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Chapter 16.38 FATS, OILS AND GREASE Rules
Fats, oil and grease trigger many problems in sanitary sewer strains. Fats, oil and grease acquire on the sides of pipes, and bacteria that feed on fats, oil and grease produce corrosive acids and gas that may damage pipes and manholes. Sewer blockages that end result can overflow onto streets and property, disrupting residential, industrial, and industrial operations, and carry the potential for well being dangers. The cost of increased upkeep and alternative of sewer strains is excessive, as effectively because the potential impacts to the setting. The necessities set forth in this chapter are designed to aid within the prevention of sanitary sewer blockages and obstructions from contributions and accumulation of animal or vegetable derived fats, oil and greases discharged to the sanitary sewer system from industrial or business institutions, particularly food preparation and serving amenities.
The aims of this chapter are to use reasonable and technically feasible controls to:
1. Forestall sanitary sewer overflows caused by fats, oils and grease.
2. Cut back the quantity of fats, oils and grease discharged to the sanitary sewer collection system.
3. Scale back maintenance prices for the sanitary sewer assortment system.
4. Enhance operation of the sanitary sewer assortment system.
5. Comply with King County Industrial Waste Local Discharge Limits and prohibited discharges.
B. Applicability. The provisions on this part shall apply to all meals processing establishments, meals sales institutions, and food service institutions, industrial businesses, and every other facility (“facility”) that discharges fats, oil and grease to the sanitary sewer collection system and is positioned throughout the municipal boundaries of the city of Issaquah Sanitary Sewer Service Area. (Ord. 2716 § 2 (Exh. A1), 2014; Ord. 2612 § 2 (Exh. A1), 2011).
The following definitions shall apply in the interpretation and enforcement of this chapter.
“Best management practices” means a way or methodology that, by way of expertise and research, has confirmed to reliably result in a desired consequence.
“Director” means the Director of Public Works, or any duly authorized consultant or agent of such Director. Those portions of this chapter that invoke the plumbing code (in Chapter 16.04 IMC) or other building improvements are delegated to the Building Official.
“Facility” means any food processing institution, meals gross sales establishment, food service establishment, laundry, car wash, automotive fueling, industrial garage, fast-lube stations, auto detail, automotive and gear repair, automotive service shop, businesses utilizing steam or pressure washers, or any other business that routinely discharges fats, oil or grease into the sanitary sewer system as a part of a enterprise operation.
“Fats, oils and greases” means natural compounds derived from animal, vegetable, petroleum or mineral origin that include multiple carbon triglyceride molecules. These substances are detectable and measurable utilizing analytical procedures established in Title 40 of the Code of Federal Laws Half 136 (40 CFR 136). Fats, oil or grease are either polar (animal or vegetable origin) or nonpolar (petroleum or mineral origin).
“Food” means any uncooked, cooked, or processed edible substance, or ingredient used or intended to be used or sale in complete or in part for consumption.
“Food grinder” means any gadget within the plumbing or sewage system of the ability for the aim of grinding meals waste or food preparation by-merchandise for the purpose of disposing in the sewer system.
“Food processing establishment” means a industrial institution through which food is manufactured or packaged for consumption.
“Food sales establishment” means retail and wholesale grocery stores, retail seafood shops, food processing institution, bakeries, confectioneries, fruit, nuts and vegetable stores and places of business and comparable institutions, mobile or everlasting, engaged in the sale of meals primarily for consumption off premises.
“Food service establishments” means any establishment that prepares and/or serves meals, lunches, quick orders, sandwiches, frozen desserts, or different edible merchandise and/or is required to have a Meals Business Permit issued by King County Department of Well being. The term contains: eating places, cafeterias, brief order cafes, luncheonettes, taverns, lunchrooms, places which manufacture retail sandwiches, soda fountains, institutional cafeterias, catering and house primarily based food institutions, food vending automobiles, and operations linked therewith; and related services by no matter name referred to as.
“Governing agency” means the town of Issaquah Sanitary Sewer Utility, which supplies sanitary sewer service to the ability.
“Gravity grease interceptor (GGI)” means a plumbing appurtenance or appliance that’s installed in a sanitary drainage system to intercept nonpetroleum fats, oils, and greases (FOG) from a wastewater discharge and is recognized by volume, 30-minute retention time, baffle(s), a minimal of 2 compartments, a minimum total quantity of 300 gallons, and gravity separation. These interceptors are designed by a registered professional engineer. Gravity grease interceptors are usually installed outdoors. Sizing standards set forth in the current adopted plumbing code.
“Grease” means rendered animal fats, vegetable shortening, and different such oily matter used for the needs of and resulting from getting ready and/or cooking meals.
“Grease interceptor” means an appurtenance or appliance that’s installed in a sanitary drainage system to intercept nonpetroleum fats, oil, and grease (FOG) from wastewater. There are two types of grease interceptors: gravity grease interceptors and hydromechanical grease interceptors.
“Hydromechanical grease interceptor (HGI)” means a plumbing appurtenance or equipment that is put in in a sanitary drainage system to intercept nonpetroleum fats, oils and grease from a wastewater discharge and is recognized by circulate rate, and separation and retention effectivity. The design incorporates air entrainment, hydromechanical separation, inside baffling, and/or barriers in combination or separately, and one in all the next:
A. External move control, with air intake (vent), immediately linked.
B. External movement management, without air intake (vent), directly linked.
C. Without external move control, straight connected.
D. Without exterior circulation control, indirectly linked.
Sizing standards set forth in the present adopted plumbing code. HGIs are usually put in inside.
“Nonpolar” means any water or waste of petroleum or mineral origin which incorporates greater than 100 components per million by weight of fat, oil or grease as measured utilizing analytical procedures established in forty CFR Part 136.
“Oil/water separator” means a large capability underground vault installed between a drain and the connecting sewer pipe designed to remove nonpolar oil (petroleum or mineral-based) from the waste stream. These vaults are designed with baffles or coalescing plates to trap sediments and retain floating oils. The large capacity of the vault slows down the wastewater, allowing oil to float to the surface and solid materials to settle out. Companies that require oil/water separators embody however should not restricted to, quick-lube stations, transportation fueling facilities, automobile/heavy tools repair, and potentially companies using steam or strain washers.
“Polar” means any water or waste of animal or vegetable origin which has seen fats, oils or grease floating on the floor or adhering to the sides of the pattern containers.
“Remodel” means any modification to an existing facility that involves an enlargement of the kitchen space or change in kitchen plumbing or drainage fixture items.
“Rendering/disposal company” means a business that possesses a King County pumper certification.
Twenty-Five Percent Rule. Requirement for grease interceptor to be cleaned when 25 % of its quantity is occupied by accumulated grease and solids.
Uniform Plumbing Code (UPC). Governs the requirements for the set up, alteration, removing, substitute, restore or construction of all plumbing, as adopted underneath Chapter sixteen.04 IMC.
“User” means any particular person, who contributes, causes or permits the contribution of wastewater into the governing agency’s sanitary sewer system. (Ord. 2716 § 2 (Exh. A1), 2014; Ord. 2612 § 2 (Exh. A1), 2011).
A. Set up of food grinders within the plumbing techniques of a new meals service, food gross sales, or food processing establishment is prohibited. If a food gross sales, food service, or meals processing establishment is bought or leased, and the brand new homeowners must apply for a enterprise license, they shall be required to take away the existing food grinder.
B. The direct addition into the grease waste line, or grease interceptor of enzymes, bacteria, chemicals, or other brokers designed to emulsify the grease compounds is prohibited. Any attempt to switch the trap right into a biological reactor by including bacterial or microbial brokers can also be prohibited.
C. Disposal of waste cooking oil into sanitary sewer and drainage pipes is prohibited. All waste cooking oils shall be collected and stored correctly in drums or tallow bin for recycling or other acceptable strategies of disposal.
D. Discharges to the sanitary sewer system that embody polar fats, oils and greases in amounts that trigger a visible sheen within the discharge or in the public sewer system, a construct-up of grease in any public sewer facility, or any water or waste which incorporates more than one hundred parts per million by weight of nonpolar fats, oils and grease as measured using analytical procedures established in forty CFR Half 136, in accordance with IMC thirteen.36.020.
E. Discharge of wastewater with a temperature higher than 140 degrees F to or by means of a grease interceptor. (Ord. 2716 § 2 (Exh. A1), 2014; Ord. 2612 § 2 (Exh. A1), 2011).
16.38.040 Grease interceptors – Requirements.
The owner of a facility with one or more fats, oil or grease generating actions shall install a grease interceptor. All grease interceptors shall be put in on the premises the place fats, oil and grease are used or generated. These amenities are required to install, function, and maintain an accredited type and adequately sized grease interceptor needed to maintain compliance with the targets of these rules. The grease interceptor shall be enough to separate and remove fats, oil and grease contained in wastewater discharges prior to the sanitary sewer system.
A. New Amenities. Newly proposed or constructed facilities, including tenant enhancements that change the use classification to a meals service establishment, meals gross sales establishment, food processing institution, or a new combined use development with the potential to generate fats, oil, and grease shall:
1. Be required to put in, operate and maintain an accredited sort and adequately sized gravity grease interceptor and/or oil/water separator as obligatory to keep up compliance with the requirements as described in this chapter, and as essential to forestall a condition of prohibited discharge; or
2. A hydromechanical grease interceptor may be utilized as a substitute of a gravity grease interceptor if it is demonstrated to the satisfaction of the Director that the installation of a gravity grease interceptor is bodily impracticable.
3. A hydromechanical grease interceptor could also be utilized as an alternative of a gravity grease interceptor if the gravity grease interceptor sizing in the at the moment adopted plumbing code results in an interceptor volume (gallons) 750 gallons or less.
Four. A separate gravity grease interceptor could also be supplied for each individual unit of a building structure that’s proposed for, or may very well be doubtlessly transformed in the future into, a food service, meals gross sales, or food processing establishment. Town may permit the separate gravity grease interceptors to be installed at a later date, when food service, meals sales, or meals processing establishments are added through tenant improvements; offered, that the aspect sewer traces leaving the building are designed to functionally accommodate the set up of future interceptors at accessible locations.
6. Any food service, meals sales, or meals processing institution undertaking a remodel, as outlined herein, will be reviewed, and may be thought-about a brand new facility for the purposes of this chapter.
7. Implement greatest management practices to cut back the amount of fats, oil and grease discharged to the sanitary sewer collection system.
B. Existing Services. Present amenities shall:
1. Implement best administration practices to cut back the amount of fats, oil and grease discharged to the sanitary sewer assortment system.
2. Be permitted to function and maintain present grease interceptors; offered, that the tools is properly sized and in efficient working situation.
3. Any facility not assembly subsection (B)(2) of this part is required to meet the at present adopted plumbing code if enterprise a transform as defined on this chapter.
Four. Set up a properly sized and functioning grease interceptor designed to fulfill the grease management requirements on this chapter if the power is understood to cause a construct-up of grease in any public sewer facility, is the result of a sanitary sewer overflow, or is in any other case causing a prohibited discharge. Set up must be completed inside 180 calendar days from notification by town.
C. Permits. Site and constructing modifications wanted to install a grease interceptor are subject to the allowing requirements of the aspect sewer code (Chapter thirteen.40 IMC), the buildings and building code (IMC Title sixteen), and other codes as relevant. (Ord. 2716 § 2 (Exh. A1), 2014; Ord. 2612 § 2 (Exh. A1), 2011).
Sixteen.38.050 Grease interceptors – Requirements.
A. Standard Requirements – Gravity Grease Interceptors.
1. Every facility is solely responsible for the cost of the grease interceptor installation, inspection, cleansing and maintenance.
2. Gravity grease interceptor sizing and set up shall conform to the necessities contained in the present edition of the Uniform Plumbing Code (UPC) or different standards as determined on a case-by-case basis primarily based on overview or related information, including, however not limited to grease interceptor performance, waste stream characteristics, facility location, maintenance wants, and/or inspection needs. Supporting sizing calculations shall be submitted to the governing agency.
Three. Gravity grease interceptors shall be designed by a mechanical engineer utilizing customary engineering principles for sedimentation and flotation in gravity separators. The grease interceptor shall have a minimum of two compartments with fittings designed for grease retention.
4. Gravity grease interceptors shall be installed at an out of doors location the place it is easily accessible for sample assortment, inspection, and cleansing and removal of retained grease. The grease interceptor may not be put in inside a building and the placement should meet the approval of the governing company.
5. Gravity grease interceptors shall be located in the lateral line between all fixtures which may introduce grease into the sanitary sewer and the connection to the sanitary sewer collection system. Such fixtures shall include however not be limited to sinks, dishwashers, floor drains for food preparation and storage areas, mop sinks, and any other fixture which is set to be a possible source of grease.
6. Gravity grease interceptors must be vented.
7. Gravity grease interceptors shall be equipped with a sampling port on the outlet of the interceptor. Inspection tees and manholes should allow the utility to watch and test the discharge for compliance with utility necessities or to permit monitoring and testing in accordance with the foundations and laws of different Federal, State or local company having governmental or contractual jurisdiction within the utility service space.
8. Entry manholes, with a minimum diameter of 24 inches, shall be supplied over each chamber and sanitary tee. The access manholes shall lengthen not less than to finished grade and be designed to prevent water inflow or infiltration. The manholes shall also have readily removable covers to facilitate inspection, cleaning and elimination of retained grease and sample assortment. Riser maximum shall not exceed sixteen inches in the city of Issaquah.
9. Sanitary wastes shall not be introduced into the gravity grease interceptor.
B. Normal Necessities – Hydromechanical Grease Interceptor.
1. Each facility is solely responsible for the cost of the HGI set up, inspection, cleansing and maintenance.
2. HGI sizing and installation shall conform to the requirements contained in the current version of the Uniform Plumbing Code or different criteria as decided on a case-by-case foundation based mostly on review or related data, together with, but not restricted to grease trap efficiency, waste stream traits, facility location, upkeep needs, and/or inspection wants.
3. HGIs shall be designed using standard engineering rules by a licensed Washington State mechanical engineer for sedimentation and flotation in gravity separators. Complete plumbing plans and isometric or riser diagrams are required at time of plan examine submittal. The plans must be stamped by the mechanical engineer of report.
Four. HGIs shall be installed at a location the place it is easily accessible for sample assortment, inspection, and cleaning and removing of retained grease.
5. The HGI shall be equipped with a device to manage the speed of circulate through the unit. The rate of move shall not exceed the manufacturer’s rated capacity really useful in gallons per minute for the unit.
6. Sanitary wastes can’t be introduced into the HGI.
C. Normal Requirements – Oil/Water Separators.
1. Every facility is solely responsible for the price of the oil/water separator installation, inspection, cleansing and upkeep.
2. Oil/water separator sizing and installation shall conform to the requirements contained in the current version of the Uniform Plumbing Code (UPC) or other criteria as decided on a case-by-case foundation based on assessment or relevant info, including, however not limited to separator performance, waste stream characteristics, facility location, maintenance wants, and/or inspection wants. The aforementioned determinations might or may not conform to the Uniform Plumbing Code development standards or sizing criteria for oil/water separators or oil and gas kuala lumpur similar gadgets.
3. Oil/water separators shall be designed utilizing commonplace engineering rules for sedimentation and flotation in gravity separators. The oil/water separator shall have a minimum of two compartments with fittings designed for grease, oil and retention. The minimal capacity guideline for an oil/water separator is to hold a maximum discharge stream for forty five minutes. The waste oil from the separator shall circulation by gravity or shall be pumped to the next elevation by an automatic pump.
Four. Oil/water separators shall be installed at a location where they’re easily accessible for pattern collection, inspection, and cleaning and removing of retained grease. The oil/water separator is probably not put in inside the building until granted by the governing company. The placement must meet the approval of the governing agency.
5. Oil/water separators shall be located within the establishment’s lateral line between all fixtures and related to all necessary flooring drains which may introduce nonpolar grease or oil into the sanitary sewer and the connection to the sanitary sewer assortment system.
6. Oil/water separators must be vented.
7. Oil/water separators shall be geared up with a sampling port at the outlet of the interceptor. Inspection tees and manholes should enable the utility to watch and take a look oil and gas kuala lumpur at the discharge for compliance with utility requirements or to allow monitoring and testing in accordance with the principles and rules of other federal, state or local company having governmental or contractual jurisdiction inside the utility service area.
Eight. Entry manholes, with a minimum diameter of 24 inches, shall be supplied over every chamber and sanitary tee. The entry manholes shall prolong at the least to finished grade and be designed to forestall water inflow or infiltration. The manholes shall even have readily removable covers to facilitate inspection, cleaning and elimination of retained grease and sample assortment. Riser maximum shall not exceed sixteen inches in the city of Issaquah. (Ord. 2716 § 2 (Exh. A1), 2014; Ord. 2612 § 2 (Exh. A1), 2011).
Sixteen.38.060 Maintenance and working requirements.
1. Gravity grease interceptors and oil/water separators shall be pumped in full when the total accumulation of fats, oil and grease reaches 25 p.c of the overall liquid depth (the “25 p.c rule”). The frequency of pumping shall be no longer than each 90 days, unless documentation is provided to the town that demonstrates a less frequent pumping will nonetheless meet the 25 p.c rule (but not less than annually).
2. HGIs should be cleaned when whole accumulations of fats, oil, and grease attain 25 % of the capability of the HGI.
3. Any facility that has a gravity grease interceptor or oil/water separator shall make the most of a licensed rendering and disposal firm. Wastes removed from a grease interceptor shall be disposed of at a facility permitted to receive such waste. Neither grease, solids nor liquids faraway from gravity grease interceptors shall be returned to any grease interceptor, personal sanitary sewer line, any portion of the sanitary sewer assortment system or any portion of the stormwater system.
4. Any working or physical situation that ends in, or is contributing to a prohibited discharge or different violation of this chapter shall be reported to the governing company within 7 calendar days. Enhancements to the power shall be made as required by IMC sixteen.38.040.
B. Best Administration Practices – Services Generating Polar Fats, Oil and Grease (e.g. Meals Processing, Sales and repair).
1. Kitchen greatest management practices shall be implemented to attenuate the discharge of fats, oil and grease to the sanitary sewer system and stop nonstormwater discharges from coming into the stormwater sewer system (as relevant):
a. Drain Screens. Drain screens shall be installed on all drainage pipes in food preparation areas.
b. Segregation and Collection of Waste Cooking Oil. All waste cooking oil shall be collected and saved correctly in fats, oil and grease receptacles comparable to drums or tallow bins. Such containers shall be maintained properly to make sure they do not leak.
c. Licensed waste haulers or an permitted recycling facility should be used to dispose of waste cooking oil.
d. Tallow bins or used waste oil drums shall be kept clear and coated.
2. Disposal of Meals Waste. All food waste shall be disposed of immediately in garbage or compost assortment bins, and never sinks. Bagging food waste that has the potential to leak in trash containers is really helpful. Scrape or dry wipe pots, pans, dishware and work areas earlier than washing to remove grease. Wash solely in a sink related to a grease management device.
3. Maintenance of Kitchen Exhaust Filters. Filters and different exhaust hood equipment shall be cleaned as ceaselessly as mandatory to take care of good working situation. The wastewater generated from cleaning shall be disposed of correctly and cleaned in sinks related to a grease removal gadget.
4. Kitchen Signage. Informational indicators on best administration practices and waste minimization practices in the meals preparation and dishwashing areas shall be posted at all times.
5. Flooring Mats and Kitchen Equipment Cleaning. The wastewater generated from flooring mat and kitchen appliance washing operations have to be disposed of to a sink with a grease control machine. Cleansing kitchen equipment in areas that drain to the stormwater sewer system is prohibited.
6. Oil and Grease Spills. Dry methods including rags and absorbents such as sawdust or kitty litter shall be used to scrub up oil and grease spills.
7. Employee Coaching. Training shall be carried out for all new kitchen staff and each 6 months. Training shall be documented with worker signatures retained indicating worker attendance. Training information shall be made accessible for assessment at any reasonable time to the governing company. The governing agency shall present training supplies upon request.
C. Greatest Management Practices – Amenities Producing Nonpolar Fats, Oil and Grease (e.g. Automotive).
1. No wastewater, fluids or other substances from commercial and industrial operations containing hazardous wastes, heavy metals, or different prohibited discharge shall enter the oil/water separator.
2. Dry cleanup procedures shall be implemented to scrub up spills. Wipe up liquids or grease with rags or absorbents, equivalent to kitty litter or sawdust.
Three. Sludge removed from oil/water separators shall be tested previous to disposal to ensure compliance with hazardous waste disposal necessities. If found to be hazardous, fast actions shall be taken to determine and remove sources of hazardous pollutants.
4. Don’t enable detergents or different emulsifying cleaning compounds to enter an oil/water separator, as this will make the oil/water separator ineffective.
D. Recordkeeping and Reporting.
1. All facilities with a grease interceptor pretreating polar or nonpolar fats, oil, and grease that discharge into the governing agency’s sanitary sewer system shall maintain a upkeep log that documents all upkeep activities for grease interceptors.
2. Meals service, food processing, or food sales institutions shall doc the date when employees coaching is conducted in the maintenance log.
3. On an annual foundation, on or before December 31st, a replica of the grease interceptor upkeep log (Appendix A to the ordinance codified in this chapter) shall be completed and delivered, mailed, or faxed to the town of Issaquah Public Works Engineering Department. (Ord. 2716 § 2 (Exh. A1), 2014; Ord. 2612 § 2 (Exh. A1), 2011).
16.38.070 Dedication of compliance.
A. A grease interceptor shall be thought-about out of compliance if any of the following situations exist:
1. A required grease interceptor has not been installed or required maintenance of a grease interceptor has not been performed, leading to a prohibited discharge, accumulation of grease inside the general public sewer system, a sewer blockage, or sanitary sewer overflow.
2. Maintenance cleansing has not been completed when the entire accumulations of fats, oil and grease exceeding 25 percent of the general liquid depth has not been met.
3. Failure to submit information to the governing company.
4. Inspection hindrance.
5. Failure to maintain on-site records of maintenance.
6. Falsification of records.
7. Discharges to the sanitary sewer system that embody polar fats, oils and greases in amounts that cause a seen sheen in the discharge or in the public sewer system, a build-up of grease in any public sewer facility, or any water or waste which accommodates more than one hundred parts per million by weight of nonpolar fats, oils and grease as measured using analytical procedures established in forty CFR Part 136, in accordance with IMC 13.36.020.
B. Routine compliance will probably be evaluated based on assessment of maintenance data. The proprietor or operator of the facility is accountable for submitting the required records to the governing company by December thirty first of annually. Compliance can be initiated by observations and studies of potential noncompliance that comes from governing agency staff, different agencies, the public, or different documented sources.
C. Inspections of facilities may be carried out by the Director at any time during regular business hours to confirm compliance with this chapter. Amenities shall permit the Director entry to all components of the premises for the purpose of inspection, data examination, measurement, sampling and testing, or different activities in accordance with the provisions of this chapter. The governing agency shall have the correct and access to arrange on the facility property any devices needed for conducting wastewater sampling inspection, compliance monitoring and/or metering operations. (Ord. 2716 § 2 (Exh. A1), 2014; Ord. 2612 § 2 (Exh. A1), 2011).
The violation or failure to comply with any of the provisions of this chapter is unlawful. If an obstruction of the sanitary sewer assortment system occurs that causes a sanitary sewer backup and/or overflow and such overflow could be attributed in part or in whole to an accumulation of fats, oil and grease within the sanitary sewer principal line, the governing company will take appropriate enforcement actions towards the generator or contributor of such fats, oil and grease. As well as, those liable for generating or contributing to unlawful discharge of fats, oil and grease to the sanitary sewer system should take rapid steps to carry the grease interceptor or other grease removing device into compliance, plus any further actions essential to carry the power into compliance with this chapter.
A. Civil Treatments. Any work or different activities that are inside the authority of this chapter in violation of any lawful order or requirement of the Director is deemed to be a public nuisance and may be abated in a fashion prescribed by the permit authority. Injunction proceedings or different appropriate action may be initiated in a court of competent jurisdiction towards any one who violates or fails to comply with the provisions of this chapter in order to stop, enjoin, abate or terminate violations of this chapter.
B. Individuals Subject to Penalty. Any one that violates or fails to comply in a well timed manner with the necessities of this chapter or who fails to conform to the phrases of an approval or order issued by the Director shall be topic to the civil and criminal penalties offered in Chapter 1.36 IMC, Code Enforcement. Each day of continued violation shall be thought-about a separate violation for functions of penalty.
C. Failure to answer corrective measures outlined in any enforcement discover will result in termination of water service which is owned, operated and maintained by the governing company.
D. Enforcement actions may embody restoration of all costs associated with clean-up actions.
E. The remedies offered on this section, whether civil or criminal, shall be cumulative and shall be in addition to every other treatment provided by regulation. (Ord. 2716 § 2 (Exh. A1), 2014; Ord. 2612 § 2 (Exh. A1), 2011).
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