HomeMy WebLinkAboutCOM 0800.008 2010-2012 o° Ni�7 Phone: (808) 961-8263
BRITTANY SMART
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ax: (808) 961-8912
Councilmember • `�%"
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Hawai`i County Council •
District 6
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Upper Puna, Ka`u, South Kona ` .tE oF'H'�='
Hawaii County Council
County of Hawai`i
25 Aupuni Street ;C)
Hilo,Hawaii 96720
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DATE: October 23, 2012
TO: Environmental Management Commissioners ti
FROM: Councilmember Brittany Smart
RE: Bill 286 D2, Relating to disposal of commercial UCO & FOG wastes
Testimony in Support & Response to DEM Comment
Aloha Commissioners:
Please consider the following as my testimony in support of Bill 286 Draft 2, and to request a
positive recommendation to the County Council for approval. In addition, I would like to respond
to comments and concerns DEM has outlined in their communication dated September 18, 2012
to the Council, which I believe has been provided for EM Commission review. I am also
providing copies of email communications between the Department and myself regarding this
issue.
First, I would like to thank the Department for their input earlier in the process of drafting this bill.
Our original draft, prior to introduction for full Council discussion, was based off City and County
of Honoluluiordinances. After receiving feedback from DEM and the Prosecuting Attorney's
Office, we scrapped our original draft entirely and simplified the changes immensely, which
resulted in the version you see before you today.
When Bill 286 Draft 1 first came up on the Council's Environmental Management Committee
agenda, the Department was supportive of the bill and it moved forward with a positive
recommendation, with minor changes based on DEM suggestions. I had no indication that the
Department changed their mind until the day before Bill 286 D2 was to be heard at full Council
at first reading. This change of heart came after working on this issue for a number of months.
To say I was disappointed is an extreme understatement.
I strongly believe that the County, most specifically the Department of Environmental
Management, who is responsible for managing our waste streams, should be leading the charge
in appropriate waste stream management, especially when viable landfill alternatives are
available locally. Historically, the Department has taken strong stances on problematic waste
streams without viable options in place, most notably the banning of tires from the landfill. In the
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Serving the Interests of the People of Our Island
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case of UCO & FOGs, the waste stream can be converted to valuable commodities in a variety
of ways, most notably as a fuel source.
The issue before you today is very simple. We have an industry in place to handle a waste
stream and convert it in to a valuable commodity. Are we going to support that effort? Policies in
the past have indicated we would, through the development of the ISWMP and the adoption of a
Zero Waste plan.
CONCERNS
1. Lack of State Dept. of Health Permitted Facilities and capacity on island to convert
commercial UCO waste or commercial FOG waste, or both into biodiesel or renewable fuel,
compost, or other marketable product. Recent information indicates that there is one facility
pursuing a permit to convert both commercial UCO and FOG waste but this has not
happened yet. In addition, there is one facility on this island that is permitted to receive only
UCO from commercial sources and process it into biodiesel though their capacity is limited.
a. DEM began looking at this issue a number of years ago. Through a grant from
DBEDT, Chris Chin-Chance and I were tasked with conducting a Used Cooking Oil
Study. The purpose of the study was to establish how much UCO was being
generated on-island, to the best extent possible, to determine if biodiesel
production was feasible. Additionally, adjacent to the lined composting facility the
County constructed at the WHSL is a I acre graded and fenced lot intended to be
used for UCO collection and biodiesel production. The County put out an RFP
regarding composting and UCO collection, of which an award was made.
Unfortunately, due to a number of reasons, the County has yet to move forward (
with this plan and the facility has remained built but unused. To a large extent, the
basis of DEM's concern is self-made.
b. DEM's assuming that "biodiesel, compost, or other marketable products"are the
only means of using UCO. They obtained this language in the first drafts of the bill,
which got scrapped primarily on the specific use of this language. There are a
number of people with pig farms or backyard biodiesel do-it-yourselfers that pick
up UCO directly from restaurants. Instead of prohibiting and possibly penalizing
these efforts, which I believe would be sending the wrong message, we shifted our
focus to banning the UCO from the landfill rather than dictating all of the places it
was allowed to be taken.
2. Absence of competition due to a very limited number of facilities who are permitted to
process commercial UCO and FOGs waste. This can be perceived as the County favoring a
particular business.
a. This is a non-issue. In fact, the same could be viewed as true if the County
continues to support the current practice of allowing Waste Management to collect
special handling fees.
b. This is inaccurate. Businesses can obtain permits to pick up UCO & FOGs waste
which can then be transported to recycling facilities. There are a variety of
industries that can handle this waste stream, including, but not limited to,
backyard biodiesel do-it-yourselfers, pig farmers, commercial biodiesel
production, and use as boiler or bunker fuel.
c. Please view attached email from Hana Steel, Maui County Recycling Coordinator
on September 18 (please note: these comments are her personal professional
opinion, and should not be viewed as directly representing the Maui County DEM
or the administration). To quote,
"Re: the questions of competition- I'm always happy when I have one facility to
handle a problem material that we (government) have had to deal with-so if you
want the private sector to take over the management of a problem material, if you
expect two businesses to survive, you may be disappointed. There may not
enough material for two businesses on an island. If there is, don't worry,
competition will rise up later.
So...my philosophy has been that if I want the private sector to take over the
management of a problem material and a business is positioned to do so, get
behind them and PUSH!"
3. Lack of a facility for the disposal of unwanted and non-recyclable commercial UCO waste
and FOG waste prior to conversion once the County Landfill is not allowed to accept this
material. Currently, the West Hawaii Sanitary Landfill (WHSL) is the only facility permitted to
accept FOGs for disposal.
a. UCO is currently recycled in-state and has been for quite some time. Most other
diversion programs within the County have an end point in the mainland or even
China. As pointed out earlier, the Big Island does have various ways UCO is being
reused. In addition, the largest biodiesel production facility has already had its
grand opening and plant production is scheduled to begin by the end of the year
b. The Commission is free to make recommendations to the Council. If the
Commission feels it is more prudent to have an implementation date be upon plant
production, rather than upon approval, we would view that as valuable feedback
and have no problem considering such a suggestion, or any other suggestion the
commission may make. Per Big Island Biodiesel, plant production is scheduled to
commence by the end of the year.
4. Haulers and generators of UCO waste and FOG waste may not have been informed of this
legislation that prohibits commercial UCO and FOGs waste to the County Landfill. This could
have an impact on their business practices if they need to consider disposal/recycling
alternatives.
a. Council agendas are public record, must comply with the Sunshine Law, and are
noticed in the newspaper, as are the Commission meetings. This item was
delayed at least once at Council due to technical difficulties, giving it more
chances for input than is generally the case for bills and resolutions before the
Council. Similarly, this Commission meeting is another opportunity not usually
afforded to other bills and resolutions before the Council.
b. Those in the industry should reasonably know that the County has been working
on increasing recycling efforts with various waste streams through the previously
mentioned ISWMP, Zero Waste Plan, and Landfill Diversion Programs.
POTENTIAL PROBLEMS
1. To DEM's knowledge, there are no facilities on the West side of the island pursuing the
status of a "permitted recycling facility." The limited location, capacity, and the availability of
this service for users on both sides of the island could result in increased transportation
costs for haulers.
a.. Again, the language "permitted recycling facility"was taken from the original draft
submitted to the Department for review and has since been struck. To reiterate, we
are not dictating all of the appropriate places UCO can be disposed, but rather
banning it from the one place we don't want it— the landfill.
b. As previously mentioned, the County invested considerable taxpayer dollars to
construct a facility at the WHSL, which has been sitting empty and unused. If this
is a serious concern of DEM, it would seem prudent to put the use of the facility
designated for biodiesel out to RFP. This may come at no cost to the County or
may even generate some revenue if'proposals offer lease payments for the use of
the site. This avenue would have the added benefit of not directing haulers to an
entirely new location, but rather to a different section of the same facility.
2. Discontinuing the solidification operation for unwanted and non-recyclable commercial UCO
waste and FOG waste at the (WHSL) may result in direct dumping of UCO and FOG waste (
into the County landfill and transfer stations.
a. Ensure all federal, state, and county laws are enforced. Transfer Station
Attendants, landfill operations staff, and Waste Management staff are responsible
for doing just this. If this were truly a point of concern, direct dumping of UCO and
FOGs waste in to the County landfill and transfer stations would be done now to
avoid paying tipping or special handling fees.
b. Unwanted or non-recyclable commercial UCO and FOGs waste is no longer a
concern with the biodiesel facility in Shipman.
3. Pursuant to current County Code, the County Wastewater Treatment Plants do not accept
FOG waste from haulers. The options for the haulers are to bring this waste to the
solidification operation at the WHSL. Discontinuing the solidification operation may likely
result in illegal dumping.
a. Again, County staff or contractors need to do their job regarding enforcement of all
laws. If this is such a concern, perhaps retraining or disciplinary action against
those unable to perform their job duties is warranted.
DEM RECOMMENDATIONS
1. The legislative branch should contact the affected haulers of UCO and FOG waste to see
how this legislation will affect their activities and businesses and provide a report of findings.
a. As mentioned above, all agendas are a matter of public record with numerous
opportunities to participate in the process. If DEM feels further outreach is needed,
I would encourage them to do so.
b. The UCO study final report provides the findings DEM is requesting. The study
should be available for public review.
2. Wait until additional permitted recycling facilities capable of processing both UCO and FOGs
are established on both sides of the island before prohibiting UCO and FOG waste drop-off
at the WHSL.
a. Unnecessary; however, as stated above, should the Commission wish to
recommend a delayed implementation upon biodiesel plant production startup, I
would be more than happy to consider that. Big Island Biodiesel anticipates
production by the end of the year.
3. Request input from the Environmental Management Commission.
a. Done.
4. Consider separate legislation for UCO and FOGs as they are different commodities and
•
have different permit requirements when it comes to source, collection, and processing
parameters. Based on current information, the volume of UCO entering the landfill is minimal
and the volume of FOGs is much greater.
a. Unnecessary. To reiterate, this legislation is only dealing with banning UCO and
FOGs from the landfill. Any permits will be the responsibility of the business or
receiving entity. Whether they are separate commodities or not is irrelevant as we
are adding both to the "prohibited materials"section of the code. To the extent
necessary, we are adding definitions clarifying what the terms mean.
5. Consider legislation to include other wastes that would have a greater impact on our island
like paper, green waste, &food waste.
a. Should the Commission concur with this recommendation, I would be more than
happy to do this. My deadline for getting items on to the Council agenda is October
23, 2012. I wish DEM had indicated they were interested in such a measure much
earlier than at this point in my term, but I will do the best I can with the limited
amount of time left.
b. While I fully support the concept, I would hope that a comprehensive composting
program or other recycling program be instituted on-island prior to taking such
action. At this point in time, the County has failed to implement a composting
program despite repeated RFPs and the majority of paper waste is shipped off
island to be handled at a MRF. Using the Hilo "Sort Station"as a MRF would be
ideal in ensuring these materials are captured and handled appropriately. Putting
the "Sort Station"out to RFP could, similar to the comment above regarding the
WHSL UCO receiving bays, generate revenue for the County while being more
responsible in appropriately managing our waste streams.
NOTICE TO HAULERS
'o•;,'' � Phone: (808) 961-8263
BRITTANY SMART :' • :,
� Fax: (808) 961-8912
Councilmember •t;�/ ;t;
-•: � bsmart @co.hawaii.hi.us
Hawai`i County Council ys�r_
District 6 ,.' •
Upper Puna, Ka Ti, South Kona •j •of N►��
Hawaii County Council
County of Hawai`i
25 Aupuni Street
Hilo,Hawaii 96720
DATE: October 25, 2012
TO: All County of Hawaii Pumping Contractors
Aloha,
The Hawai`i County Council is considering prohibiting commercial used cooking oil(UCO)waste and
commercial fats,oils, and grease(FOG)waste from entering the County landfill. There is a new facility that
will open by the end of this year to take this waste residue(from all parts of the island)and turn it into bio-fuel
and other useful products;however,this is in addition to the several alternatives already existing.
Included is a copy of the upcoming Bill 286,Draft 2,relating to disposal of UCO waste and commercial
FOGs.
Please consider providing testimony on this matter at the County Council meeting November 9,2012.
The Council is scheduled to meet at the Hilo County Council Chambers(25 Aupuni Street, Hilo,HI 96720) at
9:00AM. Oral public testimony can be given at the Hilo,Pahoa, West Hawai`i Civic Center, and the Waimea
Council office.
• Oral Public Testimony: Oral public testimony is heard at the beginning of the Council meeting for
items on the agenda. Oral public testimony is limited to three (3)minutes per agenda item.
• Written Public Testimony: The deadline for submission of written public testimony is 24 business
hours prior to the scheduled meeting day. The Office of the County Clerk will accept receipt of your
written public testimony by mail to the Office of the County Clerk at 25 Aupuni Street, Hilo, HI
96720, by facsimile to(808)961-8912 or by e-mail to counciltestimony(a,co.hawaii.hi.us. Please
submit separate written public testimony for each agenda item.
• Written Public Testimony Submitted Past Deadline: If you miss the deadline for written public
testimony,the Office of the County Clerk will accept your written public testimony at the Council
meeting. When submitting written public testimony at a Council meeting, please see a Council
Services staff person stationed at the front entrance of the Council room and provide them with your
written public testimony. The Office of the County Clerk advises that you bring fourteen(14)copies
of the written public testimony to expedite distribution to the Council members during the meeting.
Mahalo,
BS:jk
Att.
Serving the Interests of the People of Our Island
Hawaii County is an Equal Opportunity Provider and Employer
NOTIFICATION LETTER SENT TO FOLLOWING PUMPERS 10/25/2012:
AC Pumping Service
KHL Grease Disposal Services
Sewer Solutions
Aloha Pumping Service
Bob's Pumping Service
B and B Pumping Service
Kamaaina Pumping
Kona Lua Inc.
PSC Industrial Services Group
Rooter-Man
CORRESPONDENCE
=1lll comments to Bill 286 (Draft 2):
Beck, Dora <dbeck @co.hawaii.hi.us> Tue, Sep 18, 2012 at 8:43 AM
To: Councilmember Brittany Smart <hccdistrict6 @gmail.com>
Cc: "Henricks, Jon" <jenricks @co.hawaii.hi.us>, "Ho, Nelson" <nho @co.hawaii.hi.us>, "Henry, Sharron"
<shenry@co.hawaii.hi.us>, "Takaba, Bill" <wtakaba @co.hawaii.hi.us>, "Goodale, Gregory" <ggoodale @co.hawaii.hi.us>,
"Peters, Linda" <Ipeters @co.hawaii.hi.us>, "Torigoe, Ivan" <itorigoe @co.hawaii.hi.us>
• Office of Councilmember Smart:
DEM understands the merits of this legislation and has been working with your office on providing information.
Recently, further discussion with the SWD/Recycling staff has resulted in some additional insights which leads to
concerns about this legislation that we feel should be brought to your attention. Below is a testimony that DEM will
be submitting this morning to Council which lays out DEM's position at this time and hopefully will provide a helpful
understanding of the issues. Thank you.
Information pertaining to available disposal and recycling options for commercial used cooking oil waste(UCO)and
-ommercial fats,oil and grease waste(FOGs)was recently brought to the Department of Environmental Management's
DEM)attention. This information has led to several items of concern which if not addressed will negatively impact the
County's current Solid Waste management practices and commercial businesses that either generate or haul UCO and FOGs
waste.
DEM understands the intent of the proposed code amendment prohibiting dumping of commercial cooking oil waste and
commercial FOGs at County Solid Waste facilities in order to promote recycling and reduce the materials entering the
landfills. However,DEM believes that the items of concern should be addressed through further discussion and thought
before final approval of this legislation.
Items of concern to DEM:
1. Lack of State Department of Health Permitted Facilities and capacity on this island to convert commercial UCO waste
or commercial FOG waste,or both into biodiesel or renewable fuel,compost or other marketable product. Recent
information indicates that there is one facility currently pursuing a permit to convert both commercial UCO and FOG
waste but this has not happened yet.In addition,there is one facility on this island that is permitted to receive only
UCO from commercial sources and process it into biodiesel though their permitted capacity is limited.
2. Absence of competition due to a very limited number of facilities who are permitted to process commercial UCO and
FOGs waste. This can be perceived as the County favoring a particular business.
3. Lack of a facility for the disposal of unwanted and non-recyclable commercial UCO waste and FOG waste prior to
conversion once the County Landfill is not allowed to accept this material. Currently,the West Hawai'i Sanitary
Landfill (WHSL)is the only facility permitted to accept FOGs for disposal.
4. Haulers and generators of UCO waste and FOG waste may not have been informed of this legislation that prohibits
commercial UCO and FOGs waste to the County Landfill. This could have an impact on their business practices if
they need to consider disposal/recycling alternatives.
Potential Problems that may arise as a result of this legislation:
1. To DEM's knowledge,there are no facilities on the West side of the island pursuing the status of a "permitted
recycling facility". The limited location,capacity and the availability of this service for users on both sides of the
island could result in increased transportation costs for haulers.
2. Discontinuing the solidification operation for unwanted and non-recyclable commercial UCO waste and FOG waste
at the(WHSL) may result in direct dumping of UCO and FOG waste into the County landfill and transfer stations.
3. Pursuant.to current County Code,the County Wastewater Treatment Plants do not accept FOG waste from haulers.
The options for the haulers are to bring this waste to the solidification operation at the WHSL. Discontinuing the
solidification operation may likely result in illegal dumping.
•
DEM Recommendation prior to finalizing this legislation:
1. The legislative branch should contact the affected haulers of UCO and FOG waste to see how this legislation will
affect their activities and business and provide a report of findings.
2. Wait until additional permitted recycling facilities capable of processing both UCO and FOGs are established on
both sides of the island before prohibiting UCO and FOG waste drop-off at the WHSL.
3. Request input from the Environmental Management Commission.
4. Consider separate legislation for UCO and FOGs as they are different commodities and have different permit
requirements when it comes to source, collection and processing parameters. Based on current information, the
volume of UCO entering the landfill is minimal and the volume of FOGs is much greater.
5. Consider legislation to include other wastes that would have a greater impact on our island like paper, green
waste & food waste.
G G
mdi
rat.:-scilrIIe mbe r Brittany Smart<t ccdistrict @ gn a Lc m>
DEM comments to Bill 286 (Draft 2):
Dora Beck <dbeck @co.hawaii.hi.us> Tue, Sep 18, 2012 at 9:06 PM
To: Councilmember Brittany Smart <hccdistrict6 @gmail.com>
Cc: "Henry, Sharron" <shenry@co.hawaii.hi.us>
Additional DEM comments if it helps:
As the HCC Chapter 20, Section 20-31 indicates as far as "prohibited
materials", materials are prohibited from the landfill unless it is mixed
with a bulking agent so that it solidifies so that it is no longer in liquid
form. Exception to this is hazardous wastes as defined in 40 CFR, Parts
257, 258 and 261. The WHSL is permitted to accept FOGs for disposal and as
mentioned previously, Waste Management Inc. whose Contract with the County
includes disposal of FOG's, receives FOGs and solidifies it prior to
disposal in the landfill.
FOG's is less than 0.5% of this island's solid waste. The highest volume of
materials that could be recycled but are entering the landfill are paper,
greenwaste and foodwaste. These materials are not banned from the landfill
and businesses that generate these materials are not required to recycle .
although many choose to do so. Commercial haulers are not prevented from
dumping paper, greenwaste or foodwaste into the landfills even when viable
recycling opportunities exist.
While Maui's model works for them, we cannot compare this island to Maui as
the demographics and physiographics of this island is unique. It is always
good to have the private sector help with manage a problem material (which
is not the true problem as pointed out earlier), but the existing permitted
facility only handles a limited quantity of UCO. And the other facility,
when permitted, supposedly will handle UCO and FOG. However, it is located
in East Hawaii which will require haulers to travel from west to east which
results in transportation and convenience issues for generators and haulers
on top of"perceived benefits" to selected recycling businesses.
We just want to make sure haulers and commercial businesses such as
restaurants and resorts are aware of this proposed legislation and are given
an opportunity provide input on how this will affect their businesses.
----Original Message----
From: Hana Steel [mailto:Hana.Steel @co.maui.hi.us]
Sent: Tuesday, September 18, 2012 12:08 PM .
To: HCC District 6
Cc: Beck, Dora
Subject: Re: Fwd: DEM comments to Bill 286 (Draft 2):
Aloha!
Commercial liquids that do not pass the paint filter test are not allowed in
EPA Permitted Subtitle "D" Landfills as of October 9, 1993, when RCRA was
promulgated.
FOG does not pass the paint filter test, so tell me, please, why is FOG
allowed to be land filled?
Re: the questions of competition- I'm always happy when I have one facility
to handle a problem material that we (government) have had to deal with- so
if you want the private sector to take over the management of a problem
material, if you expect two businesses to survive, you may be disappointed.
There may not enough material for two businesses on an island. If there is,
don't worry, competition will rise up later.
SO...my philosophy has been that if I want the private sector to take over
the management of a problem material and a business is positioned to do so,
get behind them and PUSH!
Call with questions, and best of luck to all-
Hana
Hana Steel, Ph.D., Recycling Coordinator
Solid Waste Division
Department of Environmental Management
County of Maui
200 South High Street
Wailuku, Hawaii 96793
hana.steel @co.maui.hi.us
ph: 808-270-7847
fax: 808-270-7843
County of Maui.
IT Security measures will reject attachments
larger than 11 MB, and will block or quarantine
high-risk file types in attachments.
(' C o u ncilor b eE Brittany Smart<hcc i>ttF c 6 ) jVma y.com
>
Follow-up to your question on the Grease Trap Legislation
Beck, Dora <dbeck @co.hawaii.hi.us> Tue, Sep 18, 2012 at 8:16 AM
To: Councilmember Brittany Smart <hccdistrict6 @gmail.com>
Cc: "Henricks, Jon" <jenrccks @co.hawaii.hi.us>, "Ho, Nelson" <nho @co.hawaii.hi.us>, "Henry, Sharron"
<shenry@co.hawaii.hi.us>, "Goodale, Gregory" <ggoodale @co.hawaii.hi.us>, "Peters, Linda" <Ipeters @co.hawaii.hi.us>
Office of Councilmember Smart:
This is a follow-up to two items listed at the bottom of the August 13, 2012 email correspondence below:
1. We are not finding any Special Waste Agreements. However, DEM will be notifying WMI of the upcoming
amendments to HCC, Chapter 20 specific to Section 20-40(c)which will affect their currently ongoing operations to
receive FOGs, solidify and dispose at the WHSL.
2. Last 3 years of UCO recycled and landfilled:
Fiscal Year UCO Recycled (tons) UCO & FOGs Landfilled at
WHSL**(tons)
11-12 184 14
10-11 220 46
09-10 215*** 66
Notes: * = Data from quarterly reports submitted by Pacific Biodiesel for reimbursement from the County's Diversion
Incentive Program.
** = Data on UCO & FOGs quantities reported by WMI, Inc. who receies and solidifies this material after
drop-off by the public.
*** = Approx. 4 tons were collected from East Hawai'i by Pacific Biodiesel.
From: Beck, Dora
Sent: Monday, August 13, 2012 6:23 PM
To: 'Councilmember Brittany Smart'
Cc: Henricks, Jon; Ho, Nelson; Henry, Sharron
Subject: Follow-up to your question on the Grease Trap Legislation
Councilwoman Smart:
During our phone conversation last week, you had asked whether the County's vendor who manages the West Hawai'i
landfill operations (Waste Management, Inc. or WMI) is also contracted to dispose of FOGs. This was after I
mentioned that the second version of your ordinance could impact WMI.
WMI is not required to accept "Special Wastes" unless they make a "written Special Waste Agreement." WMI has
been accepting special wastes (which so far have included FOGs of which used cooking oil is a part) but we have not
yet found any "Special Waste Agreements." The Agreement between the County and WMI recognizes that Special
Wastes in the solid waste stream must be managed responsibly so this practice is allowed under this Agreement.
WMI charges a customer on the basis of$85 per truckload (this revenue goes to the County)followed by an applied
handling charge of$1.50 per gallon (this revenue goes to WMI). This handling charge covers the solidification process
as the landfill is not permitted to accept free liquids. The invoicing for the handling charge is a transaction that is
between WMI and the customer. We are trying to see if WMI has any "Special Waste Agreements"which might
obligate them to keep taking UCOs.
Another thing to consider is the fact that not all UCO or FOGs are recyclable due to contamination making it unusable
for biodiesel or composting. For example, Crisco and grease trappings are not fully recyclable so there may need to
be an exception for these categories. Because the County is not directly involved with recycling of UCO/FOGs, I do
not have information on what technique (if there is one) is used to determine whether UCO or FOGs are contaminated.
I do know that the DOH permit requires screening for unacceptable materials and source tracking.
At this point, I am still in the midst of gathering the following information:
1. Copy of Special Waste Agreement(s) identifying the type of special waste WMI expects to accept. It these
exist, then they may need modification when the ordinance takes effect.
2. Last 3 years of UCO recycled and landfilled
r : tot aii°idr e,<b . ` Brittany Sr' art .<hr-xdi trict6t€x gmadl,co
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Grease Trap Legislation
Beck, Dora <dbeck @co.hawaii.hi.us> Wed, Aug 8, 2012 at 4:29 PM
To: "Ho, Nelson" <nho @co.hawaii.hi.us>
Cc: Councilmember Brittany Smart <hccdistrict6 @gmail.com>, "Peters, Linda" <Ipeters @co.hawaii.hi.us>, "Henry,
Sharron" <shenry@co.hawaii.hi.us>, "Henricks, Jon" <jhenricks @co.hawaii.hi.us>, "Goodale, Gregory"
<ggoodale @co.hawaii.hi.us>, "Torigoe, Ivan" <itorigoe @co.hawaii.hi.us>
Office of Councilmember Smart:
Please see attached for DEM comments & recommendations. Thank you.
From: Ho, Nelson
Sent: Tuesday, July 24, 2012 10:56 AM
To: Beck, Dora; Goodale, Gregory; Torigoe, Ivan; Hirota, Lyle
Cc: 'Councilmember Brittany Smart'; Peters, Linda; Henry, Sharron; Henricks, Jon
Subject: RE: Grease Trap Legislation
Aloha Dora and All,
Thank you for your very substantial comments.We met with Mitch Roth yesterday and he had similar
concerns. Upon reviewing all comments we have decided to take a different approach, one that will articulate
better our desire to utilize commercial quantities of FOG as a resource while NOT limiting the small operators.
What the bill does:
Amend current definition for prohibited materials by removing language related to cooking fats, oils, greases etc.
Add definitions for commercial cooking oil waste and commercial FOG waste.
Amend section 20-40 to provide a clear and distinct provision that prohibits the dumping of any commercial cooking oil
waste and commercial FOG waste, regardless of the quantify or form of the commercial cooking oil or FOG waste.
Please note comments inserted for the added definitions. As currently drafted, both would appear to allow for disposal
of"residue"that may be derived from commercial cooking oil and FOG waste. This wording is from the Honolulu
ordinance.
Depending on what that residue is, both in content and potential quantity, the definitions may need to be amended to
remove or modify the second sentences relating to residue. These definitions were created with disposal into a public
sewer in mind. Does DEM have any concerns about this language?
We apologize for the short turn around time but we would appreciate any comments by tomorrow. We have a deadline
on Thursday to get this on the Aug. 14 committee agenda.
In preparation for that meeting, we respectfully request a DEM log of the last three years of used cooking oil recycled
and landfilled. This does not have to be rushed.
Mahelo,
Nelson
Nelson Ho
Legislative Assistant
Council Member Brittany Smart
District 6- Upper Puna, Ka'u, South Kona
County of Hawaii
25 Aupuni St. Hilo, HI 96720
(808)961-8026
nho @co.hawaii.hi.us •
•
Please consider the,environrnent before printing this email.
From: Beck, Dora
Sent: Monday,July 23, 2012 3:36 PM
To: Ho, Nelson
Cc: 'Councilmember Brittany Smart'; Henry, Sharron; Knippling, Jenny; Hirota, Lyle; Torigoe, Ivan; Goodale, Gregory;
Peters, Linda
Subject: RE: Grease Trap Legislation
Office of Councilmember Smart: Thank you for the opportunity to comment on this proposed ordinance. DEM
comments to the draft ordinance are on the attached. Additional DEM responses for your consideration regarding the
proposed legislation are as follows:
.OJ,tY OR.
COUNTY OF HAWAII STATE OF HAWAII
BILL NO.
ORDINANCE NO.
AN ORDINANCE AMENDING CHAPTER 20 OF THE HAWAII COUNTY CODE 1983
(2005 EDITION,AS AMENDED),RELATING TO DISPOSAL OF COMMERCIAL
COOKING OIL WASTE AND COMMERCIAL FATS,OILS,AND GREASES.
BE IT ORDAINED BY THE COUNCIL OF THE COUNTY OF HAWAII:
SECTION 1. Chapter 20,article 3,section 20-31 of the Hawai`i County Code 1983
(2005 Edition,as amended),is amended by amending the definition for"prohibited materials"to
read as follows:
""Prohibited materials"include, but are not limited to,paint thinner or solvents;oil
base paint waste aljiaptiWiwc 411, antifreeze or lead acid batteries; pesticides,
herbicides or rodent and insect control chemicals; household cleaner, polish or wax;
contaminated soil medical waste;propane,oxygen or acetylene tanks diesel,gasoline or
alcohol [and-,]
as v r ma �' s� - -'- ®. s
wa'�te§' z °. ,g .: ¢.° . v ' ' x � ' G.: u5. ¢ ',
mu
SECTION 2. Chapter 20, article 3, section 20-31 of the Hawaii County Code 1983 r ire
(2005 Edition,as amended), is amended by adding the following definitions to be appropriately " T �� ,
designated and to read as follows:
a¢ tic
AatrattflitLxtaratarattiW..'e-
""Commercial cooking oil waste"means cooking oil which,because of prior use,
potency loss,or contamination, is no longer usable or salable by a business engaged in
cooking food or selling cooking oil.The term does not mean the residue remaining after
the conversion of commercial cooking oil waste into a marketable product.
"Commercial FOG waste" means animal/vegetable fat,oil and grease and other
waste that is retained in or removed from a commercial pretreatment device. The term
does not mean the residue remaining after the conversion,'of comrneicialS9G cvasteinto o`,iim�n1Cs37,� s �a�(,epa S ,']
a marketable product of grease and other waste removed from a commercial pretreatment
device."
SECTION 3. Chapter 20,article 3,section 20-40 of the Hawai`i County Code 1983
(2005 Edition,as amended),is amended to read as follows:
"Section 20-40.Explosives,radioactive wastes and other prohibited materials.
(a) No person shall dump, place, or remove to any County disposal facility, including
transfer stations, any prohibited materials Plta :r§t0. a t�iol '•:®'s by the State 7C k 7, 7)4
department of health rules, regulations and standards, including any radioactive or }
teat u4
chemical waste, any pesticides, explosives, blasting materials, fuses, live 6140.406.141,
ammunition,or other substances that may explode upon contact with heat or fire.
(b) Prohibited wastes which have been rendered nonhazardous by chemical
neutralization or stabilization in accordance with applicable rules, regulations and
standards of the State department of health may be delivered directly to a landfill for
disposal.
G a { '1g t1 are alto l *siy:ff bs' flr `a®r® 'W
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-
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SECTION 4. Material to be repealed is bracketed and stricken.New material is
underscored. In printing this ordinance,the brackets,bracketed and stricken material,and X
underscoring need not be included.
SECTION 5. If any provision of this ordinance,or the application thereof to any person
or circumstance,is held invalid,such invalidity shall not affect other provisions or applications
of the ordinance which can be given effect without the invalid provision or application,and to
this end,the provisions of this ordinance are declared to be severable.
SECTION 6. This ordinance shall take effect upon its approval.
INTRODUCED BY:
COUNCIL MEMBER,COUNTY OF HAWAII
,Hawai`i
Date of Introduction:
Date of 1st Reading:
Date of 2nd Reading:
Effective Date:
2
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COLtriciItTi e.Mb a i Brittany =amart—4h .c 1s Y"ic160;gun a ii,c€' `'
Grease Trap Legislation
Beck, Dora <dbeck @co.hawaii.hi.us> Mon, Jul 23, 2012 at 3:36 PM
To: "Ho, Nelson" <nho @co.hawaii.hi.us>
Cc: Councilmember Brittany Smart <hccdistrict6 @gmail.com>, "Henry, Sharron" <shenry@co.hawaii.hi.us>, "Knippling,
Jenny" <jknippling @co.hawaii.hi.us>, "Hirota, Lyle" <lhirota@co.hawaii.hi.us>, "Torigoe, Ivan"
<itorigoe @co.hawaii.hi.us>, "Goodale, Gregory" <ggoodale @co.hawaii.hi.us>, "Peters, Linda" <Ipeters @co.hawaii.hi.us>
Office of Councilmember Smart: Thank you for the opportunity to comment on this proposed ordinance. DEM
comments to the draft ordinance are on the attached. Additional DEM responses for your consideration regarding the
proposed legislation are as follows:
1. The bill proposes to add a new section 21-7.1 to Chapter 21, Article 2 of the County Code that calls for
"required transport of commercial FOG waste and commercial cooking oil waste to recycling facility and
required conversion to marketable product". Said Article 2 governs Public Sewers, and existing section 21-
7 (c) as well as section 21-9(2)currently prohibit discharge of problematic concentrations of fats and
greases to the sewer systems. Moreover, Section 21-7 (c) mandates preliminary treatment when deemed
necessary by the DEM Director. These provisions have been effective and sufficient to protect the sewer
system from FOG and UCO.
2. Section 21-7 does not govern the disposal or recycling of FOG and UCO, except to keep them out of
the public sewer system. Said simply, the Wastewater Division is not tasked with recycling. A more
appropriate location for the proposed disposal mandates would be Chapter 20 on Refuse, where the
proposed section could be part of a new Article 5 to be entitled "Recycling."
3. In our contacts with City & County of Honolulu, DEM learned that UCO and increasingly also FOG are
valuable feedstock for biodiesel and other products. Hence, the recyclers have been paying for UCO and/or
offering FOG removal services as incentive to attract collections. Before mandating that everyone with
FOG/UCO must deliver to recyclers, it may be wise to determine whether such a mandate, with its
administrative costs, is really needed. We understand that Honolulu has suspended their FOG
enforcement, since voluntary FOG collection and recycling, sometimes by generators, is making
enforcement unnecessary. We also understand that there are private entities on the Big Island that offer
free island-wide pick-up service for UCO.
4. We also understand that UCO to biodiesel production can be done fairly simply by individuals, many of
whom create their own biodiesel for their own use. Generators may want to refine their own UCO, or
contribute it to other refiners. The proposed mandate would foreclose those grassroots options, and benefit
only the few Recycling Facilities.
5. If the free market has devised a practical system of collecting and recycling FOG/UCO without
government intervention, it may be wise to not interfere with it. Forcing all FOG/UCO to be delivered
directly to recycling centers may adversely affect other businesses and private uses which have evolved
around private recycling. Given the fragile state of the economy, such impacts should be carefully
considered.
6. The proposed ordinance is closely modeled after Revised Ordinances of Honolulu ("ROH") Chapter 14,
Article 5A. According to the information from the CCH, the Honolulu Department of Environmental Services
is set up such that they administer the FOG/UCO requirement under their existing Pre-treatment Program.
That program reportedly employs sixteen (16) people to administer and enforce the program. As
wastewater facilities for Hawaii County primarily treat domestic wastewater and are substantially smaller
than CCH facilities, the Wastewater Division does not have sufficient staff to administer and enforce a
formalized Pre-treatment program. Such a program is expected to cost in the ballpark of hundreds of
thousands of dollars per year. As operational costs for the Wastewater Division are funded solely by
wastewater fees, implementation of such a program would require significant increases in cost to
wastewater customers.
7. Honolulu's experience has shown that it is extremely difficult to enforce UCO disposal mandates. It is
difficult to ascertain the quantity of UCO that is actually generated. It is also difficult to track and verify
where the UCO is disposed of, and whether it matches what was generated. For some restaurants, UCO
may actually be recycled into food products. Again, the County lacks enforcement resources for such
tasks.
8. The proposed definition of"Recycling facility' is incomplete. We propose: `Permitted Recycling
Facility"—means a facility or business or other operation permitted by the State Department of Health to
receive and process commercial FOG waste, commercial cooking oil waste, or both into biodiesel or
renewable fuel, compost or another marketable product.
9. In terms of the Hilo Wastewater Treatment Plant, the plant uses methane gas from anaerobic digestion
for plant heating purposes which saves in fuel cost for the facility. If ever the plant (or other private faciities)
needed/wanted the option of anaerobically digesting commercial FOGs or UCO to produce methane gas,
they would not be able to do so because of the requirement that commercial FOG must be transported to a
recycling facility and converted to a marketable product. Perhaps a survey of non-county facilities should
be done to determine the current number of users in this capacity.
10. Considering that this proposed ordinance affects the public, it is suggested that the Environmental
Management Commission members review and provide their advice/recommendation.
To answer your original questions:
1. You asked: In the existing Chapter 21-2 Definitions. In the definition "Grease" we are
considering striking out the parenthetical clause "(Includes fats and oils.)" and include a new
definition of"Commercial FOG waste" means animal/vegetable fat, oil and grease and other waste
that is retained in or removed from a grease trap". Does DEM see a reason not to do that?
Response is: DEM does not recommend this as the existing definition was intended to categorize
materials using the appropriate wastewater test procedure as detailed in the"Standard Methods"
handbook.
2. You asked: In the existing Chapter 21-7. We are considering amending the title "Industrial
wastes of unusual strength." to read: "Industrial wastes of unusual strength and commercial waste."
Response: This section describes how wastewater of unusual strength (usually from industrial or
commercial sources as opposed to residential sources) could be accepted if it has been pre-treated
prior to entering the public sewer system. Therefore, there is no need to make this change. HCC
Section 21-9 (2) already prohibits discharges of wastewater containing more than 100 ppm of FOG.
3. You asked: We would further amend Chapter 21-7. (c) by amending it to read "Fats, oils and
grease shall not be discharged ....". Does DEM see a reason not to do that?
Response: DEM could go either way on this. Note that Secton 21-9(2) currently prohibits fats, oil
and grease in excess of 100 parts per million.
4. You asked: Note that SECTION 4. has the ordinance taking effect in 180 days. Would DEM
prefer a year for the implementation period?
Response: For purposes of educating private businesses, the public and those of whom may
currently involved with the rendering of FOG and UCO, DEM recommends that the ordinance take
effect in 12 months. With that being said, DEM notes that the Recycling education budget is
currently limited to supporting existing programs.
From: Ho, Nelson
Sent: Wednesday, July 11, 2012 4:35 PM
To: Beck, Dora; Hirota, Lyle; Torigoe, Ivan
Cc: Councilmember Brittany Smart; Henry, Sharron; Knippling, Jenny
Subject: Grease Trap Legislation
Aloha DEM, Lyle and Ivan,
Our office has been working on this legislation for a couple of months and we knew DEM was working on
similar legislation in the past. It is timely because we now have a recycling facility that can turn this
wastewater contaminant into a valuable product.
We request the department's input before it goes to Council. Brittany is planning to submit a draft for Council
Committee discussion on August 14, 2012.To meet the submission deadline, we would need your comments
on this version by July 23 so we could incorporate it.
This draft is modeled after the Honolulu ordinance.We would like to point out specific areas of concern.
1) In the existing Chapter 21-2 Definitions. In the definition "Grease"we are considering striking out the
parenthetical clause "(Includes fats and oils.)" and include a new definition of"Commercial FOG waste"
means animal/vegetable fat, oil and grease and other waste that is retained in or removed from a grease
trap". Does DEM see a reason not to do that?
2) In the existing Chapter 21-7.We are considering amending the title "Industrial wastes of unusual strength."
to read
"Industrial wastes of unusual strength and commercial waste."
We would further amend Chapter 21-7. (c) by amending it to read "Fats,oils and grease shall not be discharged
....". Does DEM see a reason not to do that?
3) Finally, note that SECTION 4. has the ordinance taking effect in 180 days.Would DEM prefer a year for the
implementation period?
Mahalo,
Nelson
Nelson Ho
Legislative Assistant
Council Member Brittany Smart
District 6-Upper Puna, Ka'u, South Kona
County of Hawaii
25 Aupuni St. Hilo, HI 96720
(808)961-8026
nho @co.hawaii.hi.us
Please consider the environment before printing this email.
GreasetrapinterceptorDraft071112 DEM COMMENTS db 072012 (2).doc
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IA
UCO STUDY
Study Relating to Used Cooking Oil
Generation and Biodiesel Production
Incentives in the County of Hawai'i
Study conducted by the Solid Waste Division of the Department of
Environmental Management, County of Hawai'i under a grant
from the State of Hawai'i, Department of Business, Economic
Development and Tourism, Strategic Industries Division
December 2004
The United States Department of Energy provided funds for this report under Cooperative Agreement No.
DE-FC51-02R021318. This report was prepared as an account of work sponsored by the United States
Government. Neither the United States Government nor any agency thereof,nor any of its employees,
makes any warranty,express or implied,or assumes any legal liability or responsibility for the accuracy,
completeness,or usefulness of any information,apparatus,product,or process disclosed,or represents that
its use would not infringe privately owned rights. Reference herein to any specific commercial product,
process,or service by trade name,mark,manufacturer,or otherwise,does not necessarily constitute or imply
its endorsement,recommendation,or favoring by the United States Government or any agency thereof. The
views and opinions of the authors expressed herein do not necessarily state or reflect those of the United
States Government or any agency thereof.
Table of Contents
Executive Summary 1
Methodology 4
Survey Responses 6
Analysis 20
Projection 27
Appendices
Appendix A: Methodology
Appendix B: Survey
Appendix C: Recipients
Appendix D: Data Compilation
Appendix E: County Legislation-Kauai
Appendix F: County Legislation-Maui
Appendix G: County Legislation-Oahu
Appendix H: State Incentives
Appendix I: National Policy
Executive Summary:
With the assistance of University of Hawai'i at Hilo students, the Solid Waste
Division of the Department of Environmental Management of the County of Hawai'i
conducted a mail-telephone survey of food handling establishments to determine the
overall disposal of used cooking oil on the island and if the market could support
biodiesel production. The results of the survey showed that approximately 60% of
respondents employ some method of recycling or re-use of their used cooking oil
resulting in an estimated 5,600 gallons per month diverted from the County's landfills.
Approximately 21% of establishments, representing collection of 2,000 gallons per
month, employ Pump Truck Services to dispose of their used cooking oil/grease trap
waste. Approximately 15% of establishments either dispose of their used cooking oil
directly into their solid waste trash or by dumping it into their septic/wastewater systems.
While the number of establishments using these methods was substantial, the actual
volume of oil disposed by these methods was small - approximately 300 gallons per
month. Survey respondents, who were either recycling used cooking oil or willing to
recycle if costs were comparable to or less than other forms of disposal, were the
establishments that served the greatest number of meals and purchased the most cooking
oil. Although 31% of non-recycling respondents perceived that recycling used cooking
was too costly,the results of the research indicate that recycling of the used cooking oil is
less expensive than permitted disposal at landfills. Another survey observation was that
there is a small group of private recyclers responsible for diverting small amounts of used
cooking oil from commercial establishments for use as fuel in their own vehicles.
The research presented in this report was compiled during the calendar year 2004.
It represents a baseline of information regarding the generation of used cooking oil by
commercial establishments in the County of Hawaii, as well as a compilation of existing
data on the land disposal and diversion of used cooking oil to the production of biodiesel.
Also included is information about legislation passed by other Counties in Hawai'i, State
of Hawai'i legislation, and Federal legislation directed at the promotion of a biodiesel
industry as a mean of recycling waste oil.
The survey was conducted on commercial establishments and the data compiled
under the oversight of the Solid Waste Division staff at the Department of Environmental
Management, County of Hawaii. University of Hawaii at Hilo students,Brittany Smart
and Christopher Chin Chance assisted with this research. C3 Consulting was contracted
to assist with the compilation and reporting of the data.
RESEARCH FINDINGS:
• Response rate for the survey of commercial eating establishments was 45.5%. The
data procured from these establishments was provided voluntarily and no certified
weight scales or other measurements were provided to verify quantities.
• It was reported that approximately 380 tons of used cooking oil a year are disposed
by the survey respondents. Although the results of the survey cannot be considered
1
statistically significant due to a variation in response rates for individual questions,
given the overall response rate,we can estimate that more than 800 tons of waste oil
a year are being generated by the target population.
• The businesses serving the most meals and purchasing the largest quantities of
cooking oil showed the greatest interest in recycling the oil provided the costs are
less than other forms of disposal.
• Information collected from the industry indicated that the average price per gallon
paid by establishments to have used cooking oil collected and recycled into
biodiesel was$1.13. The costs to businesses to have used cooking oil collected and
delivered to the West Hawai'i Sanitary Landfill,which is the only facility on the
Big Island to accept and properly process waste oil for land disposal,averaged
$1.91 per gallon.
• Data collected from the County of Hawaii's diversion grant program, landfill
disposal records and data provided from off-island biodiesel production companies
collecting direct from customers for off-island processing indicates 424 tons of
waste oil were tracked to proper disposal and recycling methods for FY 2003-4.
• Data provided by the biodiesel industry operating in conjunction with diversion
programs in the County of Maui indicated that over 900 tons of used cooking oil
were received in the last calendar year. Given that the 2003 population statistics for
the Counties of Maui and Hawai'i were 135,605 and 158,423 respectively, and the
fact that Maui County experiences a higher visitor count, it is presumed that the
volume of used cooking oil in Hawai'i County would be similar to Maui County.
Maui County has actively pursued the diversion of used cooking oil over the last
five years and due to the maturity of the Maui diversion program, is likely capturing
most of the used cooking oil generated in that County.
• Given the comparative data from Maui County and the estimates derived from our
survey, it is projected that somewhere between 320 to 475 tons of used cooking oil
are being generated in Hawai'i County and are being improperly disposed. Recent
anecdotal evidence of illegal disposal practices by two companies operating in
Hawai'i County indicates that illegal land disposal of waste oil may be a significant
problem.
ACTIONS TO PROMOTE BIODIESEL PRODUCTION:
• Conduct a request for proposals(RFP)to divert used cooking oil and other organics
from the island's waste stream. (Completed 2003)
• Increase the diversion grants from$40/ton to$60/ton based on information obtained
from the RFP process. (Completed 2004)
2
• As carried out in other counties,initiate legislation to waive the County fuel tax on
diesel fuels containing 20%or greater biodiesel. (TBA)
• Pass legislation at the County level requiring the use of grease trap interceptors for
all waste oil generators and strictly monitor compliance. (TBA)
• Implement receiving stations for used cooking oil drop-off on each side of the
island. (TBA)
• Educate the population of Hawai'i County about the benefits of recycling used
cooking oil and the negative impacts to the environment of improper disposal.
(Proposed 2nd round of funding from DBEDT)
• Educate the target population of waste oil generators about the costs and benefits of
recycling used cooking oil and grease trap waste. (Proposed 2nd round of funding
from DBEDT)
3
Methodology:
The survey method employed a mail survey sent to the entire population of
commercial food handling establishments with a follow-up telephone interview to
increase the response rate and verify information written on returned surveys. We
obtained a population list from the State of Hawai'i Department of Health — Sanitation
and Food and Drug Branches on food handling establishments that were licensed in the
County of Hawai'i. Establishments that were omitted from the Department of Health
listing for purposes of our survey included: Gas/Convenience stations, school cafeterias,
coffee-only establishments, bars/liquor only establishments, public institutional (i.e.
hospitals,prisons, etc.) eating establishments. These establishments were omitted due to
a determination that their generation of used cooking oil was minimal. We submitted a
draft of our survey to the Department of Business, Economic Development & Tourism
(DBEDT) for approval along with a scope of our purpose. A cover letter explaining the
purpose of the survey, a stamped self addressed envelope and the DBEDT approved
survey were sent to all qualified establishments on our population listing. The final
population-recipient list after the qualified omissions contained 725 commercial food
handling establishments. Upon return of undeliverable surveys, analysis of surveys from
respondents who replied that their businesses were no longer in operation, and multiple
telephone contact attempts resulted in an additional 33 listings being eliminated as "Out-
of-Business" listings. The initial population listing obtained from the State of Hawai'i
Department of Health appeared to have been last updated two years ago and contained
establishments that were no longer in business and multiple wrong addresses; both factors
may have contributed to a higher than anticipated non-response rate to the survey.
4
Surveys were returned to our office and tracked as "complete" or "requiring" follow-up
as some responses lacked complete information. As incomplete surveys were returned,
the students commenced follow-up telephone calls to verify information and obtain more
complete survey responses. Upon reaching the deadline for submission of the surveys the
response rate was below the projected and desired 35%rate. Telephone interviews were
conducted of non-responding establishments and to obtain more complete survey
information from the surveys that had been returned. In order to obtain a relevant
baseline of data on used cooking oil generation, follow-up telephone interviews were
largely conducted on fast food establishments and resorts which were hypothesized to
generate the most used cooking oil. After final mail surveys were returned, initial and
follow-up telephone interviews were completed that resulted in an overall 45.5%
response rate, or 314 responses from a total qualified population of 692. Due to the
variation of response rates for particular questions on the survey instrument and the
uncertainty regarding characteristics of the non-respondents, the results cannot be
considered statistically accurate and are to be used for baseline information only.
5
Survey Responses:
Microsoft Excel and SPSS statistical/data functions were used to analyze the data
obtained from our survey. To more easily understand the following tables, please note
the following definitions and explanations.
1. Valid responses=Total number of responses to that question. (Excludes multiple
responses.)
2. Frequency = Number of records that match the various answer options for the
survey question.
3. Percent=Percentage rate of the valid sample responses to the question.
4. For the frequency distribution tables all Valid response options to the question are
listed on the left hand side and are tallied in rows.
5. For the cross tabulation tables, variables under comparison are listed in the title of
the table with the various response options listed on the left side and top row of
the table and the number of responses and their corresponding percentage rates
are shown for each Valid outcome.
6
Response Item — Check here if you do not use cooking oil in your operation
and mail in the questionnaire.
COOKING OIL USED
Valid
Frequency Percent Percent
Valid BLANK 165 23.8% 52.5%
CHECK 149 21.5% 47.5%
Total 314 45.4% 100.0%
Missing 378 54.6%
Total 692 100.0%
Our total response rate for our full population sample was 45.4% or 314 out of
692 qualified population listings with 165 respondents, or 52.5% of returned surveys
replying that their establishments used cooking oil (BLANKS). Our non-response rate
("Missing") to our survey was rather large (54.6%) due possibly to a less than perfect
population listing from the Department of Health, establishments ignoring our survey,
proprietors unable to understand the survey due to foreign language difficulties, or a
general reluctance to divulge proprietary business information that could reveal
inappropriate disposal methods.
7
Question 1: What type of establishment is it?
EST. TYPE Frequency Percent
DINE-IN 110 66.7%
TAKEOUT/DELIVERY 88 53.3%
FOOD PRODUCT 28 17.0%
RESORT 9 5.5%
Total 235 142.4%
Valid 165
The large majority of the food handling establishments in the County of Hawai'i
were DINE-IN facilities, and TAKEOUT/DELIVERY operations were the second most
common response, with many establishments conducting both types of activities. Since
establishments had the option of marking more than one category, the total number of
responses exceeds the Valid number of total survey respondents who answered that they
used cooking oil in their operations.
Question IA: How many meals does your establishment serve on average
per week?
MEALS/WK Frequency Percent
1 -349 23 17.8%
350- 1999 68 52.7%
>2000 38 29.5%
Total 129 100.0%
8
While a significant number of establishments(36) failed to provide an estimate of
the number of meals served, the data provided a useful comparison variable to compare
high volume establishments versus low volume establishments with other variables.
Question 1B: What is the primary type of food offered?
MEAL TYPES Frequency Percent
PLATE LUNCH 75 45.5%
NATURAL/VEG 14 8.5%
DINER 25 15.2%
STEAK/SEAFOOD 28 17.0%
FAST FOOD 52 31.5%
FULL-SERVICE 55 33.3%
BUFFET 21 12.7%
FOOD PRODUCT 35 21.2%
ETHNIC 31 18.8%
Total 336 203.6%
Valid 165
According to the survey responses, establishments were asked to check all
categories that apply resulting in total percentage being greater than 100%.
9
Question 1C: Does your establishment have a grease trap?
GREASE TRAP Frequency Percent
NO 26 16.3%
YES 134 83.8%
Total 160 100.0%
Even though there is no County mandate for food handling establishments that
requires a grease trap in their operations, the responses to our survey indicate most
(83.8%) businesses have one. Legislation proposing a required grease trap for such
establishments is under consideration to prevent costly maintenance of the County's
wastewater system.
Question 2: How much cooking oil does your establishment purchase
monthly? (Gallons)
OIL—PURCHASED
(Gallons/Mo.) Frequency Percent
<50 88 55.7%
50—149 43 27.2%
>-150 27 17.1%
Total 158 100.0%
The majority (55.7%) of establishments report that they purchase less than 50
gallons of cooking oil per month, and only a small proportion (17.1%)use cooking oil in
volumes greater than 150 gallons per month.
10
Question 3: How much used cooking oil does your establishment dispose of
monthly? (Gallons)
OIL—DISPOSED
(Gallons/Mo.) Frequency Percent
<50 81 57.9%
50-149 45 32.1%
> 150 14 10.0%
Total 140 100.0%
As expected, the levels of cooking oil disposed by the establishments are less than
the purchased amount, and according to our survey respondents, over 3,000 gallons per
month are consumed in the food they prepare. Both the OIL-PURCHASED and OIL-
DISPOSED variables will be compared with other variables to extrapolate data that may
be relevant to survey non-responders.
11
Cooking Oil End Products
(by volume)
LIVESTOCK FEED
2%
OTHER
3% CONSUMED
31%
rilCONSUMED
° OPUMP SVC
RECYCLE
i�. •OTHER
■LIVESTOCK FEED
RECYCLE
47%
PUMP SVC
17%
Question 4: How does your establishment dispose of its used cooking oil?
DISPOSAL METHODS Frequency Percent
RECYCLE CO. 59 37.3%
PRIVATE RECYCLE 18 11.4%
PIG FARMER,ETC 22 13.9%
SW TRASH 20 12.7%
DRAIN 3 1.9%
PUMP TRUCK 34 21.5%
OTHER METHOD 2 1.3%
Total 158 100.0%
Valid 165
12
Methods of disposing of an establishment's used cooking oil varied widely but a
majority (60%) employ some type of recycling or reuse of the byproduct. The results of
this question can be compared to the various establishment types, number of meals
served, and establishment's reasons for not recycling, to yield information that will
facilitate determination of appropriate incentives to encourage recycling.
Methods of Used Cooking Oil Disposal
(by number of establishments)
OTHER METHOD
PUMP TRUCK 1%
22%
x a
1 37%
RECYCLE CO.
.'*
DRAIN
9 RECYCLE CO.
0 PRIVATE RECYCLE
IS PIG FARMER&ETC
■SW TRASH
SW TRASH ❑DRAIN
13%
C1 PUMP TRUCK
PIG FARMER&ETC PRIVATE RECYCLE MOTHER METHOD
14% 11%
A critical factor to note here is that the 59 establishments that employ RECYCLE
COMPANIES represent approximately 83% of the actual number of establishments that
recycle by that method according to the RECYCLE COMPANIES' internal business
records. These response rates indicate that self-selection was a significant factor for
establishments the use RECYCLE COMPANIES compared to establishments that may
employ other methods of disposal.
13
Question 5: If you dispose of your used cooking oil by means of a Pumping
Truck Service,which company is collecting the used cooking oil?
PUMP TRUCK SVC Frequency Percent
West HI Pump Truck Cos.(4) 33 100.0%
Total 33 100.0%
According to the survey responses most of the establishments that use a Pump
Truck Service reside on the Westside of Hawai'i County, and this has been confirmed
with internal Department data from the West Hawai'i Sanitary Landfill. Four Pump
Truck Companies service the Westside with 94% of the establishments utilizing two of
the companies. East Hawaii Sanitary Landfill does not accept waste oil for disposal.
Question 5A: Do you pay a service fee for the collection of your used cooking
oil? If yes,approximately how much?
SVC FEE$ Frequency Percent
PUMP TRUCK
FEE <$ 1.00 1 3.0%
$ 1.00-$ 1.99 22 66.7%
$2.00-$2.99 7 21.2%
>_$3.00 2 6.1%
N/E
(no estimate) 1 3.0%
Total 33 100.0%
The results of this question are compared to other disposal methods in the
"Cooking Oil Disposal Volume&Mean Disposal Cost"chart on page 25.
14
Question 6: If you don't have a recycler pick up your used cooking oil what
are the reason(s)why?
REASONS Frequency Percent
TOO COSTLY 13 3L0%
NOT ENOUGH
STORAGE SPACE 7 16.7%
NO STORAGE
CONTAINERS 8 19.0%
OTHER REASONS 30 71.4%
Total 58 138.1%
Valid 42
Establishments were able to answer"Yes"to more than one reason in response to
this question resulting in the greater than 100% cumulative response rate. Too many
surveys were blank in response to this question to make any statistically significant
conclusion as to why establishments did not employ a recycler to dispose of their used
cooking oil. The most common response was in the OTHER category where many of the
establishments were unaware of the opportunity to recycle their used cooking oil. This
lack of information will hopefully be addressed in the follow-up public education
campaign to inform the businesses as well as the public of the recycling opportunities
available to them. Many of the responders to our survey, who already were recycling
their used cooking oil, used this section of the survey to complain about the process of
recycling even though this question did not apply to them, and their responses were thus
not tallied in the above table. The number one complaint cited by establishments that
15
recycle was the cost of recycling. While many of the establishments' eligible responses
were "Too Costly" to this question and many establishments who recycle complained of
the cost of their current service, it is worthwhile to note that proper disposal of fat, oil,
and grease (FOGs)by means of Pump Truck Services is actually about equal in price per
gallon, and in many cases more expensive, depending on which Recycle Company is
available to service them.
Question 7: How much would you be willing to pay per gallon to dispose of
used cooking oil by means of a recycler instead of your current method?
Frequency Percent
ALTERNATIVE
COST$ $0.00 20 47.6%
$0.01 -$0.99 4 9.5%
$ 1.00-$ 1.99 13 31.0%
$2.00-$2.99 4 9.5%
>_$3.00 1 2.4%
Total 42 100.0%
The non-response rate to this question prevents any statistically significant
conclusion to be drawn from the data, although a large plurality (47.6%) of those who did
respond wanted the ALTERNATIVE COST to be $0.00. Many establishments who
responded with$0.00 said they thought the Recycle Companies should pay them for their
used oil, an unlikely situation given all the costs involved in handling the used cooking
oil and processing it into biodiesel. With proper legislation, diversion credits and a
16
biodiesel production facility on the Big Island, it may be possible to reduce the costs to
businesses to recycle their used cooking oil.
Question 8: Which reason(s) would convince you to consider recycling your
establishment's used cooking oil?
REASONS Frequency Percent
ENVIRONMENT YES 44 81.5%
ALTERNATIVE FUEL YES 49 90.7%
LANDFILL SPACE YES 40 74.1%
ILLEGAL DRAIN YES 30 55.6%
Total 163 301.9%
Valid 54
The responses to this question yielded a fairly even distribution for the listed
reasons: It is environmentally friendly; it is used to produce locally made alternative
fuel, which reduces dependency on foreign oil; it conserves our declining landfill space;
it becomes illegal to dispose of used cooking oil down the drain. Many surveys cited
more than one reason which resulted in the Total exceeding the 54 survey responses to
this question,and the percentage exceeding 100%.
Question 9: If you dispose of your cooking oil by means of a recycling
company,which company is collecting the used cooking oil?
17
RECYCLERS Frequency Percent
Diversion Grant Program
Participants 42 54.5%
Biodiesel Producers
15 19.5%
Other/Private Individuals
14 18.2%
Unknown/No Name Given
6 7.8%
Total 77 100.0%
The companies that participate in the County of Hawaii's Diversion Grant
Program together collect from 54.5% of the establishments that recycle. Another 19.5%
of establishments have their used cooking oil directly shipped to Biodiesel Producers.
The Diversion Grant Program Participants and the Biodiesel Producers together collect
approximately 82% of the recycled used cooking oil by volume. Another 18.2% of the
establishments responded that Other Users or Private Individuals collected their used
cooking oil for purposes of fuel oil; this represented a much smaller proportion by
volume of the used cooking oil recycled.
Question 9A: Do you pay a service fee for collection of your used cooking
oil? If yes,approximately how much?
18
SVC FEE$ Frequency Percent
RECYCLER FEE <$ 1.00 16 24.2%
$ 1.00-$ 1.99 27 40.9%
$2.00-$ 2.99 20 30.3%
>_$3.00 1 1.5%
Varies 1 1.5%
N/E 1 1.5%
Total 66 100.0%
While many establishments were able to provide us with reliable costs of their
SERVICE FEES, others were unsure or unaware of the precise per-gallon cost and
provided an estimate. These cost estimates may be influenced by the amounts
respondents are"willing to pay"as ALTERNATIVE COSTS described in Question 7.
Question 10: Do you have any additional comments or suggestions regarding
used cooking oil?
The responses to this question varied with many of the respondents saying that
they supported the concept of recycling used cooking oil and they liked the idea of the
County conducting the survey to gauge the business and public interest. Some
respondents even asked where to obtain the used cooking oil or processed biodiesel for
use in their businesses or for personal use.
19
Analysis:
In order to make projections and discover trends for used cooking oil production
covering the non-respondents and the entire population of food handling establishments,
cross tabulations of variables of interest were attempted. By using the cross tabulation
tables we were able to determine a few trends with respect to volume of cooking oil
purchased/disposed, meals served, cooking oil disposal methods and types of
establishments.
Cross Tabulation of Number of Meals vs.Used Cooking Oil Purchased.
OIL PURCHASED MEALS(per week) Total
(Gallons/mo.) 1 -349 350- 1999 >2000
<50 Count 20 38 8 66
% 95% 57% 22% 53%
50- 149 Count 1 26 13 40
% 5% 39% 35% 32%
>150 Count 3 16 19
% 0% 4% 43% 15%
Total Count 21 67 37 125
% 100% 100% 100% 100%
Cross Tabulation of Number of Meals vs. Used Cooking Oil Disposed.
OIL DISPOSED MEALS(per week) Total
(Gallons/mo.) 1-349 350-1999 >2000
<50 Count 18 40 8 66
% 95% 63% 23% 56%
50- 149 Count 1 21 17 39
% 5% 33% 49% 33%
> 150 Count 2 10 12
% 0% 3% 29% 10%
Total Count 19 63 35 117
100% 100% 100% 100%
20
In both cross tabulations of number of MEALS served per week vs. OIL
PURCHASED and DISPOSED, there is a correlation between an increasing number of
meals served and the volume of used cooking oil purchased and disposed.
Cross Tabulation of Number of Meals vs.Used Cooking Oil Disposal Methods.
METHODS OF MEALS Total
DISPOSAL 1 -349 350-1999 >2000
RECYCLE CO. Count 1 22 24 47
% 4% 32% 63% 36%
PRIVATE RECYCLE Count 1 10 3 14
4% 15% 8% 11%
PIG FARMER, ETC Count 3 14 1 18
% 13% 21% 3% 14%
SW TRASH Count 8 5 13
% 35% 7% 10%
DRAIN Count 1 1 2
% 4% 1% 2%
PUMP TRUCK Count 7 15 10 32
30% 22% 26% 25%
OTHER METHOD Count 2 2
% 9% 2%
Total Count 23 67 38 128
% 100% 100% 100% 100%
In this tabulation there is a possible relationship whereby, as the number of
MEALS served increases, establishments are more likely to employ RECYCLE
COMPANIES and less likely to dispose of used cooking oil by means of SOLID WASTE
TRASH,pouring it down the DRAIN or OTHER METHODS.
21
Cross Tabulation of Purchased Cooking Oil Volume vs. Disposal Methods.
OIL PURCHASED
METHODS OF (gallons/month) Total
DISPOSAL <50 50-149 >150
RECYCLE CO. Count 18 19 21 58
% 22% 44% 78% 38%
PRIVATE RECYCLE Count 9 7 2 18
% 11% 16% 7% 12%
PIG FARMER&ETC Count 19 3 22
23% 7% 14%
SW TRASH Count 16 3 19
% 19% 7% 12%
DRAIN Count 2 2
% 2% 1%
PUMP TRUCK Count 17 11 4 32
% 20% 26% 15% 21%
OTHER METHOD Count 2 2
2% 1%
Total Count 83 43 27 153
% 100% 100% 100% 100%
22
Cross Tabulation of Used Cooking Oil Volume vs.Disposal Methods.
OIL DISPOSED
METHODS OF (gallons/month) Total
DISPOSAL <50 50-149 >150
RECYCLE CO. Count 20 26 10 56
% 24% 57% 71% 39%
PRIVATE RECYCLE Count 12 4 1 17
14% 9% 7% 12%
PIG FARMER&ETC Count 16 0 0 16
% 19% 0% 0% 11%
SW TRASH Count 15 3 0 18
% 18% 7% 0% 13%
DRAIN Count 2 2
2% 0% 0% 1%
PUMP TRUCK Count 16 13 3 32
% 19% 28% 21% 22%
OTHER METHOD Count 2 2
% 2% 0% 0% 1%
Total Count 83 46 14 143
100% 100% 100% 100%
In both the cross tabulation tables of OIL PURCHASED and OIL DISPOSED vs.
DISPOSAL METHODS a similar correlation between increasing volume of cooking oil
and a higher rate of usage of recycling companies to dispose of the used cooking oil is
observed. The options of disposal by means of SW TRASH, down the DRAIN and
OTHER METHODS showed a decline in usage as OIL PURCHASED and DISPOSED
increased.
23
Cross Tabulation of Recycling Method vs.Type of Establishment
METHODS OF DINE-IN TAKEOUT FOOD RESORT
DISPOSAL PRODUCT
RECYCLE CO. Count 41 33 7 6
% 37.6% 37.5% 31.8% 66.7%
PRIVATE RECYCLE Count 15 8 2 0
% 13.8% 9.1% 9.1% 0.0%
PIG FARMER Count 15 14 5 0
% 13.8% 15.9% 22.7% 0.0%
SW TRASH Count 9 9 6 0
% 8.3% 10.2% 27.3% 0.0%
DRAIN Count 1 3 0 0
% 0.9% 3.4% 0.0% 0.0%
PUMP TRUCK SVC Count 27 19 2 3
% 24.8% 21.6% 9.1% 33.3%
OTHER Count 1 2 0 0
0.9% 2.3% 0.0% 0.0%
TOTAL Count 109 88 22 9
% 100.0% 100.0% 100.0% 100.0%
RECYCLE COMPANIES was the top choice among all establishment types for
disposal of their used cooking oil with RESORTS employing their services at the highest
rate. FOOD PRODUCT manufacturers were the most likely to dispose of their used
cooking oil by means of PIG FARMERS and in their SOLID WASTE TRASH.
24
Cooking Oil Disposal Volumes&Mean Disposal Costs
6000 R; •, -� 'a��-
5000 zac • ,i ;
4000 ¢
3000 ,;
o
2000
1000
0
O
4 ti4 Volume
4 •
4$9
Off'
4,
Methods Of Disposal ��
(mean disposal cost per gallon)
In the "Cooking Oil Disposal Volumes & Mean Disposal Costs" chart, we
summarize the average disposal costs for the various methods. The results according to
our survey showed that Recycling/Reuse of cooking oil was the method used to dispose
of the greatest volume of oil while Pump Truck Services was the most costly method of
disposal for the establishments. Disposal by use of the cooking oil as a livestock feed,
though very economical, may have limitations in the volume that can be disposed, and
may additionally be constrained by sanitation and livestock health impacts.
25
Cumulative Volume of Recycling Diversions &Landfilling of Used Cooking Oil
Tracked by the County of Hawaii(tons)
FY2001 FY2002 FY2003 FY2004
July 0.00 22.29 49.71 33.99
August 0.00 19.73 30.39 16.59
September 0.00 12.60 16.63 32.82
October 11.63 28.57 24.40 23.73
November 12.60 14.64 15.62 23.94
December 10.66 9.69 27.97 27.68
January 7.75 16.78 22.65 24.74
February 8.72 20.07 21.93 32.36
March 10.66 36.15 22.89 40.77
April 30.56 27.55 14.89 38.99
May 12.60 19.95 20.72 31.41
June 15.50 29.07 27.29 35.34
FY Total 120.68 257.09 - 295.09 362.35
Est. direct shipments to Island Commodities 50.00
Est. direct shipments to Pacific BioDiesel 12.00
Total direct shipments to Off-Island Recyclers 62.00
Estimated Total Cooking Oil Disposal for FY03-04 * 424.35
* Note: FY 2002, 2003 and 2004 tonnage adjusted to account for only used cooking oil disposal at the
Pu'uanahulu Landfill based on estimates by Pump Truck Service companies.
According to our survey, our respondents who employ Recyclers or Pump Truck
Services were responsible for approximately 353.32 tons (z 91,000 gallons) of the Total
Used Cooking Oil Disposed in Hawai'i County. Given that our internal Department
accounting of used cooking disposal by all establishments yielded an estimated 424.35
tons (z 110,000 gallons) in FY2004, the respondents to our survey seem to account for.
about 83%of the volume generated. This observation could be the result of a strong self-
selecting response factor by those establishments with high volumes of used cooking oil
that already recycle and this factor may skew any extrapolation based on these results.
26
Projection:
In order to determine whether there is a sufficient used cooking oil volume market
for a biodiesel production facility on the Big Island of Hawai'i, an extrapolation based on
the survey results was calculated. Assumptions were applied to the survey non-
respondents to characterize their establishments and develop a projection of used cooking
oil generation in the County of Hawai'i. Similar qualifying criteria were applied to the
Department of Health listings of non-respondents to obtain only commercial food
handling establishments under consideration. Further, remaining establishments were
then characterized by Dine-In, Takeout/Delivery, Food Product and Resort facility types
or those that did not use cooking oil based on similarities to respondents to the survey
that marked the"do not use cooking oil"option. An average volume of used cooking oil
per type of establishment was then calculated from the survey respondents. An
extrapolation based on the number of survey non-respondents by establishment type
multiplied by the average used cooking oil generation per establishment was calculated
and the results are displayed in the following table.
Extrapolation of Used Cooking Oil Generation for Survey Non-Respondents
Dine-In Takeout Product Resort
Survey Respondents 110 87 27 9
Oil per Establishment Type(gallons/mo.) 5601 4558 902 1420
Mean per Establishment 51 52 33 158
Survey Non-Respondents 161 55 18 1
Oil per Establishment Type(gallons/mo.) 8198 2882 602 158
Extrapolated Mean 51 52 33 158
Note: Non-Respondents were categorized into a single Establishment Type to avoid double counting and
simplify the extrapolation.
27
The Mean Used Oil per Establishment was calculated for the four types of food
handling establishments by dividing the Total Oil per Establishment Type by the number
of establishments. Establishments that marked multiple categories were tallied in those
columns. An interesting result of this calculation is that DINE-IN and TAKEOUT
establishments have similar per establishment used cooking oil generation while the
RESORTS had the highest volumes generated. Total used cooking oil generated by
survey respondents was 8,163 gallons per month, which translates into 380 tons per
year. The Mean per Establishment used cooking oil volumes were then multiplied by the
number of survey non-respondents that matched those establishment types to yield an
extrapolation of 11,839 gallons per month, which translates into 550 tons per year. An
estimate of the total generation of used cooking oil in the County of Hawai'i based on
this extrapolation would yield 20,002 gallons per month,which translates into 930 tons
per year.
This extrapolation is based on responses from the cooking oil survey and assumes
that the respondents and non-respondents had similar cooking oil usage characteristics.
Estimates for DINE-IN and TAKEOUT establishments could be affected by the above
average survey response rates from establishments generating larger amounts of used
cooking oil (e.g. Fast Food franchises categorized as both DINE-IN and TAKEOUT
facilities), self-reporting by respondents more concerned with recycling used cooking oil
or establishments not responding to our survey due to possible non-legal disposal or
perceived negligible amounts. The calculation was also dependent on the surveyor's
assumptions of establishment characteristics of the non-respondents to the survey. The
surveyor was unable to determine if non-respondent establishments were out-of-business
28
based on the Department of Health listing. Given these factors and assumptions, the
extrapolation result should be considered a high estimate of the used cooking oil
generated by survey non-respondents.
Since this survey was not a simple random survey but a mix of a population and
purposive sampling, extrapolations based on survey data may be biased and could affect
the outcome. Statistical analysis of the results is not possible as a result of our
methodology, but the purposes of the survey were to gauge the interest in used cooking
oil recycling and provide a baseline estimate of the volume of used cooking oil generated
on the Big Island. As such, the survey yielded some interesting results and provided
insights with regard to amounts of used cooking oil generated, recycling costs, and local
recycling options. The information gathered in this survey will be helpful in developing
a public outreach/education program to promote the recycling of commercially generated
used cooking oil for use in the local production of biodiesel.
29