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7 of Santa Ana Section 7: FOG Control Program 1) The City requires that each FSE maintain a plan and schedule for the disposal of FOG generated by its activities. The plan and schedule can be found within the FOG Control Program Manual's Appendix C. 2) In January of 2005, the City of Santa Ana implemented a FOG Control Program that includes all of the required WDR elements. A copy of the FOG Control Program Manual was submitted to the Regional Board in January, 2005. The FOG Control Program Manual is incorporated, by reference, into the SSMP and was recently updated in December 2019. All elements of the FOG Control Program are currently being implemented by a combination of City staff and consultants. The City's FOG Ordinance (Ordinance No. NS 2921) provides the legal authority necessary to enforce the FOG program. 3) The City's requirements to install grease removal devices are discussed in Section 4.3 — FOG Wastewater Discharge Requirements of the City of Santa Ana Fats, Oils, and Grease (FOG) Control Program Manual. This section, and related sections in the FOG Control Program Manual also describe the requirements for design standards for the removal devices, maintenance requirements, BMP requirements, and record keeping and reporting requirements. 4) The City has legal authority to inspect grease producing facilities established in Ordinance No. NS 2921 and the FOG Control Program Manual, and enforces any violation of the sewer ordinance in accordance with City requirements. The City has sufficient staff to provide inspections of each grease removal device in its service area at least once per year. 5) The City has identified sections of its sanitary sewer system subject to high levels of FOG in its Digital Sewer Atlas (infraMAP). Accordingly, the City's Operation and Maintenance Program includes a higher frequency (typically monthly) cleaning schedule for each of these sections. These measures have prevented FOG related SSOs from occurring. Using infraMAP, the City can also pinpoint inspections to focus on these sections identified with high FOG accumulation. Inspection results and inspection history is stored in the infraMAP database and evaluated periodically. The City of Santa Ana has created an "Enhanced Maintenance Location (EML) Database" as a part of the Sewer System Infrastructure Management System. These EMLs along with siphons are cleaned on a weekly or monthly basis, depending on the severity of the problem. 6) The City has developed and implemented source control measures for all sources of FOG discharged to the sanitary sewer system for each section of the Sewer Line Problem Areas identified by adopting Ordinance No. NS 2921. A major collaborative effort took place in this SSMP requirement during the development of the City's existing SSMP. A FOG Control Program Manual was developed to specify the key elements of the ongoing FOG Control Program, and will be further discussed and updated (when necessary) as required in the WDR. A comprehensive FOG source identification investigation process is being implemented and refined as part of the FOG Control Program. The process incorporates CCTV investigation along with FSE inspections to determine the sources of FOG discharges to sewer system EMLs. The source identification process is included in the FOG Control Program Manual. 7) City Staff and the City's FOG Program consultant meets with FSE owners during inspections, and as needed, to discuss the City's FOG Control Program and proper grease control device maintenance. The April 2020 19F-29 7-2