Colorado Springs Utilities FOG Manual by nyut545e2

VIEWS: 72 PAGES: 33

									Fats, Oil and Grease Policies
and Procedures Manual

                January 2003




           Colorado Springs Utilities
       Industrial Pretreatment Program
          845 East Las Vegas Street
         Colorado Springs, CO 80903
                 719/668-4506
                                                      Table of Contents
EXECUTIVE SUMMARY.............................................................................................................................. 1

INTRODUCTION........................................................................................................................................... 2

DEFINITIONS................................................................................................................................................ 4

LEGAL AUTHORITY.................................................................................................................................... 6
       Discharge Prohibitions .......................................................................................................................... 7
       Duty to Enforce ...................................................................................................................................... 9
COMPLIANCE REQUIREMENTS .............................................................................................................. 9
   BEST MANAGEMENT PRACTICES .................................................................................................................. 9
   QUESTIONNAIRE .......................................................................................................................................... 9
   CONTROL PLAN ......................................................................................................................................... 10
   GREASE INTERCEPTORS ............................................................................................................................ 10
BMP REQUIREMENTS.............................................................................................................................. 10
   DESCRIPTION AND APPLICABILITY .............................................................................................................. 10
   FOOD SERVICE ESTABLISHMENTS.............................................................................................................. 11
     Employee Training and Awareness.................................................................................................... 11
     Garbage Disposals and Drain Screening........................................................................................... 11
     Dry Clean-up........................................................................................................................................ 12
     Spill Prevention and Clean-up ............................................................................................................ 12
     Dishwashing and Equipment Cleaning .............................................................................................. 12
     Recycling.............................................................................................................................................. 13
     Beneficial Use of Food Wastes........................................................................................................... 13
     Grease Traps....................................................................................................................................... 13
   PRIVATE DWELLINGS ................................................................................................................................. 14
   BUILDING DRAINS AND SERVICES MAINTENANCE ....................................................................................... 14
GREASE INTERCEPTORS....................................................................................................................... 14
   DESCRIPTION AND APPLICABILITY .............................................................................................................. 14
   INSTALLATION REQUIREMENTS................................................................................................................... 15
     General................................................................................................................................................. 15
     New Food Service Establishments..................................................................................................... 15
     Existing Food Service Establishments ............................................................................................... 16
   INSTALLATION SPECIFICATIONS .................................................................................................................. 17
     Additional Considerations ................................................................................................................... 17
   OPERATION AND MAINTENANCE ................................................................................................................. 18
     Operation ............................................................................................................................................. 18
     Inspection............................................................................................................................................. 18
     Cleaning ............................................................................................................................................... 18
     Recordkeeping..................................................................................................................................... 19
PUBLIC EDUCATIONAL MATERIALS.................................................................................................... 20

ENFORCEMENT PROCEDURES ............................................................................................................ 20
   DESCRIPTION AND APPLICABILITY .............................................................................................................. 20
     Blockage and Overflow Investigation ................................................................................................. 20
   ENFORCEMENT RESPONSES ...................................................................................................................... 21
     Informal Administrative Enforcement Remedies ............................................................................... 21
     Formal Administrative Enforcement Remedies ................................................................................. 23
PROGRAMMATIC MATERIALS............................................................................................................... 24


                                                                               I
Executive Summary

      Fats, oil and grease, collectively known as FOG, are found in most kitchens and Food
      Service Establishments. Waste FOG is generated during the food preparation,
      kitchenware and equipment maintenance, and sanitizing processes. Many foods that are
      processed and served contain FOG, including meats, sauces, gravy, dressings, deep-fried
      foods, baked goods, cheeses, butter and others. The discharge of FOG to sanitary sewer
      systems is a problem because the FOG can accumulate in the sewer and cause a backup
      or overflow resulting in significant hazards to public health, and hazards to the Food
      Service Establishment, damage to other establishments and residences, or damage to the
      public sewer system. This manual was prepared to define the FOG management
      recommendations, requirements and expectations to which Food Service Establishments
      within the Colorado Springs Utilities service area shall be held.

      The Legal Authority for Colorado Springs Utilities to implement a FOG management
      program is provided by Federal pretreatment regulations, Colorado Discharge Permit
      System permit requirements, and City of Colorado Springs code.

      Compliance Requirements can be imposed under this program. These requirements can
      include implementation of Best Management Practices, completion of a quarterly
      questionnaire, development of a FOG Control Plan, and installation of a Grease
      Interceptor.

      Best Management Practices are procedures and practices that reduce the discharge of
      FOG to the building drain system and to the wastewater system. This manual provides
      descriptions of Best Management Practices for promoting employee awareness, use of
      garbage disposals and sink drains, dish and equipment washing, spill prevention and
      cleanup, FOG recycling and beneficial uses of food wastes, and Grease Trap
      maintenance. It is recommended that all Food Service Establishments develop and
      implement a Best Management Practices program that is consistent with the FOG sources
      at the establishment.

      A Grease Interceptor is an outside, underground compartment that separates FOG from
      water. The installation and maintenance of a Grease Interceptor is an important measure
      in ensuring that a Food Service Establishment does not contribute to problems with the
      sanitary sewer system. For Grease Interceptors to be effective, the units must be properly
      sized, constructed, installed in a readily accessible location, and regularly maintained.
      This manual defines grease interceptor installation, operation, and maintenance
      requirements for new and existing Food Service Establishments. It is recommended that
      all Food Service Establishments inspect their Grease Interceptor at least every 3 months
      and perform cleaning when FOG and solids reach 25 percent of the unit’s capacity. It is
      recommended that all Food Service Establishments maintain records of all inspection and
      maintenance activities.

      An array of Enforcement remedies is available to ensure proper FOG management.




                                           1
Introduction

       FOG: What is it?

       FOG refers to fats, oil and grease found in most residential and commercial kitchens and
       Food Service Establishments. Waste FOG is a semisolid, viscous liquid that is generated
       during the food cooking process or during cleaning, maintenance, and sanitizing
       processes. Many foods that are processed and served contain FOG, including meats,
       sauces, gravy, dressings, deep-fried foods, baked goods, cheeses, butter and others.
       Residential users and many different businesses generate FOG wastes by processing or
       serving food, including; eating and drinking establishments, caterers, hospitals, nursing
       homes, day care centers, schools and grocery stores.

       What's the problem with FOG?

       Liquid wastes containing FOG that are dumped down the sewer drain can coagulate and
       congeal into a hardened layer on the inside of building drain pipes and wastewater
       Collection Lines in the Wastewater Treatment System. This causes a reduction in the
       effectiveness of these Collection Lines to transport wastewater away from residences and
       businesses to the wastewater treatment plant. Wastes containing FOG can accumulate
       on the inside of these pipes and Collection Lines to such an extent that the building drains
       and wastewater Collection Lines become blocked with FOG. When building drains and
       wastewater Collection Lines become blocked, the flow of wastewater is obstructed and the
       operation of the Wastewater System is interfered with causing wastewater to back up into
       your business and also backup into residences and businesses within the vicinity of the
       blockage. These blockages can result in significant public health hazards as well as
       physical and property damages. If the FOG causing the wastewater Collection Line
       blockage originates from your business, you may likely be the first one affected. When
       wastewater backs up into a business that prepares and/or serves food (or any other facility
       or residence), a significant public health hazard is present for you and your customers, the
       business becomes disrupted, physical damages to the business property and assets
       occur. When wastewater Collection Lines become blocked with FOG, untreated
       wastewater may also overflow out of the Wastewater System into streets, parking lots,
       storm sewers, and ultimately to the environment. As numerous factors can contribute to
       sanitary sewer overflows, including residential discharges containing FOG, antiquated
       infrastructure and root accumulation, it is important to note that sole and excessive blame
       is not placed on restaurants for sanitary sewer overflows or wastewater blockages caused
       by FOG.

       Why should you care about FOG?

       Colorado Springs Utilities maintains a record of maps of the Wastewater System and
       several portable video surveillance cameras capable of tracking problems and blockages
       caused by FOG wastes. Colorado Springs Utilities uses this information to identify the
       sources of FOG wastes that have caused problems and blockages, and can initiate
       enforcement actions against businesses to insure compliance with the City Code.

       As mentioned previously, physical damage can occur when wastewater backs up into a
       residence or business, as a result of a blockage of FOG wastes. When Colorado Springs
       Utilities initiates enforcement actions for Wastewater System blockages, those responsible
       can be liable for: physical/monetary damages caused to others: costs incurred by
       Colorado Springs Utilities to respond to the blockage; and fines and penalties for


                                             2
noncompliance with the City Code. When more than one food service establishment
discharges into the wastewater system involved in the blockage, such as in a strip mall,
those establishments not using best management practices to control FOG may be held
responsible.

Any persons or businesses affected by a wastewater collection system blockage or
overflow can contact Colorado Springs Utilities at 448-4800 to file a complaint.

Federal Response

Federal General Pretreatment Regulations (40 CFR Part 403) currently prohibit any User
of a Wastewater Treatment System from discharging solid or viscous pollutants, such as
FOG, in amounts that will cause obstructions (blockages) to the flow in, and the operations
of, the Wastewater System. Businesses that cause or contribute to blockages in the
Wastewater System, because of FOG wastes, are in violation of the Clean Water Act.
These regulations also require owners and operators of public wastewater utilities, such
as Colorado Springs Utilities, to develop local regulations and programs to minimize
Wastewater System blockages that interfere with system operations, and to enforce these
regulations against businesses that cause blockages.

State Response

The Colorado Department of Public, Health and Environment (herein the “State”) has also
expressed concern with FOG wastes and their effect on wastewater pretreatment. The
State has Pretreatment Regulations (5 CCR 1002-63) that are equal to, or more stringent
than, the Federal General Pretreatment Regulations. The State's Hazardous Materials
and Waste Management Division has issued a Solid Waste Compliance Bulletin regarding
Grease Trap wastes.

Colorado Springs Utilities Response

Different utilities across the nation control discharges of FOG wastes to their Wastewater
Systems through various methods. FOG control can be either proactive or reactive.
Reactive FOG control programs respond to instances of pump station and wastewater
Collection Line blockages, or sewage backups. Proactive FOG control programs require
FOG generators to employ Best Management Practices, install grease collection
equipment, properly operate and maintain that equipment, and keep records of those
activities. Colorado Springs Utilities uses both proactive and reactive methods to control
FOG.

About this manual

This manual will describe various aspects of the FOG control program, such as; Colorado
Springs Utilities’ legal authority to implement this program, compliance requirements of the
FOG Control Program, Best Management Practices to control FOG in wastewater
discharges, sizing criteria and specifications for installing Grease Interceptors, public
educational materials, and enforcement procedures to address noncompliance.

Defined terms have initial capitals throughout this manual.




                                      3
Definitions

        Best Management Practices (BMPs): Schedules of activities, prohibitions of practices,
        maintenance procedures, and other management practices to prevent or reduce the
        pollution of waters of the State. For purposes of this manual, Best management Practices
        include procedures and practices that reduce the discharge of Fats, Oil and Grease (FOG)
        to the building drain and to the Wastewater System.

        Chief Executive Officer: The "Utilities Director" appointed pursuant to City Charter section
        6-10. The term " Chief Executive Officer " includes the Chief Executive Officer of utilities
        and the Chief Executive Officer's designees, if any.

        City Code: City Code of the City of Colorado Springs (2001).

        Collection Line: That portion of the Wastewater Treatment System, which collects and
        transmits Wastewater from Users to the wastewater treatment plant, excluding Service
        Lines.

        Colorado Discharge Permit System (CDPS) permit: Means, for purposes of this manual,
        Colorado Discharge Permit System Permit No. CO-0026735 issued by the State to the
        City of Colorado Springs.

        Domestic Wastes or Wastewaters: (i) Wastewater from normal residential activities
        including, but not limited to, Wastewater from kitchen, bath, and laundry facilities; (ii)
        Wastewater from the personal sanitary conveniences (toilets, showers, bathtubs,
        fountains, non-commercial sinks and similar structures) of commercial, industrial or
        institutional buildings, provided that the Wastewater exhibits characteristics that are similar
        to those of Wastewater from normal residential activities; and (iii) Specifically excluded is
        Wastewater from commercial, industrial or institutional laundries or food preparation
        facilities.

        Effective Date: The date of adoption of this manual by the Chief Executive Officer of
        Colorado Springs Utilities, or his/her designee, as provided on the adoption page to this
        manual.

        Existing Food Service Establishment: Any Food Service Establishment, which is not a
        New Food Service Establishment.

        Fat, Oil and Grease (FOG): A semi-solid, viscous liquid organic polar compound 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 40 Code of Federal Regulations (CFR) Part 136, as may be amended.

        Food Service Establishment: A commercial facility engaged in preparing and/or serving
        food for consumption by the public, such as a restaurant, commercial kitchen, caterer,
        hotel, school, hospital, prison, correctional facility, and care institution.

        Grease Interceptor: A tank that serves one or more fixtures and is remotely located. Such
        Grease Interceptors include, but are not limited to tanks that capture Wastewater from
        dishwashers, floor drains, pot and pan sinks and trenches. For purposes of this manual, a
        Grease Interceptor is an outside, underground, multi-compartment tank that reduces the



                                               4
amount of FOG in Wastewater prior to discharging into the Wastewater Treatment
System.

Grease Trap: A device designed to retain grease from one to a maximum of four fixtures.
A Grease Trap is not appropriate for use on heated water (e.g., dishwasher) or in-line to a
waste disposal unit (e.g., garbage disposal and grinders). For purposes of this manual, a
Grease Trap is a small, indoor device.

Industrial User: A source of discharge, which introduces pollutants into the Publicly-Owned
Treatment Works from any non-domestic source.

Interference: A discharge which, alone or in conjunction with a discharge or discharges
from other sources:

    i)       Inhibits or disrupts the Publicly-Owned Treatment Works, its treatment
             processes or operations, or its sludge processes, use or disposal; and

    ii)      Therefore is a cause of a violation of any requirement of the Publicly-Owned
             Treatment Works’ CDPS permit.

Liquid Waste Hauler: Any person, firm, corporation or other entity that collects, pumps,
transports and/or disposes of liquid wastes.

New Food Service Establishment: Any Food Service Establishment for which (1) a
contract for construction or significant reconstruction has not been entered into prior to the
Effective Date of this manual; or (2) for which tenant finish in a pre-existing building has
not commenced prior to the Effective Date of this manual. Generally, significant
reconstruction will be presumed to have taken place where the capital cost of the new
construction exceeds $100,000.

Non-Significant Industrial User Control Mechanism: A written authorization to discharge
issued to other than Significant Industrial Users as a pollution prevention measure to
minimize pollutant loading by Industrial Users.

Publicly Owned Treatment Works (POTW): For purposes of this manual means, any
devices, facilities, structures, equipment or works owned by the City or used by Utilities for
the purpose of the transmission, storage, treatment, recycling and reclamation of Industrial
and Domestic Wastes, or necessary to recycle or reuse water at the most economical cost
over the estimated life of the system, including intercepting sewers, outfall sewers,
Collection Lines, pumping, power and other equipment, and their appurtenances and
excluding Service Lines.

Service Line: The wastewater collector line extending from the wastewater disposal
facilities of the premises up to and including the connection to the Collection Line.

Standards & Specifications: Colorado Springs Utilities Standard Specifications for the
Installation of Sanitary Sewer Mains and Services.

User: Any person, firm, corporation, government or other entity that discharges, causes or
permits the discharge of Wastewater into the POTW.




                                       5
         Wastewater: The liquid and water-carried Industrial or Domestic Wastes and pollutants
         from dwellings, commercial buildings, industrial facilities and institutions, including hauled
         liquid waste, and any groundwater, surface water and stormwater that may be present,
         whether treated or untreated.

         Wastewater Treatment System: See definition of Publicly Owned Treatment Works.

         Wastewater System: See definition of Publicly Owned Treatment Works.


Legal Authority

Pretreatment Program Authority

         The control of discharges of FOG into the Wastewater Treatment System is part of a
         larger program to regulate discharges of non-domestic wastes, referred to as the
         “pretreatment program.” The pretreatment program is a national program required by the
         federal Clean Water Act and developed by the United States Environmental Protection
         Agency (EPA). The intent of the pretreatment program is to assure that all pollutants
         discharged to a sanitary sewer system are treated properly before release to the
         environment. Certain pollutants can “pass-through” a treatment plant without being
         treated and other pollutants can “interfere” with treatment processes or the collection
         portion of the Wastewater System. Thus, dischargers may be required to “pre-treat”
         certain non-domestic wastewaters before they enter the Wastewater Treatment System.

         The national pretreatment program requires all POTWs with design flow greater than 5
         million gallons per day, to establish local pretreatment programs. Colorado Springs
         Utilities treats approximately 46 million gallons of wastewater per day, and so is required to
         develop a local pretreatment program. The original Colorado Springs pretreatment
         program was approved by the EPA in 1982, as well as all subsequent modifications.

         All commercial and industrial dischargers to the Wastewater Treatment System are
         subject to regulation under the national and local pretreatment programs. Dischargers that
         introduce non-domestic pollutants into the Wastewater Treatment System are referred to
         as “Industrial Users.” In Colorado Springs, discharges by Industrial Users are regulated by
         a variety of means, including via permit, the City Code, Best Management Practice Plans
         or other control mechanisms, depending on the significance of the discharge to the
         Wastewater Treatment System.

         The Colorado Springs pretreatment program is implemented as a partnership between
         EPA, the State of Colorado (State) and Colorado Springs Utilities. The EPA Headquarters
         oversees development and enforcement of the national pretreatment program. The EPA
         Regional Office approves the Colorado Springs pretreatment program, provides technical
         assistance and may enforce against Colorado Springs and the Industrial Users of our
         Wastewater Treatment System. The State requires implementation of the national
         pretreatment program through the discharge permit it issues to Colorado Springs for
         discharges from its Wastewater Treatment System. The State can also enforce against
         Colorado Springs and Industrial Users for non-compliance with the national and local
         pretreatment program. Finally, Colorado Springs Utilities administers all aspects of the
         pretreatment program at the local level.




                                                6
FOG Control Authority

          The Colorado Springs pretreatment program is implemented through the City Code and
          various manuals, such as this one, including the Enforcement Response Plan and the
          Silver Source Control Manual. Legal authority for the specific provisions of this manual
          presently exists in the City Code. Such authority is noted in the relevant sections of this
          manual.

          Discharge Prohibitions

          Federal prohibitions on discharge to Wastewater Treatment Systems are mimicked in the
          Colorado Springs Wastewater Treatment Code (City Code Chapter 12, Article 5) and in
          the discharge permit issued by the State to the City of Colorado Springs (Authorization to
          Discharge Under the Colorado Discharge Permit System (CDPS) Permit No. CO-
          0026735). Prohibitions relevant to the discharge of FOG include the following.

          General prohibition against Interference

          Federal - 40 CFR § 403.5(a)(1):

              “A User may not introduce into a POTW any pollutant(s) which cause Pass Through
              or Interference.”

          CDPS Permit: No. CO-0026735, Part I, § A.8e.x:

              “The Permittee shall prohibit the introduction of the following pollutants into the
              [Domestic Wastewater Treatment Works] DWTW:

              (x) Any other pollutant that may cause Pass Through or Interference.”

          Specific prohibition against solid or viscous pollutants

          Federal - 40 CFR § 403.6(b)(3):

              “[T]he following pollutants shall not be introduced into a POTW:

              (3) Solid or viscous pollutants in amounts which will cause obstruction in the flow in
              the POTW resulting in Interference; . . .”

          CDPS Permit: No. CO-0026735,

              Part A.8.a: “The Permittee has the responsibility to protect the Domestic Wastewater
              Treatment Plant (DWTW) [sic], as defined at section 25.8.201(5) of the Colorado
              Water Quality Control Act, or the Publicly-Owned Treatment Works (POTW). As
              defined at 40 CFR 404.4(d) of the federal pretreatment regulations, from pollutants
              which would inhibit, interfere, or otherwise be incompatible with operation of the
              treatment works . . .”

              Part I, § A.8e.iii: “The Permittee shall prohibit the introduction of the following
              pollutants into the DWTW:

              Solid or viscous pollutants in amounts which will cause obstruction to the flow in the
              DWTW, or other interference with the operation of the DWTW; . . .”



                                                  7
City Code § 12.5.702:I:

    “It shall be unlawful for any Person to discharge or deposit or cause or allow to be
    discharged or deposited into the Wastewater Treatment System any wastes or
    Wastewater which contains the following: . . .

Solid, viscous or liquid wastes which allow or may cause obstruction to the flow in a
Collection Line or otherwise interfere with the proper operation of the Wastewater
Treatment System.

”Specific prohibition against Interference

Federal - 40 CFR § 403.6(b)(4):

    “[T]he following pollutants shall not be introduced into a POTW:

    (4) Any pollutant, including oxygen demanding pollutants (BOD, etc) released in a
    Discharge at a flow rate and/or pollutant concentration which will cause Interference in
    the POTW; . . .”

CDPS Permit: No. CO-0026735, Part I, § A.8e.iv & x

    “The Permittee shall prohibit the introduction of the following pollutants into the
    DWTW:

    (iv) Any pollutant, including oxygen demanding pollutants (e.g., BOD), released in
    discharge at a flow rate and/or pollutant concentration which will cause Interference
    with the DWTW; . . .”

City Code § 12.5.702:P:

    “It shall be unlawful for any Person to discharge or deposit or cause or allow to be
    discharged or deposited into the Wastewater Treatment System any wastes or
    Wastewater which contains the following: . . .

    P. Any pollutant, including oxygen demanding pollutants (e.g., BOD) released in a
    discharge at a flow rate and/or pollutant concentration which will cause Interference
    with the POTW.”

In order to understand these regulatory, permit and City Code prohibitions, it is necessary
to understand the definitions of the terms within the provisions. A publicly owned
treatment works (POTW) is defined to include the Collection Lines (40 CFR § 403.3(o);
City Code § 12.5.201:A). The term “Interference” includes a discharge that, alone or in
conjunction with discharges from other sources, inhibits the operations of the POTW and
causes a violation of the POTW’s discharge permit (40 CFR § 40303(I) and City Code §
12.5.201:A). Relevant portions of the regulatory and/or City Code definitions are provided
in the “Definitions” section of this manual.

A discharge of FOG, which causes a blockage of a Collection Line resulting in a release of
wastewater in violation of the Colorado Springs discharge permit, is a violation of the
Colorado Springs pretreatment requirements.




                                       8
         Duty to Enforce

         Federal and state regulations require that the POTW enforce pretreatment standards and
         requirements. Federal regulations require that the POTW demonstrate that it has the legal
         authority, resources and funding to require compliance by, and obtain remedies from,
         Industrial Users (40 CFR § 403.8). The State-issued CDPS permit for Colorado Springs
         provides, in Part I, § A.8:

             g) Section 309(f) of the [Clean Water] Act provides that EPA may issue a notice to the
             DWTW stating that a determination has been made that appropriate enforcement
             action must be taken against an industrial user for noncompliance with any
             Pretreatment standards and requirements. The notice provides the DWTW with 30
             days to commence such action. The issuance of such permit notice shall not be
             construed to limit the authority of the permit issuing authority or [EPA].

             h) . . . In those cases where a CDPS permit violation has occurred because of the
             failure of the Permittee to properly develop and enforce Pretreatment Standards and
             requirements as necessary to protect the DWTW, the state permitting authority and/or
             [EPA] shall hold the Permitttee responsible and may take legal action against the
             Permittee as well as the [Industrial User] contributing to the permit violations.


 Compliance Requirements

Best Management Practices

         This manual provides guidance and recommendations for all Food Service
         Establishments provided wastewater utility services by Colorado Springs Utilities to
         conform to Best Management Practices to control FOG wastes. Best Management
         Practices are practices, procedures, and maintenance activities performed by Food
         Service Establishments to reduce the FOG in the Wastewater discharge. Best
         Management Practices are described in greater detail in the section of this manual titled
         “Best Management Practices.” Food Service Establishments causing or contributing to
         wastewater system blockages will be required to conform to BMPs.

         The legal authority for requiring conformance to Best Management Practices is contained
         in City Code § 12.5.802.

Questionnaire

         This manual provides that, when required by the Chief Executive Officer, or designee,
         Food Service Establishments shall file a completed fat, oil, and grease wastewater
         discharge questionnaire (report) on forms provided by the Chief Executive Officer.
         Examples of this questionnaire are contained in the Appendix of this manual, titled “Fat,
         Oil and Grease Wastewater Discharge Questionnaire (Report)”. This questionnaire shall
         be submitted quarterly, not later than 30 days after receipt of the report form from the Chief
         Executive Officer. Generally, Food Service Establishments, which have caused or
         contributed to a wastewater system blockage, will be required to file such questionnaires.
         If there are multiple establishments discharging to an obstructed pipeline it will be
         assumed that those establishments not following Best Management Practices, contributed
         to the sanitary sewer overflow.



                                                9
          The legal authority for requiring Food Service Establishments to complete and submit a
          questionnaire is contained in City Code § 12.5.901:A., B.

Control Plan

          Food Service Establishments may be required to submit a fat, oil and grease control plan.
          Criteria to require Food Service Establishments to submit a FOG control plan may include,
          but are not necessarily limited to, conditions in the Wastewater Collection Line serving the
          Food Service Establishment; the degree of conformance to Best Management Practices
          by the Food Service Establishment; and the compliance history of the Food Service
          Establishment at that location or other locations (has the establishment caused or
          contributed to wastewater system blockages). A FOG control plan must include, but not
          be limited to include: Best Management Practices used by the establishment (e.g.,
          procedures to prevent discharges of waste fat, oil and grease, waste FOG handling,
          storage, and disposal procedures); a description of the Food Service Establishment
          operation; a description of the location and size of any Grease Interceptors and Grease
          Traps present; a description of how the Grease Interceptor or Grease Trap will be
          maintained (cleaned), including frequency of cleaning; and a description of how the Food
          Service Establishment will comply with reporting requirements.

          The legal authority for requiring Food Service Establishments to submit a FOG control
          plan is contained in City Code § 12.5.804 and 12.5.811.

Grease Interceptors

          There are Building and Plumbing Code requirements and Standards and Specifications
          for Food Service Establishments to install Grease Interceptors and Grease Traps to
          reduce FOG in the Wastewater discharges. These requirements are discussed in the
          section of this manual titled “Grease Interceptor Installation Requirements/Sizing
          Criteria/Specifications.”

          The criteria for requiring the installation of a Grease Interceptor at an existing Food
          Service Establishment include frequency of noncompliance, the severity of the
          noncompliance (damages/complaints), demonstration of financial hardships and good
          faith efforts of the user to follow Best Management Practices to control FOG.

          The legal authority to require the installation of a Grease Trap or Grease Interceptor by
          Food Service Establishments is contained in City Code § 12.5.802.


 BMP Requirements

Description and Applicability

          Best Management Practices are procedures and practices that reduce the discharge of
          FOG to the building drain system and to the Wastewater System. Best Management
          Practices can be implemented effectively in Food Service Establishments and private
          dwellings. Existing establishments can use Best Management Practices as an option to
          control FOG in the discharge and prevent obstructions to flow in lieu of installing an
          outside grease interceptor.




                                                10
Food Service Establishments

         The following Best Management Practices are provided as guidance and
         recommendations to assist Food Service Establishments with development of procedures
         and/or practices to reduce the amount of FOG in their Wastewater discharge.
         Implementation of Best Management Practices has the added benefit of reducing FOG
         and solids accumulation in Grease Traps and Grease Interceptors, thereby reducing the
         maintenance needs and costs of these control devices. These efforts can also minimize
         the likelihood that an establishment will cause a Wastewater System blockage that results
         in a backup into their facility or their neighbors’ homes or businesses, a release to the
         environment, and/or an enforcement action. Implementation of Best Management
         Practices can also help reduce a Food Service Establishment's maintenance needs and
         costs for building Service Line cleaning. Food Service establishments that cause or
         contribute to a wastewater system blockage will be required to adopt Best Management
         Practices to control FOG.

         Because of the variety of establishments that generate FOG, every best management
         practice described in this manual may not apply to every establishment. It is
         recommended that Food Service Establishment operators identify the FOG sources at
         their establishment and adopt Best Management Practices to fit the establishment’s
         needs. Operators are encouraged to contact the Colorado Springs Utilities Industrial
         Pretreatment Program (719/668-4506 or 668-4497), if assistance with Best Management
         Practices selection is desired.

         Employee Training and Awareness

         The success of a Food Service Establishment’s Best Management Practices program is
         largely dependent upon employees. To promote effective employee implementation:

         •   Train employees on the Best Management Practices that have been adopted for their
             establishment. All Food Service Establishments should instruct employees not to
             pour FOG down the drain and not to use the sinks to dispose of food scraps.

         •   Use the Public Education Materials and opportunities described in this manual (See
             Table of Contents).

         •   Post “No Grease” signs above sinks and on the front of dishwashers. Signs should
             be written in the language(s) that is commonly spoken by employees.

         Garbage Disposals and Drain Screening

         Excluding food particles from the Wastewater System can eliminate a large amount of
         FOG from a Food Service Establishment’s discharge. To practice this:

         •   Disconnect or minimize the use of garbage disposals and use “dry” clean-up methods
             (described below). Operators can reduce FOG discharge by up to 50 percent by
             disconnecting their garbage disposals and scraping food into the trash.

         •   Retain or install a fine meshed screen (1/8-inch and 3/16-inch screen openings are
             recommended) in the drain of each kitchen, mop, and hand sink. Clean drain screens
             frequently by placing the collected material in the garbage.




                                             11
Dry Clean-up

Remove food waste with “dry” methods such as scraping, wiping, or sweeping before
using “wet” methods that use water. Wet methods typically wash the water and waste
materials into the drains where it eventually collects on the interior walls of drainage pipes.
To practice dry clean-up:

•   Use rubber scrapers to remove food particles, fats, oils, and grease from cookware,
    utensils, chafing dishes, and serving ware. Then place the removed food particles
    and FOG in the garbage.

•   Use paper towels to wipe down all work areas.

•   Use food grade paper to soak up oil and grease under fryer baskets.

Spill Prevention and Clean-up

Preventing spills reduces the amount of waste on food preparation and serving areas that
will require clean up. In addition, a dry workplace is safer for employees in avoiding slips,
trips, and falls. For spill prevention:

•   Empty containers, before they are full, to avoid spills.

•   Use a cover when transporting spillable materials, particularly liquid wastes containing
    fats, oils, and grease.

•   Provide employees with proper tools (e.g., ladles, ample containers, etc.) to transport
    materials without spilling.

Practice effective spill containment and clean up. Spills of dry ingredients should be
swept- up or vacuumed to prevent washing them into sinks or floor drains. For FOG spills:

•   Block off all sinks and floor drains near the spill.

•   Cover the spill with absorbent material (e.g., sand, saw dust, kitty litter, salt, paper
    towels, etc.).

•   Remove spilled material and place it in the garbage.

•   Use wet clean-up methods only to remove trace residues.

Food Service Establishments that use large amounts of cooking fats (e.g., deep fat fryers)
should develop and post their spill response procedure and maintain spill containment and
absorbent supplies.

Dishwashing and Equipment Cleaning

Proper dishwashing and cleaning methods can reduce the entry of solids and FOG into
the Wastewater System. These methods include:

•   Use disposable paper products, rather than dishware, to minimize or eliminate
    dishwashing.



                                        12
•   Pre-washing dishes and cookware with hot water and no soap, prior to use of the
    dishwasher or three-compartment sink, can reduce the discharge of FOG discharge
    by 25 percent. Pre-wash sinks used for this purpose must be connected to a Grease
    Trap.

•   Prior to washing deep fat fryers, use a rubber spatula to squeegee down the sides,
    while grease and oil are still warm, and then wipe the fryer with paper towels. Dispose
    of the paper towels in the garbage.

•   Before washing grill and roaster/broiler drip pans, empty their contents into a waste
    grease container and then wipe them with paper towels. Dispose of the paper towels
    in the garbage.

•   Pour all liquid grease and oil from pots and pans into a waste grease container that is
    stored at the pot-washing sink, and then scrape out the solidified grease, if present.

•   Capture accumulated oil, during the cleaning of stoves and ventilation/exhaust hoods,
    and dispose of it in the garbage, after absorbing all free liquid.

Recycling

Think of oil and grease as a valuable commodity. When using deep fat fryers or any
process that requires or produces large amounts of plant or animal byproducts, collect the
oils and fats. Recycle the oils and fats through one of the area’s recycling companies.
This is the preferred method of disposal for Food Service Establishments that produce any
volume of food waste. To practice recycling:

•    Never dispose of fryer-vat, waste oils and fats down the drain, as this material is
     usually clean enough to be recycled.

•    Collect and store fryer-vat waste in a rendering tank. Most recycling companies will
     provide outside receptacles for storage until pickup. Some companies will offer
     services free-of-charge, and others will give a rebate on the materials collected.

Beneficial Use of Food Wastes

Food wastes can be put to beneficial use, rather than simply discarding them. To do this:

•   Contact your local health department to approve the use of food waste.

Grease Traps

For indoor Grease Traps to be effective, the units must be properly sized, constructed,
and installed in a location to provide easy access for cleaning and an adequate retention
time for settling and accumulation of the FOG. If the units are too close to the FOG
discharge and/or do not have enough volume to allow accumulation of the FOG, the
emulsified oils will pass through the unit without being captured. In addition:

•   It is recommended that Food Service Establishments inspect indoor Grease Traps
    every month. These devices are less effective if the grease occupies greater than 25
    percent of the holding capacity. If the grease occupies greater than 25 percent of the
    trap’s holding capacity, the Food Service Establishment should perform a full cleaning
    of the Grease Trap (removing all liquids and solids and scraping the walls). A


                                     13
              monthly, full cleaning of Grease Traps is recommended. If less than 75 percent of the
              trap capacity remains, the trap should be cleaned more often than once per month.

          •   Confirm that Grease Traps contain their internal baffles and inlet piping flow
              restrictors/air relief during every inspection and cleaning. These components aid in
              grease removal by reducing turbulence and increasing holding time within the trap.

          •   It is recommended that Food Service Establishments maintain a record that
              documents the cleaning activities for indoor Grease Traps. Records should include
              the name of employee who performed the cleaning, date/time of cleaning, amount of
              grease removed, and the disposal location for the grease. An example of a form that
              could be used to maintain such records is contained in the Appendix of this manual,
              titled “Fat, Oil and Grease Wastewater Discharge Questionnaire (Report);
              Maintenance Log for Inside Grease Trap”.

Private Dwellings

          Many of the above Best Management Practices for Food Service Establishments are
          equally applicable to private dwellings. For private dwellings, the following primary Best
          Management Practices are recommended:

          •   Ensure that dwelling occupants understand the importance of keeping FOG out of the
              Wastewater System.

          •   Never pour FOG down sink drains or toilets.

          •   Avoid or minimize the use of garbage disposals.

          •   Use drain screens to capture food particles and dispose of these materials in the
              garbage.

          •   Use “dry” clean up methods before using “wet” clean up methods for kitchenware and
              spills.

          •   Collect FOG and other food-wastes, and dispose of them in the garbage.

Building Drains and Services Maintenance

          Proper maintenance of building drains and sanitary service lines is required by City Code
          12.5.410.A. FOG and debris accumulation in these plumbing structures can cause or
          contribute to sanitary sewer backups and overflows. To reduce these accumulations:

          •   It is recommended that Food Service Establishments have their building drains and
              service lines professionally cleaned at least once per year.


 Grease Interceptors

Description and Applicability

          The installation and maintenance of a Grease Interceptor is an important measure in
          ensuring that a Food Service Establishment does not contribute to problems with the


                                               14
         Wastewater Treatment System. Grease Interceptors differ from Grease Traps, which are
         small indoor devices. A Grease Interceptor is an outside, underground multi-compartment
         tank that reduces the amount of pollution (FOG) in Wastewater, before discharge into the
         Wastewater Treatment System. Grease Interceptors are two-compartment units that
         apply a physical separation process to detain Wastewater and allow FOG and water to
         separate due to differences in specific gravity. The separated FOG rises to the top, water
         flows to the Wastewater System from below, and solid materials settle on the bottom. The
         floating grease layer is prevented from flowing to the Wastewater System by a “Tee” or
         baffle that is installed on the effluent chamber of the interceptor. The detention capacity of
         the unit decreases as grease and solids accumulate; therefore, regular pumping, cleaning,
         and maintenance of Grease Interceptors are essential to ensure proper operation. For
         Grease Interceptors to be effective, the units must be properly sized, constructed, and
         installed in a location that provides easy access for inspection and cleaning. Grease
         Interceptors are pretreatment facilities that are subject to the plan submission and
         operations requirements of the City Code §§ 12.5.803 and 12.5.804, respectively.

Installation Requirements

         General

         Individual Grease Interceptors can be required for Food Service Establishments, whether
         or not such facilities are located in a separate building or structure or occupy space in a
         building or structure that is occupied by other businesses. If the volume or nature of food
         service provided by the establishment dictates significant food preparation, installation and
         operation of a garbage grinder, and automatic dishwasher, a Grease Interceptor may be
         required. There are some exceptions to the requirement for a Grease Interceptor (see
         Existing Food Service Establishments below).

         Each New Grease Interceptor or Grease Interceptor that is installed to replace or upgrade
         existing Grease Traps or Grease Interceptors will be required to meet all criteria stated in
         the current building and plumbing codes, Colorado Springs Utilities’ Standard
         Specifications for the Installation of Sanitary Sewer Mains and Services (available at
         www.csu.org), and this manual. Grease Interceptors will not be required for single-family
         residences, but may be required for multiple-family residences if the Colorado Springs
         Utilities Chief Executive Officer determines that such installation is necessary. Developers
         of shopping centers currently are encouraged by Colorado Springs Utilities to install two
         dedicated sanitary Service Lines, stubouts to direct the kitchen wastes of future food
         service facilities into an outside grease interceptor, then return the effluent from the grease
         interceptor back into the building sanitary sewer.

         The Colorado Springs Utilities Chief Executive Officer may grant a waiver from the City
         Code provision requiring separate Service Lines to allow for common Grease Interceptors
         that serve multiple Food Service Establishments. Waiver requests must meet the
         requirements of the City Code and include an agreement that defines legal responsibilities
         for inspection, maintenance, and cleaning among the establishments (City Code §
         12.5.407).

         New Food Service Establishments

         Grease Interceptors shall be required for all new Food Service Establishments during the
         plan review/building permit process. Variances to this requirement may be granted based
         on Food Service Establishments performing no cooking on site and not having a
         dishwasher, nor a garbage grinder. New Food Service Establishments granted this


                                                15
variance must conform to the building and plumbing codes, which may result in installation
of a Grease Trap.

Existing Food Service Establishments

Any Food Service Establishment having a Grease Interceptor or Grease Trap prior to the
Effective Date of this manual may continue to use the units provided the existing units are
of sufficient capacity and design and are operated and maintained such as to prevent
FOG from entering the wastewater System. If the Colorado Springs Utilities Chief
Executive Officer determines that an existing trap or interceptor is incapable of adequately
retaining FOG, the Colorado Springs Utilities Chief Executive Officer may order the Food
Service Establishment to install an adequate Grease Interceptor within a specified time
period.

Existing Food Service Establishments shall be required to install or upgrade a Grease
Interceptor in conjunction with a planned modification in plumbing improvements, with a
building permit valuation of $100,000 or more. If remodeling or reconstruction of the
Existing Food Service Establishment causes it to become a New Food Service
Establishment, as defined in the Definitions section of this manual, then a Grease
Interceptor must be installed, which meets the requirements of the Regional Building
Department requirements and the Colorado Springs Utilities Standard Specifications for
the Installation of Sanitary Sewer Mains and Services.              Existing Food Service
Establishments undergoing significant remodeling or reconstruction will be required to
install a Grease Interceptor during the plan review/building permit process.

The criteria for requiring the installation of a Grease Interceptor at an existing Food
Service establishment that caused or contributed to a Wastewater System blockages or
overflows, and have not undergone significant remodeling or reconstruction, include
frequency of repeated noncompliance, the severity (damages/complaints) of the
noncompliance, demonstration of financial hardship, good faith of the user to follow best
management practices to control FOG. Any requirement for an existing food service
establishment that has not undergone significant remodeling or reconstruction to install a
grease interceptor shall be provided in a unilateral administrative order described in the
“Enforcement Procedures” section of this manual.

Food Service Establishments that are unable to install or replace their Grease Interceptor
due to exceptional physical constraints or economic hardship may appeal to the Colorado
Springs Utilities Chief Executive Officer for approval to use an alternative grease control
technology, by requesting an informal conference or a hearing in accordance with City
Code 12-5-1204. One technology that may be considered is the prewashing system
described in current version of Colorado Springs Utilities’ Standard Specifications for the
Installation of Sanitary Sewer Mains and Services (available at www.csu.org). Such
requests shall be submitted in writing and shall include those elements described in City
Code 12-5-1204, and detailed descriptions of the establishment’s physical or financial
constraints and the proposed alternative grease control technology. In order for a Food
Service Establishment to demonstrate economic hardship, they must submit balance
sheets and profit and loss statements for the preceding three years. These requests shall
be evaluated on a case-by-case basis. If the Colorado Springs Utilities Chief Executive
Officer determines that an approved alternative technology is not performing adequately,
the Food Service Establishment shall be required to take additional grease control
measures, which may include installation of a Grease Interceptor.




                                      16
Installation Specifications

          Grease Interceptors shall be installed in conformance with the current version of Colorado
          Springs Utilities’ Standard Specifications for the Installation of Sanitary Sewer Mains and
          Services. This document includes detailed specifications for the following:

          •   Required and prohibited interceptor connections,
          •   Colorado Springs Utilities’ approval and inspection process,
          •   Design requirements,
          •   Siting requirements,
          •   Maintenance requirements,
          •   Sizing criteria, and
          •   Variances.

          In addition, this manual recommends that all Grease Interceptors be installed in such a
          manner that they can be accessed, inspected, and properly maintained 24 hours per day.
          Manhole covers are required to be accessible at all times. Therefore, interceptor manhole
          covers should not be covered with asphalt, concrete, landscaping, or other materials. If a
          Grease Interceptor is located in a landscaped area, all access manhole frames and covers
          shall have a twelve (12) inch wide concrete collar.

          Assistance with contractor identification and Grease Interceptor financing may be obtained
          through Colorado Springs Utilities’ Provanta® program (719/448-4800).

          Additional Considerations

          It is important for a Food Service Establishment to weigh costs and benefits and consider
          operational characteristics when evaluating Grease Interceptor design and capacity
          needs. While the initial capital investment may be less with a smaller-capacity Grease
          Interceptor, an establishment risks paying more in pumping and maintenance fees and
          possibly fines should the interceptor prove to be inefficient in meeting FOG requirements.
          Menu expansion, seating capacity expansion or menu changes impact the effectiveness
          of Grease Interceptor collection, as do changes in facility management and the use of
          Best Management Practices. Therefore, Food Service Establishment operators are
          encouraged to consider the following when selecting and installing a Grease Interceptor:

          •    Plan for the worst-case scenario, or at the very least, invest in a Grease Interceptor
               that is slightly larger than the minimum size calculated based on the current version
               of Colorado Springs Utilities’ Standard Specifications for the Installation of Sanitary
               Sewer Mains and Services.
          •    Consider physical aspects of the building (size, parking spaces, number of seats,
               number of meals).
          •    Consider establishment characteristics (e.g., menu, serving schedule, single
               service/full service, etc.).
          •    In places where flows in the Wastewater System are low, Users need to exercise
               greater care in grease control. Areas of low flow are a normal aspect of Wastewater
               Systems and are not considered design deficiencies or engineering or infrastructure
               problems.
          •    Assess future needs for expansion and growth.
          •    Evaluate effectiveness of establishment grease management practices.
          •    Plumb the Grease Interceptor to receive kitchen wastes only. To minimize hydraulic
               load, it is recommended that a separate drain be plumbed for hand sinks,
               condensate lines, or other non-grease-laden water.



                                               17
         •    All Grease Interceptors must be fully accessible to allow for regular maintenance,
              inspection, cleaning, and potential sampling. Food Service Establishments can be
              severely inconvenienced when Grease Interceptors are placed in drive-through lanes
              or other access or parking areas.

Operation and Maintenance

         Operation

         A Grease Interceptor is a tank comprised of two compartments separated by a baffle.
         Each compartment is accessible through a separate manhole. A “Tee” is positioned on
         the inlet to the first compartment to route the flow downward to the bottom of the
         compartment thereby reducing turbulence within the unit. There is also a “Tee” on the
         outlet from the second compartment that ensures outflow originates from the bottom of the
         compartment and that the floating grease layer is retained. A missing, altered, or
         damaged outlet “Tee” constitutes an unauthorized bypass of a pretreatment system
         resulting in violations of City Code §§ 12.5.702: I & P, 12.5.803, and 12.5.804.

         Inspection

         Proper operation and maintenance of Grease Interceptors includes routine inspection,
         cleaning, pumping, and repair as described in this section. These units are less effective if
         FOG and solids occupy greater than 25 percent of the interceptor’s capacity. It is
         recommended that Food Service Establishments inspect Grease Interceptors at least
         every three months. Individual Food Service Establishments may be required to inspect
         their interceptor more frequently if it is deemed necessary by the Colorado Springs Utilities
         Chief Executive Officer. Such a determination would generally result from repeated three-
         month inspections that found greater than 25 percent of the Grease Interceptor’s capacity
         was exceeded. Use of a properly operated, automated technology device (i.e., a grease
         monitor) may eliminate the need for quarterly inspections.

         During each inspection, it is recommended that users document measurement of the
         grease layer, in inches, in both compartments by pushing a garden hoe through the
         grease layer or taking a core sample with a “sludge judge.” During each inspection of a
         Grease Interceptor, it is recommended that Food Service Establishments open both
         manholes and confirm that the “Tees” on both the inlet and outlet pipes are intact.
         Inspections should be documented in accordance with the Recordkeeping activities,
         described below.

         Cleaning

         If the FOG and solids occupy greater than 25 percent of an interceptor’s capacity, the
         Food Service Establishment is required to perform a full cleaning of the Grease
         Interceptor. Cleaning must be performed by a liquid waste hauler possessing a permit for
         liquid waste hauling, issued by Colorado Springs Utilities. Both vaults of a Grease
         Interceptor shall be left completely empty upon completion of pumping operation. The
         grease mat, liquids, sludge, and scrapings from the interior walls must be removed. Under
         no circumstances, may the Liquid Waste Hauler reintroduce the removed water or
         materials be reintroduced into the Colorado Springs Utilities Wastewater Treatment
         System, other than at the designated disposal station at the Colorado Springs Utilities
         Wastewater Treatment Plant (City Code § 12.5.1001:A.1). Flushing an interceptor with
         hot water, or the use of chemicals or other agents to dissolve or emulsify grease and allow
         it to flow into the wastewater treatment system, is a violation of City Code 17.5.702:I.


                                               18
Since the Food Service Establishment is the generator of the grease waste, is liable for
the condition of their pretreatment devices, and is paying for the cleaning service, the
Food Service Establishment owner or designee may want to witness all
cleaning/maintenance activities to verify that the Grease Interceptor is being fully cleaned
and properly maintained. The following are the pumping practices required of permitted
Liquid Waste Haulers, by Colorado Springs Utilities:

Step 1:      Skim the entire grease cap and debris from the top of the Grease Interceptor.
             The interceptor may need to be agitated slightly to loosen the grease cap.

Step 2:      Place the vacuum tube all the way into the Grease Interceptor to withdraw
             remaining solids from the bottom.

Step 3:      Vacuum water out of the Grease Interceptor.

Step 4:      Clean the sides and bottom of the Grease Interceptor. This may be done by
             “back flowing” the water from the pump truck or by using a hot water source
             to hose down the interceptor. Make sure the Grease Interceptor is
             completely clean.

Step 5:      Vacuum the remaining water out of the Grease Interceptor.

Step 6:      Check that the sanitary “Tees” on the inlet and outlet sides of the Grease
             Interceptor are not clogged, loose, or missing.

Step 7:      Verify that the baffle is secure and in place.

Step 8:      Inspect the Grease Interceptor for any cracks or other defects.

Step 9:      Check that lids are securely and properly seated after completion of pumping.

Step 10:     Provide a copy of the Liquid Waste Hauler Load Ticket (manifest) to the Food
             Service Establishment (waste generator). An example of this form is
             provided in the Programmatic Material section of this manual.

Recordkeeping

It is recommended that Food Service Establishments maintain a written record of every
time a Grease Interceptor is inspected and cleaned.

Inspection records should document date of inspection, name of company and person
performing inspection, estimated volume of FOG present, and the signature of the
manager or designee of the Food Service Establishment. An example of this record is
provided in the Programmatic Material section of this manual.

Cleaning records should document the date of maintenance, name of company and
person performing maintenance, estimated volume of FOG removed, disposal location,
and establishment manager’s, or designee’s, signature for verification. A manifest from
the permitted Liquid Waste Hauler is an acceptable record, if it contains all of the above
information.




                                       19
          It is recommended that Inspection and cleaning records be maintained on the premises for
          a period of at least three years and be made readily available to Colorado Springs Utilities
          personnel for review and inspection.


 Public Educational Materials

          Colorado Springs Utilities has partnered with the El Paso County Department Public
          Health and Environment to provide educational materials to Food Service Establishments
          at the monthly Food Safety Classes conducted by the Health Department. Brochures and
          posters have been prepared in English and Spanish that describe Best Management
          Practices to handle FOG wastes. These brochures and posters will be provided to every
          Food Service Establishment in Colorado Springs Utilities' service area to educate people
          on FOG Best Management Practices, using direct mailings, on site visits to newly licensed
          establishments and the Food Safety Classes.


 Enforcement Procedures

Description and Applicability

          This section provides a general outline of enforcement procedures that apply to Food
          Service Establishments that fail to comply with the requirements in City Code and
          Colorado Springs Utilities’ Standard Specifications for the Installation of Sanitary Sewer
          Mains and Services. Colorado Springs Utilities’ specific enforcement procedures are
          detailed in City Code Chapter 12, Article 5, Part 12 .

          The EPA, in its General Pretreatment Regulations (40 CFR Part 403) and the City, in its
          Wastewater Treatment Code (City Code Chapter 12, Article 5), prohibit any user, including
          Food Service Establishments, from discharging solid or viscous pollutants, such as FOG
          wastes, in amounts which will cause obstructions (blockages) to the flow in the
          Wastewater Treatment System and Interfere with the operation of the Wastewater
          System. Colorado Springs Utilities is required by the EPA, the State, and the local City
          Code to initiate enforcement actions against Users of the Wastewater System, who violate
          this prohibition

          Colorado Springs Utilities will initiate enforcement actions for noncompliance, but it is
          possible for the EPA or the State to initiate their own enforcement actions if, in their
          opinion, Colorado Springs Utilities has not taken adequate enforcement by following its
          approved Enforcement Response Plan (ERP).

          Blockage and Overflow Investigation

          Enforcement activities often commence with investigations of blockages and overflows of
          the Wastewater Treatment System. Such investigations may include closed circuit
          television inspection of public Collection Lines and privately owned Service Lines. These
          inspections are used to determine contributing factors causing the blockage or overflow,
          such as defective infrastructure, accumulated roots and/or debris, and to seek visual
          evidence of FOG waste accumulation between the site of the stoppage or overflow and
          upstream Food Service Establishments. If significant FOG accumulation is observed in
          the Service Line of an upstream Food Service Establishment, that establishment is
          identified as causing or contributing to the downstream stoppage or overflow. Inspection


                                                20
        findings for the Grease Traps and Grease Interceptors of upstream Food Service
        Establishments are also used to determine whether a particular Food Service
        Establishment caused or contributed to the downstream stoppage or overflow.

        When investigating blockages and overflows. Colorado Springs Utilities may not be able
        to prove the blockage and/or overflow was caused by one individual Food Service
        Establishment. In these instances, physical disconnection from the wastewater system
        will not be an enforcement used by Colorado Springs Utilities. Information obtained during
        these investigations is available to the public upon request via the Colorado Open
        Records Act.

Enforcement Responses

        Colorado Springs Utilities has an EPA approved Enforcement Response Plan (ERP) that
        will be followed in addressing noncompliance. Monetary fines are Federally required
        enforcement responses and are usually one of the last enforcement actions Colorado
        Springs Utilities uses when encountering noncompliance. Colorado Springs Utilities
        usually gets businesses into compliance using informal enforcement actions before having
        to use monetary fines.

        The City Code, at §§ 12.5.1202 and 12.5.1203 provides a range of enforcement
        responses that can be applied to Food Service Establishments. The brief descriptions of
        the responses that are used most frequently for Food Service Establishments are
        provided below. The enforcement remedies are cumulative; in other words, they may be
        used individually, sequentially, concurrently, or in any order (City Code § 12.5.1201:B).
        Additionally, Food Service Establishments, who fail to comply with requirements in an
        enforcement action, may be required to apply for and obtain a Non-Significant Industrial
        User Control Mechanism.

        Informal Administrative Enforcement Remedies

        Informal enforcement remedies include verbal notice, information production/compliance
        review meeting, inspections, field notices of observed violations, and notices of violations.
        Regarding field notices of observed violation and notices of violation, an informal
        conference with Colorado Springs Utilities may be requested and an appeal is available
        after an informal conference. The field notice of violation and notification of violation is
        more fully explained below.

        Field Notice of Observed Violation.              During an inspection of a Food Service
        Establishment, if a violation is noted, a field notice of observed violation may be served.
        This document identifies the specific violation(s), the date(s) for corrective action to be
        completed, and other compliance actions that may be required. An example of this
        document is provided in the Programmatic Materials section of this manual.

        Notification of Violation.     Whenever a Food Service Establishment is determined to
        have committed a violation, a written notice of violation may be served. This document
        identifies the specific requirements that were violated, the fact alleged to constitute the
        violations, and it may include any corrective action(s) proposed to be required. Within ten
        (10) days of the receipt date of this notice, a written explanation of or response to the
        violation and a plan for the satisfactory correction and prevention thereof must be
        submitted. An example of this document is provided in the Programmatic Materials
        section of this manual.



                                              21
The corrective actions contained in a Field Notice of Observed Violation or a Notification of
Violation could include the following:

•   Implementing specific Best Management Practices to control FOG wastes, including
    submittal of a FOG control plan;

•   Increasing the inspection and/or cleaning frequency of a Grease Trap or Grease
    Interceptor;

•   Instituting periodic reporting requirements, including submittal of FOG Wastewater
    Discharge Questionnaires);

•   Provide adequate maintenance and/or access to the Grease Trap or Grease
    Interceptor; and

•   Other items deemed appropriate by the Chief Executive Officer or his designee.

The FOG wastewater discharge questionnaire and FOG control plan are more fully
explained below.

FOG Wastewater Discharge Questionnaire

Food Service Establishments that cause or contribute to an obstruction to the flow in the
Wastewater Treatment System will be required to: perform quarterly, or more frequent,
inspections of the establishment’s Grease Interceptor or Grease Trap; clean the
interceptor or trap completely, when over 25 percent of the vessel’s capacity is occupied
by solids and grease; and report these activities quarterly on a FOG wastewater discharge
questionnaire.

The legal authority for requiring Food Service Establishments to complete and submit a
questionnaire is contained in City Code § 12.5.901:A., B.

An example of this document is provided in the Programmatic Materials section of this
manual.

FOG Control Plan

Food Service Establishments that fail to comply with the requirement to file a completed
FOG wastewater discharge questionnaire may be required to submit a FOG control plan.
A FOG control plan must include the following information:

•   A description of the Food Service Establishment operation,

•   A description of the location and size of any Grease Interceptors and Grease Traps
    present,

•   A description of the FOG Best Management Practices used by the Food Service
    Establishment,

•   A description of the procedures to prevent discharges of waste fat, oil and grease,

•   A description of waste FOG handling, storage, and disposal procedures,



                                      22
•   A description of how the Grease Interceptor or Grease Trap will be maintained
    (cleaned) including frequency of cleaning,

•   A description of how the Food Service Establishment will comply with quarterly
    reporting requirements, and

•   A certification statement that is signed by the owner or manager of the Food Service
    Establishment.

Colorado Springs Utilities shall provide the Food Service Establishment with written notice
of its acceptance of the FOG control plan. The Colorado Springs Utilities Chief Executive
Officer may require modifications to a FOG control plan, if the plan submitted by a Food
Service Establishment is determined to be inadequate. Failure to implement any element
of an accepted plan is a violation and subject enforcement as described in this section and
City Code Chapter 12, Article 5, Part 12.

The legal authority for requiring Food Service Establishments to submit a FOG control
plan is contained in City Code § 12.5.804 and 12.5.811.

Formal Administrative Enforcement Remedies

Formal administrative enforcement remedies include the issuance of a unilateral
administrative order, or, after negotiation, an executed consent administrative order.
Other formal enforcement mechanisms include an emergency suspension order and an
imminent hazard order (City Code § 12.5.1203). Formal enforcement is typically utilized
when informal enforcement remedies have not brought the Food Service Establishment
into compliance, or the Food Service Establishment has caused or contributed to an
obstruction (blockage) of the Wastewater Treatment System with 24 months of being
notified of a similar violation, or the Food Service Establishment has caused or contributed
to a violation of the CDPS permit issued to Colorado Springs. Corrective actions that may
arise in a formal administrative enforcement order include; an order to cease and desist
activities; a compliance schedule; requirements to install grease interceptor; administrative
fines; and charge to reimburse Colorado Springs Utilities for the costs of investigation,
maintenance, enforcement and clean-up.

Colorado Springs Utilities may be subject to State or Federal penalty assessments for
Collection Line overflow resulting from inadequate FOG waste management by Food
Service Establishments that causes a violation of the CDPS permit issued to Colorado
Springs. These penalties and the associated legal and administrative costs may be
passed on to Food Service Establishments that contributed to the overflow.

Administrative Hearing Procedures

After issuance of Field Notice of Violation or a Notice of Violation, or a unilateral
administrative order, the user may request an informal conference with Colorado Springs
Utilities to resolve issues in such notices or order, including the findings of a Blockage and
Overflow Investigation. The user may request a hearing after receipt of a unilateral
administrative order, emergency suspension order, or an imminent hazard order. Any
requests for informal conferences or hearings must be made in accordance with City Code
§ 12-5-1204.




                                      23
Programmatic Materials

        This section includes examples of the following documents:

        1. Fat, Oil and Grease Wastewater Discharge Questionnaire (Report): Maintenance Log
           for an Inside Grease Trap
        2. Fat, Oil and Grease Wastewater Discharge Questionnaire (Report): Maintenance Log
           for and Outside Grease Trap/Interceptor
        3. Proper Pumping Procedure for a Grease Interceptor
        4. Liquid Waste Hauler Load Ticket
        5. FOG Inspection Form
        6. Example Field Notice of Violation
        7. Example Notice of Violation




                                            24
FAT, OIL AND GREASE WASTEWATER DISCHARGE QUESTIONNAIRE (REPORT)
              MAINTENANCE LOG FOR INSIDE GREASE TRAP
            PLEASE WRITE CLEARLY & USE A SEPARATE LOG FOR EACH TRAP

 BUSINESS NAME ________________________ ADDRESS ____________________________

 LOCATION OF GREASE TRAP ____________________________________________________
                                  (For example: Under 3 compartment sink in food prep area)

  DATE OF CLEANING         NAME OF PERSON              APPROXIMATE                     HOW WAS THE
  OR INSPECTION            WHO INSPECTED               GALLONS/POUNDS                  WASTE DISPOSED?
                           OR CLEANED TRAP             OF GREASE AND/OR                (For example:
                                                       OTHER DEBRIS                    Recycled, put in trash
                                                       REMOVED? (2 cups = 1            and etc.) IF CLEANED
                                                       pound) IF CLEANED




                             MAKE ADDITIONAL COPIES IF NECESSARY

 CERTIFICATION: I certify under penalty of law that the above information is true and accurate
 and complete to the best of my knowledge. I am aware that there are significant penalties for
 submitting false information including the possibility of fine and/or imprisonment for knowing
 violations.

  _____________________________________             ______________________             ______________
  Signature of Authorized Representative            Title                              Date




                                                  25
FAT, OIL AND GREASE WASTEWATER DISCHARGE QUESTIONNAIRE (REPORT)
       MAINTENANCE LOG FOR OUTSIDE GREASE TRAP/INTERCEPTOR
                                   PLEASE WRITE CLEARLY

 BUSINESS NAME ________________________ ADDRESS ____________________________

 LOCATION OF TRAP/INTERCEPTOR ______________________________________________
                                        (For example: In parking lot on northwest side of building)

 DATE OF CLEANING         NAME OF PERSON              APPROXIMATE           HOW WAS THE WASTE
 OR INSPECTION            OR COMPANY WHO              GALLONS OF            DISPOSED?
                          INSPECTED OR                GREASE AND            (IF CLEANED)
                          CLEANED UNIT                OTHER DEBRIS
                                                      REMOVED
                                                      (IF CLEANED)




                          MAKE ADDITIONAL COPIES IF NECESSARY

 CERTIFICATION: I certify under penalty of law that the above information is true and accurate
 and complete to the best of my knowledge. I am aware that there are significant penalties for
 submitting false information including the possibility of fine and/or imprisonment for knowing
 violations.
   _____________________________________             ______________________          ______________
  Signature of Authorized Representative            Title                            Date




 CERTIFICATION OF INSPECTION: I certify under penalty of law that the above indicated
 grease trap/interceptor has been inspected on the above indicated date(s). The grease trap/
 interceptor contains solids and grease that occupy less than 25% of the holding capacity of the
 trap/interceptor.

  _____________________________________            ______________________             ______________
  Signature of Authorized Representative           Title                              Date

  _____________________________________             ________________________________________
  Date of last cleaning                            Approx. inches of grease and solids occupying
                                                   trap/interceptor




                                                 26
  PROPER PUMPING PROCEDURE FOR GREASE INTERCEPTOR
A designated representative from your facility should observe and monitor all grease
interceptor pump-outs to ensure proper pumping procedure is followed. Unless it is
absolutely unavoidable, you should use a trustworthy pumper with whom you have
established a business relationship. All four walls of the grease interceptor should be
cleaned thoroughly. Make sure your pumper observes the following pumping
procedure.

Step 1:       Skim the entire grease cap and debris from the top of the interceptor.
              The interceptor may need to be agitated slightly to loosen the grease
              cap.

Step 2:       Place vacuum tube all the way into the interceptor to suck remaining
              solids from the bottom.

Step 3:       Vacuum water out of the interceptor.

Step 4:       Clean the sides and bottom of the trap. This may be done by “back
              flowing” the water from the pump truck or by using a hot water source
              to hose down the trap. Make sure the trap is completely clean.

Step 5:       Vacuum remaining water out of the trap.

Step 6:       Check that the sanitary “T’s” on the inlet and outlet sides of the
              interceptor are not clogged or loose.

Step 7:       Make sure that the baffle is secure and in place.

Step 8:       Inspect the interceptor for any cracks or defects.

Step 9:       Check that lids are securely and properly seated after completion of
              pumping.



The above information was obtained from the Grease Summit Manual presented by
Environmental Biotech, Incorporated.




                                          27
LIQUID WASTE HAULER LOAD TICKET




              28
                               FOG INSPECTION FORM
GENERAL INFORMATION
Inspector ________________________________________________________________
Date of Inspection _________________________________________________________
Reason for Inspection ______________________________________________________
Facility Name ____________________________________________________________
Facility Address___________________________________________________________
Facility Contact Name & Title ________________________________________________
Facility Telephone Number & Fax _____________________________________________

GREASE TRAP/INTERCEPTOR INFORMATION
Does the facility have (circle one):                outside grease interceptor / inside grease trap?
Location of grease trap/interceptor? ____________________________________________
Condition of grease trap or interceptor? _________________________________________
Measurement of grease layer in inches _________________________________________
Is a “T” installed on effluent side of unit? _________________________________________
Properly installed baffles / flow restricter / air gap on grease trap?                 YES or NO
Are lids to grease trap/interceptor accessible?                                        YES or NO

BMP/INTERVIEW INFORMATION
Are appropriate BMPs being followed?                                                 YES    or   NO
Is a maintenance log on site of inspections/cleanings?                               YES    or   NO
If YES, is unit inspected at least every three (3) months?                           YES    or   NO
Does establishment keep load tickets of pumping activities?                          YES    or   NO
Is a company employee present to observe grease interceptor pumping?                 YES    or   NO
Is the grease interceptor left empty upon completion of pumping?                     YES    or   NO
Is the trap/interceptor being cleaned based on the 25% Rule?                         YES    or   NO
Are fryer vats present?                                                              YES    or   NO
If YES, are waste grease and oil storage containers present?                         YES    or   NO
Is a garbage grinder present?                                                        YES    or   NO
If NO, are drain screens used?                                                       YES    or   NO
Is an automatic dishwasher present?                                                  YES    or   NO

COMMENTS




CORRECTIONS & DUE DATE




                                                29
EXAMPLE FIELD NOTICE OF VIOLATION




               30
EXAMPLE NOTICE OF VIOLATION




            31

								
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