NCG560042_Compliance Evaluation Inspection_20240528

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.

May 28, 2024

Jennifer Heaney, Corporate Counsel
Superior Forestry Service Inc.
Email: [e-mail]

SUBJECT: Compliance Inspection Report
Superior Forestry Service
NPDES WW Permit No. NCG560042
Buncombe County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection via email of the Superior Forestry
Service on 5/1/2024. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES WW Permit No. NCG560042. The
findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled "Compliance Inspection Report".

There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.

If you should have any questions, please do not hesitate to contact me at 828-296-4667 or via email at
[e-mail].

Sincerely,

Lauren Armeni, Environmental Specialist II
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: Laserfiche
Hayden Henson (Area Manager)
DocuSign Envelope ID: 108C9F56-6345-403C-B144-06B3A0B5DB61
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 NCG560042 24/05/01 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)
Superior Forestry Service
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
08:00AM 24/05/01 21/12/18
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
09:00AM 24/05/01 26/11/30
Name, Address of Responsible Official/Title/Phone and Fax Number
Michael H Foley,36462 Highway 27 Tilly AR 72679//870-496-2442/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Other
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/
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: 108C9F56-6345-403C-B144-06B3A0B5DB61
5/28/2024
5/28/2024
NPDES yr/mo/day
24/05/01
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lauren Armeni, with the Asheville Regional Office, conducted an interview via email with Jennifer
Heaney (Corporate Counsel, Superior Forestry Service, Inc.) between December 7, 2023 and May 1,
2024. Ms. Heaney provided a copy of the Pesticide Discharge Management Plan. Superior Forestry
Service, Inc. (SFS) maintains Duke Energy right-of-ways across the state of North Carolina. The
facility's office is located in Tilly, Arkansas.
The product is ordered from a distributor (either in Virginia, North Carolina, or Indiana) who in turn
mixes it at one of the three blending facilities. SFS uses a closed-loop system, from mixing to loading
equipment. Backpacks are placed in a tub during filling to minimize or reduce spills. A custom
blending service is used, and a pre-mix concentrate is pumped from a 15-gallon drum into a
200-gallon mix tank and from the mix tank to a backpack utilizing a series of cam lock fittings. The
entire system is closed-loop to reduce exposure to workers and to minimize spills.
Equipment is examined and thoroughly inspected in the off season, and is checked daily for leaks or
defects. Replacement parts and extra sprayers are available with each crew as backup.
SFS sprays brush utilizing a low-volume backpack. According to SFS, the industry practice is to spray
until the leaves are covered to the point of run-off. They also utilize Hack and Squirt (H&S) to inject
brush over 8' tall or in sensitive areas to reduce drift or harm to sensitive crops. This method is used
around water crossing to minimize spray drift into water bodies.
Crews are trained to look for potential adverse incidents during applications to determine if any toxic
or adverse effects occurred within waters of the state on non-target plants, fish, or wildlife that are
unusual or unexpected as a result of exposure to a pesticide. They are trained to document the time,
date, and location, and to provide comments and pictures. SFS utilizes a field manager to monitor
crews and to do follow-up inspections of major water crossings 10-15 days after application. To date,
SFS has not seen any adverse conditions related to their herbicide applications.
According to Ms. Heaney, they have not had any reportable adverse incidents in North Carolina. Ms.
Heaney provided an example Daily Spray Record for the right-of-way work SFS performs.
Ms. Armeni contacted Mr. Henry Hamilton, Pesticide Operation Specialist, with the Department of
Agriculture & Consumer Services on May 1, 2024. Mr. Hamilton was not aware of any current or
historical compliance issues with SFS that pertained to surface water.
NCG560042 17 (Cont.)
Page#2
DocuSign Envelope ID: 108C9F56-6345-403C-B144-06B3A0B5DB61
Permit:NCG560042
Inspection Date:05/01/2024
Owner - Facility:
Inspection Type:
Superior Forestry Service
Compliance Evaluation
Other Yes No NA NE
Inspection was conducted with questions and a records review via email. See summary
for details.
Comment:
Page#3
DocuSign Envelope ID: 108C9F56-6345-403C-B144-06B3A0B5DB61