March 31, 2005

                                                                                                Central Ohio Sierra Club

                                                                                                36 West Gay St, Ste 314

                                                                                                Columbus, OH  43215

Division of Sewerage and Drainage

Industrial Wastewater Pretreatment Section

1250 Fairwood Ave, Room 186; Columbus, OH  43210

FOG@columbus.gov                  DOSD@columbus.gov

 

COMMENTS ON PROPOSED NEW FATS, OILS, AND GREASE PROGRAM

GENERAL COMMENTS

-All changes should be incorporated in the Columbus City Code.  The mix of present proposals via Columbus City Code, Director’s Orders, and Rules and Regulations is confusing.

-The current pollutant discharge limit for FOG discharges is 200,000 micrograms per liter (Columbus City Code 1145.25).  We suggest lowering the discharge limit to 150,000 micrograms, as other cities have done, and enforcing the standard.

-There are many sources of FOG that are or may not be covered by the new initiative.  Discharge limits should cover all significant sources of FOG:  Schools (public and private), Hotels, Catering Services, Bars that prepare food; Grocery Stores that package meat or food; Butchers; Delis; Hospitals with cafeterias; Office Buildings with cafeterias; even preventing companies that clean private service lines from discharging FOG into the public sewers.  Definitions are not clear.

-Hardened FOG deposits should be kept out of the system permanently by being burned or taken to a biofuel facility.  FOG should not be returned to the system through dumping at the truck waste facility at Berliner.

 

SPECIFIC COMMENTS

Updating of Columbus City Code 1145.05 to require outside interceptors for all new or remodeled food service establishments.

            -The updating of Columbus City Code 1145.05, Sewer Design and Construction Specifications, to require outside grease separators should apply to all significant sources of FOG, see above.

            -Is it possible to require a design that would permit exterior sampling by inspectors in order to monitor FOG and other pollutant discharges?

 

Director’s Rule to require food service establishments to develop and implement a Best Management Plan (BMP) to handle grease wastes.  

            -This change should be explicitly written into the City Code.

            - A requirement for BMPS should apply to all significant sources of FOG, see above.

 

Director’s Rule establishing a minimum cost recovery charge of $1500 per typical blockage incident attributed to the improper disposal of grease. 

            -This change should be explicitly written into the City Code.

            -The change as proposed in Rules and Regulations No. 04-01 Cost Recovery for Sewer Blockages would apply cost recovery charges anytime a sewer blockage can be confirmed, not just with fats, oils, and grease.  Such a broad change should be in the City Code.