Oil & Grease and Your Sewer Use Ordinance

Controlling POTWPass-Through/InterferenceDue to Compatible Pollutants Jerald O. Thaler, P.E.Fishbeck, Thompson, Carr & Huber, Inc.

Elaine J. Venema, PE.Fleis & VandenBrink Engineering, Inc.

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Potential Industrial Discharge Effects

www.michigan.gov/deqGeneral ProhibitionFederal Pretreatment Regulations 40 CFR 403 and Michigan Part 23--Pretreatment Rules require that:Any nondomestic user introducing pollutants into a POTW may not cause pass-through or interference

www.michigan.gov/dgallery

Pass-through Discharge from a POTW that violates any NPDES permit requirement, including:Increase in magnitude of the violationIncrease in duration of the violation

InterferenceA users discharge that, alone or in combination with other user discharge(s), causes both of the following: Disruption of the POTWs operation, wastewater treatment, and/or sludge processing Pass-through or restriction of sludge disposal

Compatible Pollutants of Concern (POC)Pollutants which a POTW is typically designed to treat, and typically subject to extra-strength surcharges:5-day Biochemical Oxygen Demand (BOD5)Total Suspended Solids (TSS)Total Phosphorus (Total-P)Ammonia Nitrogen (Ammonia-N)

What about Fats, Oil & Grease?While generally considered a compatible POC, represents a special case:

Collection system cholesterolOne of the major causes of sewer blockage Requires control at the sourceOften excluded from extra-strength surcharge programC. Bellmore/City of Mount Clemens, MI

Common Nondomestic Dischargers of Compatible POC HospitalCommercial LaundryHauled Wastes (e.g., septage)Food ProcessingDairyBrewery/WineryRenderingLandfill Leachate

Agenda Control Options1 Treatment at the Source2 Treatment at POTW with Insufficient Capacity3 Treatment at POTW with Excess Capacity Questions and Discussion