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National Pretreatment
Program
(40CFR403)
Controlling Fats, Oils, and Grease
Discharges from Food Service
Establishments
Summary
What is the
environmental
problem with FOG
discharges into
sewers?
The National Pretreatment Program provides regulatory
tools and authority to state and local POTW
pretreatment programs for eliminating pollutant
discharges that cause interference at POTWs, including
interference caused by the discharge of Fats, Oils, and
Grease (FOG) from food service establishments (FSE).
More specifically, the Pretreatment Program regulations
at 40 CFR 403.5(b)(3) prohibit "solid or viscous
pollutants in amounts which will cause obstruction" in
the POTW and its collection system.
EPA's Report to Congress on combined sewer overflows
(CSOs) and sanitary sewer overflows (SSOs) identified
that "grease from restaurants, homes, and industrial
sources are the most common cause (47%) of reported
blockages. Grease is problematic because it solidifies,
reduces conveyance capacity, and blocks flow." See
Impacts and Controls of CSOs and SSOs, EPA-833-R-
04-001, August 2004.
Controlling FOG discharges will help POTWs prevent
blockages that impact CSOs and SSOs, which cause
public health and water quality problems. Controlling
FOG discharges from FSEs is an essential element in
controlling CSOs and SSOs and ensuring the proper
operations for many POTWs. The interference incidents
identified in CSO/SSO report to Congress may indicate
the need for additional oversight and enforcement of
existing regulations and controls. See 71 FR 76660 (21
December 2006).
Office of Water
EPA-833-F-07-007
July 2007
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What is the
source of FOG at
Food Service
Establishments?
FOG wastes are generated at FSEs as byproducts from
food preparation activities. FOG captured on-site is
generally classified into two broad categories: yellow
grease and grease trap waste. Yellow grease is derived
from used cooking oil and waste greases that are
separated and collected at the point of use by the food
service establishment.
The annual production of collected grease trap waste
and uncollected grease entering sewage treatment
plants can be significant and ranges from 800 to 17,000
pounds/year per restaurant.
What is the legal
authority for
POTWs to
require FSEs to
control FOG
discharges?
What can FSEs do
to control FOG
discharges?
The National Pretreatment Program already provides
the necessary regulatory tools and authority to local
pretreatment programs for controlling interference
problems. Under the provisions of Part 403.5(c)(l) &
(2), in defined circumstances, a POTW must establish
specific local limits for industrial users to guard against
interference with the operation of the municipal
treatment works. See 46 FR 9406 (28 January 1981).
Consequently, pretreatment oversight programs should
include activities designed to identify and control
sources of potential interference and, in the event of
actual interference, enforcement against the violator.
Food service establishments can adopt a variety of best
management practices or install interceptor/collector
devices to control and capture the FOG material before
discharge to the POTW collection system.
For example, instead of discharging yellow grease to
POTWs, food service establishments usually accumulate
this material for pick up by consolidation service
companies for re-sale or re-use in the manufacture of
tallow, animal feed supplements, bio-fuels, or other
products.
Additionally, food service establishments can install
interceptor/collector devices (e.g., grease traps) in
order to accumulate grease on-site and prevent it from
entering the POTW collection system.
Office of Water
EPA-833-F-07-007
July 2007
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How should FSEs
design and
maintain their FOG
controls?
What are some
POTWs doing today
to control FOG
discharges from
FSEs?
Proper design, installation, and maintenance procedures
are critical for these devices to control and capture the
FOG. For example,
» Interceptor/collector devices must be designed and
sized appropriately to allow FOG to cool and separate
in a non-turbulent environment.
* FSE must be diligent in having their interceptor/
collector devices serviced at regular intervals.
The required maintenance frequency for
interceptor/collector devices depends greatly on the
amount of FOG a facility generates as well as any best
management practices (BMPs) that the establishment
implements to reduce the FOG discharged into its
sanitary sewer system.
In many cases, an establishment that implements BMPs
will realize financial benefit through a reduction in their
required grease interceptor and trap maintenance
frequency.
A growing number of control authorities are using their
existing authority (e.g., general pretreatment standards
in Part 403 or local authority) to establish and enforce
more FOG regulatory controls (e.g., numeric
pretreatment limits, best management practices
including the use of interceptor/collector devices) for
food service establishments to reduce interferences with
POTW operations (e.g., blockages from fats, oils, and
greases discharges, POTW treatment interference from
Nocardia filamentous foaming, damage to collection
system from hydrogen sulfide generation).
For example, since identifying a 73% non-compliance
rate with its grease trap ordinance among restaurants,
New York City has instituted a $l,000-per-day fine for
FOG violations.
Likewise, more and more municipal wastewater
authorities are addressing FOG discharges by imposing
mandatory measures of assorted kinds, including
inspections, periodic grease pumping, stiff penalties,
and even criminal citations for violators, along with
'strong waste' monthly surcharges added to restaurant
Office of Water
EPA-833-F-07-007
July 2007
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How can CMOM
help control FSE
FOG discharges?
Where can I get
more information?
sewer bills. Surcharges are reportedly ranging from
$100 to as high as $700 and more, the fees being
deemed necessary to cover the cost of inspections and
upgraded infrastructure.
Pretreatment programs are developing and using
inspection checklists for both food service
establishments and municipal pretreatment inspectors
to control FOG discharges. Additionally, EPA identified
typical numeric local limits controlling oil and grease in
the range of 50 mg/L to 450 mg/L with 100 mg/L as the
most common reported numeric pretreatment limit.
EPA expects that blockages from FOG discharges will
decrease as POTWs incorporate FOG reduction activities
into their Capacity, Management, Operations, and
Maintenance (CMOM) program and daily practices.
CMOM programs are comprehensive, dynamic, utility
specific programs for better managing, operating and
maintaining sanitary sewer collection systems,
investigating capacity constrained areas of the
collection system, and responding to SSOs.
Collection system owners or operators who adopt FOG
reduction activities as part of their CMOM program
activities are likely to reduce the occurrence of sewer
overflows and improve their operations and customer
service.
For more information on developing local limits is in the
Local Limits Development Guidance, EPA-833-R-04-
002A, July 2004, and EPA's Pretreatment Web site,
http://cfpub.epa.QOv/npdes/home.cfm7program id = 3.
CMOM information is located in the following document,
Guide for Evaluating Capacity, Management, Operation,
and Maintenance (CMOM) Programs at Sanitary Sewer
Collection Systems, EPA-305-B-05-002, January 2005,
http://cfpub.epa.aov/npdes/sso/featuredinfo.cfm.
Additional information is also available from your state
or EPA Regional Office.
Office of Water
EPA-833-F-07-007
July 2007
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