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Home My WebLink AboutNCG500657_NOD2021PC0384_Compliance Evaluation Inspection_20210608 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. June 08, 2021 Chuck Ahlrichs, President Northbrook Carolina Hydro II LLC Email: cahlrichs@nbenergy.com SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2021-PC-0384 Permit No. NCG500657 Franklin Hydroelectric Project Macon County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Franklin Hydroelectric Project on May 25, 2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NCG500657. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following deficiency(s) was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling Failure to sample as General Permit requires in Part 1 - Section B. (3.). _________________________________________________________________________________________________________________________________________________________________________ Upstream / Downstream It is unclear where the downstream sampling point is located and if that location provides Sampling representative samples. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 60830EEF-E962-4585-A683-52ED1ECAE343 Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Kyle Kroeger, Co-President Chris Sinclair, Vice President, Business Development DocuSign Envelope ID: 60830EEF-E962-4585-A683-52ED1ECAE343 EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 N 52 NCG500657 21/05/25 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Franklin Hydroelectric Project 564 Clyde Downs Rd Franklin NC 28734 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 12:00PM 21/05/25 21/01/05 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 01:00PM 21/05/25 25/11/30 Name, Address of Responsible Official/Title/Phone and Fax Number Gary Morgan,564 Clyde Downs Rd Franklin NC 28734//828-369-4605/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Effluent/Receiving Waters Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date Lauren E Armeni DWR/ARO WQ/828-296-4500/ Stephanie A Williams DWR/ARO WQ/828-296-4500/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: 60830EEF-E962-4585-A683-52ED1ECAE343 6/8/2021 6/8/2021 6/8/2021 NPDES yr/mo/day 21/05/25 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni and Stephanie Williams conducted a compliance evaluation inspection to ensure the facility is operating in compliance with general permit NCG500000. Jimmy Millsaps and Jimmy Williams (Operations and Maintenance) were present during the inspection. The Franklin Hydroelectric Station consists of two Propeller turbines. The turbines sit at lake level, and lake water is used for cooling. Each turbine has an oil catch basin that operators manually pump into a drum as needed and then take to a recycling center. The following deficiencies were noted during the inspection: 1. Effluent sampling has not been conducted as required in the General Permit, Part 1 - Section B. (3.). 2. It is unclear where the downstream sampling point is located and if that location provides representative samples. It is recommended to provide a map that outlines all sampling locations at the facility. Based on the above deficiencies, the facility is in non-compliance with the requirements outlined in the General Permit. NCG500657 17 (Cont.) Page#2 DocuSign Envelope ID: 60830EEF-E962-4585-A683-52ED1ECAE343 Permit:NCG500657 Inspection Date:05/25/2021 Owner - Facility: Inspection Type: Franklin Hydroelectric Project Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain-of-custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Page#3 DocuSign Envelope ID: 60830EEF-E962-4585-A683-52ED1ECAE343 Permit:NCG500657 Inspection Date:05/25/2021 Owner - Facility: Inspection Type: Franklin Hydroelectric Project Compliance Evaluation Record Keeping Yes No NA NE Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? A copy of the NPDES General Permit will be provided with this report and should be distribted to the facility. Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? The contract lab used for sample collection and analysis is Kace Environmental.Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Flow is calculated based on megawatt output.Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Failure to sample as General Permit requires in Part 1 - Section B. (3.).Comment: Upstream / Downstream Sampling Yes No NA NE Page#4 DocuSign Envelope ID: 60830EEF-E962-4585-A683-52ED1ECAE343 Permit:NCG500657 Inspection Date:05/25/2021 Owner - Facility: Inspection Type: Franklin Hydroelectric Project Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? It is unclear where the downstream sampling point is located and if that location provides representative samples. Comment: Page#5 DocuSign Envelope ID: 60830EEF-E962-4585-A683-52ED1ECAE343