WQ0010689_CEIARR_20210716

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED
July 16, 2021

Corey Carpentier
Email: [e-mail]
Baxter Healthcare Corporation

SUBJECT: Compliance Inspection Report-Annual Report Review
Baxter Healthcare DCAR
Non-discharge Permit No. WQ0010689
McDowell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Baxter Healthcare DCAR
on 7/15/2021. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in Non-discharge Permit No. WQ0010689. Please carefully review the
comments noted in the summary of the attached inspection report.

There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.

If you should have any questions, please do not hesitate to contact me at 828-296-4686 or via email at
[e-mail].

Sincerely,

Mikal Willmer, Environmental Specialist II
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: LF
Compliance Inspection Report
Permit:WQ0010689 Effective:12/01/19 Expiration:03/31/25 Owner :Baxter Healthcare Corporation
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Corey Carpentier
Effective:Expiration:Facility:Baxter Healthcare DCAR
65 Pitt Station Rd
Marion NC 28752
Title:Phone:[phone]EHS Associate
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
WQ0001512 Baxter Healthcare Corporation - Baxter Healthcare Corporation RLAP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
07/15/2021 01:01PM 02:00PM
Mikal Willmer 828-296-4686
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503 Exempt)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping
(See attachment summary)
Page 1 of 3
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010689
07/15/2021 Annual Report Review
Baxter Healthcare Corporation
Routine
Inspection Summary:
Mikal Willmer, with the Asheville Regional Office, conducted a review of Baxter Corporation's DCAR 2020 Annual Residuals
Report on July 15, 2021.
The facility's monitoring and reporting appeared to be in compliance with Permit No. WQ0010689.
Approximately 1,344 dry tons of residuals were distributed in 2020 requiring quarterly sampling.
The permittee should note that signed utilization agreements are no longer a requirement of the permit. Baxter may
continue using these or modify the sheets to meet the new requirements of Section III.9 of the permit.
Please verify the calculation and units used for the SAR. The SAR values appeared to be artificially high. Several of the
reported values make it appear the residual is approaching a SAR value of 10. An inaccurate SAR calculation could prevent
residuals from being distributed unnecessarily. The following formulas can be used to obtain the SAR; however, both require
initial values for Ca2+, Mg2+ and Na+ to be converted from mg/kg to mg/L.
1.SAR formula measurements in mmol/L
SAR= Na/SQRT(Ca+Mg)
Convert cation measurements from mg/L to mmol/L by dividing the concentration by the atomic mass.
2.SAR formula measurement in meq/L
SAR=Na/SQRT[0.5(Ca+Mg)]
Convert cation measurements from mg/L to meq/L by dividing the concentration by (atomic mass÷valence shell electrons)
Page 2 of 3
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010689
07/15/2021 Annual Report Review
Baxter Healthcare Corporation
Routine
Type Yes No NA NE
Land Application
Distribution and Marketing
Record Keeping Yes No NA NE
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?
The DCAR permit is for ash distribution. Pathogen and Vector attraction reduction are not
required. Non-hazardous waste characterization is only required once per permit cycle.
Comment:
Page 3 of 3