WQ0031725_CEIARR-NOD2022PC0058_20220426

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED

April 26, 2022

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

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0058
Annual Report Review 2021
Permit No. WQ0031725
Baxter Healthcare Corporation RLAP
McDowell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of Baxter Healthcare’s RLAP Annual Report
on April 26, 2022. 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. A summary of the findings
and comments noted during the inspection are provided in the enclosed copy of the inspection report. Please
carefully review all comments noted in the summary of the attached inspection report.

The Annual Report Review inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following deficiency was noted during the inspection:
Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________
Pathogen and Vector Attraction Facility did not reliably demonstrate fecal coliform levels were <2,000,000 MPN/g per Section
IV.4 of the permit. All results were reported as greater than values. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: F15A221D-F527-42F5-916A-E16745A905FA

Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. To prevent further action, carefully review these deficiencies and address the causes of
non-compliance to prevent the recurrence of similar situations.
If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4686 or via email at
[e-mail].

Sincerely,

G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: LF
Zach Key, US Biosolids
DocuSign Envelope ID: F15A221D-F527-42F5-916A-E16745A905FA
Compliance Inspection Report
Permit:WQ0031725 Effective:09/01/21 Expiration:06/30/27 Owner :Baxter Healthcare Corporation
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Corey Carpentier
Effective:Expiration:Facility:North Cove Steam Generation Plant CLRS
2859 Old Linville Rd
Marion NC 28752
Title:Phone:[phone]
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:
04/26/2022 10:30AM 11:40AM
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
DocuSign Envelope ID: F15A221D-F527-42F5-916A-E16745A905FA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031725
04/26/2022 Annual Report Review
Baxter Healthcare Corporation
Routine
Inspection Summary:
Mikal Willmer, with the Asheville Regional Office, conducted a review of Baxter’s RLAP Annual Report on April 26, 2022.
This review was conducted to determine whether the facility processed and monitored all residuals in compliance with
Permit No. WQ0031725.
US Biosolids land applied approximately 121.75 dry tons of Class B residuals to 9 of 10 permitted fields on behalf of Baxter.
Pathogen Reduction (PR): PR is met via fecal coliform density reduction below 2,000,000 MPN/g. The geometric means for
2021 is reported on the Pathogen and Vector Attraction Reduction Form as 1,221,475 MPN/g. Please note, a review of the
analytical data shows the laboratory reported the geomean as > 1,221,475 MPN/g. All seven samples analyzed were
reported as greater than the reported values. A compliance determination cannot be reliably made as the true value may be
greater than the fecal coliform reduction requirement for Class B residuals. In the future, if results come back as greater
than the reported value, additional samples must be analyzed to determine the actual pathogen reduction. Anything that
exceeds 2,000,000 MPN/g shall not be land applied until it is either reprocessed or reanalyzed and meets the reduction
requirement.
Vector Attraction Reduction (VAR): VAR is demonstrated via the 30-day bench scale test. The volatile solids reduction was
less than 15%.
Metals, Nutrients & Pollutants of Concern: Values were below the ceiling and cumulative pollutant loading rates for Class B
residuals. All metals and nutrient parameters were analyzed per section IV.3 of the permit. PAN & SAR balances are being
calculated and maintained.
Application: As a reminder, any residuals applied to grazed pasture shall have the realistic nitrogen rate reduced by 25%
per Section II.10.d. Several of the fields are listed as pasture in the most recent application (DP1-A, DP1-B, DP1-C, DP1-D,
DP4, DP5, DP6 & DP7). Additionally, please remind the property owner animals cannot graze on the land for 30 calendar
days after land application per Section III.12.a.
Soil Fertility Analysis: Lime was applied to recommended fields before application. ESPs were less than 15.
Non-Hazardous Waste Characterization: TCLP, corrosivity, reactivity and ignitibility appear to meet regulatory requirements.
Page 2 of 4
DocuSign Envelope ID: F15A221D-F527-42F5-916A-E16745A905FA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031725
04/26/2022 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 can be applied to year-round.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
DocuSign Envelope ID: F15A221D-F527-42F5-916A-E16745A905FA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031725
04/26/2022 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
30-Day bench scale results used to meet VAR. Facility did not reliably demonstrate pathogen
levels were <2,000,000 MPN/g. 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 dewatered in a centrifuge before land application.Comment:
Page 4 of 4
DocuSign Envelope ID: F15A221D-F527-42F5-916A-E16745A905FA