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Home My WebLink AboutWQ0010689_CEI_20210825 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED August 25, 2021 Corey Carpentier Email: corey_carpentier@baxter.com Baxter Healthcare Corporation SUBJECT: Compliance Inspection Report 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 8/12/2021. 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. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". Additionally, please submit a copy of the agronomist recommendations regarding the elevated SAR levels. 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 DocuSign Envelope ID: 2EA46DD4-D3AD-45C0-9B03-88B92552DBAB 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:828-756-6636EHS 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: 08/12/2021 09:00AM 11:00AM Mikal Willmer 828-296-4686 Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Distribution of Residual Solids (503 Exempt) Compliance Evaluation Question Areas: Miscellaneous Questions Record Keeping Treatment Sampling Pathogen and Vector Attraction Storage (See attachment summary) Page 1 of 4 DocuSign Envelope ID: 2EA46DD4-D3AD-45C0-9B03-88B92552DBAB Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0010689 08/12/2021 Compliance Evaluation Baxter Healthcare Corporation Routine Inspection Summary: Mikal Willmer, with the Asheville Regional Office conducted a compliance evaluation inspection of Baxter’s DCAR permit on August 13, 2021. This inspection was conducted in conjunction with the facilities RLAP and Closed-loop inspection to determine if the system was being maintained in compliance with permit no. WQ0010689. Ash is dried and stored onsite until distribution occurs. At the time of the inspection, ash was being removed from the South Pond by the local hauler and taken to nearby fields. There did not appear to be any migration of residuals from the immediate area. All runoff is recycled back through the system. Files were reviewed after the inspection. Baxter has spoken with an agronomist regarding their calculated elevated SAR numbers, and it was recommended they continue to take soil samples of the fields receiving ash distributions before and after application to ensure there are no adverse long-term impacts to soil and crop health. Additionally, please provide the ARO a copy of the written agronomist recommendations due to elevated SAR values. Page 2 of 4 DocuSign Envelope ID: 2EA46DD4-D3AD-45C0-9B03-88B92552DBAB Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0010689 08/12/2021 Compliance Evaluation 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? Distribution permit does not require soil fertility analysis. Available nutrient and metals data were reviewed. Baxter has engaged an agronomist due to elevated SAR values. See summary for details. 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) Page 3 of 4 DocuSign Envelope ID: 2EA46DD4-D3AD-45C0-9B03-88B92552DBAB Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0010689 08/12/2021 Compliance Evaluation Baxter Healthcare Corporation Routine Temperature corrected d. Salmonella (Class A, all test must be < 3MPN/4 gram day) e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench-top Aerobic/Anaerobic digestion results Facility is 503 exempt and does not monitor for pathogen and vector attraction reduction.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 boiler ash is dried on concrete basins before hauled for distribution.Comment: Sampling Yes No NA NE Describe sampling: Is sampling adequate? Is sampling representative? Comment: Page 4 of 4 DocuSign Envelope ID: 2EA46DD4-D3AD-45C0-9B03-88B92552DBAB