WQ0032618_Inspection form_20220525

Compliance Inspection Report
Permit: WO0032618 Effective: 02/16/22 Expiration: 06/30/28 Owner : Ajinomoto Health & Nutrition North America
Inc
SOC: Effective: Expiration: Facility: Ajinomoto Health & Nutrition North America Cla
County: Wake 4020 Ajinomoto Dr
Region: Raleigh
Contact Person: Ryan Faw
Raleigh NC 276102911
Title: Phone: [phone]
Directions to Facility:
Take outer beltline to Poole road. Take Poole west towards knightdale. Ajinomoto drive is second road on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/25/2022 Entry Time 10:OOAM
Exit Time: 12:OOPM
Primary Inspector: Dorothy M Robson Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Land Application Site
(See attachment summary)
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Permit: WQ0032618 Owner - Facility:Ajinomoto Health & Nutrition North America Inc
Inspection Date: 05/25/2022
Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
Dear Mr. Steinhauer:
On May 25, 2022, Dorothy Robson from the Raleigh Regional Office visited your facility to
evaluate compliance with the Nondischarge Permit W00032618. 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 onsite
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 11.9).
DocuSign Envelope ID: 56DEE195-5AA5-4F90-9BFF-29CD23BC69D1
PageI2
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 Togs.
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.
Page 2 of 5

Permit: WQ0032618 Owner - Facility:Ajinomoto Health & Nutrition North America Inc
Inspection Date: 05/25/2022
Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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.
Page 3 of 5

Permit: WQ0032618 Owner - Facility:Ajinomoto Health & Nutrition North America Inc
Inspection Date: 05/25/2022
Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment: No comments
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Yes No NA NE
El
El
Yes No NA NE
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Permit: WQ0032618 Owner - Facility:Ajinomoto Health & Nutrition North America Inc
Inspection Date: 05/25/2022
Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 1'/3' bls.
Is application occurring at the time of the inspection?
Comment: No comments
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