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Home My WebLink AboutWQ0031725_Compliance Evaluation Inspection_20181218 North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 December 18, 2018 Corey Carpentier Baxter Healthcare Corporation 65 Pitts Station Rd Marion, NC 28752 SUBJECT: Compliance Inspection Report Annual Report (2017) Review Baxter Healthcare Corporation RLAP Non-discharge Permit No. WQ0031725 McDowell County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Baxter Healthcare Corporation Residuals Land Application Program (RLAP) on 12/11/2018. 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". The following issues were noted in the review and should be addressed: 1. Corrosivity (pH) was analyzed out of hold time. The analysis was performed by PACE Analytical Services, LLC (Asheville, NC). See permit condition IV.2. 2. The residuals pH was analyzed out of hold time. The analysis was performed by Waypoint Analytical. See permit condition IV. 3. You may be able to perform the above referenced pH analyses at your facility in order to meet the hold time. Please contact Jason Smith with the NC Laboratory Certification Section @ 828.296.4679 or North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 Jason.smith@ncdenr.gov to determine if you can add the required pH certifications for biosolids to your laboratory certification. As a reminder, permit condition III.15. states…” The permittee shall acquire from each landowner or lessee/operator, a statement detailing the volume of other nutrient sources (i.e., manufactured fertilizers, manures, or other animal waste products) that have been applied to the site, and a copy of the most recent Nutrient Management Plan (NMP) for those operations were a NMP is required by the US Department of Agriculture – National Resources Conservation Service (NRCS) or other State Agencies. The Permittee shall calculate allowable nutrient loading rates based on the provided information and use appropriate reductions”. If you should have any questions, please do not hesitate to contact me at 828-296-4500 or via email at bev.price@ncdenr.gov. Sincerely, Beverly Price, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Zack Key Jason Smith WQS ARO Server LF G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\WQ0031725 - Land Application Class B Residuals\Inspections\December 11, 2018 CEIARR (2017)\20181218_WQ0031725_CEIARR.rtf Compliance Inspection Report Permit:WQ0031725 Effective:09/01/16 Expiration:08/31/21 Owner :Baxter Healthcare Corporation SOC: Contact Person: Region: County: Directions to Facility: McDowell Asheville Corey Carpentier Effective:Expiration:Facility:Baxter Healthcare Corporation RLAP 65 Pitts Sta Marion NC 28752 Title:Phone:828-756-6636 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. Zach D Key 27660 336-957-7871 Secondary ORC(s): 336-957-8909Phone:15704Certification:Dennis KeyPrimary ORC: LA,System Classifications: 24 hour contact name Corey Carpentier 828-756-6636 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: 12/11/2018 11:00AM 01:00PM Beverly Price 828-296-4500 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 Pathogen and Vector Attraction (See attachment summary) Page:1 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031725 12/11/2018 Annual Report Review Baxter Healthcare Corporation Routine Inspection Summary: This inspection consisted of a review of the 2017 Annual Report by Beverly Price of the Asheville Regional Office. 147.03 dry tons of residuals were land applied to permitted fields located in Wilkes County. Land application events were conducted by Southern Soil Builders. Nutrients/metals/TCLP analyses were conducted per permit requirements. Heavy metals ceiling concentration limits, cumulative pollutant loading rates, TCLP limits and PAN loading rates appear to be compliant with permit limits. Residuals pH analysis: The hold time was not met - analysis by Waypoint Analytical. Corrosivity (pH) analysis: The hold time was not met - analysis by PACE Analytical. Pathogen reduction was demonstrated using Alternative 1: Fecal Coliform Density. Vector Attraction Reduction was demonstrated using Option 1: 38% Volatile Solids (VS) Reduction. The following information should be submitted in conjunction with VS analysis: laboratory bench sheets. A Standard Soil Fertility Analysis was conducted September 2017. The following fields had pH’s below 6: DP1-C, DP3-C, DP3-G, DP4 & DP7. These fields received lime applications in November 2017. Residuals were applied on all fields except DP2. All Zinc & Copper Indices were <2000 for all fields. Reminders: The land owner or lessee/operator shall supply the Permittee with a statement detailing the volume of other nutrient sources that have been applied to the site. Reduce nitrogen RYE values by 25% for hay fields that are grazed. Page:2 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031725 12/11/2018 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? No seasonal restriction window. Metals/nutrient data review is for 2017 land application. Corrosivity (pH) analyzed out of hold time. Residuals (pH) analyzed out of hold time. 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) Page:3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031725 12/11/2018 Annual Report Review Baxter Healthcare Corporation Routine 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: Page:4 Certificate Of Completion Envelope Id: B886E3507FEC4C37A87567A093AB77F5 Status: Completed Subject: Please DocuSign: 20181218_WQ0031725_CEIARR.rtf, 20181218_WQ0031725_CEIARR.pdf Source Envelope: Document Pages: 6 Signatures: 1 Envelope Originator: Certificate Pages: 1 Initials: 1 Beverly Price AutoNav: Disabled EnvelopeId Stamping: Disabled Time Zone: (UTC-08:00) Pacific Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Bev.Price@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original 12/18/2018 6:37:26 AM Holder: Beverly Price Bev.Price@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Beverly Price bev.price@ncdenr.gov North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: 12/18/2018 6:39:17 AM Viewed: 12/18/2018 6:39:26 AM Signed: 12/18/2018 6:39:56 AM Freeform Signing Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 12/18/2018 6:39:17 AM Certified Delivered Security Checked 12/18/2018 6:39:26 AM Signing Complete Security Checked 12/18/2018 6:39:56 AM Completed Security Checked 12/18/2018 6:39:56 AM Payment Events Status Timestamps