WQ0032618_Inspection letter_20220610

June 10, 2022

Andrew Steinhauer
Ajinomoto Health & Nutrition North America, Inc.
4020 Ajinomoto Drive
Raleigh, NC 27610

Subject: Compliance Evaluation Inspection
Ajinomoto Health and Nutrition, North America
Class A Residuals and Distribution Program
Nondischarge Permit WQ0032618
Raleigh, NC
Wake County

Dear Mr. Steinhauer:

On May 25, 2022, Dorothy Robson from the Raleigh Regional Office visited your facility to
evaluate compliance with the Nondischarge Permit WQ0032618. The assistance Ryan Faw, and
Marion Wearing provided was greatly appreciated.

Division records indicate the facility operates a residual management and distribution program
of Class A residuals from a cell cream by-product. A pretreatment system is also managed on-
site under the City of Raleigh permit IUP#AJIN. Class A sludge cake is transported by Granville
Farms

During the inspection, the following was observed:

Schedule (Section I of permit):
1. The facility has no scheduling conflicts at the time of the inspection.
Performance (Section II):
2. The facility meets its distributed residuals pollutant concentrations for non-hazardous
characteristics, metals, and nutrients. However, the review of the on-site documentation of
fecal coliform did exceed 1,000 CFU / dry gram of residuals in November 2021. Therefore,
the monitoring frequency for pathogen and vector attraction reductions shall be provided at
the frequency listed in the table (Attachment A) if residuals from this source are distributed
for land application. Please provide additional documentation on the methods /actions you
will take or have taken to prevent land application.
3. In addition, the Sodium Absorption Ratio (SAR), sampled on November 29, 2021 indicated a
ratio of 23.96%. This exceeds field loading rates acceptable to land apply. The Residual
Annual Report dated February 23, 2022 indicated a SAR of <1.0% that was sampled on
December 7, 2021. Please provide additional information on the process that reduced the
ratio from 23.96% to 0.12%. The Division recommends implementing the recommendations
in accordance with Condition 9 (Section II.9).

DocuSign Envelope ID: 56DEE195-5AA5-4F90-9BFF-29CD23BC69D1

P a g e | 2

Operation and Maintenance (O&M) (Section III):
4. The permittee is responsible for the O&M of the residual management program as a non-
discharge system. An O&M Plan, Spill control prevention plan and safety measures are
readily available.

The process and distribution area for cake sludge were clean and satisfy spill prevention
measures. Top loading trailers from Granville Farms were observed onsite for the collection
of cake sludge. A liquid storage tanker was also observed in the loading area of the liquid
cream cell by-product for emergency purposes. Class A product (<100 pounds) was
observed bagged and labeled on outside storage shelves in a clean area. The above ground
storage tanks (ASTs) of cell cream by-products were observed in concrete berms and the
tanker fill area was slightly sloped to a storm drain that connects to a storage lagoon and
pumped into the pretreatment system prior to discharge into the City of Raleigh sanitary
sewer system. The opposite side of the cell cream by-product loading area consisted of a
landscaped grass area with a drainage pipe that leads to a storage lagoon. Although any
accidental spills and runoff from the transfer of cell cream by-product would be contained
and meets spill prevention measures, the grass landscape area may allow spills to leach
through the soils into groundwater. It is recommended to have an engineer reassess the
landscape area and put into place a preventative measure to protect the landscape area.
Monitoring and Reporting (Section IV):
5. Residuals are sampled and monitored for compliance in accordance with the permit. Due to
the changes in vectors and pathogens, reporting shall be conducted in accordance with the
conditions in Attachment A.
Inspections (Section V):
6. The facility performs maintenance and inspects the facility daily and maintains written and
digital logs.

This report is a notification of the results of the compliance inspection. Within 30-days
receipt of this letter, submit a written response to this office addressing the issues
noted in items 2 and 3 above.

Please be aware that non-compliance with your permit could result in enforcement action by
the Division of Water Resources for these and any other violations of State law. The Raleigh
Regional Office encourages you to take all necessary actions to bring your facility into
compliance.

If you have questions or comments about this inspection or the requirements to take corrective
action, then please contact via email at [e-mail] or 919-791-4241.

Sincerely,

Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

Attachment(s): NCDEQ Compliance Inspection Form

Cc: Laserfiche
DocuSign Envelope ID: 56DEE195-5AA5-4F90-9BFF-29CD23BC69D1