LEGISLATIVE REPORT                                     

October 2008

 

 

Vice-President Legislative Report

John Perales

            Well it's time for another ASPE convention I do hope all the members of The Orange County Chapter get to come out to the EPE.  I could not tell you when the next time this is event will be in the Southern California region.  So please come out and enjoy all the festivities.   I will include in next month's newsletter a summary of the results of the by-law and officer elections as well as a few stories of the fun we are having in the evenings.

            I thought I would use this section of my article to post up the results and some discussions of the IAPMO vote to repeal the FOG sizing in the new code.  This vote went about 200 - 4  in favor of retaining the new sizing method used in the 2006 UPC.  A group of manufactures are trying to revert to using the 'Meals per Hour' way of sizing Gravity Grease Interceptors.   Here are some arguments for the continued use of table 10-3 in the 2006 UPC, used to make the arguments which secured the overwhelming victory in the last IAPMO meeting. 

 

Debunking the Arguments Supporting Chapter 10 - Item #152 Sizing of Gravity Grease Interceptors (GGIs)      

I. Argument #1 - DFU’s do not equal GPMs

A.    If this were true, then Table 7-5 and Hunter’s curve would be flawed since DFUs are equated to flow capacity (GPMs) in order to determine pipe sizes. While there may not be a singular value equivalent of GPM per DFU, there is a range that varies with the number of fixture units and associated diversity that allows the correlation between fixture units, GPM, and the associated pipe size for both water and waste. This correlation has worked flawlessly for over 80 years.

B.     The original Table 10-3 developed during the 2005 FOG Task Group meetings was an expanded table that showed GPMs (below).  This expanded table was a significant element of the substantiation.  The 2005 FOG Task Group chose to shrink the final table because the expanded table was not necessary for the users of the Code.  The 2007 FOG Task Group supported this as well. If the Technical Committee prefers the expanded Table, it could be used to replace the abbreviated Table 10-3 presently in the 2006 UPC. 

 

  Table 10-3 Expanded

GRAVITY GREASE INTERCEPTOR SIZING

DFUs

Pipe Size

Slope

Flow (1)

Calculated Size (2)

Nominal Size (3)

8

2"

2%

10 gpm

300 gallons

500 gallons

35

3"

2%

29 gpm

870 gallons

1,000 gallons

172

4"

1%

44 gpm

1,320 gallons

1,500 gallons

216

4"

2%

62 gpm

1,860 gallons

2.000 gallons

  342 

5"

1%

80 gpm

2,400 gallons

3,000 gallons 

  428 

5"

2%

120 gpm

3,600 gallons

4,000 gallons 

  576 

6"

1%

140 gpm

4,200 gallons

5,000 gallons 

  720 

6"

2%

190 gpm

5,700 gallons

7,500 gallons 

 

Notes:

(1) Based on UPC “Useful Tables” for flow in half-full pipes (ref: Mohinder Nayyar Piping Handbook)

(2) Based on 30 minutes retention time (ref:  Metcalf and Eddy 3rd Edition, Small and Decentralized Wastewater Management Systems, 1998) 

(3) Rounded up to nominal capacity

II.  Argument #2 - Full pipe flow should be used instead of half-full pipe flow to determine main drain flow into the interceptor

A.    Since GGIs are centrally located (i.e., not connected to one fixture and not located in close proximity to the fixtures), the resultant flow that they carry represents a combination of all the connected fixtures. This combination has an inherent diversity that results in a maximum of half-full pipes that is the basis of Table 7-5.

B.     The GGI never sees the momentary full pipe flow that can sometimes be experienced immediately downstream of an individual fixture when it is drained at full volume.

C.     Half-full pipe flow is a very conservative assumption based on the actual flows experienced at restaurants (Ref:  North Carolina restaurant flow study data attached)

III. Argument #3 - Item #152 GGI fixture capacity sizing example

A.    The example fixture with a volume of 44.9 gallons cannot produce 1,500 gallons in 30 minutes.  It will not remain full and it will not continue to flow after emptying its contained volume. The flow rate after draining its volume would be the flow rate of the faucet, if left running, which is generally 2.2 GPM. So the 30 minute flow volume produced by this one fixture would be approximately:

44.9 gallons + (2.2 GPM x 29 minutes) = 110 gallons

IV. Argument #4 - Item #152 GGI sizing table “Bigger is Better”

A.    This would create serious problems related to over-sizing of GGIs.  Item #152 would result in most GGIs being 4,000 gallons or larger.  In fact, this would be worse than the old Appendix H sizing table which was the original problem that the 2005 FOG Task Group corrected.  Examples of problems directly related to over-sized GGIs are as follows:

a.       Low pH and sewer system corrosion

b.      Hydrogen sulfide generation due to septic conditions developing in the GGI

                                                              i.      Rotten Egg Odors

                                                            ii.      Dangerous (sometimes lethal) conditions for pumpers, plumbers, and sewer maintenance workers

c.       The larger the interceptor, the less likely it will be properly maintained

                                                              i.      Complaints from numerous pumpers/haulers and sewering agencies regarding unnecessarily large GGIs

 

 

 

V. Argument #5 – The November 29, 2007 FOG Task Group did not consist of balanced interests or expertise

In summary, the Task Group consisted of the following balance:

 

Hydromechanical GI / Grease Removal Device Reps                        6

Gravity Grease Interceptor Representatives                           4

Sewering Agency Representatives                                         3

Manufacturer - Other                                                              2         

Plumbing Engineers                                                                2

Code Consultant                                                                     1

Plumbing Inspector                                                                 1

IAPMO                                                                                               2

 

 

 

 

 

John Perales, VP Legislative