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vii-a. FOG public outreach program
Requirement: An implementation plan and schedule for a public education outreach program that promotes proper disposal of FOG.
Discussion
The possible sources of FOG discharge to the LBNL sanitary sewer collection system include the on-site cafeteria (food preparation area) and incidental discharges from other facilities.
The Facilities Division Cafeteria Manager will discuss the implementation of FOG control practices with cafeteria management subcontractors. As discussed in SSMP section vii-c, the
cafeteria has not been required to have an EBMUD Food Handling Facility Wastewater
Discharge Permit. However, the Facilities Division’s goal is to have the cafeteria operate in compliance with typical EBMUD maintenance and best management practice (BMP) standards (see SSMP section vii-d) as a measure to prevent FOG blockages in the LBNL sanitary sewer collection system or in the UC Berkeley / EBMUD systems downstream. The FOG control practices meeting between the Cafeteria Manager and cafeteria management subcontractors will include a discussion of the following topics:
Review how the discharge of FOG material to the sanitary sewer collection system can
cause blockages, SSOs, and compliance issues for LBNL.
Review the current use of the cafeteria grease interceptor device.
Provide EBMUD FOG control program materials:
o EBMUD FOG control program brochure for food handling facilities
o EBMUD grease interceptor maintenance fact sheet
o EBMUD FOG BMP chart
o EBMUD maintenance documentation log
Discuss the need to implement a regular grease interceptor pumping schedule.
Additionally, the SSO Program Manager periodically conducts the following activities (typically annually) to help ensure compliance with waste discharge regulations and requirements
applicable to LBNL:
Ensuring that labels and appropriate discharge controls are in place at all sinks and
wastewater discharge areas in all LBNL facilities that prohibit the discharge of hazardous wastes and viscous / FOG materials through cyclical inspections and communication with the Cafeteria Manager.
Element vii. FOG Control Program
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P a g e | vii-3 Sewer System Management Plan These public outreach activities are in place to ensure that hazardous wastes or FOG materials are isolated and stored for later off-site disposal rather than discharged into the sanitary sewer collection system where they can cause blockages or compliance problems.
Related Documents
o Refer to EBMUD FOG Control Program Website
http://www.ebmud.com/wastewater/industrial_&_commercial_permits_&_fees/pollution _prevention_program/FOG/default.htm
Plan & Schedule
Task Responsible Party Scheduled Date
Discuss FOG control practices and provide EBMUD FOG control guidance documents to cafeteria managerial staff.
Cafeteria Manager January 2010
Complete cafeteria sink labeling inspections and label sinks appropriately
SSO Program
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vii-b. FOG disposal
Requirement: The FOG control program shall include a plan and schedule for the disposal of FOG generated within the sanitary sewer system service area.
Discussion
Grease interceptors should be pumped regularly to remove accumulated grease. If grease is not regularly removed, the internal compartment designed to capture grease fills to maximum
capacity, and additional grease is washed downstream into the sanitary sewer collection system. The LBNL Cafeteria Manager will establish a schedule for regular maintenance and grease removal for the cafeteria grease interceptor through its blanket contract for sewer maintenance services. Facilities operating grease interceptors are required to have waste removed by grease haulers licensed by the California Department of Food and Agriculture (CDFA) in accordance with Sections 19310 - 19316 of the Food and Agricultural Code. Grease haulers are required to transport grease only to renderers also licensed by the CDFA according to Section 19300-19306 of the Food and Agricultural Code. LBNL will ensure that the grease interceptor maintenance contractor is appropriately licensed as described above, and is on EBMUD’s list of approved grease haulers.
Related Documents
o Refer to EBMUD FOG Control Program Website
http://www.ebmud.com/wastewater/industrial_&_commercial_permits_&_fees/pollution _prevention_program/FOG/default.htm
Plan & Schedule
Task Responsible Party Scheduled Date
Procure services for regularly scheduled maintenance and grease removal for LBNL cafeteria grease interceptor by licensed grease hauler.
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vii-c. Legal authority
Requirement: The legal authority to prohibit discharges to the system and identify measures to prevent SSOs and blockages caused by FOG.
Discussion
With respect to facilities other than the on-site cafeteria, LBNL Facilities Division and EH&S Division staff have full control over the operation of all processes and devices at LBNL which have the possibility of impacting the environment, and are responsible for ensuring those devices are operating properly so as to comply with all applicable regulations and LBNL environmental plans. The goal of the EH&S Division and Facilities Division is to prevent sewer blockages due to FOG in the LBNL sanitary sewer collection system and systems downstream, as well as to comply with EBMUD's discharge concentration limit for oil and grease of 100 mg/L, as stated in Ordinance No. 311A-03 Title II Section 3a and enforced through LBNL's site-wide sewage discharge permits. At this time, EBMUD has determined that the site-wide sewage discharge permit for LBNL is an adequate means to ensure that excessive levels of FOG are not discharged to the City of Berkeley and EBMUD sanitary sewer collection systems, and that a site-specific
Food Handling Wastewater Discharge Permit is not required for the LBNL cafeteria. Management and operation of the LBNL cafeteria is conducted under subcontract. The LBNL Cafeteria Manager will review the existing contract and determine if amendments to the scope of work are necessary to ensure that typical EBMUD FOG control BMPs are implemented, BMP implementation is documented, and cafeteria food preparation workers are trained by
management to follow published EBMUD FOG disposal BMPs to prevent the discharge of FOG to the LBNL sanitary sewer collection system.
Related Documents
o Refer to Cafeteria Operation Services Contract Scope of Work
o Refer to EBMUD FOG Control Program Website
http://www.ebmud.com/wastewater/industrial_&_commercial_permits_&_fees/pollution _prevention_program/FOG/default.htm
Plan & Schedule
Task Responsible Party Scheduled Date
Review existing cafeteria operation services contract and determine if a revision to the scope of work is necessary for FOG control BMP efforts.
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vii-d. Grease removal devices
Requirement: The FOG Program shall include requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance
requirements, BMP requirements, record keeping and reporting requirements.
Discussion
Grease Interceptor & Grease Trap Installation, Design, and Construction Standards
LBNL has established a list of applicable State and National infrastructure design and
construction standards and codes within LBNL’s Construction Standards and Design
Requirements - Volume 1 Part 1 – Administrative Requirements. The California Plumbing Code and the American Society for Testing and Materials (ASTM) Standard are referenced within this document as applicable standards.
The California Plumbing Code (which is based on the Uniform Plumbing Code) includes design and sizing requirements for gravity grease interceptors and hydromechanical grease traps within a chapter specifically dedicated to these devices (UPC Chapter 10). There are two ASTM standards which apply to gravity grease interceptors, which are: (1) ASTM C1613 - 09 Standard Specification for Precast Concrete Grease Interceptor Tanks; (2) ASTM F2649 - Standard Specification for Corrugated High Density Polyethylene (HDPE) Grease Interceptor Tanks. An ASTM standard applicable to grease traps is currently under development.
Section 1014.0 of the Uniform Plumbing Code (UPC) states that,
“An approved type of grease interceptor complying with the provisions of this section shall be correctly sized and properly installed in grease waste lines(s) leading from sinks and drains, such as floor drains and floor sinks and other fixtures or equipment in serving establishments such as restaurants, cafes, lunch counters, cafeterias, etc. where grease may be introduced into the drainage or sewage system in quantities that can effect line stoppage or hinder sewage treatment or private sewage disposal.”
If any significant expansion to the existing cafeteria was undertaken, or if a new food handling facility was built at LBNL in the future, the requirement to install a grease interceptor or grease trap in accordance with the California / Uniform Plumbing Code to isolate FOG discharged from all fixtures where FOG may be present in the wastewater would be adhered to. The Facilities Division is responsible for maintaining copies of mechanical plans, plumbing plans, and device operation and maintenance manuals incase assistance with the operation or maintenance of a grease trap or interceptor is required.
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Grease Interceptor & Grease Trap Maintenance, BMP, and Record Keeping Requirements
To ensure that FOG discharges from the LBNL cafeteria are adequately controlled, the Facilities Division will require that cafeteria management conduct and document regular inspections (see SSMP section vii-e) to determine if proper grease interceptor maintenance is being
performed, and BMPs are being implemented, following the implementation of FOG control BMPs in accordance with modifications to the cafeteria operation services contract (refer to SSMP section vii-c).
The LBNL cafeteria does not operate under an EBMUD Food Handling Wastewater Discharge
Permit, however the Facilities Division intends for grease interceptor maintenance and FOG control BMPs to be implemented equivalent to the requirements of the typical EBMUD permits to prevent FOG blockages in the LBNL sanitary sewer collection system. The basic operation, maintenance, and record keeping requirements for grease interceptors as stated in the EBMUD permit standard terms and conditions include:
Operation and maintenance so as to comply with 100 mg/l local discharge limit for oil
and grease at all times.
Minimum quarterly grease pumping frequency, at which time all contents of
interceptor are removed.
For each grease interceptor maintenance activity, document the following:
o Date of service
o Volume pumped (gallons)
o Name of approved food handling facility waste grease hauler
o Approved waste grease disposal location
o Maintain receipt / manifest from contractor
Initially, the Facilities Division will schedule periodic grease interceptor maintenance through its blanket contract for sewer maintenance services. The contractor will be consulted to determine if the service frequency is either too long or too short, based on the observed accumulation of grease at the time of service. The service frequency may be adjusted based on the
recommendations of the contractor, as deemed necessary by the Facilities Division. The Facilities Division will maintain documentation of grease interceptor maintenance by retaining work orders and invoices provided by the contractor, which must include identification of the data typically required to be kept by EBMUD listed above.
In addition to implementing a schedule to regularly service the grease interceptor, the
implementation of general FOG disposal BMPs in the kitchen area can help reduce the amount of FOG discharged through fixtures that may not be served by a grease interceptor. FOG disposal BMPs help to isolate and remove FOG prior to mixing with water or emulsification during the dish and ware cleaning process.
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P a g e | vii-8 Sewer System Management Plan EBMUD publishes a BMP guide for food preparation, which includes activities such as:
Training staff on implementation of the BMPs.
Posting signs above sinks that prohibit the discharge of FOG.
Collection and recycling or off-site removal (by licensed grease haulers) of waste
cooking oil / fryer grease.
o A receipt for the removal of stored grease by a licensed grease hauler should be
maintained by the Facilities Division, similar to that maintained for grease interceptor pumping.
Dry wiping grease and food solids from dishes prior to dishwashing.
Regular grease interceptor / trap maintenance and inspection.
Grease spill cleanup procedures.
Cafeteria management subcontractors will be responsible for training staff who work in the food preparation or dishwashing area on the general implementation of the BMPs promoted by EBMUD, and ensuring that the BMPs are implemented on an ongoing and regular basis.
Related Documents
o Refer to LBNL Construction Standards and Design Requirements – Volume 1 Part 1:
Administrative Requirements (Latest Revision)
http://fac.lbl.gov/DandC/CDDG_Home/Volume1- Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Admin%20Requirements%2021706.pdf
o Refer to EBMUD FOG Control Program Website
http://www.ebmud.com/wastewater/industrial_&_commercial_permits_&_fees/pollution _prevention_program/FOG/default.htm
Plan & Schedule
Task Responsible Party Scheduled Date
Oversee initial FOG disposal BMP training for cafeteria food preparation / dishwashing staff by cafeteria management subcontractors.
Cafeteria Manager April 2010
Maintain documentation of grease interceptor maintenance and grease removal, including receipts / manifests from grease hauling contractors.
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vii-e. Inspection
Requirement: Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the FOG ordinance.
Discussion
LBNL cafeteria management subcontractors conduct annual inspections of the food preparation / dishwashing area to determine the success with which regular grease interceptor maintenance and FOG disposal BMPs are being implemented. The following items will be reviewed during the inspection / site visit:
Use of cooking oil / grease storage or recycling bins for removal and off-site disposal.
Posting of sink FOG disposal posters and BMP posters.
General staff knowledge of FOG-related issues.
Description of any unscheduled grease interceptor maintenance required, grease spills,
accidental grease discharges, or other unusual grease-related events, including corrective action taken, if applicable.
New staff sign-off for FOG control BMP implementation training.
LBNL cafeteria management subcontractors document the results of the inspection using the
form shown in Attachment vii-1, and delivers the completed form to the Facilities Division
upon completion.
Assessment of the grease interceptor maintenance requirements and for implementation of FOG disposal BMPs by LBNL cafeteria staff shall be conducted informally by either Facilities Division or EH&S Division Staff through the cafeteria operation services contract or during site visits.
Related Documents
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Plan & Schedule
Task Responsible Party Scheduled Date
Oversee inspection of cafeteria food preparation facility by cafeteria management subcontractors to determine success of grease interceptor
maintenance and FOG disposal BMPs activities.
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vii-f. Identification of FOG problem areas
Requirement: The FOG control program shall include an identification of sanitary sewer system sections subject to FOG blockages and establishment of a cleaning maintenance schedule for each section.
Discussion
Currently, FOG blockages have not been documented as a problem within LBNL's sanitary sewer collection system. However, if FOG blockages occur in the future, or are discovered through CCTV inspections, Facilities Division and EH&S Division Staff plan to identify likely sources of FOG discharges through analysis of upstream operations and processes, and implement source control measures to prevent further discharges of FOG. The EH&S and Facilities Divisions will use their ability and authority to control discharge sources through process modifications or additional training of LBNL personnel in facilities that may act as a source of FOG to prevent any identified FOG issues rather than expend financial resources on sub-contractor services to mitigate FOG discharges that are affecting the sanitary sewer collection system.
Related Documents
None.
Plan & Schedule
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vii-g. Source control measures
Requirement: Development and implementation of source control measures for all sources of FOG discharged to the sanitary sewer system for each section identified in (f) above.
Discussion
As discussed in SSMP section vii-f, any identified FOG problems in the sanitary sewer
collection system will be analyzed to determine the potential sources that are contributing to the problem. EH&S Division and Facilities Division Staff will implement methods for source control as necessary to prevent future FOG discharges, which may include modifying the use of chemicals or materials in upstream processes, or installing additional pretreatment to capture FOG prior to discharge to the sanitary sewer collection system.
Related Documents
None.
Plan & Schedule