A Messy Environmental Issue: Fats, Oils, And Grease In The Sewer System And How To Control Them (Part Two)

A good FOG program is only as good as its implementation. These are some elements that should be included for a program to be successful.

• The POTW must establish legal authority. At public and especially municipal utilities, this is usually in the form of ordinances.
• Pretreatment ordinances include requirements to be met by POTWs and commercial and industrial establishments that discharge to the sewer system. This can be in the form of limits to the amount of pollutants that can be discharged or the installation of various technologies to reduce or remove the pollutants before they are discharged.
• FOG is controlled by the installation of grease traps or grease interceptors at FSEs. Therefore, the ordinance should include a requirement to install these devices and include design standards and specifications.
• Grease traps and interceptors collect fat and other cooking & cleaning waste before it discharges to the sewer. They must be designed to accommodate the flow and solids capacity generated at the FSE.

• The grease traps and interceptors must be adequately operated and maintained, which includes periodic pumping of the contents to prevent the waste from overflowing to the collection system.
• Finally, an enforcement mechanism must be established to ensure compliance with the ordinance.
• The POTW should establish a functional unit with dedicated staff to operate the FOG program. The FOG group would be responsible for the activities described below.
• FSEs should be required to submit design plans and specifications to the FOG unit for review and approval. After approval, the FSE may install the system. The FOG group should inspect the system after it is installed – but before it goes into operation – to ensure it complies with the approved plans and specifications.
• Periodic inspections should be conducted by FOG staff. The inspections will determine if the interceptors are being adequately operated and maintained, which includes ensuring they are being pumped out, completely, on a regular basis (usually at least quarterly unless another frequency is determined appropriate). There are databases available that allow FOG staff to record the results of inspections electronically on field tablet computers. This makes the inspection reports available to FSE staff immediately and can be downloaded to FOG Program databases for recordkeeping purposes.
• Inspections are an opportunity for FOG staff to identify problems with the on-site interceptor or operating procedures, and to provide guidance on how to come into compliance with local ordinances. This may include recommendations for the FSE to have an on-site representative observe pumping of the interceptor contents to ensure it is pumped out completely. Once a pumper leaves the premises it is difficult to have them return or demonstrate that they pumped the interceptor completely. Many FSEs are resistant to this process as it diverts staff from the primary duties of the establishment and FOG staff cannot be available to observe periodic pumping for every FSE. Failure to ensure adequate maintenance can result in discharge of FOG to the POTW or premature failure of the interceptor.

When commercial establishments are frequently in non-compliance with utility ordinances, enforcement may be necessary. Enforcement may be escalated depending on the seriousness and/or frequency of violations pursuant to an Enforcement Response Plan or Enforcement Escalation Policy. Enforcement actions may include:

For a FOG program to be successful, it must establish function, structure, and procedures. There should be an organizational chart to establish a chain of command. Responsibilities of individual staff or positions should be identified. Detailed procedures should be prepared for all activities being performed, including design review and approval, post-installation inspections, periodic operation and maintenance inspections, and enforcement. The FOG group should identify all FSEs in the service area to be included in the program. Finally, documentation of all activities should be created and maintained as part of recordkeeping.

Technology can help manage the planning, implementation, and recordkeeping functions of the FOG program. This can include maintenance of the list of FSEs, onsite inspection report preparation and documentation, follow up inspection reminders where problems are identified, grease interceptor pumping documentation, using dashboards, data analytics, and reporting functions.

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Additional information on the Pretreatment Program can be found in the EPA document “Introduction to the National Pretreatment Program”. (EPA-833-B-11-001, June 2011). The document can be accessed at P100EB7R.PDF (epa.gov).