WQ0031725_Regional Office Physical File Scan Up To 10/24/2022

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
July 5, 2017
Michael J. Pisarik, Senior Environmental Engineer
Baxter Healthcare Corporation
Post Office Box 1390
Marion, NC 28752
SUBJECT: Annual Report (2016) Review Follow-up Inspection
Baxter Healthcare Corporation RLAP
Permit No: WQ0031725
McDowell County
Dear Mr. Pisarik:
Enclosed please find a copy of the Annual Report Review Inspection Form from the follow-up inspection
conducted on 7/5/2017. The facility was found to be in compliance with permit WQ0031725.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions, please call me at 828-296-4500.
Sincerely,
Beverly ce
Environmental Senior Specialist
Enclosure: Inspection Report
cc: MSC 1617-Central Files -Basement
vlla'e�F ! es &L'1
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\CEI17.2016 AR Review follow Up letter.doex
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70 Swannanoa, NC 28778
828 296 4500

October 12, 2016
Regional Supervisor
North Carolina Division of Water Resources
Asheville Regional Office T
2090 U.S. Highway 70
Swannanoa, NC 28778eU�FR l6'
RE: Delegation of Signature Authority
Baxter Healthcare Corporation
NPDES Permit No. NC006564.
NPDES Stormwater Permit No. NCG060030 and No. NCG210028
Ash Distribution Program Permit No. WQ0.010689
Land Application of Residual Solids Permit No.. WQ0031725
This letter is to notify DEQ- Division.of Water Resources of the change in Signature Authority for Baxter
Healthcare North Cove facility in Marion, NC. Jon Rushford replaces Tony Johnson as signature
authority for the above mentioned permits.
Jon Rushford
VP Operations, North Cove
65 Pitts Station Rd_; Marion, NC 28762
jon rushfordit—baxter.com
828-756-6530
If you have any questions, please contact Mike Pisarik at 828-756-6017 or michael [e-mail].
Sincerely,
Jon Rushford
VP Operations, North Cove
Cc: DEQ- Asheville Office
Efi
Baxter Healthcare Corporation
61 Pitts Station Road / PO Box 1390 / Marion, North Carolina 28752
T 828.756.4151
Resourew
OCT 2 7 2016
Water Duality Regfonaf ®peraflons
Asheviite Re-giona! Office
n

rIL
,A PAT MCCRORY
3^ Governor
DONALD R. VAN DER VAART
WaterResources
ENVIRONMENTAL QUALITY
June 20, 2016
Tony Johnson, Interim Plant Manager
Baxter Healthcare Corporation
Post Office Box 1390
Marion, NC 28752
SUBJECT: Annual Report (2015) Review Inspection
Baxter Healthcare Corporation RLAP
Permit No: WQ0031725
McDowell County
Dear Mr. Johnson:
Secretary
S. JAY ZIMMERMAN
Director
Enclosed please find a copy of the Annual Report Review Inspection Form from the inspection conducted on
4/14/2016. The facility was found to be in compliance with permit WQ0031725.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions, please call me at 828-296-4500.
Sincerely,
Beverly Price
Environmental Senior Specialist
Enc.
cc: Dennis Key, ORC
MSC 1617-Central Files -Basement
ALshevlle F�1es
G:\WR\WQ\McDoweli\Wastewater\Non-discharge\Baxter Healthcare\CEI16 2015 AR Review of.docx
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70 Swannanoa, NC 28778
828 296 4500

Permit: WQ0031725
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 04/21/11 Expiration: 08/31/16 owner: Baxter Healthcare Corporation
Effective: Expiration: Facility: Baxter Healthcare Corporation RLAP
. 65 Pitts Sta
Marion NC 28752
Contact Person: Michael Joseph Pisarik Title: Sr Environmental Engineer Phone: [phone]
Directions to Facility:
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.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary-ORC(s):
Zach D Key 27660 336-957-7871
On -Site Representative(s):
24 hour contact name Michael Joseph Pisarik 828-756-6017
Related Permits:
Inspection Date: 04/14/2016 EntryTime: 10:OOAM
Primary Inspector: Beverly Price Ur
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping
(See attachment summary)
Eicit Time: 11:30AM
Phone: [phone]
Inspection Type: Annual Report Review
Pathogen and Vector Attraction
Page: 1

Permit: W00031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/14/2016 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
This inspection consisted of a review of the 2015 Annual Report and was conducted by Beverly Price of the ARO.
134.92 Dry Tons of residuals were land applied to permitted fields located in Wilkes County, NC.
Metals/nutrients/TCLP analyses were conducted according to permit requirements. Metals Ceiling Concentration and
Cumulative Pollutant Loading Rates and TCLP limits appear to be compliant with permit limits.
Pathogen Reduction is determined using Alternative 1 — Fecal Coliform Density.
Vector Attraction Reduction (VAR) is met using Option 1 — 38% Volatile Solids Reduction.
Pathogen and VAR appear to be compliant with permit requirements.
All fields that received residuals in 2015 were sampled. Fields with pH values <6.0 received lime applications. Several
fields were rated Very High for Zinc & Copper but Indices were not above 2000.
Page: 2

Permit: W00031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/1412016 Inspection Type: Annual Report Review Reason for Visit: Routine
Pathogen and Vector Attraction
Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
1111 ❑
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)
❑ ❑ E ❑
Geometric mean of 7 samples per monitoring period for class B<2.0" 1 OE6 CFU/dry gram
❑
b. PH records for alkaline stabilization (Class A)
❑ ❑ 0 ❑
c. pH records for alkaline stabilization (Class B)
❑ ❑ ❑
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑ ❑ .❑
e. Time/Temp on:
❑ ❑ M ❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
M ❑ ❑ ❑
g. Bench -top Aerobic/Anaerobic digestion results
1111 ❑
Comment:
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ M ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ 0 ❑
Are there any GW quality violations?
❑ ❑ M ❑
Is GW-59A certification form completed for facility?
❑ ❑ ❑
Is a copy of current permit on -site?
❑ ❑ ❑
Are current metals and nutrient analysis available?
0 ❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
❑ ❑ ❑
a. TCLP analysis?
❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
0 ❑ ❑ ❑
Are PAN balances being maintained?
0 ❑ ❑ ❑
Are PAN balances within permit limits?
❑ ❑ ❑
Has land application equipment been calibrated?
❑ ❑ ❑
Are there pH records for alkaline stabilization?
❑ ❑ 0 ❑
Are there pH records for the land application site?
0 ❑ ❑ ❑
Are nutrient/crop removal practices in place?
M ❑ ❑ ❑
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/14/2016 Inspection Type: Annual Report Review Reason for Visit: Routine
Record Keeping Yes No NA NE
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? ❑ 0 ❑
Comment: Applications were not during restricted window.
Type Yes No NA NE
Distribution and Marketing
Land Application
Page: 4

State of North Carolina
Aepartment of Environmental Quality
Division of Water Resources
Water Quality Permitting
Regional Staff Report
April 14, 2016
To: DWR Water Quality Permitting; Section Central Office Application No.: n0031725
Attn: Troy Doby Regional Login No.:
From: Bev Price
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 4/6 /2016
b. Site visit conducted by: Bev Price .
c. Inspection report attached? Z Yes or ❑ No
d. Person contacted: Mike Pisarik, Sr. Environmental Engineer and their contact information: 82( 8) 756-
6017; Zack Key, Consultant, SSB 336-957-7871_
e. Driving directions: From Marion: Hwy. 221 North to intersection with NCSR 1573 (Pitts Station Road).
Continue through the intersection for approximately 100 yds., the WWTP is on the right..
H. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8.' Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No'❑ N/A
If yes, attach list of sites with restrictions (Certification B)
FORM: APSRSR 04-10 Page 1 of 4

III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPL1uATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Dennis Key Certificate #: LA15704 Backup ORC: Zack Key Certificate #: LA27660
2. Are the design,. maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ® No
If no, please explain: A portion of field DPI -A is a feeding area which is denuded. A vegetative cover will
need to be re-established prior to land application.
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ® No
If no, please explain: 2015 Annual Report: Soils Analyses showed Very High for phosphorous for Fields.
DP3C, DP5, DP7. Fields 103C, DP3G, DP4, DP5, DP6, DP7 showed Very High for Copper. Fields DP31
DP4. DP5. DP6 showed Very High for Zinc. However. the Zinc and Copper Indices were not above 2000
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a.map showing -conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or Z No
If no, please explain: The fields located in Catawba County are being removed from the permit. The
renewal application did not indicate a minor modification but it was noted on the Site Certification Form.
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
O I 11
_ O I 11
O f If
_ O I 11
O 1 Il
O / If
O I If
O I If
O f //
O / //
12. Has a review of all self -monitoring data been conducted (e.g., NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: See #6 above
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ®'No
If yes, please explain:
14. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
FORM: APSRSR 04-10 Page 2 of 4

15. Have all compliance dates/c.._--.Aions in the existing, permit been satisfies.. ] Yes ❑ No ® N/A
If no, please explain:
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ® No ❑ N/A
If yes, please explain:
IV. REGIONAL OFFICE RECOldI1VIENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like APS Central Office to obtain through an additional information request:
Item Reason
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state rearms: )
6. Signature of report preparer: tJd�l/ a✓l
Signature of A S regional supervisor: _
Date:
FORM: APSRSR 04-10
Page 3 of 4

V. ADDITIONAL REGIONAL STA ,-r REVIEW ITEMS
FORM: APSRSR 04-10 Page 4 of 4

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 Owner": Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: Baxter Healthcare Corporation RLAP
County: McDowell 65 Pitts Sta
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
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.
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Corporate Responsible Official Michael Joseph Pisarik
On -site representative Zach D Key
On -site representative Michael Joseph Pisarik
Related Permits:
Inspection Date: 04/06/2016 Entry Time: 12:30PM Exit Time: 02;OOPM
Primary Inspector: Beverly Price Phone: , 828-296-4500
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Land Application Site
(See attachment summary)
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/06/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection was in conjunction with the permit renewal.
Land application had occurred on field DP7 two days prior to the site visit. Buffer flags were still in place. Notification signs
were in place. The field had a good grass cover.
Field DP3 now has a waiver buffer: residuals application within 100 ft. of 752 Austin Little Mtn. Road.
A portion of field DPI -A is denuded. This area will need to be re -seeded prior to land application.
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/06/2016 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Land Application Site
Yes No NA NE
Is a copy of the permit on -site during application events?
❑ ❑
Is the application site in overall good condition?
N ❑ ❑ ❑
Is the site, free of runoff/ponding?
❑ ❑
If present, is the application equipment in good operating condition?
N ❑ ❑ ❑
Are buffers being maintained?
❑ ❑
Are limiting slopes buffered?
10% for surface application0
❑ ❑
18% for subsurface application
❑ ❑ 0 ❑
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
0 ❑ ❑ ❑
Have performance requirements for application method been met?
For injection?
❑ ❑ 0 ❑
For incorporation?
❑ ❑0 ❑
Does permit require monitoring wells?
❑ E ❑ ❑
Have required MWs been installed?
❑ R ❑
Are MWs properly located w/ respect to RB and CB?
❑ ❑ 0 ❑
Are MWs properly constructed (including screened interval)?
❑ ❑ 0 ❑
Is the surrounding area served by public water?
❑ ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑ ❑ ❑
Are soil types consistent w/ Soil Scientist report/evaluation?
❑ ❑ ❑ N'
Is the water table greater than 173' bls.
❑ ❑ ❑
Is application occurring at the time of the inspection?
❑ ❑ ❑
Comment: Area not served by public water.
Permit does not require monitoring wells.
Tvpe
Yes No NA NE
1
Distribution and Marketing
❑
Land Application
Page: 3

Baxter
March 15, 2016
DEQ — Division of Water Resources
Information Processing Unit -
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Northrrft zSteam�Generation Pian At sh 0istribut o Pr 6ggrm
hermit : 'WQ00T-0-W91P
Waxter Heaithcare-Land Application of=Resi u l l ds§
P�rM-OmW Q093-21*7.2 O
Baxter Healthcare NPDES Stormwater Permit
Permit#: NCG060030
Baxter Healthcare NPDES Stormwater Permit
Permit#: NCG210028
Baxter Healthcare NPDES Permit
Permit#: NC0006564
This letter is to notify DEQ — Division of Water Resources of the change in Signature Authority for Baxter
Healthcare North Cove facility in Marion, NC. Tony Johnson will be replacing Alan Weiler as signature
authority for the above mentioned permits.
If you have any questions please contact Amanda Richcreek at 828-756-6809.
Sincerely,
Tony Johnson
VP, Ops — US/Canada Area
Enclosures
cc: DEQ-Asheville Office
Baxter Healthcare Corporation
One Baxter Parkway / Deerfield, Illinois 60015
T 847.948.2000
RECEIVED
1Dfvision of Water Resources
15 2016
Water Quality Regional Operations
Ashevi,ie Regions! Office

North Carolina Department of Environmental Quality!
Pat McCrory Donald R. van der Vaart
Governor Secretary
October 15, 2015
Alan Weiler, Plant Manager
Baxter Healthcare Corporation
Post Office Box 1390
Marion, NC 28752
SUBJECT: Compliance Evaluation Inspection
Baxter Healthcare Corporation Land Application of Residual Solids
Permit No: WQ0031725
McDowell County
Dear Mr. Weiler:
Enclosed please fmd a copy of the Compliance Evaluation Inspection Form from the inspection conducted on
9/29/2015. The facility was found to be in compliance with permit WQ0031725.
As a reminder, this permit expires August 31, 2016. The renewal application is due 180 days prior to expiration.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions, please call me at 828-296-4685.
Sincerely,
Beverly Pri e
Environmental Senior Specialist
Enc.
r.
cc: Mike Pisarik, Senior Environmental Engineer Baxter_ Healthcare w/Enc.
MSC 1617-Central Files -Basement
A4"AW1RlexKf4 ~
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\CEI15.docx
North Carolina Division of Water Resources — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone [phone]
FAX [phone]
Internet: http://portal.ncdenr.or--/Nveb/wq/
An Equal Opportunity/Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell 65 Pitts Sta
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
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.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Dennis Key 336-957-8909
On -site representative Michael Joseph Pisadk 828-756-6017
Related Permits:
Inspection Date: 09/29/2015 Entry Time: 08:OOAM Exit Time: 08:45AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping
(See attachment summary)
Inspection Type: Compliance Evaluation
Page: 1

Permit: W00031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/29/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This inspection included a tour of the residuals facilities and associated records. Items checked NE are evaluated in the
Annual Report.
Diffusers have been added to both digesters. The drying beds are no longer being used. The current setup is to move
residuals from the digesters to the aerated emergency pond when needed. If residuals do not flow to the emergency pond,
they flow directly to the belt -press and then to the hauler truck for land application.
The proposed upgrade to'the WWTP will include a centrifuge to replace the belt -press. The permittee hopes to break
ground on the new WWTP in October.
So far in 2015, 46 wet tons of residuals have been sent to the Foothills Regional Landfill in Lenoir, NC
Maintenance records appear to be complete. The facility is well maintained.
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/29/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Record Keeping
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?
Comment:
Yes No NA NE
Yes No NA NE
❑ ❑ E ❑
❑❑■❑
■❑❑❑
■❑❑❑
❑ ❑ ❑
❑ ❑ ❑ N
❑❑❑■
❑❑❑■
❑ ❑ ❑
❑❑■❑
❑❑■❑
❑❑❑■
❑ ❑ ❑
❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑
Page: 3

North k.arolina Department of Environmental Quality
Pat McCrory
Governor
September 29, 2015
Alan Weiler, Plant Manager
Baxter Healthcare Corporation
Post Office Box 1390
Marion, NC 28752
SUBJECT: Annual Report (2014) Review Inspection
Land Application of Residual Solids
Permit No: WQ0031725
McDowell County
Dear Mr. Weiler:
Donald R. van der Vaart
. Secretary
Enclosed please fmd a copy of the Annual Report Inspection Form from the inspection conducted on 9/23/2015.
The facility was found to be in compliance with permit WQ0031725.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions, please call me at 828-296-4685.
Sincerely,
Beverly Price
Environmental Senior Specialist
Enc.
cc: Dennis Key, ORC SSB
Mike Pisarik, Senior Environmental Engineer Baxter Healthcare
MSC 1617-Central Files -Basement
Asheville Files
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\CEI15 2014 AR Review LA.docx
North Carolina Division of Water Resources — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone-[phone]
FAX [phone]
Internet: http:/,1portaLucdenr.org/web/wq/
An Equal Opportunity/Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility:
North Cove Steam Generation Plant
County: McDowell
65 Pitts Sta
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer
Phone: [phone]
Directions to Facility:
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.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704
Phone: [phone]
Secondary ORC(s):
Zach D Key 27660
336-957-7871
On -Site Representative(s):
24 hour contact name Dennis Key
336-957-8909
Related Permits:
Inspection Date: 09/23/2015 Entry Time: 10:30AM Exit Time:
12:30PM
Primary Inspector: Beverly Price
Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type:
Annual Report Review
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/23/2015 Inspection Type: Annual Report Review Reason for visit: Routine
Inspection Summary:
108.5 dry tons of residuals were land applied to 7 permitted fields in 2014. Nutrients/metals/TCLP analyses were
conducted according to permit requirements. The metals ceiling concentration limits were met as were the TCLP limits.
Pathogen reduction was accomplished using fecal coliform analyses. Vector Attraction Reduction (VAR) was
accomplished using Option 1 - 38% Volatile Solids Reduction. All fields receiving residuals had pH values less than 6;
these fields received applications of lime.
The report appeared to be complete and accurate.
L
Page: 2

Permit: WQ0031725 owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/23/2015 Inspection Type: Annual Report Review Reason for Visit: Routine
Type
Yes No NA NE
Distribution and Marketing El
Land Application
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)
El 01:10
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)
El El 0 ❑
c. pH records for alkaline stabilization (Class B)
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
e. TimeTremp on:
El ❑
Digester (MCRT)
'Compost
El
'Class A lime stabilization
f. 'Volatile Solids Calculations
0 El 0 ❑
g. Bench -top Aerobic/Anaerobic digestion results
❑ El 0 ❑
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
Comment:
Page: 3

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 O ner : Baxter Healthcare Corporation
SOC: Effective: Expirati Facility: North Cove Steam Generation Plant
County: McDowell j� n 65 Pitts Sta
Region: Asheville i r
5 t/lit' _�f . f ��1 Marion NC 28752
,1`�
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
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.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
Related Permits:
Inspection Date: 09/29/2015
Primary Inspector: Beverly Price
Secondary Inspector(s):
Dennis Key
Michael Joseph Pisarik
l
Entry Time: 08:OOAM Exit Time: 08:45AM
Reason for Inspection: Routine
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions E' Record Keeping
336-957-8909
828-756-6017
Phone: [phone]
Inspection Type: Compliance Evaluation
(See attachment summary)
62
yyi6 V
L� . ` aC�� Page: 1
VN)���� 6r-e")- IV �; G� F\,LV wA,­tp �'

Permit: WO0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/29/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:'
)d I�D45
4
L9'
Page: 2

Permit: W00031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/29/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Record Keeping
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? 1 /1
Are nutrient and metal loading calculating most limiting parameters? �2w L( 4- L
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)? pp
Are PAN balances being maintained?
Are PAN balances within permit limits? < < < I
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?
Comment:
P_g< "0/196'C /_a-C14rC(
AJ
f� c ods rS 5NJ5 ` c L P
C UbI
Yes No NA NE
❑�❑
❑ ❑ V 1:1
❑ ❑ [k El
❑ ❑ a ❑
rd ❑ ❑ ❑
ICI ❑ ❑ ❑
❑❑❑
❑ ❑k.
❑❑❑
( ❑ ❑ [P
"❑❑�
❑❑q01?
❑ ❑ k` ❑
'❑❑❑
goes
LQU,❑ ❑❑
❑ ❑ ❑
d❑❑❑
❑ 0 ❑j�]
Ld r� Page: 3

MCDENR F
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
June 30, 2014
Terry Foxx, Interim Plant Manager
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
SUBJECT: Compliance Evaluation Inspections
Baxter Healthcare
Land Application of Residual Solids
WQ0031725
North Cove Steam Generation Plant Ash Distribution Program
Permit No: WQ0010689
McDowell County
Dear Mr. Foxx:
Enclosed please find a copy of the Compliance Evaluation Inspection Forms from the inspections conducted on June 18,
2014. The facility was found to be in compliance with permits WQ0010689 & WQ0031725.
Regarding permit WQ0010689, please resubmit the following information to the Asheville Regional Office:
1. Residuals Sampling Summary Form with the correct sample identifier or an
explanation for the sample locations given.
2. Recipient data sheets with the correct information; some sheets were dated 2012 & 2009.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any
questions, please call me at [phone].
Sincerely,
Beverly Price
Environmental Specialist
Enc.
cc: Ricky Styles, ORC
WQ Central Files
�,WQ4Asl�;u^lieFi�les r,
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\WQ0010689 & WQ0031725 CEI14 2013 AR Review.doc
Water Quality Regional Operations — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet: hftp:llportal.ncdenr.org/weblwgl
An Equal Opportunity 1 Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell Hwy 221n
Region: Asheville 65 Pitts Sta Rd
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. WVVfP is located on the right just past the intersection of Pitts
Station Rd. and Hwy. 221.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
Zach D Key 27660 336-957-7871
On -Site Representative(s):
Related Permits:
Inspection Date: 06/23/2014 EntryTime: 10:OOAM
Primary Inspector: Beverly Price
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
® Miscellaneous Questions
(See attachment summary)
Exit Time: 11:OOAM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 06/23/2014 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This inspection included a review of the 2013 Annual Report.
95.2 DT were applied over 44.56 acres. The Douglas Poplin Field DP3 is strip cropped with fescue and corn. In the future,
land application events for this field should be recorded on two separate field summary forms with acreage separated
between corn and fescue.
PathogenNector Attraction Reduction/metals/nutrients/TCLP requirements were met.
Page: 2

FILE
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
February 7, 2014
Andrea Darsey, Plant Manager
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
SUBJECT: January 31, 2014
Compliance Evaluation Facility Inspections
Baxter Healthcare Corporation
North Cove Steam Generation Plant
Wastewater Recycle System
Permit No: WQ0001512
Ash Distribution Program
W00010689
North Cove WWTP
Land Application of Residual Solids
W00031725
McDowell County
Dear Ms. Darsey:
Enclosed please find a copy of the Compliance Evaluation Inspection forms from the inspections
conducted on January 31, 2014. The facility was found to be in Compliance with permits W00001512,
WQ0010689 & W00031725.
Silt fencing/straw bales have been placed around the ash storage area to address potential runoff
to surface waters. We appreciate the immediate response to this issue.
Please refer to the enclosed inspection reports for additional observations and comments. The
assistance of Ms. Amanda Richcreek, Mr. Ricky Styles and Mr. Stephen Taylor was greatly appreciated
during the inspection. If you or your staff have any questions, please call me at [phone].
Sincerely,
Beverly Price
Environmental Specialist
Enclosures
cc: Amanda Richcreek, Environmental Engineer
Water. -Quality.. Central Files
Fad
ahtytAshevllle'Ftles.-s' `
G:\WR\WQWIcDowell\Wastewater\Non-discharge\Baxter Healthcare\W00010689 & W00001512 &
WQ0031725CEI14 Facility.doc
Water Quality Regional Operations —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX [phone]
Internet htipl/portal.ncdenrorg/web/wq
An Equal Opportunity 1 Affirmative Action Employer

Permit: WQ0031725
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective:04/21/11 Expiration:08/31/16
Effective: Expiration:
Contact Person: Amanda Richcreek
Owner: Baxter Health Care Corporation
Facility: North Cove Steam Generation Plant
Hwy 221 n
65 Pitts Sta Rd
Marion NC 28752
Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. WWTP is located on the right just past the intersection of Pitts
Station Rd. anv 221.
System Classi ica ons: LA,
Primary ORC: Dennis Key Certification: 15704
Phone: [phone]
Secondary ORC(s):
Zach D Key Certification: 27660
Phone: [phone]
On -Site Representative(s):
24 hour contact name Amanda Richcreek
Phone: [phone]
On -site representative Stephen D Taylor
Phone: [phone]
On -site representative
Related Permits:
Inspection Date: 01/31/2014
Primary Inspector: Beverly Price
Secondary Inspector(s):
Amanda Richcreek
Entry Time: 09:30 AM Exit Time: 10:30 AM
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
0 Miscellaneous Questions 0 Record Keeping Treatment
(See attachment summary)
■ Pathogen and Vector
Attraction
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 01/31/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This portion of the inspection included a tour of the WWTP/biosolids facility. Baxter is working on implementing a new
preventative maintenance system (MAXIMO)which will include all aspects of the biosolids portion of the WWTP. The
belt -press was running; next load of biosolids will be ready for land application soon. A field inspection as well as a
review of the 2013 Annual Report (AR)will be conducted before June 2014. Sampling points for volatile solids reduction
are now given on a facility map that will be included in the AR.
Inspection questions checked NE will be addressed after the 2013 AR review.
The facility appears to be well maintained and operating according to permit conditions.
Page: 2

Permit: WO0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 01/31/2014 Inspection Type: Compliance Evaluation
Type
Distribution and Marketing
Land Application
Record Keeping
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?
Comment:
Pathogen and Vector Attraction
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)
Reason for Visit: Routine
Yes No NA NE
■
Yes No NA NE
Yes No NA NE
❑ ❑ ❑ ■
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 01/31/2014 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
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)
❑ ❑
0 ❑
C.
pH records for alkaline stabilization (Class B)
❑ ❑
0 ❑
Temperature corrected
❑
d.
Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑ 000
e.
Time/Temp on:
❑ 000
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f.
Volatile Solids Calculations
❑
❑ ❑
g.
Bench -top Aerobic/Anaerobic digestion results
❑ ❑
M ❑
Comment:
Treatment
Check all that apply
Aerobic Digestion ,
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment: Belt -press
Yes No
NA
NE
■
■
Page: 4

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell Hwy 221 n
Region: Asheville 65 Pitts Sta Rd
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. WWTP is located on the right just past the intersection of Pitts
Station Rd. and Hwy. 221.
System Classifications:
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s): ZQc-V_ Ve-Y
On -Site Representative(s):
24 hour contact name
On -site representative
Related Permits:
Inspection Date: 1 O.3I 114f
Primary Inspector: Beverly Price
Secondary Inspector(s):
J '�
Amanda Richcreek Phone: [phone]
Amanda Richcreek 5� vex i �p Phone: [phone]
Entry Time: t.3Q Exit Time: 10 30
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions 0 Record Keeping Treatment ■ Pathogen and Vector
Attraction
(See attachment summary) % !
7 -'3k [+ - Pr -e- ss -- p p ( l�y'l Ea nrt
L J VIP Y I V.v10 W or (c .on
/'J
Page: 1

Permit: WO0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0031725 Owner - Facility:; Baxter Health Care Corporation
Inspection Date: Inspection Type: Compliance Evaluation
Record Keeping
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? !VJ,W re- te-u-, aM3 A �L
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)? Liji ik ir�.V a Q-(,U
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? :aoo lkR
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary? �t{7l3 A.
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?
Comment:
Pathogen and Vector Attraction
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)
Reason for Visit: Routine
Yes No NA NE
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: Inspection Type: Compliance Evaluation
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
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Reason for Visit: Routine
Yes No NA NE
n
Comment: A - j,
�1b U saVv-i��� �i off 2G�t�hU �(yi� �✓t3w. Cia,i T'iev_ Z �irc►� d J��i'!�
( ✓� s1 4'~� ;,e—c r-k s4G tv `L6so144c V lac
Page: 4

October 17, 2013 —RE C- l V E D Baxter
Ms. Beverly Price
Environmental Specialist
NCDENR Division of Water Resources
Water Quality Program
2090 U.S. Highway 70,
Swannanoa, NC 28778
OCT 2 2 2013
DWQ/Surface Water Protection Section
Asheville Regional Office
RE: 2012 Annual Land Application Report — Notice of Deficiency
NOD-2013-PC-0375
Permit No. WQ0031725
Baxter Healthcare Corporation
McDowell County
Ms. Price,
This letter is in response to the Notice of Deficiency Baxter Healthcare received on September 23, 2013 in regards
to the fecal coliform bacteria results in the 2012 Land Application of Residual Solids annual report. Baxter
Healthcare has taken the following immediate corrective actions to ensure the quality of the 2013 Land
Application data.
• Contact the Land Application Contractor and request an immediate review of the 2013 samples to ensure
all data collected has been reported in absolute values.
• Requested the Land Application Contractor contact the analytical lab, in writing, to require all samples be
diluted to be reported in absolute values.
Baxter Healthcare has taken the following actions to prevent this from reoccurring:
• Baxter Healthcare has requested in writing the following from the Land Application Contractor:
o The vendor must contact the analytical lab(s) in writing and notify them that all samples must be
diluted to be reported in absolute values. Baxter Healthcare shall be copied on this
_correspondence.
o Prior to collecting samples at the North Cove Waste Water Treatment Plant, the Land Application
Contractor must submit a sampling plan, including sampling locations, number of samples to be
collected, dates of samples and copies of the chain of custody form indicating the sampling
methods. The Waste Water Treatment Plant Certified Operator or the Facility's Environmental
Engineer must approve this plan prior to sampling.
o The Land Application Contractor is to supply Baxter Healthcare with the analytical results of the
land application sampling within 45 days of the sampling.
o The Land Application Contractor is required to give a summary in the annual report of all
sampling locations and their corresponding sampling ID's
Please contact Amanda Richcreek, Environmental Engineer, if you have any questions on the corrective and
preventative actions taken by Baxter Healthcare.
Sincerely,
Andrea Darsey
Plant Manager
Baxter Healthcare Corporation
PO Box 1390, Marion, NC 28752
T 828.756.4151

1
CDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
September 23, 2013
Andrea Darsey, Plant Manager
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
Subject: Notice of Deficiency
NOD-2013-PC-0375
Permit No.WQ0031725
Land Application of Residual Solids
McDowell County
Dear Ms. Darsey,
On August 23, 2013, staff of the NC Division of Water Resources (DWR), Water Quality Section, inspected the
subject Land Application of Residual Solids System. We wish to thank Ms. Amanda Richcreek and Mr. Stephen
Taylor who were present and assisted during the inspection. The purpose of the visit was to conduct the annual
compliance inspection.
The following item was determined to be deficient at the time of the inspection. The inspection included a review of
the 2012 Annual Report (AR). Also please refer to the attached inspection report for additional comments:
The fecal coliform bacteria results (Pathogen Reduction) given in the 2012 AR did not clearly demonstrate
compliance with pathogen reduction as required in 15A NCAC 02T .1106 (c).
You are required to take corrective measures regarding the item above on or before October 23, 2013. Please send a
letter to our office describing the corrective measures that will be implemented to insure future compliance.
Failure to comply with the State's rules may result in the assessment of civil penalties and/or the use of other
enforcement mechanisms available to the State. If you have any questions concerning this inspection or the
necessary corrective measures, you may contact me via email at [e-mail] or at [phone].
Sincerely,
Beverly Price
Environmental Specialist
Attachment
cc: Amanda Richcreek, Environmental Engineer w/Attachment
Aquifer Protection Section Central Files
tiWLQ�ARO�Files�
WATER QUALITY SECTION
North Carolina Division of Water Resources — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone [phone]
FAX [phone]
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 . Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell Hwy 221n
Region: Asheville 65 Pitts Sta Rd
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. WWTP is located on the right just past the intersection of Pitts
Station Rd. and H 221.
System Classifica ions: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
Related Permits:
Inspection Date: 08/23/2013
Primary Inspector: Beverly Price
Secondary Inspector(s):
Amanda Richcreek
Ricky Styles
Amanda Richcreek
Entry Time: 01:00 PM Exit Time: 01:30 PM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503) .
Facility Status: D Compliant ® Not Compliant
Question Areas:
Miscellaneous Questions N Record Keeping Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection included a review of the 2012 Annual Report (AR) and tour of the WWTP.
2012 AR Issues:
1. Four of the seven fecal coliform results showed "greater than" values so compliance could not be verified.
2. Please insure that all data is legible on the Field Summary Forms (FSF's). Application dates were not legible on several
of the FSF's.
3. Please indicate where the samples are collected for the percent volatile solids calculation.
A Notice of Deficiency will be issued for failure to verify pathogen reduction.
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Yes
No
NA
NE
Distribution and Marketing
❑
Land Application
19
Record Keeping
Yes
No
NA
NE
Is GW monitoring being conducted, if required?
❑
❑
a
❑
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?
®
❑
Cl
❑
Are current metals and nutrient analysis available?
W
❑
❑
❑
Are nutrient and metal loading calculating most limiting parameters?
®❑
❑
❑
a. TCLP analysis?
®❑
❑
❑
b. SSFA (Standard Soil Fertility Analysis)?
®❑
❑
Cl
Are PAN balances being maintained?
❑
❑
❑
Are PAN balances within permit limits?
❑
❑
❑
Has land application equipment been calibrated?
❑
❑
❑
mg
Are there pH records for alkaline stabilization?
❑
❑
K
❑
Are there pH records for the land application site?
W
0
❑
❑
Are nutrient/crop removal practices in place?
- ❑
❑
❑
Im
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?
❑
❑
W
❑
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)
❑
❑
®
❑
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation
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)
e. Time/Temp on:
Digester (MCRT)
Compost
Reason for Visit: Routine
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench -top Aerobic/Anaerobic digestion results
Comment: Four of the fecal coliform samples had "greater than" value, so compliance
could not be verified.
nnimn
0❑®n
n
00110
n n n
n
n
n
Eg n n n
nngn
Page: 4

I goMCDEVAR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
September 20, 2013
Andrea Darsey, Plant Manager
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
SUBJECT: August 23, 2013
Compliance Evaluation Inspection
Baxter Healthcare Corporation
North Cove Steam Generation Plant
Wastewater Recycle System
Permit No: WQ0OO1512
Ash Distribution Program
WQO01O689
McDowell County
Dear Ms. Darsey:
Enclosed please find a copy of the Compliance Evaluation Inspection Forms from the
inspections conducted on August 23, 2013. The facility was found to be in Compliance with
permits WQ0001512 & WQ0010689.
Please refer to the enclosed inspection reports for additional observations and
comments. The assistance of Ms. Amanda Richcreek and Mr. Ricky Styles was greatly
appreciated during the inspection. If you or your staff have any questions, please call me at
[phone].
Sincerely,
Beverly Pric
Environmental Specialist
Enclosures
cc: Amanda Richcreek, Environmental Engineer
APS Central Files
A—s : vt le �11' Wl._
WATER QUALITY SECTION
North Carolina Division of Water Resources —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone [phone]
FAX [phone]
Internet; h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0001512 Effective: 04/30/10 Expiration: 01/31/17 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
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.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
Related Permits:
Inspection Date: 08/23/2013
Primary Inspector: Beverly Price
Secondary Inspector(s):
Amanda Richcreek
Amanda Richcreek
Ricky Styles
Entry Time: 01:30 PM
Reason for Inspection: Routine
Permit Inspection Type: Closed -Loop Recycle
Facility Status: ON Compliant Q Not Compliant
Question Areas:
Miscellaneous Questions U Treatment
(See attachment summary)
Exit Time: 02:00 PM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Inspection Type: Compliance Evaluation
Record Keeping
Page: 1

Permit: WQ0001512 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Exceeded freeboard in June/July due to excessive precipitation; ARO was notified. Freeboard was ok on the day of the
inspection.
Facility appears to be well maintained.
Page: 2

Permit: WO0001512 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes No
NA
NE
Infiltration System
n
Reuse (Quality)
n
Lagoon Spray, LR
n
Single Family Spray, LR
n
Activated Sludge Spray, HR
Activated Sludge Drip, LR
Cl
Activated Sludge Spray, LR
n
Single Family Drip
n
Recycle/Reuse
59
Treatment
Yes No
NA
NE
Are Treatment facilities consistent with those outlined in the current permit?
® n
n
n
D II t t t 'ts a ear to be o erational? (if no note below)
n
n
n
o a rea men uni
Comment:
Record Keeping
Yes
No
NA
NE
Is a copy of current permit available?
M
n
n
n
Are monitoring reports present: NDMR?
n
n
IM
n
NDAR?
❑n®n
Are flow rates less than of permitted flow?
®
n
n
n
Are flow rates less than of permitted flow?
®n
n
n
Are application rates adhered to?
®
n
n
Is GW monitoring being conducted, if required (GW-59s submitted)?
n
Cl
®
n
Are all samples analyzed for all required parameters?
❑
n
®
n
Are there any 2L GW quality violations?
n
n
®
n
Is GW-59A certification form completed for facility?
n
n
❑
Is effluent sampled for same parameters as GW?
n
n
n
Do effluent concentrations exceed GW standards?
Cl
n
®
n
Are annual soil reports available?
n
n
®
n
# Are PAN records required?
❑
n
®
n
# Did last soil report indicate a need for lime?
n
n
M
n
Page: 3

Permit: WQ0001512 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
If so, has it been applied?
n
n
W
n
Are operational logs present?
R
n
n
❑
Are lab sheets available for review?
n
n
❑
Do lab sheets support data reported on NDMR?
n
n
®
n
Do lab sheets support data reported on GW-59s?
n
n
W
n
Are Operational and Maintenance records present?
W
n
n
n
Were Operational and Maintenance records complete?
®
n
n
n
Has permittee been free of public complaints in last 12 months?
®
n
n
n
Is a copy of the SOC readily available?
n
n
n
No treatment units bypassed since last inspection?
®
n
n
n
Comment:
Page: 4

Compliance Inspection Report
Permit: WQ0010689 Effective: 06/07/10 Expiration:-11/30/14 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
Related Permits:
Inspection Date: 08/2312013
Primary Inspector: Beverly Price
Secondary Inspector(s):
Amanda Richcreek
Amanda Richcreek
Ricky Styles
Entry Time: 02:00 PM Exit Time: 02:45 PM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: 9 Compliant ❑ Not Compliant
Question Areas:
IM Miscellaneous Questions 0 Record Keeping Treatment Sampling
(See attachment summary)
Page: 1

Permit: WQ0010689 Owner -Facility: Baxter Healthcare Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
TCLP done in 2011. Due once per permit cycle.
927.63 DT were distributed in 2012.
Samples should be collected based upon distribution totals and should correspond to the frequency/timing listed in
Attachment A.
The facility appears to operating asccording to permit conditions.
Page: 2

Permit: WO0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
'type Yes No NA NE
Land Application ❑
Distribution and Marketing
5A
Record Keeping
Yes
No
NA
NE
Is GW monitoring being conducted, if required?
❑
n
I3
❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑
®
❑
Are there any GW quality violations?
❑
❑
10
❑
Is GW-59A certification form completed for facility?
n
❑
®
n'
Is a copy of current permit on -site?
®❑
n
❑
Are current metals and nutrient analysis available?
®❑
❑
Cl
Are nutrient and metal loading calculating most limiting parameters?
®❑
❑
❑
a. TCLP analysis?
❑
❑
BE
❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑
®
❑
Are PAN balances being maintained?
❑
❑
®
❑
Are PAN balances within permit limits?
❑
❑
IN
❑
Has land application equipment been calibrated?
❑
❑
E
n
Are there pH records for alkaline stabilization?
❑
n
®
Cl
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?
9
0
❑
n
Are hauling records available?
®❑
n
❑
Are hauling records maintained and up-to-date?
®❑
Cl
❑
# Has permittee been free of public complaints in last 12 months?
®❑
❑
❑
Has application occurred during Seasonal Restriction window?
Cl
❑
®
❑
Comment:
Trpatnnent
Yes No
NA
NE
Check all that apply
Aerobic Digestion ❑
Anaerobic Digestion ❑
Alkaline Pasteurization (Class A) ❑
Page: 3

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Alkaline Stabilization (Class B)
Q
Compost
❑
Drying Beds
❑
Other
IN
Comment: Settling ponds
Sampling Yes No NA NE
Describe sampling:
When one side is taken out of production, the product is mixed w/bottom ash or dry wood and allowed to
dry. Several samples are collected from the dry pile and composited for anaylsis.
Is sampling adequate?
Is sampling representative?
Comment:
®nnn
Mnpn
Page: 4

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell L Hwy 221n
65
Region: Asheville plea jpq �`�"'Marionitts Sta Rd
9/1
Q1 NC 8752 ZS3 0)
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. WWTP is located on the right just past the intersection of Pitts
Station Rd. and hi 221.
System Classifica ions: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/23/2013 Entry Time: 01:00 PM Exit Time: 01:30 PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine I Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: OLCompliant Not Compliant
Question Areas:
Miscellaneous Questions N Record Keeping ■ Pathogen and Vector
Attraction
[V®D
(See attachment summary) .
4 � 20(2— /
fecS
lD j'�^ �'� Q,✓l c -L
37�
1/4.l V 2� S o C4 ^
in��co4%Cote��t {dI 5- ✓�K h1°lo '`
S SMIA-�2 Page:
sVo);4S C_4
o,
�

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

FFFr'
Permit: WQ0031725 Owner •Facility: Baxter Health Care Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Record Keeping Yes No N,yA, 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? ❑ ❑ go ❑
Is GW-59A certification form completed for facility? ❑ ❑ ❑
Is a copy of current permit on -site? ❑ ❑ ❑
Are current metals and nutrient analysis available? So (I- -A iz ❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters? n In ❑
a. TCLP analysis? ©❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)? F3 ❑ ❑ ❑
Are PAN balances being maintained? 0 n ❑ ❑
Are PAN balances within permit limits? It ❑ ❑ ❑
Has land application equipment been calibrated? ❑ n ❑-I Wj
Are there pH records for alkaline stabilization? ❑ ❑ ❑
Are there pH records for the land application site? j1 ❑ n f_1
Are nutrient/crop removal practices in place? ❑ ❑ ❑ V
Do lab sheets support data reported on Residual Analysis Summary? ❑ ❑ ❑
Are hauling records available? Cl n ❑
Are hauling records maintained and up-to-date? n ❑ Cl
# Has permittee been free of public complaints in last 12 months? do ❑ ❑ ❑
Has application occurred during Seasonal Restriction window? ❑ ❑ T ❑
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
rook^ _� V�'f-t L� F7tGakS-� *0,,- 0000
Fecal coliform SM 9222 D (Class B only) vkkut-c.S Vs. PAq Yti a�Lr ' k4A v,&-s L 5
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

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation
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
Comment:
Reason for Visit: Routine
n
nn n
nnin
n
n
n
nnin
❑ ❑
Page: 4

WDERR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Acting Director Secretary
June 18, 2013
Amanda Richcreek, Environmental Engineer
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
Subject: 2012 Annual Residuals Reports
Distribution of Residual Solids
Permit No.WQ0010689
Land Application of Residual Solids
Permit No.WQ0031725
Dear Ms. Richcreek:
The Asheville Regional Office has received a copy of your 2012 Annual Reports. We
have completed a preliminary review of the Reports. You will be notified if additional
information is needed or in the event any deficiencies are noted.
Thank -you for your submittal.
Sincerely,
' /V
Beverly Price
Environmental Specialist
AQUIFER PROTECTION SECTION
North Carolina Division of Water Quality — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone [phone]
FAX [phone]
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer

1
A 4 7Q
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
December 21, 2012
Amanda Richcreek
Environmental Engineer
Baxter Health Care Corporation
65 Pitts Station Road
Marion, NC 28752
SUBJECT: December 12, 2012
Compliance Evaluation Inspection
Baxter Health Care Corporation
Land Applicatin of Residual Solids
Permit No: W00031725
McDowell County
Dear Ms. Richcreek:
Enclosed please find a copy of the Compliance Evaluation Inspection Form from the
inspection conducted on December 12, 2012. The facility was found to be in compliance with
permit WQ0031725.
Please refer to the enclosed inspection report (inspection Summary Page 2) for
additional observations and comments. Your assistance and that of Mr. Zack Key was greatly
appreciated during the inspection. If you or your staff have any questions, please call me at
[phone].
Sincerely,
Price
Beverly
Environmental Specialist
Enclosure
cc: Dennis Key, ORC SSB
APS Central Files
APS Asheville Files
AQUIFER PROTECTION SECTION — Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] \ FAX: [phone]
Internet: www.ncwaterguality.org
An Equal Opportunity \ Affirmative Action Employer
One
NorthCarohna
AMWAY

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16
SOC: Effective: Expiration:
County: McDowell
Region: Asheville
Contact Person: Amanda Richcreek
Owner: Baxter Health Care Corporation
Facility: North Cove Steam Generation Plant
Hwy 221 n
65 Pitts Sta Rd
Marion NC 28752
Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. VWVTP is located on the right just past the intersection of Pitts
Station Rd. and Hw 221.
System Classifica ions: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
Zach D Key Certification: 27660 Phone: [phone]
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
Related Permits:
Inspection Date: 12/12/2012
Primary Inspector: Beverly Price
Secondary Inspector(s):
Zach D Key
Amanda Richcreek
Zach D Key
EntryTime: 10:00 AM Exit Time: 03:00 PM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Sampling
■ Pathogen and Vector ■ Transport
Attraction
(See attachment summary)
0 Land Application Site
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/12/2012 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
Land application was occurring on Douglas Poplin Field DP-3. This inspection was a follow-up to the 2011 Annual Report
reivew conducted in June 2012.
Fecal coliform samples should be collected over a two week period.
Please show the volatile solids calculations and include the volatile solids benchsheets in future annual reports.
Page: 2

Permit: WO0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/12/2012 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
■
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ E ❑
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?
■ ❑ Q ❑
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?
❑ ❑ ■ ❑
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) ❑ ❑ ■ ❑
Page: 3

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uoi;ejodloo aje0 Q8GH Ja;xeg :4113ed - Jaum0 SZLI£OODM 41wJ8d

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/12/2012 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Are limiting slopes buffered?
10% for surface application
❑ ❑ ■
❑
18% for subsurface application
❑
❑ ■
❑
Are there access restrictions and/or signs?
❑
■ ❑
❑
Is the application site free of odors or vectors?
■
❑ ❑
❑
Have performance requirements for application method been met?
For injection?
❑
❑ ■
❑
For incorporation?
❑
❑ ■
❑
Does permit require monitoring wells?
❑
■ ❑
❑
Have required MWs been installed?
❑
❑ ■
❑
Are MWs properly located w/ respect to RB and CB?
❑
❑ ■
❑
Are MWs properly constructed (including screened interval)?
❑
❑ ■
❑
Is the surrounding area served by public water?
■
❑ ❑
❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
■
❑ ❑
❑
Are soil types consistent w/ Soil Scientist reportlevaluation?
■
❑ ❑
❑
Is the water table greater than 173' bls.
❑
❑ ❑
■
Is application occurring at the time of the inspection?
■
❑ ❑
❑
Comment: Signs will be placed on site next week.
The permit does not require monitoring wells.
Page: 5

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell Hwy 221 n
Region: Asheville 65 Pitts Sta Rd
Marion NC 28752
Contact Person: Anita Jensen Title: EHS Manager Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. WWTP is located on the right just past the intersection of Pitts
tation Rd. and H 221.
ystem Classifications:
Primary ORC: Zach D Key Certification: 27660 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Zach D Key Phone: [phone]
On -site representative Zach D Key Phone: [phone]
Related Permits:
Inspection Date: 1211 Zl Entry Time: Exit Time:
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Sampling Land Application Site
■ Pathogen and Vector ■ Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: Inspection Type: Compliance Evaluation
Inspection Summary:
Reason for Visit: Routine
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ 1 0 ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ 1* ❑
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?
Y ❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
f6 ❑ ❑ ❑
a. TCLP analysis? P2v d 2.u'.A a-o �( 2
'6 ❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑ ❑ ❑
Are PAN balances being maintained?
❑ ❑ ❑
Are PAN balances within permit limits?
❑ ❑ ❑
Has land application equipment been calibrated?�
❑ ❑ ❑
�aCut ro� y�C 6�
❑ ❑ ❑
p
Are there pH records for alkaline stabilization?
II
Are there pH records for the land application site?
❑ ❑
Are nutrient/crop removal practices in place?
y ❑ ❑ ❑
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?
❑ 'j ❑ ❑
Comment:
Pathogen and Vector Attraction
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)
V ❑ ❑ ❑
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: Inspection Type: Compliance Evaluation Reason for Visit: Routine
Temperature corrected n
d. Salmonella (Class A, all test must be < 3MPN/4 gram day) n n n n
e. Time/Temp on: n n n n
Digester (MCRT) n
Compost n
Class A lime stabilization n
f. Volatile Solids Calculations o„ n n
g. Bench -top Aerobic/Anaerobic digestion results n n n
Comment:
Sampling Yen Mn NA NE
Describe sampling: 'C./va✓JS�, G"�'��'L'T
a
Is sampling adequate? i'jQ, ,( 5 ���{- c� ��,`� �,•� G v A^ w(C-
Is sampling representative? hA
Comment:
Transport Ye
Is a copy of the permit in the transport vehicle?
Is a copy of the spill control plan in the vehicle?
Is the spill control plan satisfactory?
Does transport vehicle appear to be maintained?
Comment:
Land Application Site Ye
hC1C)❑
nnn
[,Y'Qnn
R'nnn
..
iyinnn
nnn
Is a copy of the permit on -site during application events? 10 n n n
Is the application site in overall good condition? M_I n n n
Is the site free of runoff/ponding? 19 n n n
If present, is the application equipment in good operating condition? �f n n n
Are buffers being maintained? Of n n n
Are limiting slopes buffered?
10% for surface application W A q61 t 5 t _" n❑ n
18% for subsurface application n n n
Are there access restrictions and/or signs? �1O�1 �'-
EGG•: } ��� I� �r�P_ s win n Q
IL
JS
Page: 4

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
❑❑❑
For injection?
❑ ❑
❑
For incorporation?
❑ ❑
❑
Does permit require monitoring wells?
❑ 0
❑
❑
Have required MWs been installed?
❑ ❑
❑
Are MWs properly located w/ respect to RB and CB?
❑ ❑
t
❑
Are MWs properly constructed (including screened interval)?
❑t ❑
❑
ac (4,tC) is a va' (e..� t ct,
Is the surrounding area served by public water?
f3
❑
❑
�LC
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? S C� WTI I
❑
❑
❑
Are soil types consistent w/ Soil Scientist report/evaluation?
❑
❑
❑
Is the water table greater than 173' bls.
❑ ❑
❑
EY
Is application occurring at the time of the inspection?
} ❑
❑
❑
Comment:
Page: 5

v�(I f
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
June 14, 2012
Amanda Richcreek, EHS Manager
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
SUBJECT: REQUEST FOR ADDITIONAL INFORMATION
2011 Annual Report Compliance Review
Baxter Healthcare Corporation
Land Application of Residual Solids
Permit No: W00031725
McDowell County
Dear Ms. Richcreek:
On June 11, 2012, 1 conducted a review of the 2011 Annual Report for the subject permit. The following information
was not included:
The method chosen to verify Vector Attraction Reduction is Option#1-Reduction in Volatile Solids. The
laboratory data submitted included four results for percent volatile solids. Please indicate the location of
the sampling points that were chosen for percent volatile solids calculations.
Within 15 days of receipt of this letter, please submit the information referenced above to:
NCDENR - DWQ
Aquifer Protection Section
2090 U.S. Highway 70
Swannanoa, NC 28778-8211
Attn: Beverly Price
If you or your staff have any questions, please call me at 828/296-4685.
Sincerely,
/, zt'� P'L"�
Beverly Price
Environmental Specialist
cc: Michael Finnamore, EHS
�--ASP-S ARR_1Z afies
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX : [phone] One
Customer Service:1-877-623-6748 NorthCarolina
Internet: wwwmwaterguality.mg
An Equal Opportunity 1 Affirmative Action Employer NaturallY

AV
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
December 30, 2011
Anita Jensen, EHS Manager
Baxter Health Care Corporation
65 Pitts Station Road
Marion, NC 28752
Dee Freeman
Secretary
SUBJECT: December 16, 2011
Compliance Evaluation Inspection (Land
Application Site Inspection)
Baxter Health Care Corporation
Land Application of Residual Solids
Permit No: WQ0031725
McDowell County
Dear Ms. Jensen:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the
inspection that I conducted on December 16, 2011. The facility was found to be in Compliance
with permit WQ0031725.
The assistance of Mr. Stephen Taylor and Mr. Zack Key was greatly appreciated. Please
refer to the enclosed inspection report for additional observations and comments. If you or your
staff has any questions, please call me at [phone].
Sincerely, � \
Beverlytce
Environmental Specialist
Enclosure
cc: Dennis Key, ORC SSB
APS Central Files
APStAsheville-FilesI
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX: [phone]
Customer Service:1-877-623-6748
Internet: www.ncwaterquality.orq
An Equal Opportunity 1 Affirmative Action Employer
NorthCarohna
Aatura!!Y

Compliance Inspection Report
Permit: WQ0031725
Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Health Care Corporation
SOC:
Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell
Hwy 221 n
Region: Asheville
65 Pitts Sta Rd
Marion NC 28752
Contact Person: Anita Jensen Title: EHS Manager Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion
for approximately 7 miles to Baxter. WWTP is located on the right just past the intersection of Pitts
Station Rd. and Hw 221.
Classifica ions:
LA,
ystem
Primary ORC: Dennis Key
Certification: 15704 Phone: [phone]
Secondary ORC(s):
Zach D Key
Certification: 27660 Phone: [phone]
On -Site Representative(s):
24 hour contact name
Zach D Key Phone: [phone]
On -site representative
Zach D Key Phone: [phone]
On -site representative
Stephen D Taylor Phone:
On -site representative
Dennis Key Phone: [phone]
Related Permits:
Inspection Date: 12/16/2011 Entry Time: 09:00 AM Exit Time: 12:30 PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site Pathogen and Vector ■ Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Land application occurred on 12/14/11 on Douglas Poplin Field# DP5.
Buffers were flagged, no sign of run-off, field is fenced.
Record Keeping Questions checked NE (Not Evaluated) will be evaluated with the 2011 Annual Report Review.
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: 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?
❑ ❑
■ ❑
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)
■ ❑
❑ ❑
Page: 3-

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/16/2011 Inspection Type: Compliance Evaluation Reason for Visit:
Routine
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
n
b. pH records for alkaline stabilization (Class A)
n
n
■
n
c. pH records for alkaline stabilization (Class B)
n
n
■
n
Temperature corrected
n
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
n
n
■
n
e. Time/Temp on:
❑
❑
■
n
Digester (MCRT)
n
Compost
n
Class A lime stabilization
n
f. Volatile Solids Calculations
■
n
n
g. Bench -top Aerobic/Anaerobic digestion results
n
n
■
n
Comment:
Treatment
Yes No
NA
NE
Check all that apply
Aerobic Digestion
■
Anaerobic Digestion
n
Alkaline Pasteurization (Class A)
n
Alkaline Stabilization (Class B)
n
Compost
n
Drying Beds
n
Other
n
Comment:
Sampling
Yes No
NA
NE
Describe sampling:
Several grab samples are collected from the thickener for TCLP and fecal analysis. Nutrient and metals
samples are collected from the truck after passing through the belt -press.
Is sampling adequate? ■ n n n
Is sampling representative? ■ n n n
Comment:
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? ■ n n n
Page: 4

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is a copy of the spill control plan in the vehicle? ■ Cl ❑ ❑
Is the spill control plan satisfactory? ■ ❑ ❑ ❑
Does transport vehicle appear to be maintained? ■ ❑ ❑ ❑
Comment:
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? ■ ❑ ❑ ❑
Is the application site in overall good condition? ■ ❑ ❑ ❑
Is the site free of runoff/ponding? ■ ❑ ❑ ❑
If present, is the application equipment in good operating condition? ■ ❑ ❑ ❑
Are buffers being maintained? ■ ❑ ❑ ❑
Are limiting slopes buffered?
10% for surface application ■ ❑ ❑ ❑
18% for subsurface application ❑ ❑ ■ ❑
Are there access restrictions and/or signs? ■ ❑ ❑ ❑
Is the application site free of odors or vectors? ■ ❑ ❑ ❑
Have performance requirements for application method been met?
For injection?
❑ ❑ ■ ❑
For incorporation?
❑ ❑ ■ ❑
Does permit require monitoring wells?
❑ ■ ❑ ❑
Have required MWs been installed?
OOM ❑
Are MWs properly located w/ respect to RB and CB?
❑ ❑ ■ ❑
Are MWs properly constructed (including screened interval)?
❑ ❑ ■ ❑
Is the surrounding area served by public water?
❑ ■ ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
■ ❑ ❑ ❑
Are soil types consistent w/ Soil Scientist report/evaluation?
■ ❑ ❑ ❑
Is the water table greater than 173' bls.
❑ ❑ ❑ ■
Is application occurring at the time of the inspection?
❑ ■ ❑ ❑
Comment: Monitoring wells are not required.
Surrounding area not served by public water.
Page: 5

Y6 7-
Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell Hwy 221 n
Region: Asheville 65 Pitts Sta Rd
Marion NC 28752
Contact Person: Anita Jensen Title: EHS Manager Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. WWTP is located on the right just past the intersection of Pitts
Station Rd. and Fi 221.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
Related Permits:
Inspection Date: 12/16/2011
Primary Inspector: Beverly Price
Secondary Inspector(s):
Zach D Key
Entry Time: 09:00 AM Exit Time: 12:30 PM
Phone: [phone]
-t8 Z/
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: IV
Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site ■ Pathogen and Vector ■ Transport
Attraction bU l,60-
r"
(See attachment summary)
�jLi%�-, ply 5,�� s - #- ( �.:o.,.._ clQ��,�.�_ f f o �Ce�rj�sf� �,� �.z,��-�_�� ►J
d,,�esfOL- 61��
Fec.bls C6aedt�4.
L( « P r e,55 J

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

/ Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/16/2011 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Record Keeping
Yes No
NA NE
Is GW monitoring being conducted, if required?
❑
❑
W ❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑
Q ❑
Are there any GW quality violations?
❑
❑
Pi ❑
Is GW-59A certification form completed for facility?
❑
❑
❑
Is a copy of current permit on -site?
❑
Cl ❑
Are current metals and nutrient analysis available?
❑
❑ ❑
,h�;
❑
❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
a. TCLPanalysis? wail rLv�_�.w o(( �(�
❑
❑
❑
b. SSFA (Standard Soil Fertility Analysis)? V, ,,11 if CV,,_li" 'D,U4( AAA.
❑
❑
❑
Are PAN balances being maintained?
Q
❑
❑ ❑y
Are PAN balances within permit limits?�',[l irz-v' ,4A1 �1i1
❑
❑
❑� + �
Has land application equipment been calibrated?
❑
❑
r
Are there pH records for alkaline stabilization?
❑
❑
� ❑
Are there pH records for the land application site? IN 4t Ve-0161J 17LO1) ML
❑
❑
❑
Are nutrient/crop removal practices in place? +15 JS-OrZl2�
p
❑
❑ ❑
Do lab sheets support data reported on Residual Analysis Summary? rtv"-e-L I'
4$2— ❑
❑
❑
Are hauling records available?
rX
❑
❑ ❑
Are hauling records maintained and up-to-date?
1
❑
❑ ❑
# Has permittee been free of public complaints in last 12 months?
kn
❑
a ❑
Has application occurred during Seasonal Restriction window?
❑
❑
Imo1 ❑
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)
❑
❑
W ❑
Geometric mean of 7 samples per monitoring period for class 13<2.0*10E6 CFU/dry gram
❑
b. pH records for alkaline stabilization (Class A)
❑
❑
❑
c. pH records for alkaline stabilization (Class B)
11000
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Temperature corrected El
d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑
e. Time/Temp on: 0 ❑� Q
Digester (MCRT) El
Compost v 1G`'
Class A lime stabilization /if 0
f. Volatile Solids Calculations �G 0 Q 0
V"A
g. Bench -top Aerobic/Anaerobic digestion results Q
Comment: p �, ; c _1�
Trnn4mnn4 J=` Yes No NA NE
Check all that apply
Aerobic Digestion
JW
Anaerobic Digestion
n
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
❑
Compost
0
Drying Beds
171
Other
El
Comment:
Sampling
Yes No
NA
NE
Describe sampling:
Is sampling adequate?
t 0
Q
0
Is sampling representative?
❑
❑
C)
Comment:
Transport
Yes No
NA
NE
Is a copy of the permit in the transport vehicle?
C)
0
Is a copy of the spill control plan in the vehicle?
n
0
n
r
Is the spill control plan satisfactory?
0 ❑
❑
❑
Does transport vehicle appear to be maintained?
Q
Q
Comment:
Page: 4

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/16/2011 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Land Application Site
Yes No
NA
NE
Is a copy of the permit on -site during application events?
lad ❑
❑
❑
Is the application site in overall good condition?
❑
❑
❑
Is the site free of runoff/ponding?
tu' ❑
❑
❑
If present, is the application equipment in good operating condition?
❑
❑
❑
Are buffers being maintained?
❑
❑
❑
Are limiting slopes buffered?
10% for surface application
r0
❑
❑
❑
18% for subsurface application
Q
❑
0
❑
Are there access restrictions and/or signs? .{-,_
❑
❑
❑
Is the application site free of odors or vectors?
❑
❑
❑
Have performance requirements for application method been met?
For injection?
❑
❑
❑
For incorporation?
❑
❑
❑
Does permit require monitoring wells?
❑
�
❑
❑
Have required MWs been installed?
❑
❑
❑
Are MWs properly located w/ respect to RB and CB?
❑
❑
r�
❑
Are MWs properly constructed (including screened interval)?
❑
❑
ro
❑
Is the surrounding area served by public water?
❑
V,
❑
❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑
❑
Are soil types consistent w/ Soil Scientist report/evaluation?
!
❑
❑
❑
Is the water table greater than 173' bls.
❑
❑
❑
Is application occurring at the time of the inspection? �y,f; u. � © cc.vrr¢ �,
!i
01000
Comment:
Page: 5

--••I''� � � � 71 t1 f
r r��
WDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
December 6, 2011
CERTIFIED MAIL 70091680 0000 7515 2694
RETURN RECEIPT REQUESTED
RECEIPT #
Anita Jensen, EHS Manager
Baxter Health Care Corporation
Post Office Box 1390
Marion, NC 28752
Subject: Notice of Violation
NOV-2011-PC-0620
Permit No. WQ0031725
McDowellCounty
Dear Ms. Jensen,
On September 30, 2011, staff of the NC Division of Water Quality (DWQ), Aquifer Protection Section
(APS), conducted a review of.the 2010 Annual Report.
The following item specifies the permit condition that was in violation during the time of the inspection.
(Also please refer to the attached inspection report):
MONITORING AND REPORTING REQU EREMENTS
Condition IV. 5., requires that a representative soils analysis (i.e., Standard, Soil Fertility
Analysis) shall be conducted on each land application site on which a residuals land application
event in the respective calendar year has occurred or is to occur, and the results shall be
maintained on file by the Permittee for a minimum of five (5) years. The Standard Soil Fertility
Analysis shall include, but is not necessarily limited to, the following parameters:
Acidity
Exchangeable Sodium Percentage (by calculation)
Calcium
Magnesium
Phosphorous
Cation Exchange Capacity
Manganese
Potassium
Copper
Percent Humic Matter
Sodium
Base Saturation ( by calculation)
pH
Zinc
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] \ FAX: [phone]
One
Customer Service:1-877-623-6748
NorthCarolina
Internet: www.ncwatercluality.org
Aaftmall
An Equal Opportunity \ Affirmative Action Employer
/��/

Ms. Jensen
Permit No WQ0031725
December 6, 2011
Page 2 of 2
As of the DWQ review on September 30, 2011, the soils analysis had been conducted, however
the following parameters were not analyzed: Copper, Zinc and Manganese.
Southern Soil Builders has already provided a written explanation and corrective action to the
above subject violation so no additional response is necessary. However, should you have
additional information or comments which you wish to present concerning the violation, please
submit them to the attention of Beverly Price.
Failure to comply with conditions in a permit may result in a recommendation of enforcement action, to
the Director of the Division of Water Quality who may issue a civil penalty assessment of not more that
twenty-five thousand ($25,000) dollars against any "person" who violates or fails to act in accordance
with the terms, conditions, or requirements of a permit under authority of G.S. 143-215.6A. Please note
that each day a violation continues may be considered a separate violation, subject to additional civil
penalties.
If you have any questions concerning this Notice, please contact Beverly Price at 828-296-4685 or me at
828-296-4500 Ext.4680.
Sincerely,
G. Landon Davidson, L.G.
Environmental Program Supervisor
attachment:
cc: Dennis Key, ORC SSB
. McDowell County Environmental Health Department
-A`RO!A S` les
Aquifer Protection Section Central Files

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell Hwy 221 n
Region: Asheville 65 Pitts Sta Rd
Marion NC 28752
Contact Person: Anita Jensen Title: EHS Manager Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. WWTP is located on the right just past the intersection of Pitts
Station Rd. and Hw 221.
ystem Classifica ions: LA,
Primary ORC; Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
Zach D Key Certification: 27660 Phone: [phone]
On -Site Representative(s):
24 hour contact name Anita Jensen Phone: [phone]
Related Permits:
Inspection Date: 09/30/2011 Entry Time: 09:00 AM Exit Time: 10:00 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: 0 Compliant ■ Not Compliant
Question Areas:
Miscellaneous Questions 0 Record Keeping ■ Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection. Date: 09/30/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection consisted of a review of the 2010 Annual Report(AR).
The following parameters were missing from the 2010 AR (Soils Analysis): Copper, Zinc and Manganese. An Additional
Information request will follow.
Land application (on -site) follow-up inspection will be scheduled for November.
An additional information request was sent out 11/10/2011 for missing soil parameters for the 2010 AR. According to the
contract land applier, Southern Soil Builders, the parameters were not analyzed due to confusion on the Chain of
Custody Form. A Notice of Violation will follow.
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation
Type
Distribution and Marketing
Land Application
Record Keeping,
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?
Comment:
Pathogen and Vector Attraction
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)
Reason for Visit: Routine
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
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)
n
❑
❑
c. pH records for alkaline stabilization (Class B)
❑
❑
❑
Temperature corrected
Cl
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
Comment:
■ ❑ ❑ ❑
❑0M0
Page: 4

y Southern
S II Soil
0
Builders, Inc .
Tuesday, November 15, 2011
Beverly Price
Aquifer Protection Section
Asheville Regional Office
2090 US 70 Highway
Swannanoa, NC 28778-8211
Dear Ms. Price
958 Hoots.Road Roaring River, NC 28669
[phone] 9 Fax [phone]
RIECEMED
N'OU 21200', 1
Asheville Regional Office
A_gL,fer Protection
In a recent letter dated November 10, 2011; the Division conducted an inspection
of the '2010 Annual Report and found the parameters Copper, Zinc, and Manganese
missing from the soils analysis.
I contacted A&L Eastern Laboratories, Inc. concerning the missing parameters; I
found out the following information:
1. The parameters missing had not been analyzed.
2. Too much time has past to have the parameters ran
3. The reason the parameters were not ran was because of confusion on
the chain of custody.
The confusion on the chain of custody came from box S 1 which is a test for
Organic matter, estimated nitrogen release, phosphorus, potassium, magnesium, calcium;
pH, buffer pH, hydrogen, CEC, and % base saturation; box S2 which is Soluble Salts and
Sodium, and box S3 which is test S 1 plus sulfur, boron, zinc, manganese, copper, and
iron and box S23 which is test S3 plus soluble Salts and Sodium.
When the chain of custody was filled out, box S2 was checked instead the box
right beside it, box S23; which should have been the one marked. In a discussion with
A&L Labs, we have now made it standard practice to automaticall run test S23 for all
Soil Samples sent in for analysis from Southern Soil Builders, Inc.

We regret that these three parameters were missing from the 2010 annual report,
however corrective action has been put into place to make sure that all required
parameters will be ran in all future soil analysis. Also, a soil analysis is being taken this
week on each field that Baxter Healthcare land applied on in the calendar year of 2010
with all parameters required ran. These samples are going to be sent overnight to A&L
Laboratories, with copies of the results being sent to the Asheville Regional Office.
If you have any questions, please feel free to contact me at anytime at
[e-mail] or at [phone]
Zach Key,
louthem Soil Builders, Inc.
Cc: Anita Jensen

NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
November 10, 2011
Anita Jensen, EHS Manager
Baxter Health Care Corporation
Post Office Box 1390
Marion, NC 28752
Natural Resources
Dee Freeman
Secretary
SUBJECT: REQUEST FOR ADDITIONAL
INFORMATION REGARDING
2010 Annual Report
Land Application of Residual Solids
Permit No: WQ0031725
McDowell County
Dear Ms. Jensen:
In order to close the inspection records, I need additional information regarding the
inspection that I conducted on September 30, 2011. The inspection consisted of a review of the
2010 Annual Report.
The following parameters were missing from the annual soils analysis: Copper, Zinc
and Manganese.
Please provide this information to the Asheville Regional Office by November 25 2011. If
you or your staff has any questions, please call me at 828/296-4500.
Sincerely,
1
Beverly Price
Environmental Specialist
cc: Dennis Key, ORC SSB
APS Central Files
JPA 0- shrIeFiles
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX : [phone] One
Customer Service:1-877-623-6748 a
NorthCaTolin
Internet: www.ncwaterauality.org fK,Lyr ia" l L/l/n
An Equal Opportunity 1 Affirmative Action Employer A ""

Compliance Inspection Report
Permit: WQ0031726 Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell Hwy 221n
Region: Asheville 65 Pitts Sta Rd
Marion NC 28752
Contact Person: Anita Jensen Title: EHS Manager Phone: [phone]
Directions to Facility:
Take Hwy. 221 North from Marion for approximately 7 miles to Baxter. WWTP is located on the right just past the intersection of Pitts
Station Rd. and }i 221.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 1570.4 Phone: [phone]
Secondary ORC(s):
Zach D Key Certification: 27660 Phone: [phone]
On -Site Representative(s):
24 hour contact name Anita Jensen Phone: [phone]
Related ,Permits:
Inspection Date: 09/30/2011 Entry Time: 09:00 AM Exit Time: 10:00 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas: .
Miscellaneous Questions
(See attachment summary)
Page: 1

Permit: WO0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection consisted of a review of the 2010 Annual Report(AR).
The following parameters were missing from the 2010 AR (Soils Analysis): Copper, Zinc and Manganese. An Additional
Information request will follow.
Land application (on -site) follow-up inspection will be scheduled for November.
Page: 2

L74* A-L
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coieen H. Sullins Dee Freeman
Governor Director — Secretary
RECEIVED
January 28, 2011
r-Ze 18 2611
STEPHEN D. TAYLOR, WASTEWATER SUPERVISOR
BARTER HEALTHCARE CORPORATION L_V1110 Fleglo lai Once
PO Boy: 1390
MARION, NORTH CAROLINA-28752
Subject: Application No. WQ0031725
Additional Information Request
Baxter Healthcare Corporation
Land Application of Residual Solids
McDowell County
Dear Mr. Taylor:
The Aquifer Protection Section has reviewed the permit application submitted on November 10, 2010 for
the above referenced facility. Additional information is required before we may continue our review.
Please address the following items no later than the close of business on March 11, 2011.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina rules and
regulations. Any oversights that occurred in the review of the subject application package are still the
responsibility of the applicant. In addition, any omissions made in responding to the above items may
result in future requests for additional information.
Please reference the subject application number when providing the requested information. Three (3)
copies of all revised and/or additional documentation should be signed, sealed, dated and- submitted to the
Central Office at the address below. Please note that failure to provide this additional information on or
before the above requested date may result in your application being returned as incomplete.
If you have any questions regarding this request, please do not hesitate to contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
Alice M. Wessner
Environmental Engineer
Enclosures
1. Map Guidance for Residuals Land Application Permits
2. Field Maps (4)
cc: -Beverly Price_ Asheville Regfonal-Office, APS-(w/o enclosure
lZach Key, Southern Soil Builders, Inc., 958 Hoots Road, Roanng River, NC 28669 (w/ enclosures)
Permit File WQ0035140 (w/ enclosures)
AQUIFER PROTECTION SECTION
1636 Mai! Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital, Boulevard, Raleigh, North Carolina 27604 One
Phone: 919-7K-3221 1 FAX 1: 919-715-058n; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748 NoibCairolina
Internet: www.ncwateroualitv.ora
An Equal �, oorh:mt; t Af irmaiive Aciion Ernp!oyer

Mr. Taylor
January 28, 2011
Page 2 of 2
Application:
1. Please submit topographical maps for all application fields per request from our Asheville
regional office and as a requirement of Application Item B. of the Land Application Site
Certification Attachment (LASCA). For your convenience, we have included the "Map
Guidance for Residuals Land Application Permits". Please see Item 2 Topographic map.
2. The land application area map for DP 1-D shows net acres of 4.51 and the acreage on Attachment
Order-3 of the LASCA form shows 7.95 acres. Please correct the discrepancy.
3. Please clarify the items on the following fields:
YIELDNCT1vIl3ER
, . ITEMS REQUIRED' . °
Attached
Map,
Field DP-4
Please show a buffer for the ditch
#1
going across the field
Please show a buffer at the lower
Field DP-5
end of the field adjacent to the
#2
intermittent and perennial streams
During a site investigation there
Field DP-6
was evidence of overland flow in
#3
the middle of the field. Please
provide buffers for this field.
The field is terraced, however, the
Field DP-7
lowest terrace is just above a head
#4
cut and a buffer must be provided.
*T- he attached maps will assist you in understanding the information that we are
requesting.

Compliance Inspection Report
Permit: WQ0031725 Effective: 09/18/07 Expiration: 08/31/16 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: Baxter Healthcare Corporation
County: McDowell Hwy 221n
Region: Asheville Pitts Station Rd
Marion NC 28752
Contact Person: Zach D Key Title: Phone: [phone]
Directions to Facility:
From Marion take 221 North. Facility is located on the right after the road narrows to two lanes.
System Classifications: LA,
Primary ORC: Zach D Key Certification: 27660
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
Related Permits:
Inspection Date: 12/08/2010
Primary Inspector: Beverly Price
Secondary Inspector(s):
Zach D Key
Zach D Key
Entry Time: 10:30 AM Exit Time: 12:00 PM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Other Inspection Type: Reconnaissance
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant Q Not Compliant
Question Areas:
N Miscellaneous Questions
(See attachment summary)
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 12/08/2010 Inspection Type: Reconnaissance Reason for Visit: Other
Inspection Summary:
The site visit was conducted to review and verify the field buffers/soil evaluation/maps relating to the major modification
request from Baxter to add new fields to the land application program.
Staff Report submitted with additional information request.
Page: 2

��- V
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 9, 2010
Stephen Gouge
Wastewater .Treatment Supervisor
Baxter Healthcare Corporation
Post Office Box 1390
Marion, NC 28752
SUBJECT: June 3, 2010
Compliance Evaluation Inspection
Baxter Healthcare Corporation
Land Application of Residual Solids
Permit No: WQ0031725
McDowell County
Dear Mr. Gouge:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the
inspection conducted on June 3, 2010. The facility was found to be in Compliance with permit
W00031725.
The inspection included a review of the 2009 Annual Report. The PAN balances on both
application fields should be re-evaluated as it appears that the mineralization and volatilization
rates were reversed in the calculation. The SAR calculation also appears to be incorrect and it
should be reviewed. Please re -submit the PAN & SAR calculations to the following address
within 10 days of receipt of this letter:
NCDENR-DWQ -
Information Processing Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Also, the method (38% Volatile Solids Reduction) chosen to verify Vector Attraction
Reduction did not include a Total Volatile Solids (TVS) analysis. A Volatile Suspended Solids
analysis was performed instead. The volatile solids concentrations are based on total solids, not
merely on suspended solids. Please see the EPA Environmental Regulations and Technology
Control of Pathogens and Vector Attraction in Sewage Sludge, Appendix C for more information.
AQUIFER PROTECTION SECTION — Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] VAX: 828-299-7043 �TOne
Customer Service:1-877-623-6748 1� orthCa ofina
Internet: www.ncwateraualitv.org
An Equal Opportunity 1 Affirmative Action Employer �aturrxll�

Mr. Gouge
Page 2
June 9, 2010
Please refer to the enclosed inspection report for additional observations and comments.
The assistance of Mr. Zack Key was greatly appreciated. If you or your staff has any questions,
please call me at [phone].
Sincerely,
Beverly Pfice
Environmental Specialist
Enclosure
cc: Zack Key, ORC, SSB, Inc.
APS Central iles
*NaWTHMe iles

Compliance Inspection Report
Permit: WQ0031725 Effective: 09/18/07
Expiration: 08/31/15 Owner: Baxter Health Care Corporation
SOC: Effective:
Expiration: Facility: Baxter Healthcare Corporation
County: McDowell
Hwy 221n
Region: Asheville
Pitts Station Rd
Marion NC 28752
Contact Person: Zach D Key
Title: Phone: [phone]
Directions to Facility:
From Marion take 221 North. Facility is located on the
right after the road narrows to two lanes.
System Classifications: LA,
Primary ORC: Dennis Key
Certification: 15704 Phone: [phone]
Secondary ORC(s):
Zach D Key
Certification: 27660 Phone: [phone]
On -Site Representative(s):
24 hour contact name Dennis Key
Phone: [phone]
On -site representative Stephen Gouge
Phone: [phone]
On -site representative Zach D Key
Phone: [phone]
Related Permits:
Inspection Date: 06/03/2010 Entry Time: 03:00 PM Exit Time: 04:00 PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant 0 Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Sampling Land Application Site
■ Pathogen and Vector ■ Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 06/03/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection included a tour of the facility and land application site and a review of the 2009 Annual Report (AR). Residuals
were being applied to Field S-1.
2009 Annual Report Issues:
1)PAN should be re -calculated as the Mineralization & Volatilization Rates were reversed.
2)SAR appears to be incorrect, check and resubmit if necessary.
3)38% Volatile Solids Reduction is the method chosen to verify Vector Attraction Reduction (VAR). The calculation given
included a Volatile Suspended Solids rather than Total Volatile Solids analysis. A Total Volatile Solids analysis should be
performed in order to determine the 38% reduction.
Additional Information request for #1 & 2 above.
Page: 2

Permit: WO0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 06/03/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes
No
NA
NE
Distribution and Marketing
n
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?
n
n
■
n
Is GW-59A certification form completed for facility?
n
n
■
o
Is a copy of current permit on -site?
■
n
n-
n
Are current metals and nutrient analysis available?
❑
❑
Are nutrient and metal loading calculating most limiting parameters?
■
n
n
n
a. TCLP analysis?
■
n
❑
❑
b. SSFA (Standard Soil Fertility Analysis)?
■
n
n
n
Are PAN balances being maintained?
■
n
In
n
Are PAN balances within permit limits?
■
❑
n
n
Has land application equipment been calibrated?
❑
❑
n
■
Are there pH records for alkaline stabilization?
❑
❑
■
❑
Are there pH records for the land application site?
■
❑
00
Are nutrient/crop removal practices in place?
■
❑
n
❑
Do lab sheets support data reported on Residual Analysis Summary?
■
❑
n
❑
Are hauling records available?
n
❑
❑
■
Are hauling records maintained and up-to-date?
❑
n
Cl
■
# Has permittee been free of public complaints in last 12 months?
■
❑
❑
❑
Has application occurred during Seasonal Restriction window?
❑
0
■
❑
Comment:
Pathogen and Vector Attraction
Yes
No
NA
NE
a. Fecal coliform SM 9221 E (Class A or B)
■
❑
00
Class A, all test must be <1000 MPN/dry gram
n
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)
❑
❑
■
❑
Page: 3

Permit: WO0031725 Owner -Facility: Baxter Health Care Corporation
Inspection Date: 06/03/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
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)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g.' Bench -top Aerobic/Anaerobic digestion results
Comment:
Sampling
Describe sampling:
Fecals and VSS are collected from the thickener before going to the belt -press. Metals, nutrients and TCLP
samples are collected after the belt -press.
Is sampling adequate?
Is sampling representative?
Comment:
Transport
Is a copy of the permit in the transport vehicle?
Is a copy of the spill control plan in the vehicle?
Is the spill control plan satisfactory?
Does transport vehicle appear to be maintained?
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
n
nn■n
nn■n
n
n❑■n
nn■n
n
n
n
■nnn
nnnn
■nnn
■nnn
Page: 4

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 06/03/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Are limiting slopes buffered?
10% for surface application
❑ ❑
❑
18% for subsurface application
❑
❑ ■
❑
Are there access restrictions and/or signs?
■
n n
n
Is the application site free of odors or vectors?
■
n n
n
Have performance requirements for application method been met?
For injection?
❑
❑ ■
❑
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment: MWs not required.
No public water.
Page: 5

Compliance Inspection Report
Permit: WQ0031725 Effective: 09/18/07 Expiration: 08/31/15 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: Baxter Healthcare Corporation
County: McDowell Hwy 221 n
Region: Asheville Pitts Station Rd
Marion NC 28752
Contact Person: Zach D Key Title: Phone: [phone]
Directions to Facility:
System Classifications: LAB
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s): r� "
24 hour contact name Dennis -Key Phone: [phone]
On -site representative / Stephen Gouge Phone: [phone]
Related Permits:
Inspection Date: 06/03/2010 Entry Time: 03:00 PM Exit Time: 04:00 PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: X Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions 0 Record Keeping Sampling ■ Pathogen and Vector
Attraction
Z" 33 G - T5_7- 7 8 71
(See attachment summary)
jlppl yn o„ S-1
Page: 1

Permit: WO0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 06/03/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 06/03/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes
No
NA
NE
Is GW monitoring being conducted, if required?
n
n
r
❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑
ffb
❑
Are there any GW quality violations?
n
n
L1
❑
Is GW-59A certification form completed for facility?
n
n
I
n
Is a copy of current permit on -site?
6
n
n
n
Are current metals and nutrient analysis available?
Of
Cl
❑
❑
Are nutrient and metal loading calculating most limiting parameters?
n
n
n
a. TCLP analysis? \ C5 1j�.kc r� SAS r"-} �- `)�
l
n
n
n
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑
❑
L4 '04 AR
Are PAN balances being maintained?
❑
n
n
Are PAN balances within permit limits?
fl
❑
ri
❑
Has land application equipment been calibrated?
❑
❑
❑
I$I
Are there pH records for alkaline stabilization?
❑
❑
L1
n
Are there pH records for the land application site?
T
n
n
n
Are nutrient/crop removal practices in place? W',\, cw� �"`—
0
n
❑
❑
Do lab sheets support data reported on Residual Analysis Summary? A OL
❑
n
n
Are hauling records available?
n
❑
❑
11
Are hauling records maintained and up-to-date?
n
n
n
0
# Has permittee been free of public complaints in last 12 months?
al
n
n
❑
Has application occurred during Seasonal Restriction window?
n
0
❑
❑
Comment:
Pathogen and Vector Attraction
Yes
No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
fP
01111
Class A, all test must be <1000 MPN/dry gram
Cl
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
0
*n
n n
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
9
b. pH records for alkaline stabilization (Class A)
n
n n
c. pH records for alkaline stabilization (Class B)
❑
n n
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 06/03/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Temperature corrected n
d. Salmonella (Class A, all test must be < 3MPN/4 gram day) n n I n
e. Time/Temp on: n n f1 n
Digester (MCRT) n
Compost n
Class A lime stabilization I
f. Volatile Solids Calculations p
g. Bench -top Aerobic/Anaerobic digestion results n n n
Comment:
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate?I n n n
Is sampling representative? ,� n ❑ n
Comment: r
�r FI Ask 00c i., t oel (2ooq
�Cvv- pt.odoses-�
l�-eon".5 ke5
Page: 4

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 06/03/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑
❑
❑
e. Time/Temp on:
❑
❑
M ❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f.. Volatile Solids Calculations
❑
❑
o, ❑
g. Bench -top Aerobic/Anaerobic digestion results
❑
❑
W ❑
Comment:
Sampling
Yes
No
NA NE
Describe sampling:
a I-i' i C6m /hcc a7, /0 J4`p,-'(-U
Is sampling adequate? ram,,, P(p S co ¢ �'% J ❑ ❑
❑
❑
LP hr
Is sampling representative?
�'�S
❑ ❑
❑
❑
Comment: -��
I !
�s lob
s Yes No NA
NE
Transport ✓� -
Is a copy of the permit in the transport vehicle?
❑
❑
❑
Is a copy of the spill control plan in the vehicle?
❑
❑
n
Is the spill control plan satisfactory?
n
n
❑
Does transport vehicle appear to be maintained?
❑
❑
❑
Comment:
Land Application Site
Yes No
NA
NE
Is a copy of the permit on -site during application events?
� ❑
❑
❑
Is the application site in overall good condition?
r15❑
❑
❑
Is the site free of runoff/ponding?
❑
❑
❑
❑
❑
❑
If present, is the application equipment in good operating condition?
Are buffers being maintained?
❑
❑
❑
Are limiting slopes buffered?
10% for surface application
❑ ❑
❑
18% for subsurface application
n n
❑
Are there access restrictions and/or signs? ��nG��
❑
❑
❑
Page: 4

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 06/03/2010 Inspection Type: Compliance Evaluation
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 1'/3' bls.
Is application occurring at the time of the inspection?
Comment:
Reason for Visit: Routine
Mnnn
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n n n
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nnitn
n n M 0
npinn
n Z n�i
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Page: 5

AIJA
NCDENR
North Carolina Department of Environment and Natural
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
July 24, 2009
CERTIFIED MAIL 7006 2150 0005 2458 8955
RETURN RECEIPT REQUESTED
Stephen Gouge, Wastewater Treatment Supervisor
Baxter HealthCare Corporation
Post Office Box 1390
Marion, NC 28752
Subject:
Dear Mr. Gouge:
RINI COPY
Resources
NOTICE OF VIOLATION
NOV-2009-PC-0657
Compliance Evaluation Inspection
2008 Annual Report Review
Baxter Healthcare Corporation
Land Application of Residual Solids
Permit No. WQ0031725
McDowell County
Dee Freeman
Secretary
Enclosed please find a copy of the Inspection Report from the inspection conducted 2009-07-
22. Beverly Price of the Asheville Regional Office conducted the Compliance Evaluation Inspection.
The inspection consisted of a review of the 2008 Annual Report (AR). The treatment facility was
found to be in violation of Permit WQ0031725 for the following:
Inspection Area Compliance Issue
Record Keeping The following parameters were missing from the AR:
Corrosivity, Ignitability, Reactivity — See Permit Condition IV.2.
PathogenNector The AR did not contain documentation to demonstrate clear
Attraction Reduction compliance with the VAR requirements. Two volatile
(VAR) suspended solids results were submitted but this does not
demonstrate compliance. — See Permit Condition IVA.
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] \ FAX : [phone]
Customer Service:1-877-623-6748
Internet: www.ncwaterguality.org
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
naturally

Mr. Gouge
July 24, 2009
Page 2
Please refer to the enclosed Inspection Report (Inspection Summary Page 2) for any
additional observation and comments, particularly Issue #2 and #3.
To prevent further action, carefully review these violations and deficiencies and respond in
writing to this office within fifteen (15) working days of receipt of this letter. You should address the
causes of noncompliance and all actions taken to prevent the recurrence of similar situations. If you
should have any questions, please do not hesitate to contact Beverly Price at 828/296-4500.
Sincerely,
G. Landon Davidson, L.G.
Regional Supervisor
Aquifer Protection
Attachment
cc: Zack Key, Land Application ORC SSB w/ attachment
APS Central Files w/ attachment
APS Enforcement Files w/ attachment

Compliance Inspection Report
Permit: WQ0031725 Effective: 09/18/07 Expiration: 08/31/12 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: Baxter Healthcare Corporation
County: McDowell Hwy 221n.
Region: Asheville Pitts Station Rd
Marion NC 28752
Contact Person: Zach D Key Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Dennis Key
Secondary ORC(s):
Zach D Key
On -Site Representative(s):
24 hour contact name
On -site representative
Related Permits:
Inspection Date: 07/23/2009
Primary Inspector: Beverly Price
Secondary Inspector(s):
Certification: 15704
Certification: 27660
Zach Key
Zach Key
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Entry Time: 10:00 AM Exit Time: 11:00 AM
Phone: [phone]
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Q Compliant ® Not Compliant
Question Areas:
Miscellaneous Questions ® Record Keeping Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit: W00031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 071231200.9 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
This inspection is a follow-up to the 10/1/08 field inspection and consisted of a review of the 2008 Annual Report.
The following issues were noted:
1) The corrosivity, ignitability and reactivity analysis was missing from the report.
2) Fields S-02 and T-02 were transferred from the Lincoln County Residuals Program to the Baxter Healthcare Land
Application Program. The FSF shows no Prior Years Cumulative totals for metals for these fields. If these fields received
residuals while in the Lincoln County Program, the prior totals should be included in the Current Cumulative Totals on the
'08 Report.
3)Two different percent -solids results were given in the report. One result (11.5% collected around 11/20/08) was used
for calculations on the Field Summary Form while a second result (1.8% collected on 8/26/08) was used on the Metals
Field Loading Summary Form. Which percent solids value is correct?
4) There was no documentation submitted to demonstrate clear compliance with the Vector Attraction Reduction (VAR)
requirements. Two VSS results were submitted but this does not demonstrate compliance.
A Notice of Violation will be issued for missing parameters and VAR documentation.
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 07/23/2006 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
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?
❑
❑
■
n
Is GW-59A certification form completed for facility?
n
n
■
❑
Is a copy of current permit on -site?
❑
Q
❑
■
Are current metals and nutrient analysis available?
®
n
n
n
Are nutrient and metal loading calculating most limiting parameters?
■
❑
❑
❑
a. TCLP analysis?
❑
■
❑
❑
b. SSFA (Standard Soil Fertility Analysis)?
■
❑
❑
❑
Are PAN balances being maintained?
®❑
❑
n
Are PAN balances within permit limits?
❑
❑
n
Has land application equipment been calibrated?
13,000
Are there pH records for alkaline stabilization?
❑
❑
■
n
Are there pH records for the land application site?
■
o
❑
n
Are nutrient/crop removal practices in place?
_ Cl
❑
❑
■
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?
0
.n
❑
■
Comment: Missing Analyses: Ignitability; Corrosivity, Reactivity
Pathogen and Vector Attraction
Yes
No
NA
NE
a. Fecal coliform SM.9221 E (Class A or B)
®❑
❑
n
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)
❑
❑
■
❑
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 07/23/2009 Inspection Type: Compliance Evaluation
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)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench -top Aerobic/Anaerobic digestion results
Comment: Volatile Solids Reduction Calculations were missing from 2008 Annual
Report - 38% VSS Reduction not verified.
Reason for Visit: Follow-up
n
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n
nn®n
n n n
n
n
n
n®nn
nn®n
Page: 4

ication Delivery Division B _ , Healthcare Corporation -
P.O. Box 1390
ate Marion, NC 28752
July 31, 2009 Certified Mail: 7006 2760 0004 7921 0087
G. Landon Davidson, L.G.
NCDENR
Aquifer Protection Section
2090 U.S. 70 Hwy
Swannanoa, NC 28778-8211
RE: Land Application Permit No. WQ0031725
NOV-2009-PC-0657 Compliance Evaluation Inspection
Dear Mr. Davidson,
This letter is in response to the notice of violation we received on 7/28/09. The two noncompliance
issues cited from your review of our, 2008 Annual Land Application report are:
• Results for corrosivity, ignitability, and reactivity
• Clear demonstration of the Vector Attraction Reduction calculations based on our volatile
suspended solids samples
It appears that our 2008 Annual Report inadvertently omitted the analytical parameters for corrosivity,
ignitability, and reactivity. We reviewed the chain of custody and the lab report from the sludge
samples obtained for 2008 and found that the corrosivity, ignitability, and reactivity parameters were
not listed in the chain of custody or in the lab's sample results report that we have on file. Although
we review ,our.permit frequently, the samples were mistakenly omitted.
The second issue of noncompliance concerned the unclear demonstration of vector attraction reduction
(VAR) requirements on the 2008 Annual Report. Although we provided the sampling results for the
volatile solids, the sample locations were not identified and the percent reduction was not calculated
and entered in our submission to clearly demonstrate that we met the requirements in 15A NCAC 02T
.1107 (Alt 1). In this instance, the samples were taken at the digester and prior to land application then
analyzed for volatile solids to determine proper VAR requirements (12,200 mg/L and 3360 mg/L
respectively). According to our calculations we reduced the volatile suspended solids by over 72%
thus meeting and exceeding our permit requirements of a 38% reduction.
We have taken steps to prevent these omissions from happening in the future by adding the
requirements to our standard work process. We have already taken samples for our 2009 corrosivity,
ignitability, and reactivity parameters and we will also incorporate additional reviews to ensure reports
are complete before we submit our next Annual report. We appreciate how you have helped us better
understand our newest permit's conditions and we apologize that this was not clarified in our initial
report. Should you have any questions regarding our response, please contact Stephen Gouge at (828)
756-6618.
Sincerely,
Jack Martindale.
EHS Manager
Baxter Healthcare, North Cove Plant
—CEW i 07
{
Pei
AUG 0,4
Y P M�`' Aquifer Protection

Michael F. Easley, Governor
William G. Ross Jr., Secretary
7 North Carolina Depariment of Environment and Natural Resources
r -
,� Coleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION
October 8, 2008 CI
Stephen Gouge, Wastewater Treatemnt Supervisor
Baxter Healthcare Corporation
Post Office Box 1390
Marion, NC 28752
SUBJECT: October 1, 2008 Compliance
Evaluation Inspection .
Baxter Healthcare Corporation
Land Application of Residual Solids
Permit No: WQ0031725
McDowell County
.Dear Mr. Gouge:
Enclosed please find a copy of the Compliance Evaluation Inspection form from. the
inspection that I conducted on October 1, 2008... The facility was found to be. in Compliance
with permit WQ0031725.
Please refer to the enclosed inspection report (Inspection Summary Page 2) for
additional observation_ s and comments. If you or your staff has any questions, please call me
at [phone].
Sincerely,
z
Beverly ce
Environmental Specialist
Enclosure
cc: Dennis Key, ORC Southern Soil Builders 958 Hoots Road Roaring River NC 28.669
w/enclosure
APS Central Files
e
oe
NCarolina
Naturally
North Carolina Division of Water Quality - Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

Compliance Inspection Report
Permit: WQ0031.725 Effective: 09/18/07 Expiration: 08/31/12 Owner: Baxter Health Care Corporation
SOC: Effective: Expiration: Facility: Baxter Healthcare Corporation
County: McDowell
Hwy 221 n
Region: Asheville
Pitts Station Rd
Marion NC 28752
Contact Person: Zach D Key
Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Dennis Key
Certification: 15704 Phone: [phone]
Secondary ORC(s):
Zach D Key
Certification: 27660 Phone: [phone]
On -Site Representative(s):
24 hour contact name
Zach D Key Phone: [phone]
On -site representative
Zach D Key Phone: [phone]
Related Permits:
Inspection Date: 10/01/2008
Entry Time: 10:30 AM Exit Time: 12:00 PM
Primary Inspector: Beverly Price
Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site Pathogen and Vector Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 10/01/2008 Inspection Type: Compliance Evaluation
Reason for Visit: 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?
Cl ❑
■ ❑
Is GW-59A certification form completed for facility?
❑ Cl
■ ❑
Is a copy of current permit on -site?
■ ❑
❑ ❑
Are current metals and nutrient analysis available?
■ ❑
Cl ❑
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?
❑ ❑
❑ M
Are hauling records available?
■ Cl
❑ ❑
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?
❑ ■
❑ ❑
Comment: Application was not occurring during Seasonal Restriction window.
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) ❑ ❑ ■ ❑
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 10/01/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is a copy of the spill control plan in the vehicle?
■
❑
❑ ❑
Is the spill control plan satisfactory?
■
❑
❑ ❑
Does transport vehicle appear to be maintained? .
0111111
Comment:
Land Application Site
Yes
No
NA NE
Is a copy of the permit on -site during application events?
■
❑
❑ ❑
Is the application site in overall good condition?
■
❑
❑ ❑
Is the site free of runoff/ponding?
❑
❑
❑ ■
If present, is the application equipment in good operating condition?
❑
■
❑ ❑
Are buffers being maintained?
■
❑ ❑
Are limiting slopes buffered?
10% for surface application
❑
❑
■ ❑
18% for subsurface application
❑
❑
■ ❑
Are there access restrictions and/or signs?
■
❑
❑ ❑
Is the application site free of odors or vectors?
■
❑
❑ ❑
Have performance requirements for application method been met?
For injection?
❑
❑
■ ❑
For incorporation?.
❑
❑
■ ❑
Does permit require monitoring wells?
❑
■
❑ Cl
Have required MWs been installed?
❑
❑
■ ❑
Are MWs properly located w/ respect to RB and CB?
❑
❑
■ ❑
Are MWs properly constructed (including screened interval)?
❑
❑
■ ❑
Is the surrounding area served by public water?
❑
■
❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑
❑
■ ❑
Are soil types consistent w/ Soil Scientist report/evaluation?
■
Cl
❑ ❑
Is the water table greater than 173' bls.
❑
❑
❑ ■
Is application occurring at the time of the inspection?
❑
■
❑ ❑
Comment: The spreader truck had a dead battery so application was not occurring at
the time of inspection.
Ws not required.
Page: 5

Permit: WO0031725
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 09/18/07
Effective:
Contact Person: Zach D Key
Directions to Facility:
System Classifications:
Primary ORC: Zasl;-944eq 1)Q/, (ls\5
Secondary ORC(s): T 7_6_CN--j -YNI
On -Site Representative(s):
24 hour contact name
Related Permits:
Inspection Date: 10/01/2008
Primary Inspector: Beverly Price
Secondary Inspector(s):
Zach D Key
Expiration: 08/31/12 Owner: Baxter Health Care Corporation
Expiration: Facility: Baxter Healthcare Corporation
Hwy 221 n
Pitts Station Rd
Marion NC 28752
Title: Phone: [phone]
Entry Time: 10:30 AM
Certification:27660 Phone:[phone]
Exit Time: 12:00 PM
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: '0 Compliant Q Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site Pathogen and Vector ■ Transport
Attraction
(See attachment summary)
L, A , 0 , V,3.0-,w S— ( - (Ce've
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 10/01/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 10/01/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine.
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? ❑ ❑ 0 ❑
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?
39❑ ❑ ❑
b. SSFA(Standard Soil Fertility Analysis)?CGkt2c,')✓�
111
❑ ❑ ❑ YX
Are PAN balances being maintained?
❑ ❑ ❑
Are PAN balances within permit limits?Qev'1etel V_ Doi R 4
❑ ❑ ❑
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?�r�l
❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary? R4jj)Q.W ° OFi A, Q-
❑ ❑ ❑
Are hauling records available?
❑ ❑ ❑
Are hauling records maintained and up-to-date?
❑❑ ❑
# Has permittee been free of public complaints in last 12 months?
18e ❑ ❑
Has application occurred during Seasonal Restriction window?
.❑ ❑ ❑
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)
❑ ❑ A, ❑
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)
❑ ❑ ya ❑
c. pH records for alkaline stabilization (Class B)
❑ ❑ ,❑
Page: 3

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 10/01/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Temperature corrected n
d. Salmonella (Class A, all test must be < 3MPN/4 gram day) In ❑ On
e. Time/Temp on:
nnn
Digester (MCRT) n
Compost n
Class A lime stabilization n
f. Volatile Solids Calculations n n 0 n
g. Bench -top Aerobic/Anaerobic digestion results ❑ n 0 n
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion A
Anaerobic Digestion n
Alkaline Pasteurization (Class A) n
Alkaline Stabilization (Class B) In
Compost n
Drying Beds n
Other ��1� -p ❑
Comment:
Sampling
Yes
No
NA
NE
sampling: rO��S
Describe sam lin o
1_
Is sampling adequate? J
o
Q
n
n
Is sampling representative?
❑
❑
❑
❑
Comment:
Transport
Yes
No
NA
NE
Is a copy of the permit in the transport vehicle?
n
❑
n
Is a copy of the spill control plan in the vehicle?
❑
n
Is the spill control plan satisfactory?
bb
❑
❑
Does transport vehicle appear to be maintained?
n
n
n
Comment:
Page: 4

Permit: WQ0031725 Owner - Facility: Baxter Health Care Corporation
Inspection Date: 10/01/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? ❑ [I ❑
Is the application site in overall good condition? F m ❑ ❑ ❑
�,
Is the site free of runoff/ponding? `Sj',� ,,V ��� � ❑ ❑ 'K4
If present, is the application equipment in good operating condition? Sir '1'd "�Lh� ❑ ❑ ❑ ❑
Are buffers being maintained? ❑ ❑ ❑
Are limiting slopes buffered? b
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment:
0 n n n
❑❑W❑
❑❑❑
.❑00
nn0n
❑❑g❑
nf200
❑❑W0
nngfn.
❑❑00
❑�❑.❑
nnnt�
I In Pt
❑❑n
❑❑❑0
❑A❑❑
Page: 5

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Paul E. Rawls, Chairman
Water Pollution Control System Operators Certification Commission
January 17, 2008
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr Stephen Gouge
Baxter Health Care Corporation
PO Box 1390
Marion NC 28752
Subject: Classification of Land Application of Residuals System
Facility: Baxter Healthcare Corporation
Permit #: WQ0031725
County: McDowell
Dear Mr. Gouge:
KNOR 4i N1 N
JAN 22 2000
" '.eville Regional Offic�
"v )f 0fe.r protection
In accordance with North Carolina General Statute 90A-37, the Water Pollution Control System
Operators Certification Commission hereby classifies the subject facility as a Land Application of
Residuals System effective today. In accordance with 15A NCAC .8G .0201 and, your permit, you are
required to designate one Operator in Responsible Charge (ORC) and one or more back-up operators for
this facility.
You must complete and return the enclosed designation form to this office by June 30, 2008. The form
must be signed by the ORC, the backup operator(s), and you or your designee. You may designate
yourself and/or employees to be the ORC and back-up operator(s), or you may engage a contract
operations firm to perform these services. All operators designated as ORC or back-up operators must
possess active Land Application of Residuals certificates.
If construction of your system is incomplete or has not yet begun, you must notify this office, in writing,
of the anticipated startup date and your plans for obtaining and designating the required certified
operators. Please note that failure to designate a properly certified ORC and one or more backup
operator(s) 60 days prior to the introduction of waste into the system is a violation of Rule 15A
NCAC .0302(b).
A Land Application of Residuals Operators Training School is being offered April 22 — 24, 2008, at the
McKimmon Center in Raleigh. The next training school will be offered in May 2009. School registration
information and a list of contract operators are enclosed.
tCarolina
urally
Technical Assistance & Certification Unit Internet: http://h2o.enr.state.nc.us/tacu
1618 Mail Service Center, Raleigh, NC 27699-1618 Telephone [phone] Fax [phone]
An Equal Opportunity Action Employer 50% recycled/10% post -consumer paper

Stephen Gouge
WQ0031725
Page Two
If you have questions, concerning this requirement, please contact Beth Buffington at [phone],
extension 313, or [e-mail].
Sincerely,
Jerry Rimmer, Supervisor
Technical Assistance and Certification Unit
Enclosures
cc: LAU Residuals Program Coordinator
s ev711e Regonal�Office, t�:quiferProLr tot `on Section;
APS Central Files
APS Files
TACU Facility Files

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: Baxter Healthcare Corporation RLAP
County: McDowell 65 Pitts Sta
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
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.
System Classifications: LA,
Primary ORC: Certification: ' Phone:
Secondary ORC(s):
On -Site Representative(s):
Corporate Responsible Official
On -site representative
On -site representative
Related Permits:
Inspection Date: 04106/2016
Primary Inspector: Beverly Price
Secondary Inspector(s):
Michael Joseph Pisarik
Zach D Key
Michael Joseph Pisarik
Entry Time: 12:30PM
Reason for Inspection: Routine
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Land Applicatior
(See attachment summary)
Exit Time: 02:OOPM
Phone: [phone]
Inspection Type: Reconnaissance
ON
C
toCL..J- TIC ee l�
Page: 1

Permit: WQ0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/06/2016 Inspection Type: Reconnaissance Reason for Visit: Routine
Inspection Summary:
The inspection was in conjunction with the permit renewal.
Land application had occurred on field DP7 two days prior to the site visit. Buffer flags were still in place. Notification signs
were in place. The field had a good grass cover.
Field DP3 now has a waiver buffer: residuals application within 100 ft. of 752 Austin Little Mtn. Road.
A portion of field DP1-A is denuded. This area will need to be re -seeded prior to land application.
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/06/2016 Inspection Type : Reconnaissance Reason for Visit: Routine,
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment: Area not served by public water.
Permit does not require monitoring wells.
Type
Distribution and Marketing
Land Application
Yes No NA NE
❑ ❑ ❑
■❑❑❑
❑❑❑■
❑ ❑ ❑
■❑❑❑
❑ ❑ N ❑
❑❑■❑
❑■❑❑
❑ ❑ E ❑
❑❑■❑
❑ ❑ N ❑
❑■❑❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ,❑
❑ N ❑ ❑
Yes No NA NE
Page: 3

Division of Water Resources
Water Quality Permitting
Regional Staff Report
April 14, 2016
To: DWR Water Quality Permitting Section Central Office Application No.: WQ0031725'
Attn: Troy Doby Regional Login No.:
From: Bev Price
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 4/6 /2016
b. Site visit conducted by: Bev Price
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Mike Pisarik, Sr. Environmental Engineer and their contact information: 82{ 8) 756-
6017: Zack Key, Consultant, SSB 336-957-7871
e. Driving directions: From Marion: Hwy. 221 North to intersection with`NCSR 1573 (Pitts Station Road).
Continue through the intersection for approximately 100 vds., the WWTP is on the right.
II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain: _
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ❑ NIA
If no, please explain:
4. Do the plans and site map represent the actual site (property Iines, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ NIA
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program: _
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A
If yes, attach list of sites with restrictions (Certification B)
FORM: APSRSR 04-10 Page 1 of 4 --

III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Dennis Key Certificate #: LA15704 Backup ORC: Zack > Certificate #: LA27660
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ® No
If no, please explain: A portion of field DP1-A is a feeding area which is denuded. A vegetative cover will
need to be re-established prior to land application.
4. Has the site changed in any Way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:,
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ® No
If no, please explain: 2015 Annual Report: Soils Analyses showed Very High for phosphorous for Fields.
DP3C, DP5, DP7. Fields !MC, DP3G, DP4, DP5, DP6, DP7 showed Very High for Copper. Fields DP3C,
DP4, DP5, DP6 showed Very High for Zinc. However, the Zinc and Copper Indices were not above 2000.
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ®N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or Z No
If yes, attach a.map showing• conflict areas.
9. Is the description ofthe facilities as written in the existing permit correct? ❑ Yes or ® No
If no, please explain.: The fields located in Catawba County are being removed from the permit. The
renewal application did not indicate a minor modification but it was noted on the Site Certification Form.
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® NIA
If no, please explain:
11. Are the monitoring well coordinates correct in RIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
O 1 If
0 I II
O 1 It
Y O I It
'
0 1 It
O I 71
O I 1!
O I !J
' O I of
O / JJ
12. Has a review of all self -monitoring data been conducted (e.g., NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: See 46 above
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ®'No
If yes, please explain:
14. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
FORM: APSRSR 04-10 Page 2 of 4

15. Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No M N/A
If no, please explain:
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes M No ❑ NIA
If yes, please explain:
IV. REGIONAL OFFICE RECOMMENDATIONS
I . Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or M No
If yes, please explain:
2. List any items that you would like APS Central'Office to obtain through an additional information request:
Item Reason
3. List specific permit conditions recommended to be removed from the permit when issued:
I Condition I Reason I
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state rea�s:
6. Signature of report preparer:
Signature of A S regional supervisor:
Date:
FORM: APSRSR 04-10 Page 3 of 4

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: APSRSR 04- 10 . Page 4 of 4

Compliance Inspection Reaoft
Permit: WQ0031725 Effective: 04121111 Expiration: 08/31116 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: Baxter Healthcare Corporation RLAP
County: McDowell 65 Pitts Sta
Region: Asheville
Marion NG 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Fallow 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.
System classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Corporate Responsible Official
On -site representative
On -site representative
Related Permits:
inspection Date: 04106/2016
Primary Inspector_ Beverly Price
Secondary Inspector(s):
Michael Joseph Pisarik
Zach a Key
Michael Joseph Pisarik
Entry Time: 12:30PM Exit Time: 02:OOPM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant Not Compliant
Question Areas:
■ Miscellaneous Questions Land Application Site
(See attachment summary)
Page: 1

Permit: WO0031725 Owner- Facility: Baxter Healthcare corporation
Inspection Date- 04108/2018 Inspection Type: compliance Evaluation . Reason for Visit: Routine
Inspection Summary:
The inspection was in conjunction with the permit renewal.
Land application had occurred on field DP7 two days prior to the site visit. Buffer flags were still in place. Notification signs
were in place. The field had a good grass cover.
Field DP3 now has a waiver buffer: residuals application within I CC ft. of 762 Austin Little Mtn. Road.
A portion of field DR'1-A is denuded. This area will need to be re -seeded priorto land application.
Page: 2

Permit: VVQ0031725 Owner • Pacility: Baxter Healthcare Corporation
Inspection Date: 04108/2016 inspection Type : Compliance Evaluation Reason for Visit: Routine
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
•10% for surface application
18%for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located wl respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist repo rtlevaluation?
Is the water table greater than 1'13'bls.
Is application occurring at the time of the inspection?
Comment: Area not served by public water.
Permit does not require monitoring wells.
Tone
Distribution and Marketing
Land Application
Yea No NA NE
■ ❑ ❑ ❑.
❑ ❑ ❑
❑ ❑ ❑
E ❑ ❑ ❑
WOOD
❑ ❑ ❑
❑ ❑ W ❑
■❑❑❑
■❑❑❑
❑ ❑ N❑
❑❑E❑
❑■❑❑
❑❑■❑
❑❑■❑
❑❑■❑
❑■❑❑
■❑❑❑
❑❑❑■
❑ ❑ ❑
❑ N ❑❑
Yea No NA NE
Pager 3

Compliance Inspection Report
Permit: WQ0031725 Effective: 04/21/11 Expiration: 08/31/16 owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: Baxter Healthcare Corporation RLAP
County: McDowell 65 Pitts Sta
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek' Title: Environmental Engineer Phone: [phone]
Directions to Facility:
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.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
of(a/;
Inspection Date: 'B-7l 976 Entry Time:
Primary Inspector: Beverly Price
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
0P 3 _- N 13kw IAA
Exit Time:
Phone: [phone]
Inspection Type: Reconnaissance
®n #7 0-�d�
Page: 1

Permit; WO0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 07/04/1976 Inspection Type : Reconnaissance Reason for Visit: Routine
Inspection Summary:
P3- L c 6,1-A)
-67
�-tsv 06`�'l
Page: 2

Permit: WQ0031725 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 07/0411976 Inspection Type : Reconnaissance Reason for Visit: Routine
Page: 3

State of North Carolina
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Regional Staff Report
April, 2016
To: DWR Water Quality Permitting Section Central Office Application No.: W00031725
Attn: Troy Doby Regional Login No.:
From: Bev Price
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit coo ducted? ® Yes or ❑ No
a. Date of site 'ssiit: /2016
b. Site visit conducted by: Bev Price
c. Inspection report attached? ® Yes or ❑ No Za � ` I -A Dec- 33c 95-7`-737/
d. Person contacted: and their contact information: 8�) 75& - 6 307
e. Driving directions: 14Wk, 22l h,t 4.1, WUR 167*3 (P;.4s 54A,.,u iZ4 )`,
lS,© SIB 5fap 1�k4}'u3TGa iS w oob,a
H. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A
If yes, attach list of sites with restrictions (Certification B)
FORM: APSRSR 04-10 Pagel of 3

III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORC s) for the facility? Yes ❑ No ❑ N/A
OR "4'1S7erticate #: Ep 157cV- Backup OR Certificate #:I -A a7( &0
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? )6 Yes or ❑ No
If no, please explain:
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? Yes or ❑ No
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or jNo
If yes, please explain:
5. Is the residuals management plan adequate? � Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? [ Yes or ❑ No
If no, please explain: `l
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No VN/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or [$] No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? [Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No t4 N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No N N/A
If no, please complete the followinia (expand table if necessarv):
Monitoring Well
Latitude
Longitude
0 / //
0 / If
0 I //
0 / II
0 I //
0 I //
0 / II
0 f 11
0 / 11
0 I /I
12. Has a review of all self -monitoring data been conducted (e.g., NDMR, NDAR, GW)? ❑ Yes or ❑ No
Please summarize any findings resulting from this review:
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ❑ No
If yes, please explain:
14. Check all that apply:
❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium,
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No IKN/A
If no, please explain:
FORM: APSRSR 04-10 Page 2 of 3

16. Are the e any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes No ❑ N/A
If yes, please explain:
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or 0 No
If yes, please explain:
2. List any items that you would like APS Central Office to obtain through an additional information request:
Item Reason
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
VHold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: )
6. Signature of report preparer:
Signature of APS regional supervisor:
Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: APSRSR 04-10 Page 3 of 3

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Southern
Soil
Builders, Inc.
Thursday, June 1, 2017
Beverly Price
NCDEQ-DWR
2090 US Highway 70
Swannanoa, NC 28778
Subject: Additional Information Request
Baxter Healthcare Corporation
Permit WQ0031725
2016 Annual Report
958 Hoots Road Roaring River, NC 28669
[phone] Fax [phone]
In a letter received from the Asheville Regional Office of NCDEQ, two items where requested in the
review of the 2016 annual report.
The first item was the laboratory bench sheets used in the Vector Attraction Reduction analysis. I
contacted Statesville Analytical and had them forward the bench sheets to me. l have included a copy
with this letter.
The second item is the calculation used to achieve the 38% Volatile Solids reduction. I have included
with this letter the spreadsheet used to calculate the reduction and the formula used to calculate it.
If there are any questions or any other information needed, please contact me at
[e-mail] or at 336-957-7871.
Sincerely,
Zach Key,
Southern Soil.Builders, Inc...
DECEIVED
Division of Water Resources
JUN - 5 2017
Water Quality Regional Operations
Asheville Regional Office

VS in 0.0133
VS out 0.0054
VSFR= 0.59721
(VS IN - VS OUT) / (VS IN - (VS IN * VS OUT))
(0.0133-0.0054)/(0.0133-(0.0133*0.0054))=0.59721
of) il'�
w

Rev. 2/2013
Analyzed By:
Calculated By:
QC Checked By:
Date Reviewed:
Total Solids and Volatile Solids
SM 2540 B 1997
Date In 1030
Time In 1030
Date/Time Out 1030
Date/Time In 5600
Tire Out 5500:
Sample ID
D Wei ht
Dish Wei ht O
i i - �•�
�.. �
i�� .r_ jG,
L c
Weight Difference )
sarnDle volume (mL)
TS m IL
D Wei ht )
Ash Wei ht O
TVS m /L
Dish �
(IR
�7
' ` }
} '°�
I
r )1 Y
1 .
G
Calculation:
TSS= (A-B) X 1.000 000
C
CiP
U.UUz0-U,Z 9.
Where: A= Dry wt + Dish wt
B= Dish wt.
C=mL sample
EC="
Dup 1
Dup 2
% Difference:

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary.
S. JAY ZIMMERMAN
Director
May 25, 2017
Jon Rushford, VP of Manufacturing
Baxter Healthcare Corporation
Post Office Box 1390
Marion, NC 28752
SUBJECT: Additional Information Request
Annual Report (2016) Review Inspection
Baxter Healthcare Corporation RLAP
Permit No: WQ0031725
McDowell County
Dear Mr. Rushford:
On May 24, 2017, I conducted a review of the 2016 Annual Report for the subject permit. The following information
was not included:
1.The laboratory bench sheets used in the Vector Attraction Reduction analysis (38% Volatile
Solids Reduction).
2.1he calculation for the 38% Volatile Solids Reduction.
Within 10 days of receipt of this letter, please submit the information referenced above to:
NCDEQ - DWR
2090 U.S. Highway 70
Swannanoa, NC 28778
Attn: Beverly Price
If you or your staff have any questions, please call me at 828-296-4685.
Sincerely,
Beverly Price
Environmental Senior Specialist
cc: Dennis Key, ORC Southern Soil Builders
MSC 1617-Central Files -Basement
Ashewslle� egg;='
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\Baxter Add Info.docx
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70 Swannanoa, NC 28778
828 296 4500

µ
r
�pRpJECT EVALUATION AND SITE MANAGEMENT PLAN
t the end of the field summaries, a total of 59.92 acres is suitable for residuals app
lication.
ps shown a
application rates of nitrogen,
or corn
Ail fields currently exist in established fescue pasture, fescu 'known appge Crop health is
adequate. Addition of residuals must be monitored such thatispect to the
' hate potash, and lime equivalent are taken into account anagement t bles. The permanent
phosp. p applied
recommendations, or RYE limit as given from the nut runoff may occur. The corn
ure supplies adequate erosion control for those fields, however, judgment must be app
haylpast p
-,"when applying liquid biosolids to fields where slopes exceed 6 percent as r
of
silage is either planted in strips or is on gently sloping land with pii tleonce native cover downslope
such that residuals loss from the row -crop corn silage land poses d Some of the fields that
All fields have the soil type of Fairview clay loam, 2 to 8 percent slopes, erode
are included for residuals application have slopes up to 10 percent, and thus are in the Fairview C class
e with slopes of 8 to 15 percent. 2T rules require the use of nutrient management RYE
slope phas application rates of residuals.
guidance when defining app licable for
pre section. The soil test results are app •
The nutrient management tables are shown in a p. lies:
the following applies*
EXCEPT. NITROGEN. For nitrogen loading, maybe applied. R uc thi ra'
all nutrients, and lime, ere o -t 0
\1) eP uegh9y, a maxrm� t ounds a
so monitor a
' tWo S°!a {t
4 lbsxN 1aere 6. e ire to s arm gr az ,You should amendmen diti I at f`It'4
sources that may be used such as starter fertilizer or otherorganicldc aliefrom ALL nut�e
. iie tFta'maXi
2)
5purcea.
_ r � n may be applied. You should also
or -corn ilagema mZ1 pounds�percre o
additional nutrients that may be used such as fsa erg fertilize
a other
she AL organic
monitor ad ,,� �, maximum ►a
amendments. The roa a-
u -r ent`se rce
otash is
The soil test results are on the following page. For each field, either a minimal amount emen twill be met
None of the fields require phosphorus• Even thoughdaEa T
recommended. i have not,seen the waste a"nNalysis but it is likely that the potash e a
19-1
by applying the material at a N-based rate
ntal P will likely be added with the residuals, no addeitiaantael ceomsimonrci_ca�►t"rshould
a�uaurrerst sip
supplemental i i pwevca• it
s _i est ineLexes are a i v '
f sse o�ild noe-a c H, The permit may require this
of lime or a liming ent to raise soil p
application
if the residuals
All but field 1 require the addition of
of residuals, or time of residuals
uals should be tested
amendment before, the applicationlied. based on those
then
are handled in a manner that would render them as a liming source, and app
• in equivalency (also called calcium carbonate equivalency)
for their lim g q d crop health, but the soil pH should not be raised tohigh. Mon
rates. Liming is critical to the soil an p the permit and agronomic recommendations
lime requirement annually and adjust as required by
f ion of-athe mnd+r�es�
`�` er and ztn ese tevels 'ndieate past a
A soi tens are veryg+p-e�d{orresiduai
ou should coordinate with the landowner to`intsurer hatppadditional amendments are
Ilkee . you tglit eC. hm3 ,
monitored and accounted for. There ar` a o� iflt_estyregut

•-- -- •. �vT.Etti .c3xc���l .�
rh_.,This helps
NCDag�?Ctes#tioEe,ormrr� .
ran a soil and. crop issues for most common forage and row crop
insure no long- g is required to
stem. if the fescue crop appears damaged or
The hay sho
uld be cut or grazed using sound agronomic practices. Removal of the crop
be used to:diagnose the problem. You should notto hold the
continued nutrient uptake and removal from t y r lacks sufficient density
" seased; soil and plant tissue samples may ears anhealthy o
,residuals on any fields/crops where plant tissue app the set -out time for grazing animals,
Ucation permit.will specify ement
residuals in place on the field. The app ' razing requires 3 or more manag
e one where residuals have recently been applied and waiting the set-
and this must be coordinated wr h the landowner. -Typical y, g
areas: one where the animals a being applied.
Pp lied.
out time, and one where residuals are actively the soil test. The following table
re all very low
The, sodium levels aThe ESP is a calculated value from
shows each field ESP:
Soil test number Calculated ESP value
0.85
1 0.95
2 1.39
:- 3
0.88
4 0.93
5 0.93
6 1.05
concern, and
P is a arameter that should be calculated
above 15 generate a level of concern for sodium. None of these fields shows any
ESP levels lication. ES p
sodium will not be limiting for residuals
help with sodium monitoring.
annually as residuals are applied
SUMMARY
application. The sails are consistent
bedrock and seasonal high water table. Slopes exceeding 10
All soils and sites as shown in this report are suitable for residuals
and meet all required Seout separations t
percent have been flagged
opportunity to perform this service for you. please contact me if you have any
1 appreciate the pp
Questions.,
Sincerely,
Karl shaffer, L.S.
Shaffer Soil Services, Inc.
Attachments: Invoice

�ICDA&CS Agronomic Division Phone: [phone] Web site: www-ncagr-gov/agrOnomi% Copses To . Stiaffer i�ct
Grower., Poplin, Doug
r \ Key, Zach
594 Austin Little Mtn Rd
Ronda, NC 28670
ep
soil i est. ort
Farm
SERVING N.C. RESIDENTS FOR OVER 60 YEARS wo
Links to Hei[�Itsl 111f0rinatiOn Wilkes COuntY
Received: 07/01/2010 Completed: 07f/D8/• 01 t•�;
Agronomist Comments
Field Information Applied Lime Recommendations Lime N P205 K20 Mg S Cu Zn B Mn See Note
Sample No. Last Crop Mo Yr T/A Crop or Year 0 0 0 0 0 .0 0 My
1st Crop: Fes/OG/Tim,M 0 120-200 0
1 0 0 0 0 0 .0 0 13
2nd Crop: Fes/OG/Pim,M 0 120-200 0
Test Results
P-1 K-I Ca% Mg% Mn-1 MnAI(1) Mn-AI(2) Zn-I. Zn AI Cu-1 S-I SS-d NO3-N Nli'4NNa
Soil Class IIM% W/V CEC BS% Ac pH 0.1
MIN 0.71 1.03 11.7 86.0 1.6 5.9 206 158 59.0 21.0 122 92 92 861 1 70 0 41
Field Information Applied Lime Recommendations S Cu Zn B Mn See Note
- lime N PaOs Ill �
Sample No. Last Crop Mo Yr T/A Crop or Year 0 0
1st Crop: Corn,Silage .8T 180-220 0 0-20 0 0 0 0
2 0-20 0 0 0 0 .0 0
2nd Crop: Corn,Silage 0 180-220 0 i
Test Results
Zn-I ZnAd Cu-I S 1 SS-d NO3 N NH4-N Na
Soil Class HM% W/V CEC BS% Ac pH P-I K-d Ca% Mg'� Mn-I Mn-AI(1) Mn 19(2) �89 1089 '936' S2 0.1
MIN 0.41 1.05 10.5 83.0 1.8 5.5 218 119 56.0 21.0 153 109
Field Information Applied Lime Recommendations P2Os K2O Mg S Cu Za B Mn See Note
Linte N
Sample No. Last Crop Mo Yr T/A Crop or Year 10 30 0 0 0 0 .0 0 3
1st Crop: Corn,Silage 1.3T 180-220 0
3 1030 0 0 0 0 .0 0
2nd Crop: Corn,Silage 0 180420 0
Test Results Zn-I Zn-AI Ca-1 S I SS-1
NO3 N NH4-N Na
Soil Class IdM% WW/V /V CEC BS% Ac pH P-1 K I Ca% Mg% Mn-1 Mu-AI(1) Mn AI(2) 283° 61 0.1
MIN 0,32 7.2 72.0 2.0 5.0 log 100 47.0 18.0 146 105 105 `549 549
Field Information Applied Lime Recommendations
Lime N PaOs Kz0 Mg S Cu Zn B Mn See Note
Sample No. Last Crop Mo Yr T/A Crop or Year 0 20 0 0 0 0 .0 0 12
4 1st Crop: Fes/OG/Tirn,M .8T 120-200 0
2nd Crop: Fes/OG/T1m,M 0 120-200 0
0-20 0 0 0 0 .0 0 11
Test Results Zn-I Zn AI Cu-1 S-I SS-d NO3-N NH4-N Na
Soil Class HM% W/V CEC BS% Ac pH P-I IC! Ca% Mg•� Mn-d Mn-AI(1) Mn-AI(2) 0.1
MIN 0.97 0.91 11.3 82.0 2.0 5.6 100 73 59.0 20.0 152 108 108 eIT46- 1146 %67 37
i
VU l�piaJ �Qm X Z= Ib-S ��

ononu/ =' Grower Pop m, oug ,
Phone: (919)733=2655 " Web site: www:ncagd•gov/agr ;: _
NCDA$cCS Agronomic Division
Field Information
Applied Lime
Recommendations
Recomme
PzOS
KzO
1VIg S
Cu
Zn
B Mn See Note; ,rry .
Sample No. Last Crop
No Yr ?'lA
Crop or Year
Lime
N
0
0
p p
o
0
.0 0 i2
1st Crop: Fes/OG/Tim,M
.9T
120-200
0 0
0
0
0 0
5
2nd Crop: Fes/OG/Pim,M
0
120-200
0
0
Test Results
Mg•�
Mn-I Mn-AI(1) Mn Al(2)
Zn-X Zn-AI
Cu-1
S-I
SS-X NO3-N NH�-N Na
°
Soil Class HM% W/V
°
CEC BS.6
Ac pH P-d &X
Ca%
55.0 22.0
117
87
S7 97� 975
t`<.
35
0.1
MIN 0.71 0.96
10.7 81.0
2.0 5.5 93 95
Field Information
Applied Lime
Recommendations
N
PaOs
Kz0
Mg S
Cu
Zn
B Mn See Note
Sample No. Last Crop
Mo Yr 7/A
Crop or Year
Lime
0
0
0 p
p
0
.0 0 ?''
�
1st Crop: Fes/OG/Tim,M
1.1T
120-200
0 0
0
0
.0 0 12
2nd Crop: Fes/OG/Tim,M
0
120-200
0
p
Test Results
Mg'�
Mn-I
Mn-AI(1)
Mn AI(2)
Zta-X Zn Ai
Cu-I
S-I
SS -I NO3-N NH4-N Na
Soil Class HM% W/V
CBC BS%
Ac pH P-X 1� I
Ga%
21.0
122
90
9Q
-8$9 859
36
1
MIN 0.76 0.97
10.8 80.0
2.2 5.4 93 123
53.0
Field Information
Applied Lime
Recommendations
N
P205
K2O
Mg S
Cu
Zu
B Mn See Note
Sample No. Last Crop
MO Yr T/A
Crop or Year
Lime
0
10-30
0 0
0
0
.0 0
1st Crop: Fes/OG/Tim,M
1T
120-200
0
0
0
0 i2
7
2nd Crop: Fes/OG/Tim,M
0
120-20Q
0
10-30
0
.0
Test Results Mn AI(2) Zn-I Zn-AI Cu-I S I SS -I NOs-N NH4-N Na
,._-- Ulm/ W/V rxc BS% Ac p 6 Mn,X Mn-Ai(2)
H P-I K I Ca% Mk' A7 07 r668 GOS c86-'Ol 42 0.1
M1N V.�u .. .•,
�lbyth, , C'�air � l i; �;a
�•i,i ncres"1rt1YA i U11d C011111MMt01r•^d1
Reprogramming of the laboratory-informtth on -management system that makes this report possible is being fund,
rough a grant from the North Carolina Tobacco Trust Funs! Comm ssic
Thank you for using agronomic services to manage nutrients and safeguard environmental qualit
- Steve Troxler, Commissioner of Agricultu