FOG task force letter

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					                      North Carolina Pretreatment Consortium, Inc.
August 8, 2001

Mr. Bill Reid
Assistant Section Chief, Water Quality Section
Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617

Re: Recommendations for NC FOG Task Force

Dear Mr. Reid:

As you know, the NC FOG Task Force has been meeting for the last several months to develop a
guidance manual that promotes the concept of statewide consistency on issues relating to the
installation and operation of grease interceptors at food serving establishments. The group has
prepared a draft document that presents the work completed so far. The North Carolina Pretreatment
Consortium, Inc., a member of the Task Force, submits these comments regarding the proposals
brought forth in the draft document.

On July 17 and 31, 2001 members from the Eastern and Western Sections of the NC-PC met
respectively to discuss major portions of the FOG Task Force proposals. Unfortunately, requirements
for quorums were not met at either meeting, so no voting on decisions occurred. NC-PC members in
attendance did feel that the items below represent best practical technology that is effective,
rational, cost effective, and implementable. Said members therefore:

∙ Design standards for grease interceptors: Support of the concepts presented in the document

∙ Variance procedure for grease interceptor pump-out frequency: Support of the concepts presented in
the document.

∙ Sample collection procedures: Support of the concepts presented in the document.

∙ FOG analytical method differences: Support of the concepts presented in the document

∙ FOG numeric control mechanisms: With the following revisions, support of the concepts presented in
the document.
   Draft Document proposal – action levels, not numeric limits for FOG, expressed as hexane
extractable material - no recommended value proposed; each control authority would establish its own
value.
   NC – PC proposal – action level/numeric limit/performance goal/target: terms used
interchangeably, expressed as hexane extractable material – range: low of 150 mg/L, high of 200 mg/L

                            P. O. Box 40117 Raleigh, North Carolina 27629-0117
Mr. Bill Reid
August 8, 2001
Page 2




∙ Enforcement strategies: With the following revisions, support the concepts presented in the document

Draft Document proposal – three categories of violations; minor, intermediate, major. Tiered approach
to enforcement; Tiers I – VI (see table below)

                            Tier I – No Civil        Tier IV - $300.00;
                          Penalty; variety of         variety of written
                             written notices         notices and actions
                        Tier II - $50.00; variety     Tier V - $500.00;
                         of written notices and       variety of written
                                  actions            notices and actions
                           Tier III - $150.00;        Tier VI - $1000;
                           variety of written         variety of written
                          notices and actions        notices and actions


NC-PC proposal (revisions) – three categories of violations; minor, intermediate, major. Tiered
approach with ranges of civil penalties to enforcement; Tiers I – VI (see table below)


                           Tier I $0 - $100;        Tier IV $300 - $500;
                           variety of written         variety of written
                                notices              notices and actions
                         Tier II $100 - $150;       Tier V $500 - $1000;
                           variety of written       variety of notices and
                          notices and actions              actions
                         Tier III $150 - $300;      Tier VI $1000 - SUO
                           variety of written          limit; variety of
                          notices and actions        written notices and
                                                           actions

The NC-PC members that attended the regional meetings and reviewed the draft document appreciate
the effort and work undertaken by the FOG Task Force members and support the concept of state-wide
FOG consistency, while retaining municipal autonomy. These individuals, pretreatment professionals
representing many collective years of pretreatment experience, seek support from DENR on the
recommendations presented herein relating to the FOG Task Force guidance document.
Mr. Bill Reid
August 9, 2001
Page 2



Should you have any questions regarding the FOG Task Force document and the NC-PC
recommendations, please feel free to contact Leon Holt, Utility Pretreatment Coordinator for the Town
of Cary at (919) 462-3871.

With best regards,

Scott Pickard
State Chairman

Leon Holt
Past State Chairman


Cc/ Executive Committee, NC Pretreatment Consortium, Inc.




Sincerely,



Leon M. Holt
State Chairman, 1999-2000

Cc: Scott Pickard, 2001 State Chair
    John Gibson, Wake Forest, State Secretary/Treasurer
    Jill Monday, Salisbury, Western Division Chair
    Lee Kearson, Morganton, Western Division Secretary/Treasurer
    Monica Hayes, Fayetteville PWC, Eastern Division Chair
    Julie Fogleman, Hillsborough, Eastern Division Secretary/Treasurer

				
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