National Restaurant Association FATS, OILS AND GREASE CONTROL

National Restaurant Association

FATS, OILS AND GREASE CONTROLPROGRAM TOOL KIT

September 2006

Fats, Oil, andGrease

Manholes

PotentialManhole

Inlet

From KitchenTo Sewer

Solids

Outlet

GreaseFloats

SolidsSettle

1 Photo courtesy of Monterey Regional Water Pollution Control Agency

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Cooking grease in wastewater discharged from apartmentbuildings, homes, restaurants, and hotels is causing fats, oil,and grease (FOG or grease) blockages in sewer lines. Thesegrease blockages, located in either the property owner’s sewerlateral or the public agency’s sanitary sewer system, can causeback-ups into kitchens or basements, or can lead to sanitarysewer overflows (SSOs) which can cause untreated sewage toflow onto streets and travel to storm drains, creeks, and othersurface waters. SSOs have become the focus of many largelawsuits and a Report to Congress by the EPA in 2004. This hasmade the control of grease blockages a high priority for theEPA and many states which are now requiring municipalities toadopt FOG Control Programs that include controlling the FOGdischarge from restaurants.

In September 2005, Connecticut issued a General Permitrequiring restaurants and other food service establishments toinstall grease interceptors. In May 2006, California adopted astate law to reduce SSOs that requires each sewer agency toadopt a FOG Control Program and to regulate restaurants andother food service establishments. Other states have adoptedor are considering similar regulations.

The National Restaurant Association supports efforts to reducegrease blockages and SSOs which will protect the environmentand help keep restaurant drain lines clear. As with any newenvironmental program, we also have a concern that some newregulations may negatively impact restaurants without substan-tial benefit in reducing grease blockages.

This paper has been developed to provide State RestaurantAssociations and individual restaurants with a general under-standing of the FOG blockage problem, new FOG controlregulations, logical FOG control practices, and guidance forevaluating FOG control requirements. This Tool Kit should beused by State Associations and individual restaurants to worktogether with sewering agencies to develop logical and techni-cally based FOG Control Programs that are effective and fair.

Issue Overview/History

The following terms are often usedinterchangeably throughout theUnited States, but for the sake ofthe readers of this Tool Kit, theseterms are defined as follows:

Conventional Grease InterceptorA large grease control tank, typical-ly installed outside and in-ground,cleaned by a pumping company

Grease TrapA small grease control devicewith manual grease removal, typi-cally installed inside and aboveground, generally cleaned andmaintained by restaurant staff

Grease Removal Device(Automatic Grease Trap)A small grease control device withautomatic grease removal, typical-ly installed inside and aboveground, generally cleaned andmaintained by restaurant staff

Grease Control DeviceGeneral term used for any con-ventional grease interceptor,grease trap, grease removaldevice, or alternative technologyused to separate oil and greasefrom kitchen wastewater.

Note: Many plumbing codes andagency ordinances are now usingthe term “grease interceptors” forall grease control devices.

TERMINOLOGY



Due to new State regulations, EPAenforcement, or SSO lawsuits, your localsewer agency may have already con-tacted your restaurant to explain theirFOG Control Program or to issue yourrestaurant a wastewater discharge per-mit. You may have been asked to installa grease interceptor or grease trap. Atthe very least, you have probably beenissued a flyer or poster encouraging youto reduce your FOG discharge throughkitchen Best Management Practices(BMPs) such as scraping plates or recy-cling your fryer grease.

The following grease control pro-gram elements may soon berequired for your restaurant, if theyhaven’t been required already:

PERMITS Some agencies are issuingor are requiring restaurants to applyfor a wastewater discharge permit inorder to regulate their grease dis-charge. This allows the agency to spellout the restaurant’s responsibilities,but the permitting process can be verycomplicated and burdensome for boththe agency and the restaurant. TheNational Restaurant Association recog-nizes that some agencies may chooseto permit restaurants, but the permitsshould be simple and straightforward.Many agencies have developed a briefand easy to understand permit thatrefers to an agency’s ordinance orother policy documents. This permitprocess works well for the agency andthe restaurant.

IMPLEMENTATION OF KITCHENBEST MANAGEMENT PRACTICES(BMPS) Although many restaurants

have already implemented KitchenBest Management Practices (BMPs)to prevent grease from being dis-charged down the drains, some agen-cies are requiring restaurants to imple-ment specific Kitchen BMPs as a con-dition of their FOG Control Program.The National Restaurant Associationsupports BMPs that will preventgrease blockages; however, the BMPsshould be practical and cost effective.

GREASE CONTROL DEVICEINSTALLATION REQUIREMENTSGrease control devices have been inuse for years at many restaurants.However, many agencies are lookingto require more restaurants to installgrease control devices. Although thesedevices are a logical requirement formany restaurants, the NationalRestaurant Association is concernedthat some agencies may requirerestaurants that discharge little or nogrease to unnecessarily install expen-sive grease control devices.

GREASE CONTROL DEVICECLEANING AND MAINTENANCEREQUIREMENTS Grease controldevices must be cleaned or main-tained regularly in order to functionproperly. Quarterly cleaning is suffi-cient for most conventional greaseinterceptors and weekly cleaning ormaintenance is sufficient for mostgrease traps and grease removaldevices, particularly if Kitchen BMPsare implemented. However, someagencies are requiring mandatorymonthly cleaning of conventionalgrease interceptors or daily cleaningor maintenance of grease traps or

grease removal devices. This isexcessive at a vast majority ofrestaurants. The National RestaurantAssociation recognizes that morefrequent cleaning or maintenancemay be warranted for specificrestaurants, but this should only bea requirement if there is evidence tojustify these frequencies.

WASTEWATER DISCHARGE–OIL ANDGREASE CONCENTRATION LIMITREQUIREMENT Some agencies aresampling and analyzing the waste-water discharge from restaurants (ortheir grease control devices) andrequiring that the wastewater containless than a prescribed concentrationlimit of oil and grease. Oil and greaselimits can vary from 100 milligramsper liter (mg/L) to 500 mg/L. Theselimits can also be stated as parts permillion (ppm). Because the laboratorytest used for this analysis measuresboth emulsified and non-emulsifiedoil and grease, these limits are not atrue indication of the effectiveness ofgrease control devices or the greaseblockage potential of the restaurantdischarge. For this reason, manyagencies are moving away from oiland grease limits and relying insteadon inspection of grease controldevices to confirm proper mainte-nance and in some cases closed cir-cuit television (CCTV) monitoring ofthe sewer line. The NationalRestaurant Association does not sup-port oil and grease limits, but doessupport any monitoring efforts byagencies that provide a true indica-tion of the impact of grease dis-charges by restaurants.

Elements of greasecontrol programs



kitchen best managementpractices (BMPs)

There are many ways in which restaurants can pre-vent or reduce the amount of grease that is dis-charged into kitchen drains. Based on researchingKitchen BMPs throughout the country, the NationalRestaurant Association has prepared the followinglist of helpful Kitchen BMPs that are consideredpractical and cost effective for most restaurants:

1. KEEP GREASE OUT OF THE DRAINS/COLLECT ANDRENDER YELLOW GREASE Prevent pouring excess oilor grease down the drain. This “yellow grease” shouldbe collected and rendered. The more yellow grease thatis collected and rendered, the less grease that ends upin drains, or in grease interceptors or grease traps.

2. SCRAPE GREASE ANDFOOD FROM PLATES ANDCOOKWARE BEFOREWASHING Using gloves orrubber spatulas, greaseand greasy food scrapsshould be scraped offplates and cookwarebefore washing. Thismaterial should be addedto the trash or recycled aspart of a food waste recy-cling program.

3. USE DRAIN SCREENS Using drain screens, particu-larly on sink drains, will prevent much of the greaseand greasy food particles from ending up in thedrains.

4. WIPE UP GREASESPILLS BEFORE USINGWATER Grease spills andgrease drippings should bewiped up with a paper orcloth towel or through theuse of other adsorbentmaterials such as kitty litterbefore using water to mini-mize the amount of greaseending up in the drains.

5. LIMIT GARBAGE DISPOSAL USE TO NON-GREASYFOOD MATERIALS For restaurants that have garbage dis-posals, they should be limited to processing non-greasyfood materials such as lettuce in food preparation areas tominimize the amount of grease ending up in the drains.

6. EMPLOYEE TRAINING Employees must be trainedto implement the kitchen BMPs and/or to properlyclean out grease control devices such as grease traps.

* Photos 1, 2 and 4 courtesy of East Bay Municipal Utility District.



benefits to the restaurant ofimproving fog control

Whether a restaurant is part of a FOG control program or not, improved FOG control providesmultiple benefits for restaurants:

• Avoidance of non-compliance fees or fines

• Benefit the environment and the community

FOG Control Practice Benefit

• Reduced drain line blockages and cleaning

• Reduced cost of drain line cleaning and jetting

• Reduced SSOs

• Reduced odors

• Reduced non-renderable waste grease generation

• Reduced drain line blockages and cleaning

• Reduced SSOs

• Reduced odors

Improved Kitchen BMPs (less grease downthe drain)

Increased cleaning or maintenance ofgrease control devices

Overall compliance with the FOG controlprogram



Most agencies consider the requirement to install grease control devices to be the most important part of their FOGcontrol program. The general thinking is that even if Kitchen BMPs are not fully implemented, the grease controldevice(s) will capture the grease and protect the sewer. Sewer use ordinances based on national plumbing codesprovide the authority for agencies to require certain restaurants to install grease control devices. However, deter-mining which restaurants require grease control devices and which grease control device(s) is the most appropriatefor a specific restaurant provides a challenge for every agency.

requirements to install agrease control device

Requirements for New RestaurantsMost new restaurants are required to install a greasecontrol device to prevent grease from flowing into theagency’s sanitary sewer system. This is a logicalrequirement for new restaurants that are expected todischarge grease due to their menu or kitchen fixtures.Examples include restaurants that prepare significantquantities of steak, pork, chicken, fish, pasta, soup, orfried food using grills, fryers, rotisseries, woks, and tiltkettles. Conversely, many new restaurants should notbe required to install a grease control device if they arenot expected to discharge much grease due to theirmenu or kitchen fixtures. For example, the requirementto install a conventional grease interceptor is most like-ly unnecessary for sandwich shops, coffee shops, juiceshops and other non-grease generating restaurants.

Concerning these new non-grease generating restau-rants, some sewering agencies believe that they shouldrequire the installation of conventional grease intercep-tors. This requirement may be due to the agency’s con-cern that the next owner or tenant may convert the busi-ness into a restaurant that will discharge a significantamount of grease. The National Restaurant Associationrecognizes this concern and encourages sewering agen-cies to not require the current restaurant to incur thecost of installing and maintaining a conventional greaseinterceptor for grease that may or may not be dis-charged by a future restaurant. One logical solution is torequire these new restaurants to plumb the kitchenwaste piping separately from the sanitary waste pipingand to provide outdoor space for a conventional greaseinterceptor in case a retrofit is needed in the future.Indoor grease control devices may also be installed inthe restaurant, if space is not available outside.

Requirements for Existing RestaurantsMany existing restaurants already have grease controldevices installed. If these devices are properly main-tained, they should provide sufficient grease controland no other devices should be needed for theserestaurants in most cases. Due to new grease controlrequirements in many areas of the country, existingrestaurants without grease control devices are beingrequired to install a grease control device(s). However,many agencies are “grandfathering” (i.e., removing orpostponing the requirement) existing restaurants due tothe potential significant cost of purchasing the deviceor retrofitting the facility. Logical reasons why someagencies may not “grandfather” certain existing restau-rants and may require grease removal devices are: 1)when a significant remodel occurs; 2) non-adherence toFOG Control Program requirements; or 3) dischargingto a portion of the sewer system that has a history ofgrease blockages.

Plumbing and Sizing RequirementsGrease control device plumbing and sizing require-ments vary throughout the United States based on dif-fering plumbing codes and agency preferences. TheNational Restaurant Association is planning to providemore information in this area through future literatureor on our Web site.



CONVENTIONAL GREASE INTERCEPTORS

Conventional grease interceptors operate by gravity separation. Givensufficient space and time, floating grease and settled solids separatefrom the kitchen wastewater and slowly accumulate in the interceptor(see the figure below).

For the interceptor to perform correctly, the floating grease and settledsolids must be removed before they accumulate beyond a certain levelto avoid clogging the plumbing in the interceptor or significantly reduc-ing the overall space in the interceptor, which affects the ability of theinterceptor to separate the waste material from the wastewater. Thestandard maintenance level for floating grease and settled solids accu-mulation is “The 25% Rule.” According to “The 25% Rule,” if the com-bined accumulation of floating grease and or settled solids exceeds25% of the capacity of the interceptor, the interceptor must be cleaned(pumped) by a waste hauler. The “25% Rule” or a similar standard hasbeen adopted and is now being enforced by many sewering agenciesaround the country.

Many agencies require that conventional grease interceptors be cleanedat a mandatory minimum frequency to prevent the over-accumulation offloating grease and settled solids. Minimum quarterly cleaning is per-haps the most common requirement, but some agencies require morefrequent cleaning (e.g., monthly cleaning). Although more frequentcleaning may be appropriate for some restaurants with unusually highgrease discharge, this is likely overkill for a vast majority of restaurants.

It is important that conventional grease interceptors be pumped outcompletely when they are cleaned. Otherwise the settled solids willaccumulate and eventually clog the internal plumbing in the intercep-tor. At the very least, the decay of the solids over time will generatehydrogen sulfide gas and unpleasant odors (rotten egg smell). Manyagencies require that conventional grease interceptors be fully pumpedout every time due to these concerns.

cleaning and/or maintenanceof grease control devices

GREASE TRAP1

Grease traps also operate by gravity separation;however, grease traps use a flow control device andbaffles to allow the separation of floating FOG andsettled solids in a much smaller tank (see the figurebelow).

Like a conventional grease interceptor, in order for agrease trap to perform correctly, the floating FOGand settled solids must be removed regularly.However, since grease traps are significantly smallerthan conventional grease interceptors, the necessaryfrequency of cleaning is much greater. Minimumweekly cleaning is required by some agencies. Somerestaurants may have to clean out their grease trapmore often than weekly due to unusually highgrease discharge from specific fixtures. It is reason-able for most restaurants to conduct weekly checksor cleaning of the grease trap to ensure properoperation.

Grease trap cleaning is typically conducted byrestaurant staff; however, some agencies requirethat pumping companies conduct the cleaning. Thisis problematic for most restaurants since the cost ofusing a pumping company for such a frequent basiccleaning practice may discourage the restaurantfrom cleaning the grease trap as often as it isneeded.

1 Grease Removal Devices (GRDs) are very similar to greasetraps in terms of their size and how they separate the oiland grease from the wastewater. Due to their automaticgrease removal design, grease removal devices do notrequire as much cleaning as grease traps, but they typicallyrequire more frequent maintenance.


Removable Lid Cleanout

Outlet

Air Relief

Baffles

Solids

Inlet

Flow Control Device

CONVENTIONAL GREASE INTERCEPTOR Outdoor, In-ground–Precast Concrete (Typical)

GREASE TRAP Indoor, Above Ground (Typical)


Manholes

PotentialManhole

Inlet

From KitchenTo Sewer

Solids

Outlet

GreaseFloats

SolidsSettle



National Restaurant AssociationGovernment Affairs & Public Policy

PersonnelNational Restaurant Association1200 17th Street, NWWashington, DC 20036(202) 331-5900Fax: (202) 973-5374www.restaurant.org

John GaySenior Vice President, GovernmentAffairs & Public Policy(202) 331- 5912Fax: (202) [email protected]

Federal Relations(202) 973-5373www.restaurant.org/government/issues

Brendan FlanaganVice President, Federal Relations(202) [email protected]: Labor, Health Care, Minimum Wage, CoalitionOn Job Opportunities (COJO), Obesity LawsuitCoalition, Education & Workforce, Health EducationLabor & Pensions (HELP) Committee, Health SavingsAccounts, Association Health Plans, Fair LaborStandards Act (FLSA) Reform, Regulatory Reform,Occupational Safety & Health Act (OSHA) Reform,Family & Medical Leave, Pensions/Retirement, SocialSecurity, Federal Budget, Child Labor, CompensatoryTime, Education, Ergonomics

Michelle ReinkeDirector, Legislative Affairs(202) [email protected]: Tax, Nutrition/Healthy Lifestyles, Trade, Ways& Means Committee, Finance Committee, Obesity(general), Menu Labeling, Uniformity, BuildingDepreciation, Estate Tax, Food Donations, FederalInsurance Contributions Act (FICA), FederalUnemployment Tax Act (FUTA), Alternative MinimumTax (AMT), Travel & Tourism, Food Safety & Security,Bovine Spongiform Encephalopathy (BSE), Country ofOrigin Labeling, Food Allergies, Biotechnology &Acrylamide, Transportation

Mike ShutleyDirector, Legislative Affairs(202) [email protected]: Immigration, Litigation/Tort Reform, H-2BCoalition, Obesity Lawsuit Coalition, JudiciaryCommittee, Energy & Commerce Committee, SmallBusiness Committee, Banking/Financial ServicesCommittee, Obesity Lawsuits, Lawsuit AbuseReduction Act, Americans with Disabilities Act (ADA)Notification, Lobby Reform, Credit Card/InterchangeFees, Social Security, Fax Ban, Music Licensing,Smoking, Air Quality/Environment, Energy

Kathleen O’Leary(202) [email protected]: Tax, Tip Audits, Business Meal Deductions

Casey StanfordCoordinator, Federal Relations(202) [email protected]

State Relations & Grassroots(202) 973-5374www.restaurant.org/government/state

Tom FoulkesVice President, State Relations

& Grassroots Programs(202) [email protected]

Kelly BenedettiDirector, Save American Free Enterprise (SAFE) Fund(202) [email protected]

Meredith NethercuttManager, State Relations & Grassroots(202) [email protected]

Amanda M. RieterManager, State Relations (202) [email protected]

Tim EhlertCoordinator, State Relations (202) [email protected]

Political AffairsNed MonroeVice President, Political Affairs(202) [email protected]

Lindsay MacMeansManager, Political Affairs(202) [email protected]

Health & SafetyRegulatory Affairs(202) 973-3671www.restaurant.org/foodsafety

Dr. Donna GarrenVice President, Health & Safety Regulatory Affairs(202) [email protected]

Christine AndrewsDirector, Health & Safety Regulatory Affairs(202) 331-5985

Sheila Cohn WeissDirector, Nutrition Policy(202) [email protected]

Jo CerraOffice Manager(202) [email protected]

Environmental Engineering &Contracting, Inc. (EEC)

FOG control consultant for agencies,industry, and commercial businesses,provided technical support for this Tool Kit.

501 Parkcenter DriveSanta Ana, CA 92705(714) 667-2300Fax: (714) 667-2310www.eecworld.com

Documents

National Restaurant Association FATS, OILS AND GREASE CONTROL