WQ0010689_CEIARR_20230628

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

June 28, 2023

Derek Bouchard
Baxter Healthcare Corporation
Email: [e-mail]

SUBJECT: Compliance Inspection Report
Annual Report Review 2022
Baxter Healthcare DCAR
Non-discharge Permit No. WQ0010689
McDowell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Baxter Healthcare DCAR
on 5/30/2023. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in Non-discharge Permit No. WQ0010689. The findings and
comments noted during this inspection are provided in the enclosed copy of the inspection report
entitled "Compliance Inspection Report".

There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.

If you should have any questions, please do not hesitate to contact Melanie Kemp with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at
[e-mail].

Sincerely,

Melanie Kemp, Environmental Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: LF
Compliance Inspection Report
Permit:WQ0010689 Effective:12/01/19 Expiration:03/31/25 Owner :Baxter Healthcare Corporation
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Corey Carpentier
Effective:Expiration:Facility:Baxter Healthcare DCAR
65 Pitt Station Rd
Marion NC 28752
Title:Phone:[phone]EHS Associate
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
WQ0001512 Baxter Healthcare Corporation - North Cove Steam Generation Plant CLRS
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
05/30/2023 01:00PM 04:00PM
Melanie Kemp
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503 Exempt)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
(See attachment summary)
Page 1 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010689
05/30/2023 Annual Report Review
Baxter Healthcare Corporation
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, conducted a review of Baxter Healthcare’s DCAR 2022 Annual Report on
May 30, 2023. This review was conducted to determine whether the facility processed and monitored all residuals in
compliance with non-discharge permit WQ0010689.
Baxter distributed approximately 1,182 dry tons of boiler ash residuals in 2022.
Pathogen and Vector Attraction Reduction are not required for the boiler ash residuals.
Metals, Nutrients and Pollutants of Concern: Required quarterly based on tons distributed. All parameters appear to have
been sampled, reported and in compliance with permit requirements. Please include values in non-detect sample results
(i.e. <3.0 instead of ND). Continue to closely monitor SAR values and utilize the revised agreement as needed. Please note
that Cadmium was reported incorrectly (reported as 304 on DMSDF form and 3.4 on lab report).
Non-Hazardous Waste Characterization: Required once per permit cycle. As a reminder, Baxter will need to submit all
hazardous waste characteristics as outlined under section IV.2 of the permit before the end of the permit cycle in 2025.
Page 2 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010689
05/30/2023 Annual Report Review
Baxter Healthcare Corporation
Routine
Type Yes No NA NE
Land Application
Distribution and Marketing
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on-site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Class A product is distributed for use as a soil amendment. Hazardous waste characterization is
required once per permit cycle (before 2025).
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
Page 3 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010689
05/30/2023 Annual Report Review
Baxter Healthcare Corporation
Routine
Boiler ash residual does not meet definition of biologial residual, therefore no treatment
required.
Comment:
Page 4 of 4