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FATS, OILS,AND GREASE ENFORCEMENT RESPONSE PLAN <br /> Section 1- Introduction <br /> This Fats, Oils and Grease Enforcement Response Plan (FOG ERP) has been developed for <br /> guidance and is not intended to create legal rights or obligations, or to limit the enforcement <br /> discretion of the WWTP Chief Operator or the City of Elk River. <br /> This FOG Enforcement Response Plan (ERP) is an effective way to ensure that the City of Elk <br /> River takes fair, consistent and equitable enforcement actions against food service establishments <br /> (FSE) or food manufacturer's/processors (FM/P) for violations of the city's Fats, Oils and Grease <br /> Control Ordinance, Section 78-156 of the City Code. It should be noted that, even with a FOG <br /> ERP, judgment and flexibility is needed at times in response to unusual instances of noncompliance. <br /> Some violations may require a response that deviates from the ERP depending on the particulars of <br /> the situation. <br /> This is a progressive enforcement plan in that problems are addressed at the lowest level and with <br /> the least formality possible consistent with the specific violation. However,no enforcement <br /> procedure is contingent upon the completion of any"lesser" activity. <br /> In general, enforcement actions against FSEs and FM/Ps will be taken in accordance with this <br /> Enforcement Response Plan. However,the enforcement actions listed here are not exclusive and <br /> the City of Elk River reserves the right to implement other enforcement responses available to it <br /> under the City Code,Minnesota and federal laws, separately or in combination with these responses. <br /> Section 2 -Enforcement Actions Available Under the Fats, Oils and Grease Control Policy <br /> The City of Elk River is empowered by the Environmental Protection Agency's National <br /> Pretreatment Program (40 CFR 403) and the city's Fats, Oils and Grease Control Ordinance,to take <br /> the necessary enforcement actions to ensure compliance. The following is a list of those actions. <br /> ENFORCEMENT NOTIFICATION/ACTIONS <br /> ACTION DESCRIPTION <br /> Notice of Written notice that a violation/deficiency has occurred and should be <br /> Deficiency [NOD] corrected. In general,NTCs are used for minor isolated violations or an <br /> and/or Notice to initial step leading to an escalated enforcement response. NODS/NTCs <br /> Correct [NTC] are documented and kept on file. <br /> Informal meeting used to gather information concerning noncompliance, <br /> Enforcement discuss steps to alleviate noncompliance and determine the commitment <br /> Meeting level of the FSE. <br /> Initiation of Self- Notice to a FSE to begin self-monitoring the effluent from the food <br /> Monitoring preparation discharge from the facility. <br /> 1 <br />