WQ0010689_CEIARR 2023_20240618

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

June 18, 2024

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

SUBJECT: Compliance Inspection Report
Annual Report Review 2023
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 6/18/2024. 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: Compliance Evaluation 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
Matthew Morin
Effective:Expiration:Facility:Baxter Healthcare DCAR
65 Pitt Station Rd
Marion NC 28752
Title:Phone:[phone]
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:
06/18/2024 10:00AM 01:00PM
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
06/18/2024 Annual Report Review
Baxter Healthcare Corporation
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, conducted a review of Baxter Healthcare’s DCAR 2023 Annual Report to
determine whether the facility processed and monitored all residuals in compliance with non-discharge permit WQ0010689.
Baxter produced approximately 1,218 dry tons and distributed approximately 1,026 dry tons of boiler ash residuals in 2023.
Note that the November product out total on form DMSDF Supp (p. 2) is incorrect (should be 556.19 dry tons and total
should be 1,218.39 dry tons)
Pathogen and Vector Attraction Reduction are not required for the boiler ash residuals.
Metals, Nutrients and Pollutants of Concern: Sampling is only required when residuals are distributed, and requirement is
based on tons distributed. All parameters appear to have been sampled, reported and are in compliance with permit
requirements.
Non-Hazardous Waste Characterization: TCLP sampling is 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.
The following issues were noted with the report:
•The sample date should be provided on the header of form DMSDF, not the lab sample ID.
•Please report non-detect values as "<" and include the reporting limit value, instead of reporting as "ND".
•Although it is reported as non-detect, it should be noted that the reporting limit (99.5 mg/kg) for molybdenum for sample ID
NP91923B is higher than the regulatory limit (75 mg/kg).
•The value reported value for magnesium (188,000 mg/kg), for sampling ID NP91923A, is incorrect (lab report value is 18,800
mg/kg).
•The PAN and SAR values listed on form DMSDF were calculated correctly, but calculations should be provided as an
attachment in the annual report.
Page 2 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010689
06/18/2024 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
06/18/2024 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
Annual Report Review Class A Distribution Permit No. WQ00_________

Reporting Period: ___________

Permit Details:

• Is 503 OR 257
• Maximum Dry Tons Per Year: ________
• Monitoring Frequency for TCLP: ________
• Monitoring Frequency for Residuals Analysis: ________
• Monitoring Frequency for Pathogen & Vector Attraction Reduction: ________

1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted? Yes No
• Was distribution conducted during the reported period? Yes No
• How many dry tons were produced and distributed? ________
• Were the distributions with the permitted amount? ________
• Were recipient’s information listed? ________
• Did it indicate compliance? Yes No
• Was form complete? Yes No
• Was it signed by the appropriate people? Yes No

2. Monitoring
• Were the analyses conducted at the required frequency? Yes No
• Was an analyses taken for each source that was distributed? Yes No
• Were the metals analyses reported on the Residual Sampling Summary Form? Yes No
• Were the results reported in mg/kg? Yes No
• Were the pH’s 6.0 or greater for each residual sample? Yes No
• Were the heavy metals within ceiling concentration permit limits? Yes No
o Were the lab analyses attached? Yes No
• Were all the required parameters tested? Yes No
• Was TCLP analysis conducted? Yes No
• Were the TLCP contaminants within regulatory limits? Yes No
• Was a corrosivity, ignitability, and reactivity analysis conducted? Yes No

010689
2023
3200
Once per permit cycle
1,218 produced, 1,026 distributed
quarterly
none
Yes
Yes
Comments: -The sample date should be provided on form DMSDF, not the lab sample ID.-Please report non-detect values as "<" and include the RL value, instead of reporting as "ND".-Although it is reported as non-detect, it should be noted that the reporting limit (99.5 mg/kg) for molybdenum for sample ID NP91923B is higher than the regulatory limit (75 mg/kg).-The value reported value for magnesium (188,000 mg/kg), for sampling ID NP91923A, is incorrect (actual is 18,800 mg/kg).-It appears as though the PAN and SAR values listed on form DMSDF were calculated correctly, but calculations should be provided as an attachment in the annual report.-TCLP is 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.
Comment: Note that the November Product Out total on DMSDF Supp form is incorrect (should be 556.19)
3. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? Yes No
• Did the form indicate the period of coverage, the residual class, and the pathogen reduction alternative
and the vector attraction reduction option used? Yes No
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the
report? Yes No
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?Yes No

Class A Pathogen Review

To be Class A, residuals shall meet either fecal Coliform density or salmonella density.

Fecal Coliform density
· Was the sampling conducted at the required frequency? Yes No
· Were multiple samples taken? Yes No
· Was each sample less than 1000 MPN/gram of total solids? Yes No

OR

Salmonella density
· Was the sampling conducted at the required frequency? Yes No
· Were multiple samples taken? Yes No
· Was each sample less than 3 MPN/4 grams of total solids? Yes No

To be Class A, residuals shall meet one of the following alternatives:

Alternative 1 – Time/Temperature
· Were the residuals maintained for correct time and temperature? Yes No
· Were logs submitted showing time and temperature? Yes No
· Were temperatures within range for complete time period? Yes No

Alternative 2 – Alkaline Treatment
· Were logs submitted showing time and temperature? Yes No
· Was the pH raised to 12 or greater and maintained for 72 hours or longer? Yes No
· Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater?
Yes No
· Were logs submitted showing time and pH? Yes No
· Was the temperature corrected to 25°C (77°F)? Yes No

Alternative 5 – Process To Further Reduce Pathogens
PFRP Composting
· Were the within-vessel method or static aerated pile methods used? Yes No
· Was the residuals temperature maintained at 55°C (131°F) or higher for three consecutive days or
longer in the within-vessel method or static aerated pile method? Yes No
OR
· Was the windrow composting method used? Yes No
· Was the residuals temperature maintained at 55°C or higher for 15 consecutive days or longer in the
windrow method, and the windrow turned a minimum of five times during this time? Yes No
PFRP Heat Drying
· Was the residuals dried by direct or indirect contact with hot gases and the moisture content of
residuals reduced to 10% or lower? Yes No
· Did the temperature of the residuals or the of the wet bulb temperature of the gas in contact with the
residuals as the residuals leave the dryer exceed 80°C (176°F)? Yes No

Not required
Vector Attraction Reduction Review

• Was the sampling conducted at the required frequency? Yes No

Option 1 – 38% Volatile Solids Reduction
· Was there 38% reduction? Yes No
· Were lab sheets/calculations in report? Yes No
· Was the reduction on volatile solids (not total solids)? Yes No
· Were the samples taken at beginning of digestion process and before application (Inspection)?
Yes No
· Were calculations correct? Yes No

Option 2 – 40-Day Bench Scale Test
· Were residuals from anaerobically digested treatment (Inspection)? Yes No
· Were residuals anaerobically digested in lab? Yes No
· Was the test run for 40 days? Yes No
· Was the test done between 30°C (86°F) and 37°C (99°F)? Yes No
· Was the reduction of on volatile solids (not total solids)? Yes No
· Was the reduction less than 17%? Yes No
· Were lab sheets/calculations in report? Yes No
· Were calculations correct? Yes No

Option 3 – 30-Day Bench Scale Test
· Were residuals from aerobically digested treatment (Inspection)? Yes No
· Were residuals aerobically digested in lab? Yes No
· Were residuals 2% or less total solids? Yes No
· If not 2% total solids, was the test ran on a sample diluted to 2% with unchlorinated effluent?
Yes No
· Was the test run for 30 days? Yes No
· Was the test done at 20°C (68°F)? Yes No
· Was the reduction of on volatile solids (not total solids)? Yes No
· Was the reduction less than 15%? Yes No
· Were lab sheets/calculations in report? Yes No
· Were calculations correct? Yes No

Option 4 – Specific Oxygen Uptake Rate (SOUR)
· Were residuals form aerobically digested treatment (Inspection)? Yes No
· Were residuals 2% or less total solids (dry weight basis) (not diluted)? Yes No
· Was the test done between 10°C (50°F) and 30°C (86°F)? Yes No
· Was the temperature corrected to 20°C (68°F)? Yes No
· Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of total residual solids (dry
weight basis)? Yes No
· Was the sampling holding time two hours? Yes No
· Was the test started within 15 minutes of sampling or aeration maintained? Yes No

Option 5 – 14-Day Aerobic Process
· Were the residuals from aerobically digested treatment (Inspection)? Yes No
· Were the residuals treated for 14 days? Yes No
· Was the residuals temperature higher than 40°C (104°F) for a 14-day period? Yes No
· Was the average residuals temperature higher than 45°C (113°F)? Yes No

Option 6 – Alkaline Stabilization
· Was the pH of the residuals raised to 12 or higher by the addition of alkali? Yes No
· Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
Yes No
· Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours without the
addition of more alkali? Yes No
· Was the pH corrected to 25°C (77°F)? Yes No

Option 7 – Drying of Stabilized Residuals
· Does the residuals contain any unstabilized residuals? Yes No
· Were the residuals mixed with any other materials? Yes No
· Were the residuals dried up to 75% total solids? Yes No

Option 8 – Drying of Unstabilized Residuals
· Were the residuals mixed with any other materials? Yes No
· Were the residuals dried to 90% total solids? Yes No

Option 9/10 – Injection/Incorporation
· Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
Yes No
· Was injection done on pasture or hay field? Yes No
· Was injection done at time that crop was growing? Yes No
· If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? Yes No
· Was incorporation done six hours after application (Inspection)? Yes No

4. General
• Was the report in the proper format? Yes No
• Was the annual report complete? Yes No
• Was the report submitted on time? Yes No
Pollutant Limits
Pollutant Ceiling
Concentration
Below
Limit
Cumulative
Pollutant
Loading Rate
Below
Limit
Arsenic 75 41
Cadmium 85 39
Copper 4300 1500
Lead 840 300
Mercury 57 17
Molybdenum 75 N/A
Nickel 420 420
Selenium 100 100
Zinc 7500 2800

TCLP
Parameter Below
Limit
Parameter Below
Limit
Parameter Below
Limit
Arsenic (5.0) 1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0)
Barium (100.0) 1,2-Dichloroethane (0.5) Pentachlorophenol (100.0)
Benzene (0.5) 1,1-Dichloroethylene (0.7) Pyridine (5.0)
Cadmium (1.0) 2,4-Dinitrotoluene (0.13) Selenium (5.0)
Carbon tetrachloride (0.5) Endrin (0.02) Silver (5.0)
Chlorodane (0.03) Hepatachlor (and its
epoxide) (0.008)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0) Hexachlorobenzene (0.13) Toxaphene (0.5)
Chloroform (6.0) Hexachlorobutadiene (0.5) Trichloroethylene (0.5)
Chromium (5.0) Hexachloroethane (3.0) 2,4,5-Trichlorophenol
(400.0)

m-Cresol (200.0) Lead (5.0) 2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0) Lindane (0.4) 2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0) Mercury (0.2) Vinyl Chloride (0.2)
Cresol (200.0) Methoxychlor (10.0)
2,4-D (10.0) Methyl ethyl Ketone (200.0)

Residuals Analysis
Parameter Analyzed For Parameter Analyzed For Parameter Analyzed For
Aluminum Mercury Potassium
Ammonia-
Nitrogen
Molybdenum Selenium
Arsenic Nickel Sodium
Cadmium Nitrate-
Nitrite
Nitrogen
SAR
Calcium % TS TKN
Copper pH Zinc
Lead Phosphorus
Magnesium PAN

y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y