, etc.)
Grease Control Devices • Assess condition and note: – Level of thickness and temperatures • Obtain Measurements – Always in traps and generally revisited for interceptors – 25% Rule: when a GCD reaches the level of 25% combined solids (floating grease + bottom food solids) it begins to operate inefficiently.
Interceptors • Check: – Piping inlets, baffles and outlets – Temperature at inlet, chambers and outlets
Traps • Check: – Inlets, outlets – Presences of baffles – Mechanical or automatic GCDs (example: Big Dippers) • Screens • Wiper blades and trough • Timers set correctly • Plugged into wall outlet
Grease Trap with & without Baffle
Old GCD without baffle
New GCD with baffle
Big Dippers Require More FSE Staff Maintenance
Maintenance Log • GCD Cleaning Receipts or Log of Cleaning Events: – Shall be readily available for inspector to review – Shall be available for at least 3 years
BMPs • Disposal of food waste to trash • Dry wiping of pots, pans and dishes prior to rinsing and washing
BMPs Continued â&#x20AC;˘ Presence of screens in drains and frequent cleaning of the screens
BMPs Continued â&#x20AC;˘ Safe and proper procedure for disposing of FOG, especially used fryer oil
BMPs Continued • • • •
Mop wastewater disposal location Employee training Dry method for spill clean up of FOG Posters displayed
BMPs Continued â&#x20AC;˘ Proper surface cleaning procedures: â&#x20AC;&#x201C; Sweep up all messes first, next use a wet mop only, without chemicals, to clean up any remaining soiled messes. If all messes and spills have been cleaned, a minimal amount of water can be used to rinse surface areas and allowed to drain to the storm drain system.
Stormwater Issues • Tallow Bins • Garbage and Recycle Areas • Washing Kitchen Equipment Outside • Dumping Soapy Waste Water
Tallow Bin Condition â&#x20AC;˘ Tallow bins shall be kept clean, covered with lids and free from excessive FOG and debris.
Drainage Fixtures â&#x20AC;˘ Survey the grease generating drainage fixtures, non grease generating drainage fixtures and hot discharge fixtures â&#x20AC;˘ Use of tracing dye to confirm connections to GCDs or sanitary sewer if hard to visually identify
Distribution of Outreach Material • BAPPG Poster – Available in 5 languages
• Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) Package – Includes letter, list of top ten cleaning practices and stormwater pollution prevention poster
• FOG scrapers • “How to Clean a Grease Trap” (created by MRWPCA) poster for FSEs whose staff cleans their GCDs