WQCSD0164_Compliance Evaluation Inspection_20200206

ROY COOPER
Governor
MICHAEL S. REGAN
secrerary
S. DANIEL SMITH
Dlrccror
NORTH CAROLINA
Environmental Quality
February 6, 2020
Mr. Bill McClure, Facility Engineering
NC State Fair Division — Maintenance
NC Department of Agriculture & Consumer Services
1010 Mail Service Center
Raleigh, NC 27699-1010
Subject:
Dear Mr. McClure:
Compliance Evaluation Inspection
NC State Fair Wastewater Collection System
Permit No. WQCSDO164
Wake County
On January 28, 2020, Jason Robinson of the NC Division of Water Resource's Raleigh Regional Office
(RRO) conducted a compliance evaluation inspection of the NC State Fair's Wastewater Collection
System. I would like to thank you and Mr. Peter Green (Safety Coordinator & Maintenance Office
Manager) for your assistance.
An inspection checklist is attached attached. The following observations were made:
1. The NC State Fair's Wastewater Collection System is covered by a Deemed Permit (WQCD0164).
"Deemed" permitted systems are permitted by regulation (no individual permit) and must meet
the requirements of 15A NCAC 02T.0403 (attached). If the system exceeds an average of
200,000 GPD, an individual Collection System Permit may be issued.
2. The Fair's Wastewater Collection System flows into the City of Raleigh's Collection System
(WQC500002) in two areas. Some areas on the eastern side of the fairgrounds, including Dorton
Arena flow towards the intersection of Hillsborough and Blue Ridge Road. The other areas of
the fairgrounds flow towards the larger pond on the northwestern side of the fairgrounds near
the horse complex, where it connects to Raleigh's Richland Creek Outfall.
3. Staff effectively maintain and operate the Collection System to prevent any contravention of
groundwater standards or surface water standards. (15A NCAC 02T .0403 (1))
4. A hard copy of the map was available for review.
a) Please add the direction of flow and the approximate age of pipes to the ma 15A
NCAC 02T .0403 (2)).
b) Also staff explained that the Collection System is separated into two basins that flow
into Raleigh's system in two different locations see Item 2 above). However, the ma
shows that these two basins are inter -connected. Please confirm this and revise the
^� Noth Carolina Department of Environmental Quality Division of 4vater Resources
Raleigh kgtonal Dlfice 13800 Barrett Drive Ralci h, Nottft Carolina 27601)
n.wrsm.. eetm+�nnx arw�r\ / 910 791,1200

man if necessa
A Sanitary Sewer Overflow (SSO) has not been reported from this facility since 2005. Please be
reminded that spills greater than 1,000 gallons, and any discharges that reach surface waters
(regardless of size) shall be reported to the Department as soon as practicable, but no later than
24 hours after the discharge has reached surface waters in accordance with 15A NCAC 02B
.0506(a), and public notice shall be provided as required by G.S.143-215.1C. (15A NCAC 02T
.0403(7))
6. A Spill Response Plan was available in DWR's file for this Collection System that was developed
by Mr. Matt Daly and dated November 17, 2014. This Spill Response Plan should be updated to
include current staff and any other necessary revisions. This Plan should be distributed to all
appropriate staff. (15A NCAC 02T .0403 (3))
7. The Collection System has no pump stations or high -priority lines. (15A NCAC 02T .0403((5) &
(6))
8. Manholes are opened and inspected at least once a year. A log should be kept for dates,
locations and observation of these inspections. (15A NCAC 02T .0403(6) & (10).
9. The Collection System is cleaned annually before the State Fair in October with facility -owned
jetters. A log should be kept documenting dates locations and observations of cleanin s. (15A
NCAC 02T .0403 (1) & (10))
10. The fairgrounds has approximately six outdoor grease traps ranging in size from 500 to 2,000
gallons and five indoor grease traps ranging in size from 10 to 25 gallons. There are also two
1,000 gallon in -ground fryer oil tanks that collect water throughout the year. Additional drums
and containers are utilized for grease containment during special events. All grease traps/tanks
are pumped at least 2-3 times per year by Valley Proteins, and invoices were available for
review. A list of the grease traps/tanks is attached to this report. A grease trap was opened and
observed outside the Expo Building and an indoor grease trap was observed in Dorton Arena.
No grease was observed. Staff explained that the grease traps/tanks are also routinely
inspected by the City of Raleigh. Instructions should be provided to vendors and
kitchen restaurant staff explaining that grease should not be improperly disposed of into the
collection system. (15A NCAC 02T .0403(8))
11. Easements are maintained for personnel and equipment accessibility. (15A NCAC 02T .0403
(9)).
12. Please make sure to document how all re uirements of 15A NCAC 02T attached are met as
required in Section (10).
Please address the underlined items above. if you have any questions regarding the attached reports or
any of the findings, please contact Jason Robinson at Jason.t.robinson(@ncdenr.gov. Thank you for your
cooperation.
Sincerely,
I n#' ;

15C Y-L
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Inspection Checklist
List of Grease Traps/Tanks
15A NCAC 02T (Permitted by Regulation Requirements)
Cc: DWR Laserfiche
Raleigh Regional Office w/attachment
Peter Green, Maintenance Office Manager: 1010 Mail Service Center, Raleigh, NC 27699-1010
G. Kent Yelverton, P.E.: 1010 Mail Service Center, Raleigh, NC 27699-1010
w d if, 15

List of Grease Traps/Tanks:
outdoor in ground grease traps
2,000 gallon in Kerr Scott lot
2,000 gallon near Grandstand / North Side Dorton /waterfall
2,000 gallon front Expo Building
1,000 gallon front Graham Building
2,000 gallon back Expo Building
500 gallon back Horse Complex Restaurant
Water filled outdoor in -ground fryer oil tanks
1,000 gallon near Grandstand / North Side Dorton / waterfall
1,000 gallon front of Expo Building
Indoor grease traos
20-25 gallon Kerr Scott Building concession
20-25 gallon 1853 Grill
20-25 gallon North Side Dorton Arena concession
10 gallon South Side Dorton Arena
Education Building concession
.1 nq';

15 A S C AC 02T .0403 PER1iITTING BY REGULATION
(a) Collection systems Ilavms tell acrilal, permitted or Dil'isloll-approved average daily flow le» than '00,000
gallons per day shall be deeilled permitted, ptu sll'lllt 10 Rllle .0 11* of this Subchapter if the Iv'real meet-, the crirena
ill Rule .0113 of this ,50chaptel ind all efiterii required hi This Rule:
(1) The collection system shall be effectively maintained and operated at all times to prevent
dischm2e to land or surface naters and to prevent ally contravention of gloluldiyater standards or
stuface hater standards.
(2) A map of rile collection svitem,hall Ilaye been developed and >Ilall be 111a1ma111ed.
(3) Sill opelitioll anti 111a111tellaIlce plan. including plunp station inspection fiequeney. pleventitive
llnlntenance selledule. spare parr, ixll.11talti. and overflow response shall have been developed
and implemented.
(4) Plllllp aIaliolli That ire 1101 colulected To a telemetry $hell :hall be iiiipecTe.l by the peIlnittee Or
ir, I'epresentative every day, 364 days per Fear, unieSi Tile peinliuee deInollstnte> That daily
inspection; ire not Ilecessary because The p11111p iMt1011 his sufficient storage capaclry. above the
elevation at Which rile plllllp activates. to justify a longed' impection IIlterval Ill I10 case shall the
inspection a11erval exceed seven day;. Plllllp Statious that are colulected to a telelllerl-' sysieul
shall be iinpected once per week.
{`) High-pnofity sewers Shall be inspected by Tile pe1'11111tee Or its 1'e])lesenTa[lye OIlCa ay2EZ six -
Months. and in_pecriom shall be documented.
(6) A general observation by The perinlittee or its iepraiantative of the entire collecrion system shall be
conducted once per year.
('} Oveislt its and btpa»es $hall be reported to [lie appropriate Division regional office al accordance
Nvith 15A `CAC 0_B .0406(a), and public notice shall be provided as required by G.5 143-
21;.1C.
18) a Grease Control PiclZralll $llali be ill place as follows:
iA) For publicly owned collection s}=teirls, Tile Glease Control Prommi ,hall include bi-
mnlual disrlibmion of educational materials for born comineicial and rewlemial users and
Tile legal illems to i'ecluire gease imerceprors for clew comtruction and retrofit and if
Ilece- bSal-_]' v. of ease illlercepror5 at existing _smbliAunents. The plan illall also mclukle
legal meads fur inspections of the grease llltelcepTOl�!. ellforcelneilt for violatols and the
legal mean: to COIJ101 Dea,e enteli]12 the iy,Talll fi'onl other public Xhl p61"ate satellite
collection systems.
(B I For privately owiled collection systelus, rile Grease C onti'ol Pro_I'ain shall include bl-
alinual distribution Of gl'ease edllcat1O11 111aTerlal5 To Users of the C0IleCTi0II $V5ttlll by rile
perillittee Ol its 1'epres2liTa[lye.
(C) Grease education materials shall be distributed alone often than required ill Parts (A) and
(B) of this Subpara_laph if aace$sary to prevent grease -relived sanitary serer overYloxv>
(9) Right-of-ways and easements silall be maintained to the frill easement nidtli for pei-,omiel and
equipment iccessiblIlty.
(10) Doctuneutation of compliance with Subpala_riphs ia,t I i Through (a)i91 of this Rule shall be
mauitained by the collection system owner for duce years WiTil t]le exception of the neap, which
511,111 be I111111mined for the life of The s,yitelll.
(b) Private Collection sysreal, oil .1 smgle property senvinz an mdli�tilal flLlllty from lvlllcll th:.lom_snc n-asten-ater
contriblition is leis Than 200.000 gallons per day ;hall be deemed permitted
(c) The Director niay determ111e that i collection system shall not be deenned To be pe111mted in accordance with Iles
Rule and Rule .0113 of rhit. Subellipter. This derenrlinatloa _hall be made i11 accordance «ith Rule .0113i e) of Ilu�.
Subchapter,
Histon, Vote: - urhorin• G. S. 143-21 il3ta): 1-t_ • 215. aB:
Ej . September 1, 2006:
Readopted E(f September 1, '015.

Permit: WQCSDO164
SOC:
County: Wake
Region: Raleigh
Contact Person: Bill McClure
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Ins ection Re ort
Effective: 03/01/00 Expiration
Effective: Expiration
Title:
Certification:
Owner: NC Department Of Agriculture & Consumer
Services
Facility: NC State Fair
Phone: [phone]
Phone:
Inspection Date: 01/28/2020 Entry Time: 10 00AM Exit Time: 11 30AM
Primary Inspector. Jason T Robinson Qil 744.� Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampl ng
Permit Inspection Type: Deemed permitted collection system management and operation
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions General Grease Control
Spills/Response Plan
(See attachment summary)
Page 1 of 4

permit; WOCSDO164 owner - Facility: NC Department Of Agriculture & Consumer Services
Inspection Date: 01/2812020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
1. The NC State Fair's Wastewater Collection System is covered by a Deemed Permit (WQCD0164). "Deemed" permitted
systems are permitted by regulation (no individual permit) and must meet the requirements of 15A NCAC 02T.0403
(attached). If the system exceeds an average of 200.000 GPD, an individual Collection System Permit may be issued.
2. The Fair's Wastewater Collection System flows into the City of Raleigh's Collection System (WQCS00002) in two
areas. Some areas on the eastern side of the fairgrounds, including Dorton Arena flow towards the intersection of
Hillsborough and Blue Ridge Road. The other areas of the fairgrounds flow towards the larger pond on the northwestern side
of the fairgrounds near the horse complex, where it connects to Raleigh's Richland Creek Outfall.
3. Staff effectively maintain and operate the Collection System to prevent any contravention of groundwater standards or
surface water standards. (15A NCAC 02T .0403 (1))
4. A hard copy of the map was available for review,
a) Please add the direction of flow and the approximate age of pipes to the map (15A NCAC 02T .0403 (2)).
b) Also, staff explained that the Collection System is separated into two basins that flow into Raleigh's system in two
different locations (see Item 2 above). However, the map shows that these two basins are inter -connected. Please confirm
this, and revise the map if necessary.
5. A Sanitary Sewer Overflow (SSO) has not been reported from this facility since 2005, Please be reminded that spills
greater than 1,000 gallons, and any discharges that reach surface waters (regardless of size) shall be reported to the
Department as soon as practicable, but no later than 24 hours after the discharge has reached surface waters in accordance
with 15A NCAC 02B .0506(a), and public notice shall be provided as required by G.S. 143-215.1C. (15A NCAC 02T
.0403(7))
6. A Spill Response Plan was available in DWR's file for this Collection System that was developed by Mr. Matt Daly and
dated November 17, 2014. This Spill Response Plan should be updated to include current staff and any other necessary
revisions. This Plan should be distributed to all appropriate staff. (15A NCAC 02T .0403 (3))
7. The Collection System has no pump stations or high -priority lines. (15A NCAC 02T .0403((5) & (6))
8. Manholes are opened and inspected at least once a year. A log should be kept for dates, locations and observation of
these inspections. (15A NCAC 02T .0403(6) & (10).
9. The Collection System is cleaned annually before the Stale Fair in October with facility -owned jetters. A log should be
kept documenting dates, locations and observations of cleanings. (15A NCAC 02T .0403 (1) & (10))
10. The fairgrounds has approximately six outdoor grease traps ranging in size from 500 to 2,000 gallons and five indoor
grease traps ranging in size from 10 to 25 gallons. There are also two 1,000 gallon in -ground fryer oil tanks that collect
water throughout the year. Additional drums and containers are utilized for grease containment during special events. All
grease traps/tanks are pumped at least 2-3 times per year by Valley Proteins, and invoices were available for review. A list
of the grease trapsltanks is attached to this report. A grease trap was opened and observed outside the Expo Building and
an indoor grease trap was observed in Dorton Arena. No grease was observed. Staff explained that the grease trapsltanks
are also routinely inspected by the City of Raleigh. Instructions should be provided to vendors and kitchen/restaurant staff
explaining that grease should not be improperly disposed of into the collection system. (15A NCAC 02T .0403(8))
11, Easements are maintained for personnel and equipment accessibility, (15A NCAC 02T .0403 (9)).
12. Please make sure to document how all requirements of 15A NCAC 02T (attached) are met, as required in Section (10).
Page 2 of 4

Permit: WOCSD0164 Owner - Facility: NC Department Of Agriculture & Consumer Services
Inspection Date: 01/28/2020 Inspection Type: Collection System Inspect Non Sampling Reason for Visit:
Routine
General
Yes No NA NE
# Is this system a satellite system?
■El❑ El
# If Yes, what is system name or permit number?
Raleigh -
VVQCSo0002
Is there a overall sewer system map?
Does the map include:
Pipe sizes
❑ ❑
Pipe materials (PVC, DIP, etc)
❑ ❑ ❑
Pipe location
■ ❑ El 0
# Flow direction
# Approximate pipe age
El ■ 0 ❑
# Pump station ID, location and capacity
❑ ■ ❑
# Force main air release valve location & type
# Location of satellite connections
❑ El n
Are system maintenance records maintained?
❑ ❑ El
Comment: Add flow direction and pipe age to maps
Grease Control
Yes No_NA NE
Is grease/sewer education program documented with req'd customer distribution?
0 110
# Are other types of education tools used like websites, booths, special meetings, etc?
If Yes, what are they? (This can reduce mailing to annual.)
Distribute directionsrnfo to vendors and kitchenlreslraunl staff
For public systems, is there a Grease Control Program via an ordinance/agreement? ❑
If Yes, does it require grease control devices at applicable locations?
Is the Grease Control Program enforced via periodic Inspectionstrecords review?
Is action taken against violators? ❑
Comment:
Spills and Response Action Plan Yes No NA NE
# Is system free of known points of bypass?
If No, describe type of bypass and location
# Have there been any sewer spills in the past 3 years?
If Yes, were they reported to the Division if meeting the reportable criteria?
If applicable, is there documentation of press releases and public notices issued? M
Are all spills or sewer related issues/complaints documented? 0 El❑ ❑
# Are there repeated overflows/problems (2 or more in 12 months) at same location? ❑ M F1 ❑
# If Yes, is there a corrective action plan?
Page 3 of 4

permit: WOCSDO164 Owner - Facility: NC Department Of Agriculture & Consumer Services
Inspection Date: 01/28/2020 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine
is a Spill Response Action Plan available?
Is a Spill Response Action Plan available for all personnel?
Does the plan include:
# 24-hour contact numbers
# Response time
# Equipment list and spare parts inventory
# Access to cleaning equipment
# Access to construction crews, contractors, andlor engineers
# Source of emergency funds
# Site sanitation and cleanup materials
# Post-overtlowlspill assessment
Comment: Old Spill Response Plan needs to be updated and distributed to staff.
M ❑ ❑ ❑
■❑❑❑
❑ ❑ ❑
M ❑ ❑ ❑
❑ ❑ ❑
■❑Ell]
M ❑ ❑ ❑
■❑❑❑
M ❑ 1111
❑ ❑ ❑
Page 4 of 4