Defending Your Collection System from FROG: Strength in Numbers

We’ve talked previously on the blog about planning for sewer overflows and managing your assets appropriately to prevent catastrophes from happening rather than just responding when they do. Another significant component of a proactive approach to collection system management, though, is managing the problematic substances that get poured into our drains, namely fats, rags, oil, and grease (FROG).

Combined sewer overflows (CSOs) and sanitary sewer overflows (SSOs) pose a serious risk to public health by releasing untreated wastewater into the environment, and most of these overflow events are caused by some sort of system blockage. The EPA estimates that fats, oils, and grease (FOG) alone are the most common source of this, accounting for 47% of the blockages that lead to overflow events. When you add to that the issues caused by flushing items that aren’t truly “flushable” like nonwoven wipes or rags, you get an even bigger problem: FROG. While communities across the country are dealing with the challenges of keeping FROG out of their sewer systems, the problems caused by these substances can be even more pronounced in cities with aging or overstrained infrastructure.

Increased awareness leads to increased action

FOG, which generally comes from used cooking oil and waste grease, that’s released into sewers cools down, congeals, and builds up inside pipes, wastewater pump stations, and treatment facilities, which not only leads to blockages but can also encourage the deterioration of wastewater equipment and rodent colonization. Similarly, “flushable” wipes do not break down like standard toilet paper and can wreak havoc on collection systems. In a recent example, a community spent $30,000 and a weeks’ worth of time flushing a 24-inch pipe that was 90% blocked with grease. That same community authorized 100 hours of labor time in a single calendar year for unclogging wipes from a neighborhood pump station. Unfortunately, though, if you don’t know about the problem, you can’t help fix it, and this topic isn’t one that’s commonly discussed at dinner parties (for obvious reasons).

There are lots of practical measures that the biggest producers of FOG, namely restaurants and other food service establishments, can take to reduce their impact on their collection system, like wiping plates clean into the trash before rinsing and properly maintaining internal and external grease traps. The other FOG contributors are residential dwellings that collectively can be just as damaging to the system. The key is to educate users of best FOG management practices and inform them of how their actions have a direct impact on their water and sewer rates. Without creating widespread public awareness, there’s very little chance they’ll take the necessary preventative steps. More and more cities and towns are taking regulatory action to limit the amount of FOG entering their collection systems, and developing a program with specific requirements for installing FOG control equipment along with enforcement procedures for non-compliant facilities is important. However, the programs that will be the most successful are those that incorporate and promote a significant public education and outreach component while collaborating across departmental lines to tackle the issue.

Gaining traction through a collective approach

Developing a program to reduce FROG often requires the cooperation of several different municipal departments. For instance, the Board of Health might be responsible for administering an actual ordinance but would delegate various responsibilities to the Water and Sewer Department and Inspectional Services Department to carry out the program. These two departments would take ownership of building inspections, training, sewer infrastructure maintenance, and abatement activities, while the food inspector, who is also involved in this process, would need to notify food service establishments of the applicable pretreatment requirements and carry out periodic inspections of these facilities. Additionally, the Plumbing Inspector can be a key team contributor as they typically have the most knowledge of grease trap operation, size and best management practices.

These key players may not have necessarily worked together before on such a collaborative effort. To help gain everyone’s buy-in, several interdepartmental meetings will likely need to take place over the course of the program development period to discuss how the program should look and to help define roles and responsibilities. These discussions are critical in gaining the valuable perspective of each different department and ensuring the program being developed would work for all involved.

In addition to getting the right departments on board, you’ll also need to engage the community in working toward the common goal of FROG reduction, which is why a substantial public outreach program is also a fundamental part of a successful program. Think beyond the traditional methods of getting information out (like press releases and printed materials) to tactics that can provide more context and offer the opportunity for feedback. Informational training sessions can be helpful in walking food service establishment owners through any permitting process that’s part of your program, as well as answering questions about the regulatory requirements. Spread the word using social media and through a dedicated page on your city’s website that provides basic facts about FROG and how to reduce it.

It takes a community to create a FROG problem, and it takes a community to fix one as well. Water and sewer departments can’t take on this issue alone, so dedicate time to gaining an understanding of where and how your residents get information and develop a plan for communicating your message about protecting your collection system from these destructive substances. The time will be well worth it in your continuing efforts to take a proactive approach to managing your collection system.

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Justin deMello Client Manager Water

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