Workshop for Area 7 Fats, Oils, & Grease (FOG) PROPOSED Program and Ordinance Orange County Sanitation District August 3, 2004
What is FOG? Fats from cooking meats Lard, shortening, cooking oils Fryer grease
What is the Problem? FOG is causing blockages and sewer overflows in: Drain lines Private sewer laterals Main sewer lines and lift stations
Food Service Establishment Sanitary Waste Drain Grease Int. Grease Waste Drain Combined Waste Lateral Sewer Main
Too Much FOG is Being Discharged into Kitchen Drains Fryer drippings, spills Grills, woks Dishwashing Garbage disposals (food grinders)
There are Many Sources of FOG Food service establishments Homes Apartment buildings
Grease Removal Devices (GRDs) Grease Interceptors or Traps Removes grease before it causes sewer blockages Most FSEs have no GRD installed Many installed are not cleaned or maintained adequately
Why Are We Here? 2001 OC Grand Jury Report Most sewer overflows are caused by FOG blockages Sewer overflows result in health hazards, beach contamination and closures
Why Are We Here? Waste Discharge Requirements (WDR) Order No. R8-2002-0014 Issued by state Generally agreed with Grand Jury findings All north Orange County sewer system operations must have FOG Control Programs in place by Dec. 2004 OCSD operates the sewer system for the City of Tustin and a few small neighboring areas
WDR Requirements Limit grease discharges that may cause blockages Prohibit FOG discharges that may cause sewer overflows Adopt and enforce an ordinance, inspect FSEs Require implementation of kitchen best management practices (BMPs)
WDR Requirements (cont d) Require installation of grease removal devices, as necessary Implement source control measures for sewer line hot spots
Proposed OCSD FOG Control Program
Goals FOG Control Program No FOG related sewer overflows Control FOG through education, permitting, and enforcement Develop a program that is fair and equitable
Basics FOG Control Program Implement kitchen BMPs Install grease interceptors, when necessary Prevent FOG from going down the drain!
Studying the Problem First Orange County FOG Control Study findings and recommendations Local FOG Characterization Study Inspect all FSEs Map sewer system hot spots Camera inspection of the sewer lines and individual FOG sources
FOG Source Identification Identification of significant grease from an individual lateral
Basis FOG Control Program Design Program Equity: Logical minimum requirements for all FSEs Case-by-case additional requirements for FSEs that may potentially cause or contribute to a blockage or sewer overflow Strike a balance between cost and environmental benefit Issue waivers / variances until it becomes necessary to go further
OCSD Proposed FOG Control Program All FSEs Kitchen BMPs Existing FSE OCSD Grants Grease Interceptor Conditional Waiver or Variance * Grease Interceptors New/Remodeled FSE FSE Permit Violations NO YES NO Continued Permit Violations YES Revoke Waiver or Variance FSE Causes or Contributes to Blockage or SSO NO OCSD Program Evaluation New FSE Waiver/Variance YES Revoke Waiver or Variance End Conditional Waiver Grease Interceptor or Approved Alternative * A waiver or variance may not be granted for existing FSEs that are already identified as significant sources of FOG
Structure FOG Control Program FOG Control Ordinance scheduled for adoption by Dec 2004 Individual permits issued by January 2005 Enforcement inspections of sewer lines, grease interceptors, kitchen BMPs Fees
Core Elements FOG Control Program Permit: Required for all FSEs explaining the program requirements Exemption for limited food prep establishments (e.g., no on-site cooking or dishwashing)
Core Elements FOG Control Program Prohibitions: No food grinders (garbage disposal units) for new or existing FSEs 180 days to retrofit No emulsifying additives, no use as a supplement to interceptor maintenance No disposal of waste cooking oil into drains
Core Elements FOG Control Program Prohibitions: No discharge of wastewater from dishwashers into grease trap or interceptor No toilet discharge into grease interceptor No interceptor waste into the sewer system 25% Rule on grease interceptor operation
Fees FOG Control Program Estimated at $100 Permit Fee Noncompliance Fee at $100 per event No additional fees
Proposed OCSD FOG Ordinance
Core Elements FOG Ordinance Kitchen BMP Requirements: Installation and use of drain screens Segregation, collection, and recycling of cooking oil Disposal of food waste into the trash Proper maintenance of kitchen exhaust filters Kitchen signage Employee training
Core Elements FOG Ordinance FOG Pretreatment requirement for new and remodeled FSEs: Requirement for standard dischargers Require space and plumbing segregation considerations for insignificant dischargers Remodel triggers Substantial change in discharge $50,000 remodel
Core Elements FOG Ordinance FOG Pretreatment requirement for existing FSEs: Insignificant dischargers conditional waiver Standard dischargers 3-year conditional waiver for most (more detail later) Installation required within 180 days of notification Variance with an approved alternative pretreatment technology Waiver with grease disposal mitigation fee where grease interceptor is not feasible due to space or plumbing slope issues
Core Elements FOG Ordinance Grease Interceptors: Design follows California plumbing code Maintenance requirements Must pump-out completely before 25% full of FOG and / or solids Must maintain records Compliance will be verified through inspections 90-day minimum pump-out frequency Variance request required for 3-6 months pump out frequency
Core Elements FOG Ordinance 3-year Conditional Waiver for Existing FSEs: Waiver can be revoked based on noncompliance or identification as a significant source of FOG Encourages Kitchen BMPs by all FSEs Allows considerations for alternatives FOG control program will be reevaluated along with the waiver
Adoption Process FOG Ordinance Current Schedule: Oct 27, 2004 First Reading, OCSD Board Meeting Nov 17, 2004 Second Reading, OCSD Board Meeting Dec 28, 2004 Adoption by OCSD Board
Immediate Impacts on FSEs All FSEs required to follow Kitchen BMPs FSEs with grease interceptors required to pump them out quarterly, at a minimum Most existing FSEs without grease interceptors will receive a conditional waiver Some existing FSEs without grease interceptors required to retrofit their facility
Long-Term Impacts on FSEs If program successful little change If program unsuccessful there will be more stringent requirements
Questions? For further information, contact: Mahin Talebi (714) 593-7410 Source Control Division mtalebi@ocsd.com Jerry Evangelista (714) 593-7419 Source Control Division jevangelista@ocsd.com Orange County Sanitation District www.ocsd.com/fog