NCG560041_Compliance Evaluation Inspection_20240723

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

July 23, 2024

Colon L Saunders
Rutherford Electric Membership Corporation
Email: [e-mail]

SUBJECT: Compliance Inspection Report
Rutherford EMC Vegetation Control
NPDES WW Permit No. NCG560041
Rutherford County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Rutherford EMC
Vegetation Control on 7/08/2024. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES WW Permit No. NCG560041. 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 Lauren Armeni with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4667 or via email at
[e-mail].

Sincerely,

Andrew Moore, Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: Laserfiche
Scott Campbell (Staking Technician)
Docusign Envelope ID: 0A14DE5B-B464-45EB-8317-4E341CAF6C81
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 NCG560041 24/07/08 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)
Rutherford EMC Vegetation Control
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:00AM 24/07/08 21/12/18
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
11:00AM 24/07/08 26/11/30
Name, Address of Responsible Official/Title/Phone and Fax Number
Colon L Saunders,PO Box 1569 Forest City NC
280431569//828-245-1621/8282482319
Contacted
Yes
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/
Mikal Willmer DWR/ARO WQ/828-296-4686/
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: 0A14DE5B-B464-45EB-8317-4E341CAF6C81
7/23/2024
7/23/2024
7/23/2024
NPDES yr/mo/day
24/07/08
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lauren Armeni and Mikal Willmer, with the Asheville Regional Office, conducted a Compliance
Evaluation Inspection of Rutherford Electric Membership Corporation (EMC) Vegetation Control on
July 8, 2024. This inspection was conducted to determine whether the facility is being operated and
maintained in compliance with General NPDES Permit No. NCG560000. Scott Campbell (Staking
Technician), Tommy Eubanks (Owner, Top Gun Application Services, LLC), and TJ Eubanks
(Co-owner, Top Gun Application Services, LLC) were present during the inspection.
Top Gun Application Services, LLC handles all herbicide application for Rutherford EMC. Top Gun
specializes in the treatment of intrusive vegetation within powerline right of ways (ROWs). Mr.
Campbell indicated that all herbicides used for intrusive vegetation treatment in ROWs are EPA
approved for aquatic use.
Herbicides stored onsite at Rutherford EMC are kept in a locked closet. The majority of herbicides
are stored at Mr. Tommy Eubanks home during the spray application season for short periods
inbetween applications. A copy of the NPDES permit and Pesticide Discharge Management Plan were
available onsite at Rutherford EMC. Chemicals are pre-mixed upon delivery and pumped into a
200-gallon holding tank mounted on a truck. Chemicals are then pumped into a backpack sprayer for
application. Empty drums are sent back for refilling. Stainless steel nozzles and hoses are routinely
checked for maintenance. Calibration is not required due to the stainless steel adjustable cone nozzle
on backpack sprayers. Employees are trained at the beginning of the spray season as well as
weekly. Daily records including herbicide application dates, concentrations, location, and acreage
were available. Mr. Campbell indicated there have been no spills, leaks, or other reportable adverse
incidents since the last inspection.
One item noted for the Pesticide Discharge Management Plan was to add the NCDEQ name and
number to the spill response page within the Plan.
Ms. Armeni contacted Mr. Henry Hamilton, Pesticide Operation Specialist, with the Department of
Agriculture & Consumer Services on July 12, 2024. Mr. Hamilton was not aware of any current or
historical compliance issues with Rutherford EMC that pertained to surface water.
NCG560041 17 (Cont.)
Page#2
Docusign Envelope ID: 0A14DE5B-B464-45EB-8317-4E341CAF6C81
Permit:NCG560041
Inspection Date:07/08/2024
Owner - Facility:
Inspection Type:
Rutherford EMC Vegetation Control
Compliance Evaluation
Other Yes No NA NE
See summary for details.Comment:
Page#3
Docusign Envelope ID: 0A14DE5B-B464-45EB-8317-4E341CAF6C81