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HomeMy WebLinkAboutncg560048_Compliance Evaluation Inspection_20190930DocuSign Envelope ID: EF4FDE78-F9AF-4574-9BF0-3CCC59B620BB ROY COOPER G&v-�rr1ar K41CHAEL S. REGAN Secretary LINDA CULPEPPER arwfOr 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. Page# 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 ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 3