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SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED
July 19, 2021
Corey Carpentier
Email: corey_carpentier@baxter.com
Baxter Healthcare Corporation
SUBJECT: Compliance Inspection Report
Baxter Healthcare Corporation RLAP
Non-discharge Permit No. WQ0031725
McDowell County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Baxter Healthcare
Corporation RLAP 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. WQ0031725. The
findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled "Compliance 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
mikal.willmer@ncdenr.gov.
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:WQ0031725 Effective:09/01/16 Expiration:08/31/21 Owner :Baxter Healthcare Corporation
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Corey Carpentier
Effective:Expiration:Facility:Baxter Healthcare Corporation RLAP
65 Pitts Station
Marion NC 28752
Title:Phone:828-756-6636
Follow Hwy. 221 north from Marion to NCSR 1573 (Pitts Station Rd.), turn right. At intersection of Pitts Station Rd. & NCSR 1560
(Old Linville Rd.), turn left. Facility is approximately 0.25 mi. on the left.
Secondary ORC(s):
Phone:Certification:Primary ORC:
LA,System Classifications:
On-Site Representative(s):
Related Permits:
NC0006564 Baxter Healthcare Corporation - Baxter Healthcare Corporation
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
07/15/2021 09:27AM 10:27AM
Mikal Willmer 828-296-4686
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Land Application of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031725
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 RLAP 2019 Annual Residuals
Report on July 15, 2021.
The facility appeared to be in compliance with the processing and monitoring requirements outlined in Permit No.
WQ0031725. Please review any comments below.
Approximately 149.68 dry tons were land applied on 9 of 10 permitted fields. Annual monitoring is required for all parameters
as outlined in Attachment A.
Pathogen and Vector Attraction Reduction: Pathogen reduction was met using Alt.1 (Fecal coliform density) and vector
attraction was met using Alt. 3 (30-day bench test). Laboratory bench sheets were included with the report indicating a
volatile solids reduction <1%.
Continue to monitor copper indices and phosphorus. The NC Department Agriculture recommends utilizing new fields when
when the Cu-I reaches 2000.
Additionally, if any of the hay fields are used for pasture, the nitrogen rate shall be reduced by 25%. See permit condition
II.12.
Page 2 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031725
07/15/2021 Annual Report Review
Baxter Healthcare Corporation
Routine
Type Yes No NA NE
Distribution and Marketing
Land Application
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?
Fescue has an 11-month application window. DP3 is strip cropped with fescue and corn.Comment:
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
Class A, all test must be <1000 MPN/dry gram
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
Fecal coliform SM 9222 D (Class B only)
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
b. pH records for alkaline stabilization (Class A)
c. pH records for alkaline stabilization (Class B)
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
Page 3 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031725
07/15/2021 Annual Report Review
Baxter Healthcare Corporation
Routine
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Vector attraction reduction is demonstrated through the 30-day bench scale volatile solids
reduction.
Comment:
Page 4 of 4