NCG560041_Pesticide Discharge Management Plan_20240808

RUTHERFORD ELECTRIC
MEMBERSHIP CORPORATION

186 Hudlow Road
Forest City, NC 28043

2024 Pesticide Discharge Management Plan
(PDMP)

Overview

Rutherford Electric Membership Corporation (Rutherford EMC) is a member owned
electric cooperative serving approximately 75,497 members in portions of ten counties in
the southwestern Piedmont region of North Carolina. A map of Rutherford EMC’s
service territory along with a table of the counties and members per county served is
shown below.

County # of members
Burke 13,927
Caldwell 409
Catawba 3,322
Cleveland 6,214
Gaston 16,132
Lincoln 16,439
McDowell 7,190
Mitchell 17
Polk 5,301
Rutherford 6,456
Total 75,497
Page 1
Within this service territory Rutherford EMC currently operates 46 substations, 20
breaker stations, 3,813.00 miles of distribution lines, and 194.72 miles of transmission
lines. Rutherford EMC is dedicated to operating and diligently maintaining these electric
facilities in an effort to fulfill an obligation to its members to always offer the most
continuous and highest quality power possible.

Environmental Stewardship

While Rutherford EMC is consistently working to provide reliable electric service to the
members within its service territory by operating and maintaining its facilities at a high
standard, the environmental impacts of our daily activities are viewed as a very important
issue. Integrated Vegetation Management (IVM) has evolved as the key factor in
maintaining right-of-ways at a tolerable threshold throughout Rutherford EMC's broad
service territory. Planned herbicide applications play a vital role in the vegetation
management plan and we as environmental stewards are willing to make every effort
possible to oversee this as an environmentally responsible management approach.

Rutherford EMC and Top Gun Applications Services, LLC in a joint effort have carefully
selected an herbicide mixture that will maintain the desired control of woody vegetation
within the right of ways, while adhering to an "Aquatic Label" restriction. Rutherford
EMC will be utilizing a blend of the following three solutions:

1.) 4% solution of AquaNeat which is manufactured by Nufarm Americas Inc,
with an EPA Registration Number of 228-365.

2.) ½% solution of Imazapyr which is manufactured by Alligare,LLC with an EPA
Registration Number of 81927-24.

3.) 2.73 oz Per 100 gallons Milestone VM which is manufactured by Dow
AgroSciences LLC with an EPA Registration Number of 62719-537.

The Mixture Rates, Specimen Labels and Material Safety Data Sheets for each of these
products are attached to this report in Appendix A.

Rutherford EMC strives to keep its herbicide application activities away from the direct
vicinity of all water sources. Use of these aquatic labeled herbicides significantly
decreases the risk of a potential environmental hazard or water source pollution in case an
unforeseen spill or leak does occur. We realize the use of aquatic labeled herbicides is
not mandatory, but an added protection that we as responsible environmental stewards
feel is money well spent.
Page 2
Section 1 - PDMP Team

Rutherford EMC is the company named on the Notice of Intent for implementing the
Pesticide Discharge Management Plan. Rutherford EMC is headquartered at 186 Hudlow
Road in Forest City, North Carolina 28043. The following persons have been appointed
to develop, revise and successfully implement all aspects of the Pesticide Discharge
Management Plan.
------------------------------------------------------------------------------------------------------------
Name: Colon L. Saunders
Title: Rutherford EMC's Vice President of Operations
Phone: [phone] ext. 420
Email: [e-mail]
Responsibilities to the PDMP: Final draft review, Authorization, Project oversight
------------------------------------------------------------------------------------------------------------
Name: M. Scott Campbell
Title: Staking Technician
Phone: [phone] ext. 448
Email: [e-mail]
Responsibilities to the PDMP: Development and Revision, Implementing corrective
actions and other ongoing requirements, Filing Notice of Intent with NCDWQ, Project
field supervision, Maintain NC Pesticide License as Public Operator
------------------------------------------------------------------------------------------------------------
Name: Chad E. Bailey
Title: Member Services Representative
Phone: [phone] ext. 450
Email: [e-mail]
Responsibilities to the PDMP: Development and Revision, Implementing corrective
actions and other ongoing requirements, Maintain NC Pesticide License as Public
Operator
------------------------------------------------------------------------------------------------------------
Name: E. Scott Sams
Title: Engineering Aide
Phone: [phone] ext. 472
Email: [e-mail]
Responsibilities to the PDMP: GIS management, Oversees map documents and water
data used to file permits and perform field application activities

------------------------------------------------------------------------------------------------------------

Page 3
------------------------------------------------------------------------------------------------------------
Name: Thomas Mitchell Eubanks (Tommy)
Title: Top Gun Application Services Manager
Phone: [phone]
Fax: [phone]
Responsibilities to the PDMP: Licensed Contractor acting as pesticide applicator,
Managing pests in relation to the pest management area, Assist in advising and
implementing corrective actions, Spill response team leader, Field crew supervision

------------------------------------------------------------------------------------------------------------
Name: Thomas Mitchell Eubanks, Jr. (T.J.)
Title: Top Gun Application Services Licensed Applicator
Phone: [phone]
Fax: [phone]
Responsibilities to the PDMP: Licensed Contractor acting pesticide applicator,
Managing pests in relation to the pest management area, Assist in advising and
implementing corrective actions, Spill response team member, Field crew supervision

------------------------------------------------------------------------------------------------------------

On March,14 2024 Rutherford EMC signed the "2024 Low Volume Herbicide Spraying
and Contract Specifications", (see Appendix B), annual contract with Top Gun
Application Services, LLC, a for-hire contractor, to perform the applications covered
under this permit. As indicated above, Top Gun Application Services, LLC plays a very
active role on Rutherford EMC's PDMP team.

Contract Company Name: Top Gun Application Services, LLC
Address: 160 Eubanks Farm Road Inman, SC 29349
Phone: [phone]
Fax: [phone]

Certified Applicator: Certified Applicator:
Thomas Mitchell Eubanks Thomas Mitchell Eubanks Jr.
License No. 026-19491 License No. 026-28647
Phone: [phone] Phone: [phone]

Page 4
Section 2-Pesticide Management Area Description

This PDMP will be used to encompass a broad area within the Rutherford EMC service
territory. The herbicide applications work will take place along approximately 1,473.40
miles of distribution power line right-of-way and 34.36 miles of transmission line right-
of-way. This project will be concentrated in specific areas of ten counties, all within the
state of North Carolina. The following counties are included in the project: Burke,
McDowell, Mitchell, Rutherford, Catawba, Cleveland, Gaston, Lincoln, Caldwell and
Polk. The specific work areas are color coded on the field maps included with this
PDMP, see Appendix C.

Management of the "Woody Stemmed Vegetation" growing within the power line right-
of-ways is the target of this project. A spot spray on each individual undesired plant is
the intended approach to managing the woody vegetation. Our goal is to maintain the
right-of-ways in a vegetative state that promotes low growing lush vegetation and
grasses. It is crucial to maintain a low tolerance of woody stemmed vegetation within the
power line right-of-ways to ensure that proper safety and maintenance in and around the
facilities can be achieved. The right-of-ways are subject to be used for vehicular and/or
foot traffic at any given time if an outage or maintenance issue arises.

Numerous rivers, creeks, streams and springs are sporadically located along the right-of-
way corridors within the Rutherford EMC service territory. These tributaries are typically
traversed in a perpendicular manner as the right-of-ways seldom run parallel with a
stream or body of water, thus exposing only a minimal amount of the stream to our
maintenance exercises. Various areas near Lake Adger, Lake James, Moss Lake and
Lake Wylie are within Rutherford EMC's service territory. Right-of-Ways in proximity
to some of these lakes are on the maintenance schedule in 2024. This PDMP will be
covering those areas for the 2024 season. There are no "In Water" treatments scheduled
along any of the bodies of water listed above for the 2024 season. If any should take
place they will be well under the allowed permit threshold and will be counted in the
linear mileage of right-of-way.

Page 5
Section 3-Schedules and Procedures

A. Spill Prevention

Special care and attention are practiced daily to deter the likelihood of any spills.
Equipment inspection and maintenance are made a part of the daily routine and all work
is halted if any piece of equipment is not found to be in proper working order. Daily
maintenance and spill prevention activities include the following:

1.) All herbicide containers are stored in an upright position in their original containers
2.) Only the licensed applicators are allowed to handle and mix concentrated solutions
3.) Products are tank mixed in 100-200 gallon tanks to minimize handling procedures
4.) Quick cut off valves are installed on each bulk tank hose
5.) All hoses and fittings are inspected for tightness and proper fit before each use

B. Pesticide Application Equipment

The project will be completed using Stihl backpack sprayers as the primary
application equipment. Stationary 100-200 gallon mix tanks will be used for bulk
mixing of the solution before transfer into the individual backpack sprayers.

Maintenance procedures and inspections of application equipment are performed
daily. The following is a list of procedures that must be followed:

• Calibration of spray pattern as needed
• Triple rinse spray tanks at start of each project and pour all rinse waters back
into the bulk tank before beginning the new fill
• Hoses and fittings are checked for leaks and tightness on a daily basis and as
needed between each fill up
• All equipment is inspected, tested and put into good repair before the
beginning of each spray season. All equipment seals are replaced with new
Viton seals seasonally.

C. Pest Surveillance

Pre-application pest surveillance is not necessary for this type of application procedure.
All applications are performed as a spot spray on the target woody stemmed species. If
the woody stemmed vegetation is not present, no application is made. Each rotation the
stem count is lowered due to the previous application and eventually the right-of-way
corridors should be dominated by a mix of low growing and grassy vegetation.

Page 6
Rutherford EMC's right-of-way facilitator and Top Gun Applications Services manager
will conduct an efficacy inspection of the applications performed in 2021 to ensure that
the desired results were achieved and note any changes that need to be made to improve
upon future application procedures.

D. Problem Identification

It is crucial to maintain a low tolerance of woody vegetation within the power line rights-
of-way to ensure that proper safety and maintenance in and around the facilities can be
achieved. The right-of-ways are subject to be used for vehicular and/or foot traffic at any
given time if an outage or maintenance issue should arise.

E. Additional Control Measures

Rutherford EMC and Top Gun Application Services are continuously looking for
additional ways to avoid any chance of an herbicide spill. As an additional preventative
measure we have implemented a rule that only the licensed applicators are allowed to
handle and mix the concentrated solutions of herbicide. Non-licensed applicators are
barred from handling any concentrated solutions. This is a control measure that we feel
puts an emphasis on the importance of safe handling procedures.

F. Spill Response

As outlined in the 2024 Low Volume Herbicide Spraying Contract and Specifications
between Rutherford EMC and Top Gun Application Services, spill response equipment
must be available at all times while storing and/or transporting herbicides. Approved
spill kits shall be in place on all vehicles. Material Safety Data Sheets (MSDS) and
herbicide labels shall be reviewed and carried with all personnel involved in the handling
of herbicides.

Thomas Mitchell Eubanks is designated by Rutherford EMC to be the primary
respondent to a spill; he is a member of the PDMP team for Rutherford EMC, a North
and South Carolina Licensed Commercial Applicator and holds an ACRT Urban Forestry
Training Certification. He will be responsible for overseeing the completion of the
"Herbicide Spill Documentation Sheet" and the collection of all facts and figures if a spill
should occur. Mr. Eubanks is a trained professional in the herbicide and applications
field and displays a strong background of knowledge pertaining to herbicide safety and
spill management.

Page 7
G. Required Spill Response Equipment For Each Vehicle

1. PPE (chemical resistant gloves, safety glasses)
2. (2) plastic bags/trash bags
3. Absorbent granules (oil dry or kitty litter)
4. Dust pan and sweep brush
5. Absorbent sock
6. Sponge
7. MSDS sheets and specimen labels
8. 5 gallon plastic bucket with proper "Spill Kit" labeling
9. Eyewash station or multiple eyewash bottles
10. (2) Shovels

Page 8
H. Spill Response Procedures

For Minor Spills:

1.) Warn fellow workers in close proximity
2.) Keep everyone without proper PPE away
4.) Confine the spill and notify Tommy Eubanks (PDMP Team Leader/Spill Response)
5.) If the spill is spreading create a dike with sand, dirt or an absorbent sock to stop it
6.) Prevent the spilled chemical from reaching any type of water source
7.) Use absorbent materials to soak up the spill
8.) Shovel materials into an appropriate container with a sealed lid
9.) Dispose of properly

For Major Spills:

1.) Warn fellow workers in close proximity
2.) Keep everyone without proper PPE away
4.) Confine the spill and notify Tommy Eubanks (PDMP Team Leader/Spill Response)
5.) If the spill is spreading create a dike with sand, dirt or an absorbent sock to stop it
6.) Prevent the spilled chemical from reaching any type of water source
7.) Contact the following persons/agencies for response procedures beyond your control:

CHEMTREC: 1-800-424-9300 Local FIRE/POLICE: 911

Tommy Eubanks @ Top Gun Application Services: Cell # 1-864-978-0303

Rutherford EMC: Colon Saunders 1-800-521-0920 ext.420 or Cell # 828-429-5771

Rutherford EMC 24 Hour Dispatch # 1-704-435-5929

Police Department Listing By County

Burke.............828-438-5500 Caldwell.........828-758-2324

Catawba.........828-465-8489 Cleveland.......704-484-4888

Gaston............704-866-3320 Lincoln...........707-732-9050

McDowell.......828-652-2235 Mitchell..........828-688-3982

Polk................ 828-894-3001 Rutherford.....828-287-6249

Once the spill has been contained and turned over to proper authorities the "Spill
Response Documentation Sheet" must be completed and turned in to a member of
Rutherford EMC's PDMP Team within 24 Hours, NO EXCEPTIONS.
Page 9
SPILL RESPONSE DOCUMENTATION SHEET
(This sheet must be completed and submitted to a member of Rutherford EMC's
PDMP Team no later than 24 hours after occurrence)

1.) Name of person/employee reporting spill___________________________________

2.) Contact number for person who caused or reported spill: _______________________

3.) Date and time of spill or discovery: _______________________________________

4.) Estimate of amount released: __________________________________________

5.) Exact location:
County/State: __________________
Road name: ___________________
REMC Map location: ____________

6.) Chemical Name: (Circle all that apply)

A. Aqua Neat
B. Imazapyr 4 SL
C. Milestone VM
D. Cohere

7.) Probable cause of spill: _________________________________________________

8.) Name of affected water sources and distance from source of the spill:
*See work map to provide specific names of each water source*
____________________________________________________________________
____________________________________________________________________

9.) Actions taken: _______________________________________________________

10.) Personnel responding to incident: _______________________________________

Rutherford EMC /PDMP Team Member:

Signature: __________________________

Date: ____________

Time: ____________
Page 10

I. Adverse Incident Response Procedures:

Rutherford EMC will follow all rules and regulations of reporting a spill or adverse
incident to non-target species. Once a Rutherford EMC PDMP Team member receives
an "Adverse Incident Documentation Sheet" the incident will be investigated by proper
personnel. The outcome findings will be documented and precautionary measures will be
taken to keep this from reoccurring. All pertinent documentation and records will be
immediately reported and available to the following agencies and personnel as required.

1.) Rutherford EMC Vice President of Operations
Colon L. Saunders
186 Hudlow Road
Forest City, North Carolina 280423
1-800-521-0920 ext.420
Cell # 828-429-5771

2.) North Carolina Department of Environment and Natural Resources

*Environmental Emergency: 1-800-858-03687

Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Phone: [phone]
Fax: [phone]

3.) US Fish and Wildlife Service
Region 9 Special Agent Office
` 160 Zillicoa Street, Suite C
Asheville, North Carolina 28801
Phone: [phone]
Fax: [phone]

OR

US Fish and Wildlife Service
Asheville Ecological Services Field Office (Southeast-Region 4)
160 Zillicoa Street, Suite C
Asheville, North Carolina 28801
Phone: [phone]
Fax: [phone]

Page 11

4.) CHEMTREC
For chemical spill, leak, fire or exposure 24/7
1-800-424-9300
For Medical Emergencies only
1-877-325-1840

5.) North Carolina Department of Transportation Roadside Environmental

Jeff Wait
Division 13 Roadside Environmental Unit
(Burke, McDowell and Rutherford Counties)
P.O. Box 3279
Asheville, North Carolina 28802
Phone: [phone] or 828-225-6496

Ryan Barbee
Division 12 Roadside Environmental Unit
(Catawba, Cleveland, Lincoln and Gaston Counties)
2312 Kings Rd. Ext
Shelby, North Carolina 28151
Phone: [phone]

Austin Phillips
Division 14 Roadside Environmental Unit
(Polk County)
253 Webster Road
Sylva, North Carolina 28779
Phone: [phone]
Fax: [phone]

6.) North Carolina Department of Agriculture and Consumer Services
Structural Pest Control & Pesticides Division
Jordan McCurry
Pesticide Inspector
1090 Mail Service Center
Raleigh, North Carolina 27699
Phone: [phone]
Fax: [phone]
Cell: 704-734-7454

Page 12
J. Pesticide Monitoring Procedures:

Rutherford EMC in a cooperative effort is constantly monitoring its right-of ways. Each
employee provides an overview of the right of way while working in the field on a daily
basis. If any adverse conditions are noticed they are brought to the attention of Colon
Saunders, Vice President of Operations. It is his responsibility to see that the problem is
investigated and corrections made.

Scott Campbell of Rutherford EMC and Tommy Eubanks of Top Gun Application
Services are responsible for coordination of the daily monitoring of pesticide activities
during the application season. Post-application inspections are performed approximately
one month after the initial treatment to check the efficacy of the products used.

Guideline 12 of the "2024 Low Volume Herbicide Spraying Contract and Specifications"
states that Top Gun Application Services, (contractor), shall accompany Rutherford
EMC's Right of way facilitator, during the first week of July 2025 to inspect sites sprayed
during the 2023 season. During this annual inspection a determination is made
concerning the product mixture and concentration amounts used and also whether they
should be changed or adjusted for the next season. Documentation of any non-target
species affected is made at this time. An effort is made to use the least amount of
herbicide possible to control the targeted woody vegetation. This annual inspection is an
ideal indicator and has always proved to be very instrumental in the decision making for
the next spray season.

Each year Rutherford EMC files an "Application For Permit To Apply Herbicides Along
Utility Encroachments" to the North Carolina Department of Transportation (NCDOT).
The NCDOT Environmental Unit in each Division where herbicide applications are to be
performed receives its own application. They each require the proposed herbicide and
mixture rates to be used, the approximate application dates and maps showing the
overlapping Rutherford EMC and NCDOT right-of way areas to be treated. This
information is reviewed by the Division Engineer and a permit is issued subject to their
rules and regulations. A copy of the permits issued to Rutherford EMC for 2024 by
NCDOT Districts 12, 13 and 14 can be found in Appendix D.

Page 13
Signature:

In accordance with Penal Law 210.45, I certify under penalty of perjury that information
on this plan is true to the best of my knowledge and belief.

Rutherford Electric Membership Corporation
186 Hudlow Road
Forest City, North Carolina 28043

By: ___________________________________________

Title: __________________________________________

Date: __________________________________________

Dates of plan review and update:

Page 14

TABLE OF CONTENTS

I. Overview ........................................................................ Page 1

II. Environmental Stewardship............................................... Page 2
A. Mixture Rates........................................................ Page 2

III. Section 1 - PDMP Team................................................... Page 3

IV. Section 2 - Pesticide Management Area Description ...... Page 4

V. Section 3 - Schedules and Procedures ............................... Page 5
A. Spill Prevention ................................................. Page 6
B. Pesticide Application Equipment ......................... Page 6
C. Pest Surveillance ................................................. Page 6
D. Problem Identification ..................................... Page 7
E. Additional Control Measures ................................. Page 7
F. Spill Response ........................................................ Page 7
G. Required Spill Response Equipment ..................... Page 8
H. Spill Response Procedures .................................... Page 9
Documentation Sheet ..................................... Page 10
I. Adverse Incident Response Procedures ................. . Page 11
J. Pesticide Monitoring Procedures ............................

VI. Signatory .......................................................................... Page 14

Appendix A ..... Herbicide Mix Rates, Specimen Labels and MSDS
Appendix B ..... Rutherford EMC/Top Gun Contract
Appendix C ..... Maps Located @ Rutherford EMC Office
Appendix D ..... NCDOT 2019 Permits
General Permit NCG560000

APPENDIX A
2024 MIXTURE RATES

● 4% solution of Aqua Neat which is manufactured by
Nufarm Americas Inc, with and EPA Registration
Number of 228-365.

• ½% solution of Imazapyr which is manufactured by
Alligare LLC, with an EPA Registration Number of
81927-24.

• 2.73 oz per 100 gallons of Milestone VM which is
manufactured by Dow AgroSciences with an EPA
Registration Number of 62719-537

APPENDIX C
MAPS

Rutherford EMC has been using herbicide applications as a part of its
Integrated Vegetation Management Plan for many years. The following is a
list of work that has been completed since 2019. A hard copy of all maps
showing the areas that have been treated as well as the areas to be treated
during 2024 are stored in this binder and larger scale maps are located in
Scott Campbell’s office at the Rutherford EMC Operations Center, Building
B, located at 186 Hudlow Road in Forest City, North Carolina 28043. They
will be made available upon request.

Year Distribution Sprayed Transmission Sprayed
2019 1,224.23 90.52
2020 1,224.60 70.50 ,
2021 1,353.80 30.88
2022 1,341.70 90.67
2023 1,106.10 67.15
2024 1,473.40 34.36