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Home My WebLink AboutNCG500666_Compliance Evaluation Inspection_20180726 State of North Carolina | Environmental Quality | Water Resources 2090 US 70 Highway, Swannanoa, NC 28778 828-296-4500 July 26, 2018 Chris Sinclair, Vice President Northbrook Carolina Hydro, LLC 14550 N Frank Lloyd Wright Blvd, Ste. 210 Scottsdale, AZ 85260 Subject: Compliance Inspection Report Turner Shoals Hydroelectric Facility Certificate of Coverage NCG500666/General Permit NCG500000 Polk County, NC Dear Mr. Sinclair, Personnel with the North Carolina Division of Water Resources Asheville Regional Office (ARO) conducted a Compliance Evaluation Inspection of the Turner Shoals Hydroelectric Facility on July 10, 2018. This inspection was conducted to verify the facility is operating in compliance with the conditions and limitations specified in General NPDES Permit No. NCG500000. Overall the facility is well maintained; however, based on the on-site visit and discussions with Northbrook Carolina Hydro staff, the facility was determined to be non-compliant. The following items noted during the inspection should be addressed as soon as po ssible to return the system to compliance:  Outfalls: The Notice of Intent (NOI) submitted in 2013 only indicated two outfalls. Please clarify if the facility sumps discharge through a separate outfall and notify the ARO.  Monitoring: Sampling was not being conducted as required by General NPDES Permit No. NCG500000. Please notify the ARO once the first sampling event has occurred (reference Section A (2) and A(3) of the General Permit). Please refer to the enclosed inspection report and the email sent on Ju ly 12, 2018 for additional observations and recommendations. The assistance of Mr. Jeff McCraw was greatly appreciated. If you have any questions, please do not hesitate to contact me at 828-296-4686 or by email at mikal.willmer@ncdenr.gov. DocuSign Envelope ID: FD88F8BD-987F-4002-BC3C-DA81EC58C9CE Sincerely, Mikal Willmer, Environmental Specialist Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ Enclosure: Inspection Report Ec: WQS-ARO Server NPDES-LF Jeff McCraw, Northbrook Hdyro 20180726_NCG500666_CEI DocuSign Envelope ID: FD88F8BD-987F-4002-BC3C-DA81EC58C9CE 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 NCG500666 18/07/10 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) Turner Shoals hydro facility NC Hwy 9 Mill Spring NC 28756 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 09:10AM 18/07/10 16/04/26 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 10:00AM 18/07/10 20/07/31 Name, Address of Responsible Official/Title/Phone and Fax Number Jeff McCraw,PO Box 35 Mill Spring NC 287560035//828-289-6675/8286250759 Contacted Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Facility Site Review Effluent/Receiving Waters 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 Mikal Willmer Division of Water Quality//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: FD88F8BD-987F-4002-BC3C-DA81EC58C9CE 7/27/2018 7/27/2018 NPDES yr/mo/day 18/07/10 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Inspector Mikal Willmer, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Turner Shoals Hydroelectric Facility operated by Northbrook Hydro on July 10, 2018. Jeff McCraw, Northbrook Hydro, was present and assisted in the inspection. Overall the facility is being well maintained. Catch pans and absorbent pads are used near the generators to collect any excess oil. Oil is disposed of in drums contained onsite and hauled to the landfill when needed. No apparent floor drains in the main gallery that connect to the turbine room. The facility discharges water used to rotate the turbines through two draft tubes. There are three sumps used to collect excess water from the turbines. The sump discharges to the Green River. Mr. McCraw stated he was unaware of the monitoring requirements for the hydroelectric facility and did not have a copy of the permit on hand. It should be noted this is the first inspection on record by our office at this facility. Northbrook has operated the facility since 1996. Currently monitoring is not being completed in accordance with the General NCG500000 Permit. An email was sent to Mr. Sinclair and Mr. McCraw detailing the sampling requirements and options moving forward. Quarterly and Semi-annual monitoring is required and should be started as soon as possible. Upstream and Downstream sampling locations were discussed during the inspection. Samples are to be analyzed by a certified laboratory. Northbrook Hydro should clarify the number of discharges from the facility. The notice of intent submitted in 2016 indicates only two outfalls (one for each draft tube). During the inspection, it was noted there are three sumps that collect and discharge to the Green River. Please clarify whether this discharges through a separate outfall from the draft tubes. If it does, this should be on record as a third outfall. Effluent Limitations A(2) and A(3) apply to this facility. Chemical Oxygen Demand and Total Residual Chlorine monitoring are not applicable based on discussions with Mr. McCraw. Monitoring data is not required to be submitted under the General Permit; however, all sampling records are to be kept on file for review. The ARO requests notification after the first sampling event has occurred. NCG500666 17 (Cont.) Page#2 DocuSign Envelope ID: FD88F8BD-987F-4002-BC3C-DA81EC58C9CE Permit:NCG500666 Inspection Date:07/10/2018 Owner - Facility: Inspection Type: Turner Shoals hydro facility Compliance Evaluation 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: 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? This is a general permit. Monitoring applicable to hydroelectric facilities applies. Two draft tube discharges and a sump discharge to the Green River. 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? Is a copy of the current NPDES permit available on site? Page#3 DocuSign Envelope ID: FD88F8BD-987F-4002-BC3C-DA81EC58C9CE Permit:NCG500666 Inspection Date:07/10/2018 Owner - Facility: Inspection Type: Turner Shoals hydro facility Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? Maintenance records and daily log were available on-site. Mr. McCraw stated he did not have a copy of the General NPDES Permit. An electronic copy has been mailed to Mr. McCraw and Mr. Sinclair. 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)? No facility inspection of record. Facility staff did not have a copy of the permit. Moving forward all applicable sampling must be completed. Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Upstream and Downstream temperature measurements are required. Discussed potential locations for upstream and downstream monitoring with Mr. McCraw. Sampling is not currently being performed. Comment: Page#4 DocuSign Envelope ID: FD88F8BD-987F-4002-BC3C-DA81EC58C9CE