WQ0031725_More Information (Received)_20210618

Baxter
June 18, 2021
NCDEQ Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1636
Subject: Application No. WQ0031725
Additional Information Request
Baxter Healthcare Corporation
Land Application of Class B Residuals
Dear Poorva Mokashi,
Included with this cover letter, you will find updated permit renewal application information as
requested. Specifically:
A. Site Map. Updated to include a note indicating the delineation of the compliance and
review boundaries.
B. Operation and Maintenance Plan: Updated to include both a description of necessary
operations for program function, and whom will perform the function, and the names and
titles of personnel performing sampling and monitoring.
Sincerely,
Scott Overbeck
Site Director
Baxter Healthcare Corporation
PO Box 1390. Marion, NC 28752
T 828.756.4154

The Compliance Boundary is established either 250 feet from the perimeter of the residuals application area or 5 C. feet ',A -jinni
the properhi boundary: wliichever is closer. The Review Boundary is established midway between the Compliance Bouni3ry
and the perimeter -dale resicluOs application area
Poplin, Douglas: Site Overview
Parcel Id: 0602427
Wilkes County, NC
36.2362,-80.9418
• Property Boundary
- - - 500' Parcel Buffer
Field Boundary
USGS Stream
0 500 1,000 2,000 Feet
_1 1
North Carolina State lane, NAD83
U.S. Biosolids, Inc.

.4404Compliance Boundar5- established either 250 feet from the perimeter of the residuals application area or 5D feet Irithin
the property boundary; whichever ia closer. The Review BoinulAry is established midway between the Compliance Boundary
and the perimeter .o.f the residuals application area
4
, I e.,411:114
4471
- 1009
• 4
'St*,
— Property Boundary
— Field Boundary
— USGS Stream
E22 Unused Area
Poplin, Douglas: Site Evaluation Field Map
Field: DP1-A
Acres: 5.5 0 125 250 500 Feet
Wilkes County. NC
36.23364,-80.94244 North Carolina Stateplane, NAD83
A House
• Well

The Compliance Boundary is established either 250 feet from the perimeter of the residuals application area or 5 D feet within
the property boundary; whichever is closer. The Review Bonnria¢y is established midway between the Camplia.nce Bonnikry
and the per :peter :`_'the residua's auplicat:on area_
NC Cn
•
Buffers
Perennial Stream (100')
House 100'
House 400')
Well (1 0')
Property Boundary
—Field Boundary
USGS Stream
® Unused Area
House
Well
Board
Poplin, Douglas: Site Evaluation Field Map
Field: DP1-B
Acres 1.6 0 125 250
Wilkes County, NC
36 23499.-80.94459
r 1 i
North Carolina Stateplane NAD83
500 Feet

The Compliance Boandars is established either 250 feet from the perimeter of the ressduals applicaotion area or 50 feet within
the property boundar..: '.vhichever is closer. The Review Boundary =s established midway between the Compliance Boundary
and the perimeter o= the va_idu-s application area_
Poplin, Douglas: Site 5valuation Field Map
Field: DP1-C
Acres: 3.0
Wilkes County, NC
36.23609,-80.94623
0
NC On
Board
- Property Boundary
— Field Boundary
- USGS Stream
®Unused Area
125 250 500 Feet
1 1 1 1 1 { 1
North Carolina Stateplane, NAD83

— Property Boundary
— Field Boundary
- USGS Stream
® Unused Area
A House
• Well
Poplin, Douglas: Site Evaluation Field Map
Field: DP1-D
Acres: 9.6
Wilkes County, NC
36.23738,-80.94606
0
The Compliance Boundary is established either 250 feet from the perimeter of the residuals application area or f.D feet within
the property boundari, whichever is closer. The Review Bcundary :s established midway betty{en tlae Compliance Boundary
and the perimeter of the residuals application area_
N,G� 9.51•ap, NV�en,te> fey, Geaar.";Iy.flmfcarmati:onrand Analysis NC 911 Board
125 250 500 Feet
i I r r
North Carolina Statenlane. NAD83

The Compliance Boundary is established either 250 feet from the perimeter of the residuals application area or 5D feet within
the property bozmdar}_, wihiche er is closer. The Review Bcnnthiry is established midway between the Compliance Boundary
and the perimeter of the residuals application area_
Poplin, Douglas: Site Evaluation Field Map
Field: DP2
Acres: 0.8
Wilkes County, NC
36 23529.-80 94665
0
l t
— Property Boundary
Field Boundary
USGS Stream
® Unused Area
125 250
I I L 1 L
North Carolina State: lane NAD83
500 Feet
t 1

Poplin, Douglas: Site Evaluation Field Map
Field: OP3
Acres: 14.6
Wilkes County, NG
36.24022,-80.9 4041
u
The Compliance Boundary is established either 250 feet from the perimeter of the residuals application area or 7p feet ). ithin
the properly brnmaan; whichever is closer. The Review Boundary- is established midway between the Compliance Bo„nrlary
and the per nneter of the reEddu=:s aalicaton area_
Buffers
Perennial Stream (100')
House 100'
House (400'
Well (100')
Property Boundary
— Field Boundary
- USGS Stream
® Unused Area
NC One
- ---,-f
125 250 500 Feet
1 1 I 1 I 1 I
North Carolina Stateplane, NADB3
A House
• Well

The Compliance Boundary is established either 250 feet from the perimeter of the residuals application area or 5 D feet within
the property boundary_, wlii..chever is closer. The Review Boundary is established midway behveen the Compliance B&nngiary
Mai the perimeter of the residuals application area-
��."
Poplin, Douglas: Site Evaluation Field Map
Field: DP4
Acres: 8.7
DP4
8.7 acres
0 125 250
Property Boundary
— Field Boundary
— USGS Stream
®Unused Area
Wilkes County, NC 1 i i 1
6.23854,-80.93787 North Carolina Stateplane, NAD83
A House
• Well
500 Feet
1

Buffers
Perennial Stream (100')
House 100')
House 400')
Well (1 0')
— Property Boundary
—Field Boundary
USGS Stream
772Unused Area
Poplin, Douglas:
Field: DP5
Acres: 15.9
Wilkes County, NC
36.23630.-80 94054
The Compliance Boundary is established either 250 feet from the perimeter of the residuals application area or 5 D feet within
theproperty boundary, whichever is closer. The Review Bonndary :s established midway between the Compliance Boundary
and. the perimeter of the residues application area_
Site Evaluation Field Map
0 125
250 500 Feet
t t I i i
North Carolina Stateplane, NAD83

= The Compliance Boundary is established either 250 feet from the perimeter of the residuals application area or , D feet within
the property boundary; wtichever is closer. The Review Bcnnrlary is established midway between the Compliance Bornrlarl-
and the per:meter = the residuals application area_
SOIL$
Poplin, Douglas: Site Evaluation Field Map
Field: DP6
Acres: 5.5
NC On
Board
•
—Property Boundary
- Field Boundary
- USGS Stream
®Unused Area
0 125 250 500 Feet
Wilkes County, NC
36.23790 -80.94212 North Carolina Stateplane, NAD83
Q House
® Well

The Compliance Boundary is established either 250 feet from the perimeter of the residuals application area or 5D feet within
the property boundary; whichever is closer. The Review BormelAry is established midway between the Compliance Borimiar-
and the perimeter of the residuis application area.
•
Poplin, Douglas: Site Evaluation Field Map
Field: DP7
Acres: 4.4
Wilkes County, NC
36.23980, -80.94334
0
•
4 r
Property Boundary
Field Boundary
—USGS Stream
® Unused Area
125 250
i l t i
North Carolina Stateplane, NAD83
A House
• Well
500 Feet

Operation and Maintenance Plan
Baxter Healthcare Corporation
Permit No. WQ00031725
In accordance with the requirements as issued by the North Carolina Department of
Environmental Quality using NCGS 143-215.1 and 143-215.3(a) based on 15A NCAC 02T .110,
Baxter Healthcare Corporation and U.S Biosolids, Inc. is implementing this Operation and
Maintenance Plan.
The Land Application of Non -Dedicated Class B Residuals from the Baxter Healthcare
Corporation will be conducted from the Wastewater Treatment facility, located at 65 Pitts Station
Road Marion, NC 28752. Residuals will be removed and given away to farmers to be used as a
soil amendment. The residuals will be removed on as needed bases as fluctuation in the output of
the plant will vary with changing economic conditions. The day-to-day operation of the running
of the Wastewater Treatment will be conducted by Brian Valiquette, ORC of Baxter Healthcare
Corporation or his/her designee. The operations of the land application program will be
conducted by Dennis Key of U.S Biosolids, Inc. or his/her designee.
Land application of residuals will be determined once enough residuals have been produced from
belt pressing to fill the dump trailer that is placed under the conveyer belt of the belt press. The
land application event is initiated by the Baxter Wastewater Treatment plant contacting U.S.
Biosolids, Inc. U.S. Biosolids, Inc. will send an empty dump trailer to place under the conveyor
belt of the belt press while the full trailer of residuals is transported to the land application site;
where, when weather allows, will be dumped, and immediately loaded onto spreader equipment
for land application. The residuals will not be stored on the ground at any time.
Prior to land applying these residuals to permitted sites, the following sampling conditions must
be met (as is outlined in greater detail in the sampling plan attached to this Operation and
Maintenance Plan).
Toxicity Characteristics Leaching Procedure (TCLP) will be conducted once per
year, if a land application event takes place.
A metals and nutrients analysis, pathogen and vector attraction, and soil analysis will be
conducted annually if a land application event takes place.
These samples will be collected by Zach Key of U.S. Biosolids or his/her designee and
transported to an approved lab the same day the samples are taken, as in accordance with 15A
NCAC 02B .0505. The samples must be taken in a matter to ensure a representative sample of
the residuals has been taken.
An inspection will be conducted daily while a land application event is taking place. This
inspection will confirm that all requirements of permit WQ0031725 are complying with
regulations. The fields should be inspected daily for compliance with the conditions that is
outline in then permit. The inspection should consist of (but not limited to):

1. All required setbacks and buffers are complying.
2. All required record keeping of truck and fields sheets are maintained and properly filled
out so accurate records of the volume and locate of residuals are keep.
3. All public access points are controlled (signs posted, gates closed)
4. Make sure all fields' records are turned over to the ORC so records can be reviewed by
NCDEQ and an annual report can be constructed.
The daily land application inspection will be conducted by the following personal:
Dennis Key, ORC U.S. Biosolids, Inc.
Zach Key, BORC U.S. Biosolids, Inc.
If any issues or violations are discovered, the ORC of Land Application, Baxter Healthcare
Corporation and the Asheville Regional Office should be contacted as soon as safely possible.
o ORC of Land Application, US Biosolids, Inc. 336-957-7878
o Baxter WWTP 828-756-6262
o Asheville Regional Office 828-296-4500
To prevent any spills and or safety issues from occurring the flowing will take place during a
land application event. In the unlikely event of a spill consult the spill control plan immediately.
1. Access to the facility will be controlled with a locked gates and fences and signs to
prevent any unauthorized entry into the complex.
2. All pumps and hose will be checked at the start of each day for leaks or loose
fittings.
3. All tanker valves are closed prior to loading and lids are closed prior to transport.
4. All dump trailers or dump trucks gates are tightly fastened and do not leak prior to
transport.
5. All on road equipment is check as per DOT regulations for any safety or mechanical
hazards or issues.
6. All equipment is secured at the end of each working day to prevent any tampering or
unauthorized use.

7. Enough freeboard is maintained in the residual digesters so to prevent overflowing.
This can be accomplished by maintaining the levels of residuals to an acceptable level
by planning adequate land application events to keep up with residuals production.

Baxter Healthcare Corporation
Permit No. WQ0031725
SAMPLING PLAN
Annually, if a land application event occurs, grab samples are collected from the aerobic
digesters and the belt press. These samples will be combined to form individual grab samples to be sent
to a laboratory for analysis.
These individual grab samples are collected and tested for fecal coliform analysis, volatile solids
reduction, nutrient analysis, and a TCLP test. These tests will be taken by Zach Key of U.S. Biosolids, Inc.
All samples apart from the composite residual sample will be taken to Statesville Analytical. The
composite residual sample will be sent to Waypoint Analytical. All samples taken will be taken in the
same condition as the residuals are to be land applied.
The volatile solids reduction requirement will first be attempted by using option 1 [503.33(b)
(1)]; Reduction of volatile solids by at least 38%. The "IN" sample will be taken from the residuals
pumped from the clarifiers and the "OUT" sample from aerobic digester No. 1. If this requirement can't
be met, a gallon of residuals will be sampled from the aerobic digester and analyzed for option 3
503.33(b) (3); known as a 30 day bench scale. This test requires less than 15% additional volatile solids
reduction during bench -scale aerobic batch digestion for 30 days.
Fecal Coliform are gathered in seven (7) individual samples from the aerobic digester and tested
to meet the requirements of [503.32(b)(2)]. This requirement is for the geometric mean fecal coliform
density of the samples be less than two million (2,000,000) MPN per gram. These samples will be placed
in 250m1 containers and placed on ice, in a cooler for transport to the laboratory before 1600 hours
(4pm) the same day the samples are obtained.
Annually, if land application occurs, a composite residual sample will be collected from the belt
press and analyzed, prior to a land application event for: Cadmium, Copper, Lead, Mercury,
Molybdenum, Nickel, Selenium, Zinc, Aluminum, Ammonia Nitrogen, Calcium, Nitrate Nitrogen,
Magnesium, % total Solids, pH, Phosphorus, Potassium, TKN, Sodium. From this information, the Plant
Available Nitrogen (PAN) and a Sodium Absorption Ratio (SAR) will be calculated. This sample will
collected in a non -breakable container, at least one quart in size.
A full TCLP test, including corrosivity, ignitability, and reactivity will be taken in two (2) gallon
containers from the aerobic digester. This test will be run annually unless prior approval is granted from
the division to reduce this requirement to once per permit cycle.

SPILL CONTROL PLAN- U.S. Biosolids, Inc.
Baxter Healthcare Corporation Permit No. WQ0031725
In the event of a spill, the following should be taken IMMEDITALY.
1. Make sure all personal and bystanders are safe- if not contact emergency
services
2. Halt the source of the spill- overturned truck, leaking valve, ruptured tank.
3. Contain the spill. Use straw bales or earthen barrier to form a dike to contain the
spill.
4. Cleanup. Employ vacuum trucks, dump trucks, and loaders to remove as much
of the spilled material as possible. Use straw to soak -up the remaining material.
Dispose of the same in a landfill.
5. Flush the roadways with water if needed. If the spill occurred on a tillable area, till
the same into the soil and spread lime if necessary. If a spill occurs on private
property, final clean-up should be to the satisfaction of the owner.
6. Notification. (This should be done as soon as safely possible.)
A. U.S Biosolids, Inc. Main Office [phone]
B. Baxter Healthcare [phone]

C. NCDEQ-Asheville Regional Office- [phone]
D. County Emergency Services (Sheriff, Fire Dept.) 911
7. Reporting:
The Permittee shall report by telephone to the Asheville Regional Office,
telephone number [phone], as soon as possible, but in no case more than
24 hours or on the next working day following the occurrence or first knowledge
of the occurrence of any of the following:
A. Surface disposal of residuals abnormal in quantity or characteristic.
B. Any failure of the surface disposal program resulting in a release of
material to surface waters.
C. Any time self -monitoring indicates the facility has gone out of compliance
with its permit limitations.
D. Any process unit failure, due to known or unknown reasons, rendering the
facility incapable of adequate residual treatment
E. Any spill or discharge from a vehicle or piping system during residuals
transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface
waters, imminent failure of a storage structure, etc.) outside of normal business
hours shall be reported to the Division's Emergency Response personnel at
telephone number [phone], [phone], or [phone]. Persons
reporting such occurrences by telephone shall also file a written report in letter
form within five days following first knowledge of the occurrence. This report shall
outline the actions taken or proposed to be taken to ensure that the problem
does not recur.
8. Spill Prevention. The easiest way to clean a spill is to prevent one.
A. Ensure loading personal watch the vehicle being loaded.
B. Ensure all valves and lids are closed
C. Inspect all seals and replace if necessary.