STATE OF CONNECTICUTDEPARTMENT OF ENVIRONMENTAL PROTECTION

September 2005 Gina McCarthy, Commissioner

GENERAL PERMIT FOR THE DISCHARGE OF WASTEWATER ASSOCIATED WITH FOODPREPARATION ESTABLISHMENTS

IntroductionThe Department of Environmental Protection (theDepartment) has issued a “General Permit for theDischarge of Wastewater Associated with FoodPreparation Establishments”. This fact sheetsummarizes the major requirements of the generalpermit. Please refer to the DEP website for a copyof the general permit.

Regulated UniverseThe general permit regulates the discharge ofwastewaters from food preparation establishmentsthat are classified as Class III or Class IV foodservice establishments, as defined in the CT PublicHealth Code, and that discharge to a sanitary sewer.This would include, but not be limited to,restaurants, hotel kitchens, hospital kitchens, schoolkitchens, bars and cafes, factory cafeterias, churchkitchens, bakeries and special club kitchens. Foodpreparation establishments discharging to septicsystems are not covered by this general permit.

No Registration RequiredThe general permit does not require that thePermittee register with the Department. ThePermittee will work directly with an authorizedagent of the municipality in which the permittee islocated to comply, as necessary. The municipalagent may be the Water Pollution Control Authority(WPCA) or its designee or the local building officialif there is not a WPCA.

Compliance TimelineAny new regulated food preparation establishmentinitiating a discharge after the date of permitissuance shall comply with the permit requirementimmediately. All regulated food preparationestablishments existing at the date of permit issuanceshall comply no later than July 1, 2011. However,there are three permit conditions that can triggerearlier compliance for existing food preparationestablishments. These include a change inownership, a renovation of the facility or themunicipality designating an area of the sewer systemas a problem area.

Requirements of the PermitPermittees are required to install either a 1,000gallon (minimum) outside passive grease interceptoror an automatic grease recovery unit (AGRU) inaccordance with technical requirements specified inthe general permit. The decision as to whattechnology to install will be made by the permittee.Kitchen fixtures and drains as specified in thegeneral permit shall be connected to the greaseinterceptor or AGRU. Pollution prevention/bestmanagement practices are also required of thepermittee including quarterly inspections of theinstalled equipment and pump-outs of the passivegrease interceptor at least every three months.Recovered fats, oils and grease shall be disposed ofat a regional collection/transfer/disposal site.

ExemptionsThe authorized agent of the municipality may grant awaiver of the requirements for a greasetrap/interceptor if, in the judgment of the authorizedagent, there is limited potential for FOG in thedischarge when considering the frequency of thedischarge, the volume of flow and the potential offats, oils and grease based upon the menu.

Further GuidanceThe Department has circulated an electronic copy ofa “Guidance Document and Resource Document Forthe Discharge of Wastewater Associated With FoodPreparation Establishments” to all municipal waterpollution control authorities in Connecticutmunicipality with sanitary sewers. With theissuance of the final general permit, the guidanceand resource documents will be updated andreissued again to all water pollution controlauthorities. In addition, the Department will preparea guidance document for food preparationestablishments by the end of 2005 and will conducteducational seminars for permittees and municipalofficials. Specific dates will be announced in thefuture.

BackgroundThe uncontrolled and/or inadequately controlleddischarge of fats, oils and grease into municipalsanitary sewage systems has been the cause ofsignificant numbers of raw sewage overflowsresulting in both public health risks and negativeimpacts to Connecticut waterways.

In 1998, the Department initiated an effort tominimize or eliminate sewage overflows caused byfats, oils and grease (FOG) blockages by awardingfunding to the City of Torrington to conduct aregional study on this matter. With the assistance ofWright-Pierce and Community Compliance,consultants to the City, and the Torrington AreaHealth Department, the City concluded several yearsof study in 2002 with the completion of a reporttitled “Guidance Document For The Management ofFats, Oil and Grease From Food PreparationEstablishments in Connecticut”. The reportrecommended the development of a state-widegeneral permit to be issued by the Department as theadministrative mechanism to control FOG that isdischarged to sanitary sewers.

The Commissioner issued a public notice of intent toissue the “General Permit for the Discharge ofWastewater Associated with Food PreparationEstablishments” that discharge to sanitary sewers onAugust 6, 2004 with a thirty day comment period.During the comment period, comments werereceived including two requests for a public hearing.A public hearing was held on December 1, 2004 atthe Department’s offices.

Following the public hearing, the Departmentconsidered all written and verbal comments receivedas a result of both public notices, prepared a hearingreport and issued the general permit September 30,2005 with modifications from the public input.

The General Permit was issued to address thefollowing issues:

1. Environmental and health impacts of rawsewage overflows

For the period from January 2002 through June2004, 258 sewer overflows caused by blockageswere reported to the Department. Of theseoverflows, 70% or 178, were caused by FOG. Thisresults in an average of six FOG overflows permonth. Blockages that cause raw sewage overflowsinto rivers and streams result in environmentalimpacts, violate water quality standards, and can bea serious health risk to anyone coming in contactwith the water. Blockages that result in raw sewagebacking up into basements of homes and commercialbuildings are a serious public health risk and resultin business closures and displacement ofhomeowners until expensive cleaning and repair aremade.

2. Pollution Prevention/Controlling FOG at ItsSource

The principle of pollution prevention is that controlof a pollutant at its source is a preferred strategy.

3. Impacts on Treatment Plant Operations

Excessive FOG, especially on smaller treatmentplants, has created treatment plant upsets in the pastresulting in water quality impacts and permitviolations. Excessive FOG at larger facilities cancause a lessening of treatment plant efficiency that isdetrimental to the environment.

4. Future EPA Regulatory Requirements

Two new rules concerning bypasses are beingdeveloped by EPA. Both of these rules will requiremunicipalities to control FOG. A state-wide generalpermit will provide a useful tool to assist all 130municipalities with sanitary sewers with compliancewith future EPA rules.

5. Municipal Requests for Help

Water pollution control administrators andwastewater operators have requested assistance fromthe Department to help them address FOGdischarges. These local officials see the generalpermit as a tool that they can use locally to properlycontrol FOG.

For more information, please contact:

Joseph NesticoSenior Environmental AnalystBureau of Water ManagementMunicipal Facilities SectionCT Department of Environmental Protection79 Elm StreetHartford, CT 06106-5127

(860) 424-3755joseph.nestico@po.state.ct.us

This overview is designed to answer general questions and provide basic information. You should refer to the appropriatestatutes and regulations for the specific regulatory language of the different permit programs. This document should not berelied upon to determine whether or not an environmental permit is required. It is your responsibility to obtain and complywith all required permits.