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Home My WebLink AboutWQ0031725_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 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 8/13/2021. 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". 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: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): 336-957-7871Phone:27660Certification:Zach D KeyPrimary 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: 08/13/2021 09:00AM 11:00AM Mikal Willmer 828-296-4686 Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Land Application of Residual Solids (503) Compliance Evaluation Question Areas: Miscellaneous Questions Record Keeping Treatment 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: WQ0031725 08/13/2021 Compliance Evaluation Baxter Healthcare Corporation Routine Inspection Summary: Mikal Willmer, with the Asheville Regional Office conducted a compliance evaluation inspection of Baxter’s RLAP facility on August 13, 2021. This inspection was conducted in conjunction with the facility’s DCAR and Closed-loop inspection to determine if the system was being maintained in compliance with permit no. WQ0031725. Solids from the digester are sent to the facility’s centrifuge and are discharged to a US Biosolids trailer at approximately 20% Total Solids. Baxter reports solids are hauled twice a month depending on production at the manufacturing plant. Pathogen and Vector Attraction Reduction: Upon review of the fecal results submitted by Statesville Analytical it was noted all results were reported as greater than values. Please note, the data receiver cannot determine compliance confidently as there is the potential the value is underestimated. Hazardous waste and Pollutant Monitoring: TCLP, corrosivity, reactivity and ignitibility appeared to be in compliance. All metals values appeared to be less than both ceiling and monthly pollutant concentration limits. Recommended the permittee continue to monitor the fields within their permit as the phosphorus index has been high for several years. Please note, the current permit does not have an action level for phosphorus levels; however, agronomic rates do have to be taken into consideration for overall system health. Phosphorus levels above the crop uptake rate can lead to increased phosphorus mobility in soils, potentially leading to surface water impacts. Copper indices should also be closely monitored. Page 2 of 4 DocuSign Envelope ID: 2EA46DD4-D3AD-45C0-9B03-88B92552DBAB Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031725 08/13/2021 Compliance Evaluation 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? Results available to date were reviewed. Soil fertility analysis has not been received for the year. 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 Page 3 of 4 DocuSign Envelope ID: 2EA46DD4-D3AD-45C0-9B03-88B92552DBAB Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031725 08/13/2021 Compliance Evaluation Baxter Healthcare Corporation Routine 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 See summary for details.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 digested sludge is centrifuged and tested before land application.Comment: Page 4 of 4 DocuSign Envelope ID: 2EA46DD4-D3AD-45C0-9B03-88B92552DBAB