North Carolina Pretreatment Consortium, Inc.
July 18, 2000
Mr. Bill Reid
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Reference: Comments on HB 1160 related to sanitary sewer overflows
Dear Mr. Reid:
Thank you for requesting, from the North Carolina Pretreatment Consortium, Inc., (NCPC) comments
on what we feel are pertinent issues related to sanitary sewer overflows in North Carolina. We
appreciate the opportunity to express our views and opinions from the realm and perspective of
industrial waste and pretreatment objectives, as related to the topics addressed in HB 1160.
The North Carolina Pretreatment Consortium, Inc. is comprised of individuals employed by
municipalities, sewer authorities, districts and commissions from areas across the state working in the
field of industrial waste and pretreatment. Industrial waste is our primary area of work, although we
are strategically involved in efforts and undertakings that address inflow and infiltration (I&I) and fats,
oils, and greases (FOG) contributions to sanitary sewer collection systems. To that end, the comments
presented herein are directed. These opinions and suggestions were collected and compiled from eight
pretreatment program coordinators from eastern, central, and western areas of the state. For the
purpose of brevity, the term municipality, used herein, denotes sewer authorities, districts, towns,
cities, sewer commissions, and other sewer utility agencies.
More Frequent Inspections by DENR Staff
The NCPC feels that more inspections by the DWQ of sanitary sewer collection systems and treatment
works will not reduce the frequency and severity of sanitary sewer overflows (SSOs). Increasing
inspections of these systems will unnecessarily tax that agency’s staff and resources further. This
effort would be better administered at the local level. Our internal surveys indicate that between 40 –
60% of SSOs are caused by grease blockages and/or I&I problems. The NCPC feels that most of the
municipalities themselves know where problem areas in the collection system exist and have targeted
those areas for increased scrutiny, inspections, and action. The NCPC attempts to educate its members
of the obligations and requirements of the Clean Water Act of 1999. We are actively involved with the
Division of Pollution Prevention and Environmental Assistance to that end.
P. O. Box 40117 Raleigh, North Carolina 27629-0117
Mr. Bill Reid
July 18, 2000
Page 2
Unpermitted Discharges and Violations of Permitted Discharges
As mentioned above, FOG contributions are acknowledged to be a major contributor of SSOs.
Also contributing to the SSO problem are broken sewer mains, root intrusion, misaligned pipe
sections, and vandalism. As you know, collection system infrastructure is costly to install and
maintain. At approximately $100 per foot, installed sanitary sewer collection pipe cost, the outlay of
monies to hire an adequately trained city/town inspector to assure correct sewer collection system
installation would yield a positive cost/benefit outcome. However, many small towns and
municipalities cannot afford to establish such a position. State funding would assist towards that
objective.
The NCPC would welcome DENR input on co-developing guidelines for technically rational and
defensible FOG control programs. Such guidelines, operating in conjunction with implementing best
management practices (BMP) should reduce the incidence of unpermitted discharges occurring from
FOG blockages. Establishing permits and technically based rational numeric limits for FOG
contributors is difficult but not impossible.
Recommendations of the North Carolina Pretreatment Consortium
∙ The formation of a committee, consisting of municipal pretreatment personnel, collection system
operators, DWQ staff, plumbing and building inspectors, (both state and local), and state public health
officials needs to be created to review adequacy of current rules and propose development of alternate
guidelines.
∙ Food grinders are just a convenience. The product they produce, ground up pieces of food, are a
major contributor of FOG. State plumbing codes, acknowledging the above stated condition, prohibit
food grinder connections to grease interceptors. Yet, in addition to particulate generation, significant
amounts of oil and grease adhere to these particles, which then are flushed into the sanitary sewer
collection system. These devices should not be allowed to be installed, and existing ones need to be
removed. Scraping of food wastes from ware into solid waste receptacles, prior to washing is a best
management strategy and should be required.
∙ A surveyed NCPC member believes that legislation should be passed requiring a certain amount of
money be spent on collection system maintenance every year or a sinking fund be established for
wholesale replacement at the end of a sewer line’s design life.
∙ Adopt, as a rule, the Best Management Practices currently being promoted and distributed by the
DPPEA, NC Restaurant Association, NC Pretreatment Consortium, and Department of Health
Services.
∙ Recycling of FOG needs to be encouraged, rather than continuing more and more land application
sites.
Mr. Bill Reid
July 18, 2000
Page 3
∙ Revision of the North Carolina plumbing codes to reflect language that designates the local plumbing
inspector and persons deemed appropriate by the local municipality to serve as responsible agents
charged with task of determining size and type of grease interceptor to be installed in a food
preparation or serving facility. This determination should be a cooperative undertaking involving
qualified water quality (pretreatment, Public Works and/or Utilities, or equivalent) staff, and should
demonstrate accepted engineering and hydraulic principals. USEPA has sizing criteria for grease
traps or interceptors that is technically defensible. This procedure and others that employ defensible
technical strategies should be required.
It should be noted that these suggestions and proposals are individual’s opinions and as such do not
necessarily reflect the opinions of their respective employers.
Commentors that contributed in this report are:
Jim Gwyn: City of High Point
Dolores Bradshaw: City of Wilmington
Leon Holt: Town of Cary
John Gibson: Town of Wake Forest
Carol Rogers: City of Statesville
Jon Van Hoff and Neal Klimek: Buncombe County Metropolitan Sewer District
Jill Monday: City of Salisbury
Tim Woody: Town of Garner
All are directly involved at their respective jurisdiction in industrial pretreatment as coordinators,
inspectors, or administrators.
Thank you again for the opportunity to address the issue of sanitary sewer overflows in North
Carolina. If you have questions or need further information regarding this matter, please feel free to
contact me at (919) 462-3871.
Yours truly,
Leon M. Holt
State Chairman
Cc: Commentors
Gary Hunt, DENR, Director NCPPEA
Tom Poe, DENR, DWQ, Industrial Pretreatment Program