A-1 Restaurant Services, L.L.C. (A-1) provided restaurant waste removal services, including grease trap and interceptor pumping and cleaning. Restaurants use either a grease trap or an interceptor to collect fats, oils and grease (collectively referred to herein as “grease”) in its wastewater before it enters the public sewer system. Over time, the grease in the trap or interceptor settles on top as the wastewater collects in the tank. Solids that do not float settle in the bottom of the tank. As the tank fills, the wastewater reaches an overflow point which causes it to flow to the public sewer connected to the local publicly owned treatment works (POTW). To maintain its separation efficiency, grease traps and interceptors must be cleaned periodically by pumping out the entire contents of the trap or interceptor. The grease and wastewater collected during the cleaning process is taken to an approved disposal facility.

The discharge of trucked or hauled pollutants to a POTW servicing the Cities of Cottonwood, Flagstaff, Mesa, Prescott, Show Low, and Surprise, Arizona, is prohibited unless approved by the POTW. An A-1 truck discharged grease and wastewater pumped from the interceptor of one or more restaurants into a different interceptor. The interceptors the employees discharged into were connected to a local POTW and not were approved by the applicable POTW as discharge points for trucked or hauled pollutants.

A-1 did not properly monitor the waste disposal practices of its employees or audit its waste disposal records. By failing to adequately monitor the waste disposal practices of its employees, A-1 negligently caused the discharge of trucked or hauled pollutants – grease and wastewater – to a POTW at unapproved discharge points.

• Clean Water Act (CWA)