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Memorandum from the Department of Environmental Protection
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STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION
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To:     All Superintendents and Water Pollution Control Authorities

From:   William R. Hogan, Engineer of WPCF, Municipal Facilities Section

Date:   January 14, 2004

Re:     FOG General Permit Update and Coordination with Building Officials

The FOG General Permit, specifically called the “General Permit for the Discharge of Wastewater Associated with Food Preparation Establishments”, is undergoing final review within the DEP. It is anticipated that the public notice of intent to issue the permit will occur this spring of 2004. Actual issuance of the permit may or may not be several months later with the timing dependent upon the number of comments received during the public notice period. Therefore, your written support during the comment period will affect the time table of this General Permit.

As the permit is currently drafted, any food preparation establishment in operation on or before the day of issuance will be allowed three years to comply with the conditions of the permit. Any food preparation establishment that begins operation after the issuance will need to be in compliance when operations begin. This may create a dilemma for some food preparation establishments that are seeking local approvals now or that might seek local approvals in the near future.

In order to minimize this dilemma, DEP is attaching for your immediate use the conditions of the General Permit including the compliance schedule, approvals, treatment requirements, and reporting and record keeping requirements. Copies of this document should be made available through the WPCA and local building official to all food preparation establishments seeking approval from your municipality to initiate operations or to create a new connection to your sanitary sewers. Any food preparation establishment developing a new facility this spring would be advised to plan for the construction of a grease trap/interceptor constructed in accordance with the treatment requirements in the attached document.

As stated above, your assistance in this matter will make the implementation of this permit run smoother. To further aid all municipalities, the Department will provide a DEP funded Model F.O.G. Program in the form of a Guidance Document and Resource Manual that will be mailed to all municipalities prior to the public notice of intent to issue the general permit. These documents will greatly aid the municipal staff that will be dealing directly with.the food preparation establishments.

Please feel free to contact Joe Nestico at (860) 424-3755 if you have any questions. The joint efforts of the DEP with those of your municipality will create a statewide program to address the serious impacts of uncontrolled grease discharges to the sanitary sewers.


(Printed on Recycled Paper)
79 Elm Street  Hartford, CT 06106 - 5127
An Equal Opportunity Employer


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STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION
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To:     All Superintendents and Water Pollution Control Authorities
From:    William R Hogan, Engineer of WPCF, Municipal Facilities Section
Date:     January 2l, 2004
Re:     Missing Attachments to January 14, 2004 Memo

Below please find conditions from the FOG General Permit Draft regarding a compliance schedule, approvals, treatment requirements, pollution prevention/best management practices and reporting and record keeping requirements. As stated in my January 14,2004 memo to you, “copies of this document should be made available through the WPCA and local building official to all food preparation establishments seeking approval from your municipality to initiate operations or to create a new connection to your sanitary sewers. Any food preparation establishment developing a new facility thus spring would be advised to plan for the construction of a grease trap/interceptor constructed in accordance with the treatment requirements in the attached document.”

Conditions of This General Permit
(a) Compliance Schedule

A permittee shall assure that every authorized discharge is conducted in accordance with the following schedule:

(1)     A facility, which discharges as of the date of issuance of this general permit shall comply with all the conditions of the general permit no later than three (3) years from the effective date of this general permit. -

(2)     A facility, which begins discharging after the effective date of this general permit, shall comply with all conditions before initiating the discharge.
        
(b) Approvals

(1)     If the wastewater is to be directed to a POTW, the design of grease trap/interceptor shall be approved in writing by the applicable Water Pollution Control Authority and/or local building official.

(2)     If the wastewater is to be directed to a large subsurface sewage disposal system with a design flow greater than 3000 gallons per day, then the grease trap/interceptor shall be approved in writing by the Commissioner.

(c) Treatment Requirements

An authorized discharge shall meet the following specifications:

(1)     Outdoor In-Ground Grease Trap/Interceptor

(A)     The grease trap/interceptor shall be installed on a separate building sewer line servicing kitchen flows and shall be connected only to those fixtures or drains


which would allow fats, oils, and grease to be discharged. This shall include:

     circlebullet.jpgPot sinks;

        circlebullet.jpgPre-rinse sinks;

        circlebullet.jpgAny sink into which fats, oils, or grease are likely to be introduced

        circlebullet.jpgSoup kettles or similar devices;

        circlebullet.jpgWok stations;

        circlebullet.jpgFloor drains or sinks into which kettles may be drained;

        circlebullet.jpgAutomatic hood wash units;

        circlebullet.jpgAny other fixtures or drains that are likely to allow fats, oils and grease to be discharged and

        circlebullet.jpgDishwashers without pre-rinse sinks.

(B)     The outdoor in-ground grease trap/interceptor shall have a minimum detention time of the greater of (1) at least twenty-four (24) hours of the maximum daily flow from the fixtures described in subparagraph (A) of this section based on water meter records or other methods of calculation as approved by the Water Pollution Control Authority and/or local building official or the Commissioner or (2) 1000 gallons. The grease trap/interceptor shall have a minimum depth of four (4) feet

(C)     The grease trap/interceptor shall be watertight and constructed of concrete or other durable material. It shall be located so as to be accessible for convenient inspection and maintenance. No permanent or temporary structures or containers shall be placed directly over the grease trap/interceptor. Grease trap/interceptors installed in areas subject to traffic shall be designed to accommodate traffic loading.

(D)     If the grease trap/interceptor is constructed of concrete the following requirements shall apply:

i)      All concrete grease trap/interceptors shall be produced with minimum 4,000-psi concrete per ASTM standards with four (4) to seven (7) percent air entrainment.

ii)     The minimum liqui4 depth of the grease trap/interceptor shall be thirty-six inches, measured from the bottom of the tank to the outlet invert.

iii)    The air space provided between the liquid height and the underside of the tank top shall be a minimum of eight (8) inches.

iv)     All structural seams and/or lifting holes shall be grouted with non-shrinking cement or similar material and coated with a waterproof sealant. .In areas where seasonal high ground water is at an elevation greater than the bottom of the grease trap/interceptor, the exterior of the grease trap/interceptor including the exterior top, sides and bottom shall be coated with a waterproof sealant creating a water tight condition for the tank. In areas where seasonal high ground water is at an elevation greater than the top of the grease trap/interceptor, the exterior of the extension to grade manholes shall be coated with a waterproof sealant creating a water tight condition for the extension to grade manhole.

v)      All new grease trap/interceptors shall be manufactured with manhole covers that have a placard with a warning “Entrance into the tank could be fatal”.

vi)     The liquid capacity of the tank shall be marked on the top of the tank between the outlet access hole and outlet wall or on the vertical wall between the top of the tank and the top of the outlet opening.

vii)    The invert elevation of the inlet shall be between 2” and 4” above the invert elevation of the outlet.

(E)     All non-concrete tanks shall meet the requirements set forth in Sections 5(cXlXC) and 5(cXl)(DXii), (iii), (v), (vi) and (vii) of this general permit.

(F)     Separate cleanout covers shall be provided over the inlet and outlet of the grease trap/interceptor so as to provide easy access for inspection and cleaning. Cleanout ports shall be fitted with manhole extensions to grade. In areas subject to traffic, the extensions shall have ductile iron frames and manhole covers. Where concrete covers are used, the lid must weigh a minimum of 59 pounds or be provided with a lock system to prevent unauthorized entrance. The manholes, extensions, and accesses to the grease trap/interceptor shall have a minimum inside diameter of seventeen (17) inches.

(G)     The inlet and outlet piping shall be PVC ASTM D 1785 Schedule 40 with rubber compression gaskets or solvent weld couplings. The joints must meet ASTM D 3212 specifications.   The Water Pollution Control Authority and/or Local Building Official may approve other piping materials for use.. The minimum diameter of the inlet and outlet piping shall be four (4) inches. The inlet and outlet shall utilize a tee-pipe fitting on the interior of the grease trap interceptor. The tee-pipe of the inlet and outlet shall extend to within twelve (12) inches of the bottom and at least three (3) inches above the static liquid level of the tank.

(H)     The grease trap/interceptor shall be set level on a consolidated, stable base such that no settling or tipping of the grease trap/interceptor can occur.

(I)     The outlet discharge line from the grease trap/interceptor shall be directly connected to the municipal sanitary sewer or large subsurface sewage disposal systems

(J)     No fixture or drain other than those listed in subsection (aXl)A of this section shall be connected to the grease trap/interceptor unless approved by the Water Pollution Control Authority and/or local building official or the Commissioner.

(K)     The grease trap/interceptor shall be located so as to maintain separating

distances from well water supplies based on flow and horizontal measurements set forth in Section 19-13-B5ld of the Public Health Code.

(L)     Minimum separating distances shall be maintained between the grease trap/interceptor and such items (e.g. buildings, watercourses, drains) as those listed in Section 19-13-B103 of the Public Health Code.

(M)  If the Water Pollution Control Authority or the Commissioner notifies the permittee that testing is required, it shall be performed in the following manner:

i)     Vacuum Test - Seal the empty tank and apply a vacuum to two (2) inches (50mm) of mercury. The tank is acceptable if 90% of vacuum is held for two (2) minutes.

ii)     Water-Pressure Test-Seal the tank, fill with water, and let stand for twenty-four (24) hours. Refill the tank The tank is acceptable if the water level is held for one (1) hour.

(2)     AGRU

When the Water Pollution Control Authority and/or local building official or the Commissioner agrees with the permittee that it is not possible such as but not limited to site restrictions or site constraints for the permittee to install an outdoor in-ground grease trap/interceptor per Section 5(cXl), installation of an indoor AGRU is required. The AGRU shall meet the following requirements:

(A)  An AGRU shall be installed immediately downstream of each fixture or multiple fixtures listed in subsection (a)(1) of this section.

(B  The AGRU shall be sized to properly pre-treat the measured or calculated flows for all connected fixtures or drains as listed in subsection (a)(1) of this section.

(C)  The AGRU shall be constructed of corrosion-resistant material such as stainless steel or plastic.

(D)  Solids shall be intercepted and separate4 from the effluent flow using an internal or external strainer mechanism. This mechanism shall be an integral part of the unit.

(E)  The unit shall operate using a skimming device, automatic draw-off, or other mechanical/hard wired electrical means to automatically remove separated fats and oils. This automatic skimming device shall be controlled using a timer or level control. The operation of the automatic skimming device shall be field adjustable. The AGRU shall operate no less than once per day.

(F) The AGRU shall be fitted with an internal or external flow control device to prevent the exceedence of the manufacturer’s recommended design flow.

(G)The AGRU shall be located so as to permit access for maintenance.

(H)No fixture or drain other than those listed in subsection (cXlXA) of this section shall be connected to the AGRU.

(I)All AGRUs shall be designed and installed in accordance with the manufacturer’s specifications.

(3)     Other Approved Unit

If the permittee requests the use of other units other than an outdoor in-ground grease trap/interceptor or an AGRU, the permittee must demonstrate that the other unit can reliably meet the effluent limitations in subsection 5(d) of this section. Upon written approval by the Water Pollution Control Authority and/or local building official or the Commissioner who agrees the permittee that it is possible then the other unit may be installed.


(4) Pollution Prevention /Best Management eat Practices (IMP)

(1)     No valve or piping bypass equipment that could prevent the discharge of food preparation wastewater from entering appropriate treatment equipment shall be present at such facility.

(2)     Renderable fats, oils, and grease shall only be disposed of in separate storage containers for recycling by a renderer. No renderable fats oils, and grease shall be discharged into grease trap/interceptors or AGRUs, sanitary sewers, large subsurface sewage disposal systems, dumpsters or storm sewers.

(3)     At a minimum, the permiittee shall perform quarterly inspections off the grease trap/interceptors or other approved units.

(4)     Outdoor in-ground grease trap/interceptor(s) shall be cleaned by a subsurface sewage disposal cleaner whenever 25% of the operating depth of the grease trap/interceptor is occupied by fats, oils, grease and settled solids or a minimum of once every free (3)months whichever is more frequent. If less frequent cleaning is required for the grease trap/interceptor to operate effectively, the permittee shall provide adequate proof through the quarterly inspections or other documentation to demonstrate to the satisfaction of the Water Pollution Control Authority and/or local building official or the Commissioner to allow less frequent cleaning. Such approval shall be in writing. The permittec shall maintain a written log on-site of grease trap/interceptor cleaning and maintenance, shall maintain copies of the subsurface sewage disposal cleaner’s receipts and shall maintain a
                copy of such approval for five years.

(5)     All AGRUs shall be maintained as per the manufacturer’s recommendations.

(6)     For all grease trap/interceptors, AGRUs and other approved units, disposal of non-renderable fats, oils, and grease shall be at a Regional Disposal Site.

(7)     The permittee shall not use hot water, steam, physical means, chemicals or biological additives that could cause the fats, oils, and grease fraction tobe released from the grease

trap/interceptors, AGRUs and other approved units into the sanitary sewer or large subsurface sewage disposal systems.

(8)     No food grinder or food pulper shall discharge to any grease trap/interceptors, AGRUs and other approved units.

         (9)      Wastewater flow from the fixtures allowed in subsection (c)(e)(1)(A) of this section shall be screened to prevent solids from entering the grease trap/interceptors, AGRUs and other approved units. Screened solids shall be disposed of in accordance with applicable solid waste regulations.

(e) Reporting and Record Keeping Requirement


(1)     A written log of all inspections required in subdivisions 5(e)(3) and 5(e)(4) of this section shall be maintained for each discharge authorized by this general permit. The log shall document: the date of the inspection; the inspector’s name; title and signature; the depth, as measured at the time of the inspection, of fats, oils, grease and food waste located within the grease trap/interceptor; and any maintenance work and changes in equipment associated with such discharge that has taken place at the site since the last inspection.

  (2)   Except as provided in subsection (e) of this section, the permittee shall retain, for a period of five (5) years at the subject facility, all inspections, cleaning and maintenance logs and analytical results from any monitoring elected to be done by the permitted. All records and reports shall be made available in writing to the Water Pollution Control Authority and/or local building official or the Commissioner upon request.

(3)     immediately upon learning or having reason to believe that an discharge may cause or has caused a sewer blockage or may adversely affect the operations of a POTW, the permittee shall notify the POTW Authority.


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