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, record

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

o Approxim ately 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 F OG “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) Cert ification 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 ce rtification 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 ce rtification 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 inte rceptors 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 co nducted 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 Pro gram, 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 re quirement 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 compan ies, 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. Clarksvill e 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: 4 63 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 record s/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 ( S ewer Maintenance, O verflows, and F OG T racking). 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 /

Denti st
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: 1,36 1 5.8 323

MINIMIM: 428 1.4 1664

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

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