WQ0031725_CEIARR_20230629

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

June 29, 2023

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

SUBJECT: Compliance Inspection Report
Annual Report Review 2022
North Cove Steam Generation Plant CLRS
Non-discharge Permit No. WQ0031725
McDowell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the North Cove Steam
Generation Plant CLRS on 5/31/2023. This inspection was conducted to verify that the facility is
operating in compliance with the conditions and limitations specified in Non-discharge Permit No.
WQ0031725. 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:WQ0031725 Effective:09/01/21 Expiration:06/30/27 Owner :Baxter Healthcare Corporation
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Corey Carpentier
Effective:Expiration:Facility:North Cove Steam Generation Plant CLRS
2859 Old Linville Rd
Marion NC 28752
Title:Phone:[phone]
Follow Hwy. 221 north from Marion to NCSR 1573 (Pitts Station Rd.), turn right. At intersection of Pitts Station Rd. & NCSR 1560
(Old Linville Rd.), turn left. Facility is approximately 0.25 mi. on the left.
Secondary ORC(s):
336-957-7878Phone:15704Certification:Dennis KeyPrimary ORC:
LA,System Classifications:
On-Site Representative(s):
Related Permits:
NC0006564 Baxter Healthcare Corporation - Baxter Healthcare Corporation
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
05/31/2023 01:00PM 04:00PM
Melanie Kemp
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Land Application of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031725
05/31/2023 Annual Report Review
Baxter Healthcare Corporation
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, conducted a review of Baxter’s RLAP Annual Report on May 31, 2023.
This review was conducted to determine whether the facility processed and monitored all residuals in compliance with
non-discharge permit WQ0031725.
US Biosolids land applied approximately 144.45 dry tons of Class B residuals to 8 of 10 permitted fields on behalf of Baxter.
Pathogen Reduction (PR): PR is met via fecal coliform density reduction below 2,000,000 MPN/g. The geometric mean for
2022 was reported on the Pathogen and Vector Attraction Reduction Form as 707,302 MPN/g.
Vector Attraction Reduction (VAR): VAR is demonstrated via the 30-day bench scale test. The volatile solids reduction was
less than 15%.
Metals, Nutrients & Pollutants of Concern: Values were below the ceiling and cumulative pollutant loading rates for Class B
residuals. All metals and nutrient parameters were analyzed per section IV.3 of the permit. PAN & SAR balances are being
calculated and maintained.
Application: As a reminder, any residuals applied to grazed pasture shall have the realistic nitrogen rate reduced by 25% per
Section II.10.d. Several of the fields are listed as pasture in the most recent application (DP1-A, DP1-B, DP1-C, DP1-D,
DP4, DP5, DP6 & DP7). Additionally, please remind the property owner animals cannot graze on the land for 30 calendar
days after land application per Section III.12.a.
Land Application Field Summary: Please note that the predominant soil series on form FSF for fields DP3 and DP4 were
listed incorrectly. The permit specifies the soil series as FcB2 for these fields, and was reported as FcC2. This affects the
max PAN values, but the correct PAN max values are higher than what was reported on FSF forms so resulted in no issues.
Please take note of this and correct accordingly for next year’s submittal.
Soil Fertility Analysis: Lime was applied to recommended fields in December 2022 (DP1-D, DP3, and DP5). ESPs were less
than 15.
Non-Hazardous Waste Characterization: TCLP, corrosivity, reactivity and ignitibility appear to meet regulatory requirements.
Page 2 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031725
05/31/2023 Annual Report Review
Baxter Healthcare Corporation
Routine
Type Yes No NA NE
Distribution and Marketing
Land Application
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on-site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Fescue can be applied to year-round. Corn field was applied to within seasonal growing
window (Feb-June).
Comment:
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
Class A, all test must be <1000 MPN/dry gram
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
Fecal coliform SM 9222 D (Class B only)
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
b. pH records for alkaline stabilization (Class A)
c. pH records for alkaline stabilization (Class B)
Temperature corrected
Page 3 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031725
05/31/2023 Annual Report Review
Baxter Healthcare Corporation
Routine
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
30-day bench scale results used to meet VAR (option 3).Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Digested sludge is dewatered in a centrifuge before land application.Comment:
Page 4 of 4