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JCSA - Fats, Oils & Grease

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1. What is FOG?

FOG stands for Fats, Oils and Grease and is found or produced in kitchen areas and garages. The main contribution of FOG is from discharge of used grease from cooking processes, but can also be caused by machinery lubricants discharged into floor drains.

Many of the foods we eat contain FOG. These include meats, sauces, salad dressings, deep-fried dishes, cookies, pastries, batters, icings, dairy products, butter and many others. Generally, food scraps washed down the drain also contribute to FOG in the sewers. Grease accumulation in the sewer system causes obstruction by constricting flow of the sewer pipes, and interfering with the normal operation of your community wastewater treatment system.

2. What are the negative impacts of FOG?

FOG is certainly a community issue. To learn about the harmful impact FOG can have on community health and your neighborhood, please visit the Health Hazards page.

3. What is a Grease Control Device?

Problems caused by waste from restaurants and other grease-producing establishments, have served as the basis for ordinances governing the discharge of grease materials to the sanitary sewer system. This type of waste has forced the requirement of the installation of preliminary treatment facilities, commonly known as a Grease Control Device (GCD). GCD’s include gravity grease interceptors (GGI’s), and hydromechanical grease interceptors (HGI’s), also known as grease traps.

Gravity Grease Interceptors (GGI) are usually larger (up to 2000 gallons), made from concrete, and located outside underground. Like HGIs, these interceptors are also designed to separate and retain FOG and solids while allowing the remaining wastewater to be discharged to the sanitary sewer.

HGI’s are typically small and located indoors. These devices are designed for separating and retaining the FOG and settled solids while allowing water to continue to flow at a designated flow rate into the sanitary sewer using gravity. Newer HGIs made from polycarbonate plastic are tested and rated to breakdown and retain a high capacity of grease.

Newer HGI’s and older model grease traps are smaller sized reservoirs built into wastewater piping typically a short distance from the grease producing area. This is normally an under sink box-shaped fixture located in the kitchen, though they can also be installed in the service area floor.  They typically have a liquid capacity of not more than 20-30 gallons. Reservoir baffles retain the wastewater long enough to allow the grease to solidify and rise to the surface. Building staff can then remove and dispose the grease properly, either in a building exterior grease collection tub, or in the trash. Due to the nature of this system being so limited in size, constant monitoring and maintenance an absolute must.

4. What is a gravity grease interceptor and how does it work?

Read about gravity grease interceptors and how they work by visiting the Grease Interceptors page.

5. What is hydromechanical grease interceptor and how does it work?

Read about Hydromechanical Grease Interceptors (HGI) and how they work by visiting the Hydromechanical Grease Interceptors page.

6. What is a Food Service Establishment (FSE)?

For the purpose of the regulatory requirements of the JCSA’s Fats Oil and Grease (FOG) Program, an FSE is any commercial, industrial, institutional, or food processing facility discharging kitchen or food preparation wastewaters including, but not limited to, restaurants, commercial kitchens, caterers, motels, hotels, cafeterias, correctional facilities, prisons or jails, care institutions, hospitals, schools, bars, and churches. Any establishment engaged in preparing, serving, or otherwise making food available for consumption by the public shall be included. Such establishments use one or more of the following preparation activities: cooking by frying (all methods), baking (all methods), grilling, sautéing, rotisserie cooking, broiling, boiling, blanching, roasting, toasting, or poaching. Also included are infrared heating, searing, barbequing, and other preparation activity that produces a hot, non-drinkable food product in or on a receptacle that requires washing.

7. Do I need a grease control device?

As of October of 2020, all new and existing Food Service Establishments (FSE’s) that are served by the JCSA sewer collection system are required to have a grease control device (GCD). This will include businesses, establishments, and properties that may lie outside of James City County but are connected to the JCSA sewer collection system. The GCD shall be installed according to the manufacturer’s instructions, and the International Plumbing Code. Additionally, the JCSA Fats, Oil and Grease Program and Policy and the Hampton Roads Regional Technical Standards for Grease Control Devices provide direction and guidance for proper sizing and maintenance frequency. These requirements can change if the JCSA continues to discover grease buildup, or blockages in the downstream sewer line that requires maintenance from the JCSA.

Further federal and regional directives and guidelines may also apply as set forth by the Environmental Protection Agency (EPA), The Virginia Department of Environmental Quality (VDEQ), The Virginia Department of Health (VDH), and the Hampton Roads Sanitation District (HRSD). James City County and Virginia State codes prohibit the discharge of materials that can solidify and create blockages in the wastewater collection system or treatment plants. The VDH makes periodic inspections to see that no health problems exist due to improperly maintained grease interceptors. The JCSA has an ongoing program of inspection and verification of correct preventive maintenance procedures.

8. Can you recommend a maintenance schedule?

Gravity Grease Interceptors shall be pumped out completely when the total accumulation of FOG, including floating solids and settled solids, reaches 25% of the overall liquid volume. At a minimum, Gravity Grease Interceptors shall be cleaned once every three (3) months unless approved in writing by the General Manager for good cause shown. Approval will be granted on a case-by-case basis upon submittal of a request by the FSE, documenting reasons for the proposed frequency variance.  

Existing older types of grease traps and grease removal devices shall be opened, inspected, and completely cleaned of food solids and FOG a minimum of once per week, unless otherwise approved in writing by the General Manager for good cause shown. Approval will be granted on a case-by-case basis upon submittal of a request by the FSE documenting reasons for the proposed frequency variance. In no event shall the content of food solids and FOG exceed 25% of the overall liquid depth of the device.

Hydromechanical Grease Interceptors shall be cleaned before their maximum capacity is reached as established by the manufacturer in accordance with test reports validated by a third party. The maintenance frequency shall be determined in accordance with the sizing and selection requirements for HGIs in the Hampton Roads Regional Technical Standards for Grease Control Devices. At no time shall an HGI be cleaned less frequently than once every 3 months, or as otherwise approved in writing by the General Manager.

9. Do I have to have any training on proper FOG handling procedures?

At least one staff member or employee must obtain the regional FOG Certification. The certification program is free and is available online at the HRFog website.

10. How can I get in compliance?

The facility manager can contact the JCSA Regulatory Compliance Office at 757-259-4138. If you don’t have a grease control device (GCD) and need to install one, the property owner will be required to file for a permit for device installation. This may be done through JCC Building Safety and Permits office located in the James City County Government Center, 101 Mounts Bay Road, Building E. or online via Permitlink. This ensures proper installation with an accredited plumbing contractor for a correctly sized grease collection device that will meet the code requirements, the Hampton Roads Regional Technical Standards for Grease Control Devices and the JCSA Fats, Oil and Grease Program and Policy. Additionally, the facility should follow the administrative and maintenance instructions provided in the two aforementioned Regulatory Guidance documents.

11. Do I have to keep any records?

Food Service Establishments (FSE’s) shall maintain records of cleanings, and yellow grease disposal recycling pickups for a minimum of 3 years. This is an important requirement that will be looked at during routine and or random inspections. Sample forms to assist with maintaining your required records are available from HRPDC and can located here: (Grease Control Device Cleaning/Maintenance Log and Yellow Grease Disposal Log).

12. What if I don’t install a grease control device?

If a FSE uses or generates FOG in food preparation, it will eventually encounter a maintenance problem with a plugged building sewer line. The blockage can create a sewer backup situation and ultimately a potential health problem within the establishment. If the problem develops on the private side of the sewer line, then the establishment has direct responsibility for paying for the repair or remediation. If the grease blockage is in the public sewer main, and it can be proven that the establishment is the cause of the blockage, then the establishment could pay for the public sewer to be maintained. Additionally, HRSD (Hampton Roads Sanitation District) will be notified and can place a monitoring station on your sewer outflow. Should they discover excessive FOG amounts, an additional charge will be added to the facility utility bill. Please note that restricting or blocking a sanitary sewer line is considered a violation of the federal Clean Water Act.

13. How does the JCSA ensure compliance?

JCSA will randomly inspect FSEs without advance notice and with inspectors observing the normal operations at the FSE. This is also to ensure that BMPs are properly implemented. During inspection, they will ask for maintenance logs and manifest records (receipts) from licensed grease haulers and recyclers. These records will verify compliance with proper waste disposal requirements. All records of cleanings should be maintained for 3 years. The JCSA also utilizes CCTV footage of the sewer lines found during routine maintenance. This footage can pinpoint the exact source of FOG and is utilized to assist with mitigating problem areas that are caused by FOG.

14. Are there any fees or penalties for non-compliance?

The JCSA prefers to resolve the FOG problems through informative discussions and follow actions undergone by the customer. However, if it is found that a customer is introducing FOG into the sewer collection system and or is not performing the proper maintenance actions to alleviate FOG from entering the sewer system, there are fees and fines that will be imposed. More information about these charges can be found in the JCSA Fats, Oil and Grease Program and Policy.

15. What are the criteria for inspecting grease control devices?

All food service establishments (FSEs) suspected of causing problems to the collection system or treatment facilities may be subject to random inspections. The JCSA utilizes both random inspections and CCTV footage of the sewer lines found during routine maintenance to assist with mitigating problem areas that are caused by FOG. For more information, please visit the Interceptor Maintenance page.

16. What about using my garbage disposal or use detergent to wash it down the drain?

Garbage disposals do not keep grease out of your sewer system, nor will it prevent grease from building up. Products such as detergents that claim to dissolve grease will pass the grease down the pipeline and cause problems elsewhere. In short, you may remove it from your immediate vicinity but you will only help to create a larger problem downstream.

17. What is the JCSA doing about educating the public?

The JCSA has partnered with our regional municipalities to help provide educational outreach through the askHRgreen.org program. Together we have created a residential grease abatement program that educates and informs residents about the effects of dumping oil and grease down the kitchen sink. Protect your community and preserve your environment. Doing so will be a financial benefit to you, your home, and your quality of life. For more information, please visit the Fat Free Drains website.