Grease Trap Ordinance to be Enforced

8/23/01

For at least the last few of years, the City of Maquoketa has experienced serious problems in its sewer mains, lift stations, and at the Wastewater Treatment Plant due to excessive accumulations of fats, grease, and oil in the wastewater system.

The main contributors to this problem are the byproducts of food preparation and clean-up. Due to an overabundance of these substances, the City has been plagued by clogged sewer mains, accumulations of grease in excess of 4 feet on the walls of lift stations, and a less effective wastewater treatment process.

Although City ordinances have long-required devices like grease traps, the City did not previously pursue any type of strong enforcement of these provisions. Necessity has now compelled the City to enforce these provisions.

The Spring of 1999.
In 1999, Wastewater Department personnel conducted a number of inspections of local kitchen facilities. For the most part, there was a general lack of either internal or external grease traps or interceptors. More specifically, when the initial series of inspections was performed, it included 38 businesses that have kitchen facilities. Of these 38, 30 did not have grease traps. There was also a lack of useful record-keeping by some of the facilities that did have interceptors.

In late May of 1999, the City sent out letters to about 50 facilities that operate commercial or non-residential kitchens along with the local plumbers.

It was the City Council's intention to allow facilities to have until January 1, 2000 before the City actively began to inspect various locations to see if a grease trap is in place and if it is appropriately maintained. The City asked owner/operators of facilities to use the time between June 1 and December 31 to work with the plumber or engineer of their choice to determine the type of equipment that is proper for their operation.

Reactions to the Letter.
After the May 27 letter was sent-out, there were three basic reactions to it.

The first reaction was the belief by several businesses that they did not cook in grease, serve greasy food, create grease, or intentionally dispose of grease in the City's sewer system. In some cases, the belief by some facilities that they do not produce grease caused an emotional or an angry response to the City's announcement about enforcing the ordinance.

The second reaction was the most prevalent. Namely, the City fielded a number of requests from a number of facilities for variances or waivers from the requirements of the ordinance.

The third reaction was from those seeking information on how to size a grease trap for a given facility. There was no definitive word or source that everyone concerned could agree on as an authority on the issue.

The City asked its engineering firm to find information on the proper use of grease traps. The engineering firm also attempted to find other sources such as plumbing inspectors in other communities and grease trap vendors. Of these sources, only one grease trap vendor offered to conduct a meeting in Maquoketa.

A meeting was held in held in August at City Hall. It was conducted by a member of the City's engineering firm and a single grease trap vendor. It was shown live on the City's local access cable channel and was rebroadcast a number of times. However, it was not well-attended by local plumbers and kitchen facility owners/operators.

By December 1999.
In December, two letters were sent out to the owners/operators of kitchen facilities. Since the City was concerned that the six-month period to install grease traps might not have been used effectively by some facilities the first letter included this language:

"If you do not have a grease trap in use or if you have a grease trap that is not adequately maintained, your operation will be subject to the City's municipal infractions ordinance which can include daily fines ranging from $50-$200."

That letter was also meant to address the issue of variances to the grease trap ordinance. Although no variances or waivers had been granted and no process for even applying for one had ever been set up, there was still some discussion in the public that variances might still be allowed.

On this, the letter stated that while "some of the reasons given for possible variances were that some facilities or businesses use certain cooking/clean-up procedures or provide selective menus that cause little or no grease and fats to be deposited into the City's wastewater systemƒour City Council members have considered these factors, but have decided to decline the applications for variances to this ordinance."

The letter of December 7 ended with:

"We know that the information in this letter is not the type of information that anyone would wish to receive. It is also not the type of information that the City wishes to convey to any of its citizens.

No one ever relishes the idea of telling people that they are either faced with spending money on items like grease traps or face penalties if they don't. This very fact is probably why the ordinance was not enforced previously.

But, the Council now feels that the sewer system is being over-burdened with problems and related costs caused by non-residential grease, fats, and oils. And, the Council now feels that the belated enforcement of this ordinance is an unfortunate responsibility that must be pursued."

Late December 1999 and January 2000.
The strongest reaction to the letter of December 7 was to the reference about daily fines under the City's municipal infractions ordinance. Among some facility owners/operators a rush began to try to find grease traps for their facilities.

Again, requests came for information about proper sizing for grease traps. On December 24, another letter was issued which included eight points which the City provided about the proper sizing of grease traps. The eight points came from both the City's engineering firm and the lone grease trap vendor who offered to be a source of information. The eight points were meant only to be suggestions. The City wanted to provide information that might be used, but did not want to venture into telling facilities the type and brand of grease traps that they should use.

The eight points included:

1.) How many meals are served each day?

2.) What is the flow?

3.) Are there other sources? Are any other sources of grease being discharged to the grease trap such as dishwashers, garbage disposals or floor drains?

4.) How often does the business/facility want to clean the grease trap? Quarterly, semi annually, annually, or something else?

5.) Who's going to clean the grease trap? Will it be the owner or a grease trap service?

6.) There needs to be a sample point. There must be an easily accessible sample point on the discharge side of the grease trap for future use by City employees for future random enforcement of the City's grease and oil ordinance.

7. Flow Control. Although some grease traps have an internal flow control, not all of them do. If there is no internal flow control, then a flow control must be on the inlet side only.

8.) How far away is the grease trap? For example, if the kitchen is on first floor and the grease trap is going in the basement, the grease trap needs to be sized larger than if they are both on the same floor.

Still, problems arose when different facilities, plumbers, and grease trap salespeople interpreted the factors for sizing grease traps in different ways.

As January 1, 2000 came and went, the City and facility owners/operators were trying to find language that facilities and their plumbers could use as a guide. The City is also reviewing the ordinance to see if it needs changes in its wording that will avoid the perception that there are exceptions or variance possibilities that are present.

March-July, 2000.
In March, the City Council passed a revision to the sewer ordinance which stated that the design and installation of grease traps must be based on the 1994 Uniform Plumbing Code. The revised ordinance also stated that chemical additives, such as enzymes, are not allowed.

Upon the passage of these revisions, the City's inspections for grease traps resumed. Those inspections found that, of the 44 premises that were checked, at least 25 did not have grease traps yet.

On March 22, a letter was sent to all operators of commercial kitchen facilities and was copied to all local plumbers. The letter was targeted to locations that did not yet have a grease trap in place. The letter went on to say:

"At its meeting on March 20, 2000, the Council voted to place all commercial/non-residential kitchen facilities that do not have a grease trap or grease interceptor on a 30-day notice (or by April 21, 2000) to submit to the City an "Action Plan" for installing such devices.

Further, the Council voted to place all such facilities on a 90-day notice (or by July 20, 2000) by which to have their grease traps or interceptors installed and operational."

Action Plans were to be due no than April 21, 2000.

An Action Plan could include any of the following:

1.) A receipt showing that a facility purchased a grease trap and was now waiting for a plumber to install it by a specific date that falls before July 20, 2000.

2.) A written statement that a facility would order a grease trap or grease interceptor and hire a plumber to install it by a specific date that is no later than July 20, 2000.

3.) A proposed Action Plan that was based on reasons that were unique to a particular situation.

By the time of the April 21 deadline, nearly every facility had provided the City with an Action Plan. Three facilities that had not were given 10-day warnings before municipal infractions citations would be issued. Before the 10 days lapsed, 2 of the 3 facilities had complied. The last facility was cited under the municipal infractions ordinance, but has since complied with the grease trap ordinance.

After the July 20 deadline for the execution of all Action Plans, facilities will be subject to inspection to see check for compliance. Inspections for compliance will involve a review of maintenance records to see if grease traps have been properly maintained. Some inspections may involve a determination of whether or not the grease trap in a particular facility is properly sized.

The pertinent sections of the City ordinance governing the installation grease traps appear below:

"6. A grease trap that complies with the requirements of this section shall be installed in the waste line leading from sinks, drains, and other fixtures or equipment in the following establishments: restaurants, cafes, lunch counters, cafeterias, bars, taverns and clubs, hotel, hospital, sanitarium, factory or school kitchens, or other establishments where food is prepared for distribution to the public or is prepared for sale or for compensation. A grease trap shall be installed in any other building at which grease or oil may be introduced into the drainage or sewage system in quantities that can effect line stoppage or hinder sewage treatment or private sewage disposal. A grease trap is not required for individual dwelling units or for any private living quarters. A grease trap required by this section shall be installed and its operation and maintenance shall be according to the requirements of Chapter 10 and Appendix H of the Uniform Plumbing Code 1994 as adopted by the Iowa Building Code Commissioner and as that code may from time to time be amended by the Iowa Building Code Commissioner.

The use of enzymes to clean or flush a grease trap is prohibited and any means of cleaning a grease trap other than the means required by this ordinance is prohibited."