Town Of Culpeper
Grab Sample –
Department Of Environmental Service
Fats, Oils, and Grease (FOG) Regulation
Effective Date: January 1, 2010Town Of Culpeper
Fats, Oils and Grease (FOG) Regulation
- Nature of the Problem: Fats, oils and greases (FOG) are a significant concern for the Town in operation of the wastewater collection system and the wastewater treatment plant. When not disposed of properly, FOG components congeal and accumulate along the walls of the sanitary sewers. This constricts the pipes, impedes the flow of wastewater, and raises the potential for blockage. Grease also affects the proper operation of pump stations, leading to sewage accumulation in wet wells. Either of these situations can eventually result in a sanitary sewer overflow in which wastewater is discharged from a manhole, or wastewater enters homes and businesses. This is both an environmental issue and a public health concern, in which sewage can contaminate the ground, local bodies of water, and any property with which the wastewater comes into contact.
- Financial Consequences to the Town: The financial burden related to excessive FOG is potentially two-fold. Maintenance crews of the Town devote considerable time to cleaning sewerage components, and treatment processes may be hindered at the Town of Culpeper wastewater treatment plant.
- Sources of FOG: FOG discharges relate directly to the preparation, cooking, and disposal of food items. These can originate from residences and from commercial, institutional, and industrial facilities. However, it is restaurants and related commercial food service users that are the most significant source of FOG due to the amount of oil and grease used in cooking, and with other food preparation.
- Purposes of this Regulation: This Regulation is adopted for the following purposes:
Applicability of this Regulation: The provisions of this Regulation are applicable to all significant industrial users as defined in Town Code § 24-146 and all other businesses or other dischargers whose discharges contain fats, oil, and or greases in concentrations above one hundred milligrams per liter (100mg/l), including all commercial food service users, institutions with food service, and industries with food service that discharge to the Town’s wastewater collection system.
- To set forth requirements for non-residential users of the Town’s sanitary sewer system to capture and dispose of FOG, enabling the Town to comply with all applicable federal and state laws, and to prohibit the discharge of any wastewater containing more than 100 parts per million of FOG.
- To reduce the operational and maintenance costs of the Town by limiting the introduction of FOG into the sanitary sewer system.
- To reduce the impact on the Town’s wastewater treatment plant operations by limiting the amount of FOG delivered by the Town’s sewer system.
- To protect the general public health and prevent environmental disturbances by eliminating or reducing sanitary sewer overflows due to grease accumulations.
Best Management Practices – A schedule of activities, a prohibition of practices, and other management policies designed to prevent or reduce the introduction of fats, oils and grease into the Town’s sanitary sewer system.
Commercial Food Service User – A commercial facility discharging wastewater into the Town’s sanitary sewer system, that is engaged entirely or primarily in the activities of preparing, serving, or otherwise making foodstuffs available for consumption by the public. This includes, but is not limited to, such users as restaurants, cafeterias, delicatessens, luncheonettes, sandwich shops, food courts, ice cream parlors, coffee shops, bakeries, catering businesses, grocery stores, and butcher shops. This also includes such commercial facilities as motels, inns, bed and breakfast users, and related lodging facilities, where food preparation and serving are an integral part of the operations, and includes bars, taverns, pubs, nightclubs, and related users serving alcohol, where food preparation and serving are an integral part of the operations.
Fats, Oils and Grease (FOG) – Organic, non-petroleum compounds derived from animal and/or plant sources that contain multiple carbon chain triglyceride molecules. These substances are detectable and measurable using analytical test procedures established in the United States Code of Federal Regulations 40 CFR 136, as may be amended from time to time. All are sometimes referred to herein as “grease” or “oil and grease.”
Commercial Food Serviced User sometimes referred to as Commercial Facility or Industrial Facility.
A water sample collected in an instantaneous manner without regard to possible variations in the flow rate or the chemical concentrations of the sample.
Grease Control Device –
A device utilized to bring about the separation of waterborne fats, oils and grease from wastewater by reducing the flow rate of the wastewater, and thus eliminate or reduce the oil and grease discharged to the Town’s sanitary sewer system. Note that a distinction is made herein between grease interceptor and grease trap; other references may use these terms interchangeably.
Grease Interceptor –
A large-capacity grease control device that is an underground tank or vault, typically constructed of precast concrete, consisting of at least two chambers, and holding several hundred to a few thousand gallons of liquid. It is generally located outside a facility with access lids at ground level, and operates by providing greater retention time which allows for more efficient separation of fats, oils and grease from the remaining wastewater.
Grease Trap –
A small-capacity grease control device that is constructed of resistant metal or plastic, typically holds fewer than 50 gallons of liquid, and is located inside a facility. It may be positioned below floor level or directly beneath a facility sink, and operates to reduce flow rate by a series of baffles.
Hexane Extractable Material (HEM) –
The typical name used by analytical laboratories for detectable and measurable fats, oils and grease using the analytical test procedures established in the United States Code of Federal Regulations 40 CFR Part 136.
Industry with Food Service –
An industrial user, discharging wastewater to the Town’s sanitary sewer system, within which a cafeteria is engaged in the activities of preparing, serving, or otherwise making foodstuffs available for consumption by its employees.
Institution with Food Service – An institutional user, discharging wastewater to the Town’s sanitary sewer system, engaged, at least in part, in the activities of preparing, serving, or otherwise making foodstuffs available for consumption by its students, patients, residents, inmates, congregants, and/or employees. This includes, but is not limited to, such institutional users as schools, hospitals, nursing homes and related residential care facilities, childcare facilities, correctional facilities, and churches.
II) PERFORMANCE STANDARDS
III) GREASE TRAPS AND INTERCEPTORS
Two (2) copies of calculations and plans shall be submitted to the Town for review and permit issuance. All grease interceptor construction details shall be reflected in the as-built plans submitted to the Town upon substantial completion, or completion, of the project.
IV) FOG WASTE DISCHARGE PERMIT
Enforcement: Enforcement of these Regulations shall be as provided in the Town Code, Chapter 24, Article IV, Division 4.
- Discharges of wastewater containing more than 100 parts per million of FOG, measured as Hexane Extractable Material (HEM), are prohibited.
- All commercial food service users, and institutions or industries with food service, shall install, operate, and maintain at their expense a grease control device.
- All commercial food service users, and institutions or industries with food service, which are required to install a grease interceptor, shall obtain a FOG Waste Discharge Permit per section 24-241 of the Town Code.
- The maintenance costs related to excessive grease in the Town’s sanitary sewer system, and traceable to the food service operations of a facility, may be the responsibility of the user.
- The maintenance costs of a sanitary sewer overflow that is related to excessive grease in the Town’s sanitary sewer system, and traceable to the food service operations of a facility, shall be the responsibility of the user.
- Any fines imposed upon the Town by the State of Virginia or the United States of America in regard to a sanitary sewer overflow which is related to excessive grease in the Town’s sanitary sewer system, and traceable to the food service operations of a facility, shall be the responsibility of the user.
Exemption From Grease Control Device Requirements
- As noted in Town Code § 24-261, grease traps and interceptors are not required for private living quarters or dwelling units.
- A commercial food service user, or institution or industry with food service, which is determined to have no, or minimal, adverse grease impact upon the Town’s sanitary sewer system due to the nature of its operations, may be granted an exemption from the requirements to install and maintain a grease control device.
- All new commercial food service users, and institutions or industries with food service, shall be required to install the appropriate grease control device, approved by the Town, prior to initiating operations. Following a review of the preliminary construction plans, the Town shall notify the owner in writing of the specific grease control device for installation. In general, this shall be a grease interceptor for all sizeable restaurants, and for hospitals, schools, motels and industries. A facility that is required to install a grease interceptor shall also obtain a FOG Waste Discharge Permit.
- The Town strongly recommends that each new building, located in a commercial complex generally referred to as a strip mall, provide a stub-out for a separate waste line for possible future grease interceptor installation. This shall apply to all buildings in the complex not initially planned as restaurants. The designer of such new structures shall consider suitable physical space and sewer gradient on the property that will be conducive for the installation of a grease interceptor(s).
Existing User; New User In Existing Building
- All existing commercial food service users, and institutions or industries with food service, shall have grease control devices that meet the same general requirements for installation and design as for new users. This shall also pertain to a new user that begins operations in an existing building, and an existing user that expands its food service operations.
- Any commercial food service user, or institution or industry with food service, whose grease handling facilities or methods are determined by the Town to be inadequate to prevent excessive FOG from entering the Town’s sanitary sewer system, shall be notified in writing of the deficiencies, the required improvements, and a compliance deadline. Required improvements may include modifications of the maintenance schedule, the installation of a larger, or additional, grease trap, or the installation of a grease interceptor. The user may be required to provide a schedule of corrective action to meet full compliance.
- A facility without a grease control device shall be allowed a compliance deadline not to exceed two (2) months for the installation of a grease trap, or not to exceed six (6) months for the installation of a grease interceptor, following written notification from the Town. If a facility, which is required to install a grease interceptor, does not have an existing grease trap, then the latter shall be installed within two (2) months of notification by the Town, unless the grease interceptor is installed within that time period.
- The Environmental Services Director or his designated agent may decide in certain instances that the installation of a grease interceptor on an existing facility property is physically impossible due to space limitations, is not feasible due to inadequate slope for proper gravity flow, or for other reasons. In these instances, an approved grease trap, or traps, meeting the design specifications listed herein, shall be allowed. The facility manager shall be responsible for an aggressive kitchen Best Management Practices and grease trap maintenance program to produce wastewater that meets the FOG discharge requirements.
Grandfathering of Existing Users
- Existing facilities in which a grease trap or interceptor has been installed prior to the effective date of this Regulation shall be allowed to continue operation of the existing unit only if the device is effective in producing wastewater that meets the FOG discharge limits.
- An existing user which operates a grease trap may be required to add a sample valve to the discharge line from the device and prior to a union with any sanitary sewer line in the building. This requirement shall typically be limited to facilities in which there is a history of poor grease trap maintenance.
- An existing user which expands its food service operations may be required to install a larger grease trap, additional grease traps, or a grease interceptor to replace, or operate in conjunction with, an existing grease trap.
Grease Interceptor Plan Submittal: Facilities required to install a grease interceptor shall submit the following to the Town:
- A completed FOG Waste Discharge Permit application.
- Detailed calculations by a licensed engineer showing the design and size of the grease interceptor.
- A complete list of all kitchen fixtures in which the dimensions and drain sizes of all sinks shall be included, as well the discharge flow rates of all dishwashers as determined by the manufacturer’s specifications.
- Plans that show the location and detail of the grease interceptor and the kitchen fixture plumbing.
Design, Sizing, And Installation Requirements
- All grease traps and interceptors shall be designed, sized, and installed according to the standards of the Uniform Plumbing Code, and the Town’s General Water and Sewer Construction Specifications, and be of a type, capacity, and location approved by the Town.
- Various formulas exist to calculate the proper size of a grease interceptor. The Town shall not require the use of any one formula, but rather the use of sound engineering judgment in this instance. The Environmental Services Director or his designated agent shall make all final decisions on the requirement for a specific grease control device, its design, and its size.
- General specifications are as follows.
A grease trap shall:
- be constructed of corrosion-resistant metal or plastic;
- be accessible for cleaning, maintenance, and inspection;
- contain properly installed and functioning baffles necessary to achieve the appropriate retention time to allow for proper separation of FOG and solids from the remaining wastewater;
- handle the flow from no more than three (3) kitchen sinks, and shall be located inside the facility as close to the sink(s) as possible;
- never receive wastewater from sanitary sewer lines;
- not receive discharge that exceeds 120 degrees Fahrenheit;
- not receive discharge from a dishwasher or food grinding unit;
- be installed with an approved flow control or restricting device to restrict the flow to the rated capacity of the trap, and for cleaning purposes; and
- be installed with a sample valve on the discharge line from the device and prior to a union with any sanitary sewer line in the building.
A grease interceptor shall:
- be constructed of precast concrete with a minimum compressive strength of 3,000 psi.
- be sized from a minimum of 1,000 gallons to a maximum of 3,000 gallons.
- contain multiple chambers and properly positioned tee piping to achieve a thirty (30) minute retention time before wastewater is discharged to the Town’s sewer system.
- be installed on the facility property and in a location outside the facility, with access for inspection, cleaning, pumping, and maintenance.
- not be installed in areas subject to heavy traffic, where possible, and shall be accessible for inspections at all times, having no permanent or temporary structure or container placed directly over the unit.
- have a minimum 24” diameter manhole, extended to finish grade, over each chamber, interior baffle wall, and sanitary tee.
- have solid manhole covers that are traffic rated and that prevent infiltration of storm water or other surface water. Any gaskets shall be positioned beneath the cover.
- be designed with a minimum 8” diameter sample box or sample tee at the outlet.
- receive the discharge from all facility drains and fixtures through which grease may be released, including all sinks, floor drains, food grinding units, and dishwashers.
- never receive wastewater from sanitary sewer lines.
- be installed at a minimum distance of ten (10), and a maximum distance of fifty (50) feet from dishwashers and sinks to allow for optimal cooling of the wastewater.
- not receive discharge that exceeds 150 degrees Fahrenheit.
- include a properly-sized solids interceptor, and have its volume increased by 25%, when receiving discharge from a food grinding unit.
- be installed with an approved flow control or restricting device to stop the flow for cleaning purposes.
- Permit Required: All commercial food service users, and institutions and industries with food service, which currently possess, or are required to install a grease trap or grease interceptor, shall be required to obtain a FOG Waste Discharge Permit. It shall be unlawful for such facilities to discharge to the Town’s sanitary sewer system without first obtaining a permit.
Contents of Permit: The permit application shall, at a minimum, include the following information:
- Name, address, and telephone number of applicant, and name, address, and telephone number of the owner of the facility.
- A description of the food service operations, cuisine, the hours of operation, and number of meals served per day.
- A summary of all kitchen and food preparation appliances, their sizes and locations, and any grease traps or other pretreatment equipment currently installed.
Town’s Right to Require Additional Information: Other information related to the user’s food service operations and potential food service discharges may be requested to properly evaluate the permit application. The Town may refuse to process an application further until the information is provided.
Review of Applications: The completed FOG Waste Discharge Permit application shall be submitted to the Town for review. The Town may elect to inspect the facility during its normal business hours. If the application is accepted, a draft permit shall be issued within thirty (30) days after receipt of the permit application. The applicant shall be allowed a thirty (30) day comment period. Upon expiration of the comment period, the Town shall issue or deny a permit. A permit shall contain general, and possibly specific, conditions for the facility.
Permit Duration: Permits shall be issued for a period not to exceed five (5) years. An expired permit shall continue to be in effect and enforceable if failure to reissue the permit is not due to any delinquency on the part of the facility. No permit shall be transferable to another facility or to another entity operating the same facility.
Denial of Permits: Denial of a permit shall be based upon an incomplete or inaccurate application, an unacceptable size and/or design of the grease interceptor, failure to pay fines that have been levied, a history of FOG discharge violations, or other related factors.
V) FOG WASTE DISCHARGE PERMIT CONDITIONS
VI) GENERAL MAINTENANCE OF GREASE TRAPS AND INTERCEPTORS
VII) SAMPLING AND TESTING: The Town shall collect and analyze annual samples for laboratory testing to determine if a user is in compliance with the requirements of this Regulation. The expense of any additional sample collection, shipment, and analyses shall be borne by the user.
Limits and Conditions: The issuance of a FOG Waste Discharge Permit shall contain the following limits or conditions:
A limit of 100 parts per million of FOG, measured as Hexane Extractable Material, in the discharge from the facility grease interceptor.
A requirement for annual laboratory testing of FOG, BOD and suspended solids to be at the expense of the Town. Testing shall be conducted at least annually to document that the above is being met. Any sampling and testing performed in addition to the annual testing required by the permit shall be at the expense of the user.
A requirement for the proper operation and maintenance of the grease interceptor and any other grease control devices.
The documentation of a cleaning and maintenance schedule for the grease interceptor and any other grease control devices.
A requirement for implementation and documentation of kitchen Best Management Practices.
A requirement to report to the Town any anticipated expansion of food service operations prior to initiating such a project.
The issuance of a permit shall not relieve the user from complying with all applicable laws, regulations and ordinances promulgated by other governmental authorities.
The user agrees to hold harmless the Town and its employees from any liabilities arising from the facility’s operations.
Future Modifications of Permits: The terms and conditions of the permit are subject to modification by the Town at any time as just cause exists. The user shall be informed of any proposed change in the issued permit at least thirty (30) days prior to the effective date of the change, and shall be given a reasonable timetable for compliance.
Proper maintenance of grease traps and interceptors is crucial to establish optimal efficiency of the devices. They shall be cleaned as often as necessary to ensure that:
floating material and sediment do not accumulate to impair the operation of the device.
the discharge of FOG to the Town’s sanitary sewer system meets the stated limitations.
no visible grease is observed in the discharge.
Upon request, the Town shall provide information that describes proper cleaning and maintenance of the devices. However, due to varying designs and sizes, the user shall follow specific manufacturer guidelines for cleaning and maintenance, at a minimum, in all instances. General guidelines for cleaning and maintenance include:
Grease traps and interceptors shall be kept free at all times of such solid materials as gravel, sand, bones, shells, cigarettes, utensils, towels and rags that will reduce the effective volume of the device and increase the frequency of cleaning.
The total depth of the surface FOG, combined with the settled solids, should not exceed approximately 25% of the total depth of the liquid/solid column.
Based upon the above, a grease trap will typically require cleaning every 1-4 weeks, and a grease interceptor will generally require cleaning every 2-4 months. However, the actual loading on a device will determine the specific cleaning schedule.
Kitchen Best Management Practices: The application of kitchen Best Management Practices (BMPs) serves as a critical initial step in reducing the amount of oil and grease that enters a facility’s grease control device, and therefore in prolonging the periods between cleaning and maintenance. All facilities with food service operations shall establish kitchen BMPs, and provide continuous training and monitoring of employees.
Waste Grease Disposal:All facilities are encouraged to use designated buckets for the disposal of waste grease removed from grease traps during cleaning. Such material shall not be combined with cooking oil that is to be recycled. Buckets should have a well-sealing lid and shall be disposed at a disposal site permitted to receive such waste.
Grease Interceptor Cleaning And Maintenance: Specific requirements for the servicing of grease interceptors shall include the following:
Cleaning and related maintenance shall be contracted to a company that is approved by the Town and permitted by the State of Virginia to transport waste.
Such service shall be performed at least every four (4) months, unless written permission for a schedule of less frequent service has been obtained from the Town.
Cleaning and maintenance shall include the evacuation of all contents of the interceptor, including floating materials, wastewater, and settled solids.
All waste removed from an interceptor shall be disposed at a disposal site permitted to receive such wastes.
Clean water shall be returned to the interceptor following waste evacuation and cleaning.
Other than the clean water immediately returned to the interceptor to complete maintenance, none of the waste material removed from an interceptor shall be discharged to the Town’s sanitary sewer system.
Prohibitions: The following practices and devices are prohibited:
Any modification of a grease interceptor, such as alteration or removal of a flow constricting device, that causes flow to rise above the design capacity of the unit or reduce the retention time.
Interceptor cleaning that involves only skimming the surface layer, partial cleaning, or the use of any method that does not remove the entire contents of the vessel.
The introduction of such agents as concentrated detergents, other surfactants, emulsifiers, degreasers, solvents, or any other type of product that will liquefy grease wastes.
The addition of any chemical enzyme product unless written permission has been granted by the Town.
The addition of bacteria unless written permission has been granted by the Town.
The use of automatic, or mechanically operated, grease removal systems, unless written permission has been granted by the Town.
Facilities with a grease control device shall maintain records of all cleaning and maintenance of the device. These records shall include, at a minimum:
the date and time of service
the name and signature of user representative who performed or witnessed the service
the contract company which performed the service (if applicable)
the name and signature of the contract company employee (if applicable)
the gallons of waste removed
a copy of the service record or manifest from the contract company (if applicable)
All facilities shall keep records of their waste grease disposal or recycling, including the number and size of containers, the dates on which they were disposed of or recycled, and the name and contact information of the disposal or recycling service or location.
Records shall be placed in a logbook, folder, or binder, shall be maintained on site for at least three (3) years, and shall be immediately made available to the Town on demand during an inspection, or at intervals specified in a permit.
Any falsification of required records is a violation of this policy.
Right of Entry and Inspections: Authorized representatives of the Town shall have the right to enter the premises of any facility operating a grease control device to determine whether the user is in compliance with all requirements of this Regulation. Entry shall be during normal operating hours and for the purpose of inspection and evaluation of the facility’s grease control program. If entry is refused, the Town shall have recourse to the remedies provided by law for entry.
Inspection may involve any or all of the following items:
the integrity of the grease control device,
the amount of grease present in the device,
wastewater appearance and clarity,
cleaning and maintenance records,
waste grease disposal and recycling storage and records,
all food processing areas and fixtures, and
sampling of discharge water from the device.
It shall be the responsibility of the user to keep its grease control devices accessible at all times. The Town shall have the option of requesting that a grease trap be opened by a representative of the user.
The result of the inspection shall be made available to the user’s representative verbally. A written report shall be mailed within ten (10) business days of the inspection if the facility is found to be out of compliance with any of the requirements outlined in this Regulation, and shall include the necessary corrective action and a timetable for accomplishing such improvements.
Frequency of Sampling: Sampling shall be at least annually from any facility maintaining a grease trap/interceptor and holding an FOG Waste Discharge Permit, and shall consist of FOG, BOD and suspended solids testing. Additional sample collection and testing shall be at the discretion of the Town, and shall relate to a history of the user’s discharge, or to existing conditions.
Sampling Methods and Cost: Sampling shall involve grab samples which are collected, stored, transported, and analyzed in accordance with the procedures specified in 40 CFR Part 136. All annual testing required by the permit shall be conducted by the Town’s wastewater laboratory at the Town’s expense. Any additional sampling and testing required by the Town to demonstrate compliance for facilities that have experienced non-complyingdischarges, shall be conducted by a private commercial laboratory which is in good standing with the Virginia Department of Environmental Quality and shall be at the user’s expense.
Sample Collection: Sample collection from a grease interceptor shall be from the sample box at the outlet of the device, if present, or from the nearest manhole. Sample collection from a grease trap shall be from the sample valve at the outlet of the device, if present, or from the nearest manhole.
Analysis Reports: A copy of the analysis report of any laboratory testing on samples collected from a facility by anyone other than the Town shall be provided directly to the Town. The Town shall mail a copy to the user within ten (10) business days of receipt by the Town. The report shall include, at a minimum, an explanatory cover letter, the chain of custody form, the laboratory at which testing took place, the results of the testing, the test methods used, and the dates of analyses.