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Home My WebLink AboutNCG560042_Compliance Evaluation Inspection_20190924ROY COOPER G&v-�rr1ar K41CHAEL S. REGAN Secretary LINDA CULPEPPER arwfar Michael H Foley Superior Forestry Service Inc 36462 Highway 27 Tilly, AR 72679 NORTH CAROUNA Environmental [duality September 24, 2019 SUBJECT: Compliance Inspection Report Superior Forestry Service NPDES WW Permit No. NCG560042 Buncombe County Dear Permittee: The North Carolina Division of Water Resources conducted a phone and records inspection of the Superior Forestry Service on 9/24/2019. 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". If you should have any questions, please do not hesitate to contact me at 828-296-4500 or via email at zan.price@ncdenr.gov. Sincerely, Zan Price, PE. Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Ec: ARO Server, LF G:\WR\WQ\Buncombe\Wastewater\General\NCG56 Pesticide\NCG560042\20190924_NCG560042_CEI.rtf NorthCaro;!raQepartn,entofEr.v:rorrnertta;Qua:rty I diuisiauofWater Resources D, E 0! Ashev;;e Regnr.s Off. 1 2090 U.S. 70 F?glm-sy I Swaunsros, North Caro:ars 2377S DocuSign Envelope ID: C47A784C-6E5F-4263-85BB-833A47A4BB15 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report 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 IN I 2 15 I 3 I NCG560042 111 12 I 19/09/24 I17 18 I S J 19 L G] 201 I 211111 1 1 I I I I II I I I I I I I I I I I I 1 I I I I I I I I I I II I I I I I f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA ---------------------- Reserved ------------------- 671 70 I I 71 I I 72 I r I u ty 73 � 74 75I I I I I I I I80 I I Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES oermit Number) 10:30AM 19/09/24 18/05/18 Superior Forestry Service Exit Time/Date Permit Expiration Date 11:30AM 19/09/24 21/10/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Michael H Foley,36462 Highway 27 Tilly AR 72679//870-496-2442/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Records/Reports 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 George A Price DWR/ARO WQ/828-296-4500/ 9/24/2019 Signature of I ATMq§men1_Q A Reviewer Agency/Office/Phone and Fax Numbers Date 9/24/2019 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: C47A784C-6E5F-4263-85BB-833A47A4BB15 NPDES yr/mo/day Inspection Type (Cont.) NCG560042 I11 121 19/09/24 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Zan Price with the Asheville Regional Office (ARO) conducted a phone interview with Michael Foley, Chemical Operations Manager, on September 24, 2019. Mr. Foley provided a copy of the Pesticide Discharge Management Plan before the interview. Superior Forestry Service, Inc, (SFS) maintains Duke Energy right of ways across the state of NC. Product is ordered from a distributor who in turn mixes it at a blending facility in Virginia. 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 mix tank to a backpack utilizing a series of cam lock fittings. The entire system is a closed loop to reduce exposure to workers and to minimize spills. Equipment is examined and gone over thoroughly 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 Low -Volume backpack. According 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 conditions during applications that might be harmed by our applications. They are trained to document 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 SFS, they have not had any reportable adverse incidents in North Carolina. Mr. Price contacted Charles Clark, pesticide inspector, with the Department of Agriculture. Mr. Clark was not aware of any current or historical compliance issues with SFS. Page# DocuSign Envelope ID: C47A784C-6E5F-4263-85BB-833A47A4BB15 Permit: NCG560042 Owner - Facility: Superior Forestry Service Inspection Date: 09/24/2019 Inspection Type: 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? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ 0 ❑ ❑ Is access to the plant site restricted to the general public? ❑ ❑ 0 ❑ Is the inspector granted access to all areas for inspection? ❑ ❑ 0 ❑ Comment: Company and facility is based out of Tilly, Arkansas. The company does not have an office or storage facility in NC. A phone interview and review of records was determined to be the most efficient wav to conduct this inspection. See summary for additional information. Page# 3