1

Fats, Oils and Grease (FOG) Program Information - April 21, 2011

Byron Ross, Monitoring & Management Services, LLC

Monitoring & Management Services, LLC (MMS) has provided FOG Program contract services (limited 

and full program) for over 50 POTWs. Below is information regarding inspections, monitoring, recordkeeping and enforcement for some of these POTWs.

INSPECTIONS

1. Large City: Number of FSEs > 2,000

Can only provide detailed data for two cities: Nashville, TN and Louisville, KY. Other large cities have 

only been limited contract work.

Metro Water Services, Nashville, TN: 2,698 FSEs.

o 130 “regular” FSE inspections (by MMS) conducted each month. Inspection areas are 

based on zip code. Goal is to inspect all FSEs at least every 18 months.

o Approximately 20 (range 10 to 30) Follow-up FSE inspections are conducted each month

to check on FSEs that have provided inadequate response or have not responded to 

Noncompliance Notifications (NCN) that were previously issued to the FSE; or to check 

on FSEs in FOG “hotspot” areas to determine if FOG impact has decreased. Also, FSE 

inspections are triggered if the FSE (or grease waste hauler company) has submitted a 

Grease Interceptor or Grease Trap Certification that “failed”.

 Grease Control Equipment (GCE) Certification Program- This was implemented 

in 2005 by MMS for Nashville and has been successful (and is used by 10 other 

MMS client cities). Grease Waste Haulers and Plumbers are required to attend 

the GCE Certification class, pass a test and are issued a certification card. The 

class is approximately 1 hour. Each FSE is required, as per their FOG Permit, to 

have their facility’s grease interceptor or grease trap certified at least annually. 

The FSE must use a grease waste hauler or plumber to do the GCE certification 

that has completed the GCE certification class. Note: this is not 

pumping/cleaning of the GCE, this is certification which checks for proper 

components (i.e. inlet T, outlet T, no leaks or deterioration, etc...). 

Pumping/Cleaning of grease interceptors is required every 90 days, full pump. 

Pumping/Cleaning of grease traps is required every month. See the attachments 

that include the Metro Nashville Grease Interceptor Certification and the Grease 

Trap Certification forms.

 During the inspection, all FSEs are asked to provide records/manifest of the 

grease interceptor or grease trap maintenance/pumping/cleaning. Records are 

required to be kept for 3 years. If records are not available, a NCN may be 

issued. Also, the GI FOG layer is checked, walk through of the kitchen to check 

on Best Mgt Practices, and downstream MHs are checked during the inspection.

o Manhole Survey Work: Periodically (approximately every 6 months), inspectors will 

check downstream manholes at previous FOG “Hotspot” areas, and in residential areas 

that have apartment complexes. Apartment complexes are contacted if there is evidence 

of moderate to heavy FOG in the downstream sewer, and if problem identified, 
2

Residential FOG Control Notification letters are distributed to tenants and single family 

units.

Metro Sewer District, Louisville, KY: 3,200 FSEs.- Louisville MSD is set up basically the same 

as the Nashville program (all POTWs that MMS conducts full program work for include same 

elements). Inspections prior to 2009 were conducted on new FSEs, and as needed in response to 

problems. A regular inspection schedule was to be established. GCE certification for grease 

waste haulers and plumbers is required, as well as the FSEs reporting the Grease Interceptor (GI) 

or Grease Trap (GT) certification to Louisville annually.

2. Medium Cities: Number of FSEs 200 to 2,000.

Knoxville, TN: 1,050 FSEs – FSE inspections were conducted annually, but this 

apparently has decreased temporarily. The inspection included checking 

manifest/records of GI or GT pumping, and profiling the GI (sludge-judge) the tank to 

determine the FOG layer and food solids layer are not over 25% of the tank capacity.

o MMS is in the process of working with Knoxville Utilities Board to implement 

the GCE Certification Program, and the Approved Grease Waste Hauler (GWH) 

Agreement. The GCE Certification Class is scheduled for June 23, 2011. Also, 

the GCE class will be a joint effort between Knoxville, Oak Ridge and First UD 

of Knox County. This consistent certification requirement has benefits for 

POTW and the GWHs and plumbers, since everyone in the area knows the 

requirements, and POTWs can exchange information about GWHs and 

plumbers.

o Approved Grease Waste Hauler Agreement: The POTW sends an agreement to 

the GWH companies, and if the GWH company wants to be an “Approved 

GWH” they agree to the conditions. Conditions include reporting each month to 

the POTW the FSEs that the GWH pumped; this includes reporting FSE name, 

address, date pumped and volume pumped. Clarksville and Franklin, listed 

below also have the GCE certification requirement and Approved GWH 

Agreement program.

Chattanooga, TN: 950 FSEs – FSE inspections are conducted annually, and they have 

implemented the GCE certification requirement.

Clarksville, TN: 463 FSEs- FSE inspections are conducted annually. MMS completed 

the inspections within a 7 month period. Follow-up inspections are conducted on FSEs 

that had NCNs issued, failure of GI or GT certification, not doing GI or GT certification, 

or FSEs in FOG “hotspot” areas.

Franklin, TN: 242 FSEs – Same as for Clarksville above.

Bowling Green, KY: 450 FSEs – Soon to start annual inspections and adopt GCE 

certification and Approved GWH agreement .

3. Small Cities: Number of FSEs < 200.

All small cities that MMS works with conduct FSE inspections at least annually. Some 

conduct semi-annual inspections (Kingsport, TN), as well as conducting follow-up 

inspections.
3

REPORTING, RECORDKEEPING, DATA TRACKING

1. Large Cities: Nashville, TN and Louisville, KY

Require records/manifests be kept on site for all GI or GT maintenance/pumping/cleaning 

for period of 3 years. GI must be pumped every 90 days. GT every month, 

recommended every 2 weeks.

Require GWH companies to report monthly the FSE name, address, volume pumped and 

date pumped. Note: Some GWH companies may report over 300 FSEs to the POTW in 

a month, with total monthly volumes over 250,000 gallons.

Require annual certification of the GI or GT, and is to be reported on original form to the 

POTW.

Data Tracking: MMS developed an ACCESS Database ( and now has web-based 

database) called SOFT (Sewer Maintenance, Overflows, and FOG Tracking). SOFT is 

used by Nashville, TN and 12 other client cities. The FOG module of the database has 

FSE contact information, tracking of inspections, NCNs, NOVs, GCE certifications, 

pump events, correspondence, etc...). SOFT is used for follow-ups to enforcement 

actions, provides list of FSEs that have not conducted a GCE certification, and FSEs 

GCE pumping events. Other cities in Florida, Georgia, North Carolina, and Tennessee 

require that the pump record or manifest be faxed or mailed to the POTW by the FSE.

2. Medium Cities: Same as above

3. Small Cities: Same as above, with exception that many small cities can use EXCEL format to 

track FSE pumping frequencies easily.

Cities in Tennessee: Comparison of Dentists, Population, & Food Service Establishments for FOG program

City Population

Dentists 

*

Food Service 

Establishments 

(FSEs) in FOG 

Program

Population / 

Dentist Ratio

FSEs / 

Dentist 

Ratio

Population 

/ FSEs Ratio

Nashville 635,710 467 2,698 1,361 5.8 236

Knoxville 173,890 244 1,050 713 4.3 166

Chattanooga 155,554 209 900 744 4.3 173

Clarksville 103,455 92 463 1,125 5.0 223

Franklin 54,461 70 242 778 3.5 225

Kingsport 44,905 62 168 724 2.7 267

Brentwood 29,556 69 98 428 1.4 302

Oak Ridge 27,751 46 86 603 1.9 323

Lebanon 25,005 31 85 807 2.7 294

Mt. Juliet 21,718 18 83 1,207 4.6 262

Goodlettsville 17,299 24 72 721 3.0 240

AVERAGE: 837 3.6 246

MAXIMUM: 1,361 5.8 323

MINIMIM: 428 1.4 166
4

* Yellow Pages review, and comparison to 2009 Tennessee Dental Association 

Sourcebook

Comments/Recommendations for Dental Amalgam Separator Monitoring is provided in other email 

attachment.