Fats, Oils and Grease Licensing

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Fats, Oils and Grease Licensing Enforcement in
Cork County Council

• Alan Costello
• A/Scientist
• Wastewater Laboratory
• Cork County Council

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FOG Problems in WWTPs

• FOG (Now referred to as Oils and Greases)
• CnH2n1COOH
• 50-100mg/l in untreated wastewater, 3040 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
• 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

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Local Government (Water Pollution) Act 1977

• Section 16
• A person.. shall notdischarge 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).

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• 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
  sewagelack 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.

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Water Services Act 2007

• Section 63 (not yet commenced-will replace S16
  of the LG(WP)A 1977-1990)
• A personshall notdischarge 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.

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Cork County Council FOG Programme

• 1st FSE FOG License issued in 2005
• Number of licenses issued by Cork County
  Council
• 143 FOG licenses issued
• 19 FOG licences issued in Kinsale
• 15 FOG licenses issued in Midleton
• FOG programme currently under review

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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.

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FOG Licence Application Information Required

• Applicant details, company reg. no. etc.
• Details of activity
• Usage of premises ( employees, hours of business
  etc.)
• Drawings showing
• Layout
• Sewer connection
• FOG producing equipment
• 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

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FOG License Requirements

• Adequately sized GRU
• Passive retention/active grease removal to I.S
  E.N 1825
• Concentration should not exceed 25mg/l or
• 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
• 50mg/l FOG
• 1000mg/l BOD
• Annual Licence Fee ( 100/year)

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FOG Licence Application Form issues

• Applicant unable to identify sewer connection
• no idea, assume its outside the shop somewhere
• Poor / absent drawings
• Sections left completely blank
• Im too stupid to fill it in
• Improvised forms used
• No analysis of effluent
• Who is the owner/operator?
• Applicant doesnt exist
• To whom do we issue the licence?
• Cost of analysis
• Application fee is 380.42 irrespective of size
  of operation

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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
• Warning letter
• S.16 (1) WPA Prosecution
• S.16(13) WPA Notice

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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

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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 dont know what else is
  connected to that pipe
• Unlikely to obtain a sample given low volumes of
  discharge
• Frequent adjournments

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Enforcement Options

• Try to have enough circumstantial evidence to
  persuade an individual to plead include
• Photographs of dishes in sinks
• Dye test from sink
• Sample if possible
• Camera survey of sewer
• 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
• 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?

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-Thank You-