NCG560048_Compliance Evaluation Inspection_20240903

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

September 3, 2024

Gregory C Fowler
French Broad Electric Membership Corp
Email: [e-mail]

SUBJECT: Compliance Inspection Report
French Broad EMC vegetation control
NPDES WW Permit No. NCG560048
Madison County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the French Broad EMC
vegetation control on 8/16/2024. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES WW Permit No. NCG560048. 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 828-296-4500 or via email at
[e-mail].

Sincerely,

Richard Eguino, Environmental Specialist I
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: Laserfiche
Docusign Envelope ID: 7D305B1A-23E6-4D5F-89A3-4D191FB99BA6
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 NCG560048 24/08/16 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)
French Broad EMC vegetation control
3043 NC Hwy 213
Marshall NC 28753
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
12:18PM 24/08/16 21/12/18
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
01:25PM 24/08/16 26/11/30
Name, Address of Responsible Official/Title/Phone and Fax Number
Gregory C Fowler,PO Box 9 Marshall NC 28753//828-649-2051/8286492989 Contacted
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Records/Reports Facility Site Review
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
Richard Eguino 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: 7D305B1A-23E6-4D5F-89A3-4D191FB99BA6
9/3/2024
9/3/2024
NPDES yr/mo/day
24/08/16
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Richard Eguino, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of
French Broad EMC Vegetation Control on August 16, 2024. The inspection was conducted to verify
compliance with General Permit No. NCG560000 (pesticides). Gregory Fowler, Manager with French
Broad EMC, was present and assisted with the inspection.
French Broad EMC is an electric co-op servicing Madison and Yancey Counties, as well as portions
of adjacent counties. To maintain accessibility throughout their power line right-of-ways, herbicide
applications are used for vegetation control. Mr. Fowler explained that all herbicide applications have
been contracted out to Southeast Woodland Services (SWS, Permit/File No. NCG560040), and that
French Broad EMC plans to continue maintaining their own Certificate of Coverage.
Mr. Fowler explained, while herbicides are not sprayed into aquatic environments, that only
herbicides which are EPA approved for aquatic use are used to minimize adverse effects if an aquatic
environment is inadvertently impacted. The primary herbicides used are Polaris AC (EPA No.
228-570) and Aquaneat Aquatic Herbicide (EPA No. 228-365). Foliar application is the primary
method of treatment, but stem injection is used if the vegetation is taller than 8 ft or if it is near water.
The Notice of Intent, Pesticide Discharge Management Plan (PDMP), pesticide application records,
and visual monitoring records were reviewed and appeared to be complete, thorough, and up to
date. French Broad EMC tracks all herbicide applications (including those conducted by SWS) and
post application surveillances in their GIS application. Their GIS application also outlines critical
habitat for the Appalachian Elktoe, an endangered mussel.
SWS supplies the herbicide products and stages them inside the site’s transformer room which is
sloped inward to provide spill containment. There were no signs of spills in the transformer room. The
herbicide products are in 15 gal drums equipped with micromatic couplings. Mixing tanks, where the
product is mixed with water to create the final application solution, and transfer hoses are located in
the beds of SWS work trucks and are also fitted with micromatic couplings. The use of the micromatic
couplings is considered a closed loop container management system and is viewed as a best
management practice in this industry. Backpack sprayers are then filled from the mixing tanks in the
field. The backpack sprayers are manually adjustable and do not require calibration.
Overall, French Broad EMC’s vegetation control program appeared to be in compliance with the
requirements of General Permit No. NCG560000.
NCG560048 17 (Cont.)
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Docusign Envelope ID: 7D305B1A-23E6-4D5F-89A3-4D191FB99BA6
Permit:NCG560048
Inspection Date:08/16/2024
Owner - Facility:
Inspection Type:
French Broad EMC vegetation control
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?
The facility has been issued a Certificate of Coverage applicable to pesticides General
Permit NCG560000.
Comment:
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Docusign Envelope ID: 7D305B1A-23E6-4D5F-89A3-4D191FB99BA6