Statewide Grease Regulation to take Full Effect on July 1, 2011

by Kathryn Scott, Hadlyme Environmental Engineers

If you watch the TV show Dirty Jobs you may have seen the episode where Mike Rowe helps clean a basement that has been flooded with sewage. Within Connecticut, municipal wastewater overflows the collection system an average of 180 times each year contaminating waterways, flooding streets, and destroying property. Data collected by the Connecticut Department of Environmental Protection (CTDEP) indicates that animal fat, cooking oils, and food related grease cause around one third of these events. Mechanical failure and objects, such as rocks or wood, lodged in the sewage system cause most of the other overflow events.

Fat, oil, and grease are liquid when warm; therefore, many people think that pouring grease down the drain is an appropriate means of disposal. However, as the grease cools it solidifies and coats the inside of the sewage collection pipe. Even small volumes of grease discharged every day, over time, can completely block the sewer pipes and cause sewage to overflow the system. The resulting overflow is usually distant from where the grease originated so the facility discharging the grease may be unaware of the problem. Properly sized and maintained grease traps can collect the grease discharged with wastewater and prevent accumulation in the sewage pipes where it can be difficult and expensive to remove.

Requirements for grease traps have been part of the public health code and sewer use ordinances for decades. These codes and ordinances provided no guidance on cleaning or maintenance of the traps and made no provisions for disposal of the material removed from the traps. The result was installation of inefficient undersized indoor passive grease traps. The traps rarely received cleaning or maintenance and when they were maintained, proper disposal of the material was generally not readily available.

In an effort to correct these collections and disposal problems, the CTDEP developed a disposal system for grease, guidance on appropriately sized grease traps, and the required maintenance. The CTDEP's General Permit for the Disposal of Wastewater Associated with Food Preparation Establishments, which takes full effect on July 1, 2011, provides the minimum requirements for local programs. Local municipalities are responsible for overseeing the implementation of their own FOG Program. These local FOG Programs will affect all Class III and IV Food Service Establishments connected to municipal sewage collection systems.

The General Permit requires, at a minimum, a 1,000-gallon outdoor grease trap or an indoor automatic grease recovery unit (AGRU). Maintenance and documentation of that maintenance for both types of grease traps is required. Outdoor grease traps must be cleaned by a Septage/Grease Hauler once every three months. AGRUs need to be cleaned daily by the kitchen staff. Septage/Grease Haulers must dispose of the material removed from outside traps at a permitted regional grease collection facility.  Grease removed from AGRUs may be disposed of by the Septage/Grease Hauler at the regional facility or at a local collection site for transport to the regional facility. Grease from fryers is to be stored and disposed of separately with a Renderer.

Because the General Permit provides the framework for local programs, there will be variations in the requirements in each municipality. For details in your area, contact the local Water Pollution Control Authority. To view the General Permit and supporting documents visit www.ct.gov/dep. Use the DEP search function for "FOG Permit" to navigate to the appropriate area of the site.