HomeMy WebLinkAboutncg560048_Compliance Evaluation Inspection_20190930DocuSign Envelope ID: EF4FDE78-F9AF-4574-9BF0-3CCC59B620BB
ROY COOPER
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K41CHAEL S. REGAN
Secretary
LINDA CULPEPPER
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NORTH CAROUNA
Environmental [duality
September 30, 2019
Greg Fowler
French Broad Electric Membership Corporation
P.O. Box 9
Marshall, NC 28753
SUBJECT: Compliance Inspection Report
French Broad Electric Membership Corporation 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 Electric
Membership Corporation Vegetation Control on 9/26/2019. This inspection was conducted to verify that
the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit
No. NCG560048. 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
Andrew.W.Moore@ncdenr.gov.
Sincerely,
LK147FWAE9400
DocuSignedby:
_.
Andrew Moore
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Ec: ARO Server, LF
G:\WR\WQ\Madison\Wastewater\General\NCG56 Pesticide\NCG560048\20190930_NCG560048_CEI.rtf
Nortl: Caro i!naDepartrnentofEnv:ronrnantaiQusirty I DiuisionofWater Resources
Ashev;;e Ragnnai4ff:ce l 20090 U.S. 70 Highway I Snwannsnos, North Qsroian 23773
DocuSign Envelope ID: EF4FDE78-F9AF-4574-9BF0-3CCC59B620BB
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 NCG560048 111 12 I 19/09/26 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 r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA
----------------------
Reserved -------------------
671
70 I I 71 I I 72 I r I
u ty
73 I I 174 751 I I I I I I I80
I 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)
11:00AM 19/09/26
18/05/21
French Broad EMC vegetation control
3043 NC Hwy 213
Exit Time/Date
Permit Expiration Date
Marshall NC 28753
11:45AM 19/09/26
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
Gregory C Fowler,PO Box 9 Marshall NC 28753//828-649-2051/8286492989
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Records/Reports 0 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
Andrew W Moore DWR/ARO WQ/828-296-4684/
DS'g dby:
IL "OZ OG
E
9/30/2019
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
ED ... Sig- by-
9/30/2019
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#
DocuSign Envelope ID: EF4FDE78-F9AF-4574-9BF0-3CCC59B620BB
NPDES yr/mo/day Inspection Type (Cont.)
NCG560048 I11 121 19/09/26 117 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Andrew Moore met with Greg Fowler to conduct a compliance evaluation inspection of the subject
permit. French Broad EMC contracts their easement vegetation control work to Southeast Woodland
Services (NCG560040). Southeast Woodland Services maintains a majority of the pesticides used for
French Broad EMC and is responsible for equipment maintenance. Easements are sprayed on a
two-year cycle after the initial spraying and every three years thereafter. French Broad EMC does
maintain a small volume of pesticides on -site in the Marshall facility within the transformer room, which
is constructed with concrete secondary containment.
The Pesticide Discharge Management Plan was available and appeared up-to-date. French Broad
EMC maintains thorough records of treatment areas, dates of treatment, and volumes of pesticides
used. We discussed the need to include the EPA's National Response Center phone number in the
spill notification section of the Pesticide Discharge Management Plan.
Critical habitat for the endangered Appalachian Elktoe mussel is within French Broad EMC's
maintenance territory. A map of this critical habitat area was provided to French Broad EMC so that
they could update their service maps to note these critical areas.
French Broad EMC lacks a post -application surveillance visual monitoring program as required in Part
4.2 of the NCG56 General Permit. We discussed the need to incorporate this type of visual monitoring
into future post -application surveillance checks, which are already conducted by French Broad EMC.
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DocuSign Envelope ID: EF4FDE78-F9AF-4574-9BF0-3CCC59B620BB
Permit: NCG560048
Inspection Date: 09/26/2019
Permit
Owner - Facility: French Broad EMC vegetation control
Inspection Type: Compliance Evaluation
(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?
Comment:
Yes No NA NE
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