Understand how FOG-caused sanitary sewer overflows (SSOs) trigger Clean Water Act enforcement against a POTW, and how that flows down to FSE-level FOG programs

Steps

1. Review EPA's general NPDES/Clean Water Act enforcement framework for sanitary sewer overflows to understand that FOG accumulation causing pipe obstructions is a recognized, common contributing cause of SSOs that can put a POTW's NPDES permit compliance at risk
2. Recognize that when a POTW is found in violation of its Clean Water Act permit due to recurring SSOs, EPA and/or the state environmental agency and DOJ can require the POTW to enter a consent decree mandating specific remedial programs, which frequently include a dedicated FOG control program with defined performance and maintenance requirements
3. As a live example, review a real EPA/state consent order requiring a POTW to submit a FOG Control Program Plan for approval, to see the kind of specific commitments (inspection frequency, enforcement authority, public education) regulators require in these decrees
4. Understand that POTWs typically respond to such consent-decree obligations by tightening their local sewer-use/pretreatment ordinance — increasing FSE inspection frequency, interceptor sizing/maintenance requirements, and penalty schedules — meaning FSE-level FOG obligations often trace back to an SSO enforcement action further upstream
5. For a specific POTW, check whether it is currently operating under an active consent decree or administrative order (often disclosed on the utility's own site or via EPA/DOJ enforcement case announcements) since this can indicate the FOG ordinance is subject to closer-than-average scrutiny and periodic tightening