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HomeMy WebLinkAboutWQ0031725_CEIARR_20190708 July 8, 2019 Corey Carpentier Baxter Healthcare Corporation 65 Pitts Station Rd Marion, NC 28752 SUBJECT: Compliance Inspection Report Annual Report (2018) 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 RLAP on 6/21/2019. 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. Please carefully review the comments and recommendations listed in the inspection report, specifically, those concerning the correct analytical methods for Ignitability & Corrosivity. If you should have any questions, please do not hesitate to contact me at 828-296-4686 or via email at mikal.willmer@ncdenr.gov. Sincerely, Mikal Willmer, Environmental Specialist I Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: WQS ARO Server LF G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\WQ0031725 - Land Application Class B Residuals\Inspections\June 21, 2019 CEIARR (2018)\20190708_WQ0031725_CEIARR 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. Secondary ORC(s): 336-957-7878Phone: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: 06/21/2019 09:30AM 11:00AM Mikal Willmer 828-296-4686 Beverly Price 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 of 4 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031725 06/21/2019 Annual Report Review Baxter Healthcare Corporation Routine Inspection Summary: The inspection was conducted by Mikal Willmer and Beverly Price of the Asheville Regional Office. 167.51 DT of residuals were land applied to permitted fields (10) located in Wilkes County. Land application was carried out by Southern Soil Builders. Metals/nutrients/TCLP analyses were conducted according to permit requiremetns. Heavy metals ceiling concentration limits, Cumulative Pollutant Loading Rates (CPLR), TCLP limits and PAN loading rates appear to be compliant with permit limits. Phosphorous Index P-I is high for several fields according to the soils report; agronomist recommendations should be followed. Soils Analyses: Fields DP3C, DP5 & DP7 had pH's <6; lime was added to those fields. Pathogen Reduction was verified using Fecal Coliform Density: Geometric Mean was less than 2025 MPN/gram of total solids. Vector Attraction Reduction was verified using Alternative 1, 38% VS Reduction . Laboratory bench sheets should be submitted with the Annual Report. Ensure that the laboratory is using the correct method for Ignitability and Corrosivity. Page 2 of 4 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031725 06/21/2019 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? Metals/nutrient data is for 2018 land application events. Metals results appear to be compliant with permit limits. Methods for Ignitability and Corrosivity appear to be incorrect. Corrosivity should be analyzed using Method SW846 9040C or 9045D depending on percent solids. The Ignitability analytical method is also dependent upon percent solids. 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 of 4 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031725 06/21/2019 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 of 4 Certificate Of Completion Envelope Id: A3A379ACBF664FEF98E3EA98AF3331DF Status: Completed Subject: Please DocuSign: 20190708_WQ0031725_CEIARR.docx, 20190708_WQ0031725_CEIARR.draft.pdf Source Envelope: Document Pages: 5 Signatures: 1 Envelope Originator: Certificate Pages: 1 Initials: 1 Mikal Willmer AutoNav: Disabled EnvelopeId Stamping: Disabled Time Zone: (UTC-05:00) Eastern Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Mikal.willmer@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Jul 9, 2019 | 14:05 Holder: Mikal Willmer Mikal.willmer@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Mikal Willmer mikal.willmer@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Drawn on Device Using IP Address: 149.168.204.10 Sent: Jul 9, 2019 | 14:05 Viewed: Jul 9, 2019 | 14:05 Signed: Jul 9, 2019 | 14:05 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 Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted Jul 9, 2019 | 14:05 Certified Delivered Security Checked Jul 9, 2019 | 14:05 Signing Complete Security Checked Jul 9, 2019 | 14:05 Completed Security Checked Jul 9, 2019 | 14:05 Payment Events Status Timestamps