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FOG Compliance for Louisiana POTWs: Managing Restaurant and Auto Shop Grease Under LPDES
Not every industrial user in Louisiana’s Industrial Corridor is a refinery or a chemical plant. Alongside the heavy industrial dischargers covered under LPDES pretreatment permits, POTWs also oversee a very different, and far more numerous, category: restaurants and auto repair shops that generate fats, oils, and grease, commonly shortened to FOG.
Where FOG Fits Under LPDES Pretreatment Rules
Louisiana’s LPDES pretreatment programs require POTWs to identify Non-Significant Industrial Dischargers, such as restaurants and auto repair shops, that generate FOG that may pass through a POTW treatment facility. This is a distinct category from the Significant Industrial Users, the categorical dischargers and high-strength or high-volume facilities, covered in the companion article, LPDES Pretreatment in Louisiana’s Industrial Corridor: Managing Complex Chemical Industrial Users. The oversight approach for FOG generators is built around a different problem: not chemical treatment, but grease that solidifies and blocks collection lines.
Why FOG Gets Its Own Inspection Cadence
The Pretreatment Program requires the POTW to conduct periodic, for example annual, multi-day monitoring and inspections of IU and SIU facilities. For FOG generators, that requirement typically plays out as recurring interceptor inspections rather than lab sampling, since compliance for a restaurant or auto shop is fundamentally about equipment maintenance, whether the interceptor is properly sized, installed, and pumped on schedule, rather than effluent chemistry.
Reporting Rolls Up to the Same Annual Pretreatment Report
Regardless of how different a FOG generator looks from a petrochemical SIU on a day-to-day basis, the POTW must prepare and submit reports, such as the Annual Pretreatment Report, to LDEQ documenting all program activities, FOG facilities included. Whatever tracking method a POTW uses for restaurant and auto shop inspections must roll up into the same annual documentation as the rest of the pretreatment program.
Where This Fits in a Broader Pretreatment Program
A POTW might be managing a handful of heavy industrial SIUs alongside hundreds of small FOG accounts, restaurants, auto shops, and similar establishments, each needing its own inspection schedule and compliance history. Keeping both categories in one system, rather than tracking SIUs in a permit database and FOG accounts in a separate spreadsheet, is what makes the Annual Pretreatment Report accurate instead of an end-of-year reconciliation project. SAMS’s dedicated FOG module (njbsoft.com/sams-fog) handles the restaurant and auto shop side, permits, inspections, pump-out manifests, and hauler tracking, while SAMS’s Industrial Pretreatment module (njbsoft.com/sams-ipp) covers the SIU side, so both categories stay in one connected system.
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About The Author
At NJBSoft, we’re proud to collaborate with experts like Robert Hollander, P.E., whose extensive experience in water quality and regulatory compliance allows us to design SAMS in order to meet industry needs. Bob’s leadership and deep industry knowledge supports utilities in staying organized, compliant, and focused on protecting public health every day.
Robert Hollander
- 45 years of experience in water quality, regulatory compliance, and utility management
- President of Hollander Consulting Services
- Held senior roles at the City of Peoria, City of Phoenix, and the Arizona Department of Environmental Quality
- Served as President of the AZ Water Association and the Western Coalition of Arid States
- Licensed Professional Engineer in Arizona with multiple Grade 3 operator certifications
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