NC0006564_Fact Sheet_20220404

Fact Sheet
NPDES Permit No. NC0006564
Permit Writer/Email Contact Julia Byrd, [e-mail]:
Date: December 30, 2021
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑X Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Baxter Healthcare Corporation
Applicant Address:
65 Pitts Station Rd, Marion, NC 28752
Facility Address:
US Highway 221 at North Cove, Marion, NC 28752
Permitted Flow:
1.2 MGD
Facility Type/Waste:
50% domestic/50% industrial
Facility Class:
Class 3
Treatment Units:
Non -contact Cooling Water, Boiler Feed Water, Process Water, and
Sanitary Wastewater
Pretreatment Program (Y/N)
N
County:
McDowell
Region
Asheville
Briefly describe the proposed permitting action and facility background:
NPDES permitting history
The Baxter Corporation requires a National Pollutant Discharge Elimination System (NPDES) discharge
permit to dispose of treated non -contact cooling water, boiler feed water, process wastewater, and sanitary
wastewater through surface water discharge. The facility manufactures sterile liquid solutions in flexible
bags for medical procedures. Baxter Corporation's NPDES permit expired January 31, 2020; the renewal
application was received by the Division July 19, 2019.
The source of the wastewater is non -contact cooling water, boiler feed water, process water, and sanitary
wastewater. The facility upgraded its wastewater treatment system and relocated the outfall (001) 550 ft.
upstream to accommodate the upgrade.
After treatment, wastewater is discharged through outfall 001 into the North Fork Catawba River, which is
classified B-Trout Waters, in the Catawba River Basin.
In 1995, the Division of Water Resources issued an Authorization to Construct that permitted the
construction of a new outfall into the North Fork Catawba River 3.2 miles upstream of the confluence with
Armstrong Creek. Prior to 1996, Baxter Healthcare and American Threads discharged through outfalls
constructed at the same location in the North Fork Catawba River (0.2 miles downstream of the confluence
with Armstrong Creek).
Page 1 of 10

STREAM CONDITIONS
Baxter Healthcare discharges into the North Fork Catawba River, 3.2 miles upstream of the confluence with
Armstrong Creek. In 1994, DWR modeled the North Fork Catawba River from Baxter Corporation's outfall
to Lake James. The model included the interactions of Baxter's discharge with American Threads (no
longer exists). The North Fork Catawba River changes classification at the confluence of Armstrong Creek
and North Fork Catawba River. The upstream classification is B —Tr and the downstream classification is
C. The model was based on the BOD load of 1321 (daily max) and 880 (monthly average). The current
load is substantially lower.
The model indicated that dissolved oxygen concentrations from the outfall to the confluence with
Armstrong Creek did not fall below the state standard of 6.0 mg/L for trout waters. The lowest predicted
value in this reach did not fall below 7.0 mg/L.
Current permitting actions:
Baxter Corporation's NPDES permit expired January 31, 2020; the renewal application was received by
the Division July 19, 2019. The application cover letter indicated that no significant manufacturing changes
occurred since the last renewal. Based on results of testing over the course of the permit cycle, it is not
anticipated that oil and grease will be present in effluent; therefore, the applicant requested that oil and
grease limits are removed, or monitoring reduced in the reissued permit. The current permit limits for Oil
and Grease are based on 40 CFR 463 Subpart A as applicable to cooling water from extruders, and Best
Professional Judgement (BPJ) for sanitary wastewater. The current monthly average and daily maximum
limits, 47.7 and 95.4 pounds per day, respectively will be maintained but monitoring reduced to twice per
month.
The limits based on TBELS calculated during this review were less stringent than the previous permit.
Since the facility has no current plans for future expansion no changes are proposed. Based on results of
the Waste Load Allocation (WLA) conducted for this review, seasonal ammonia -nitrogen limits will be
added, as well as upstream and effluent hardness monitoring. Turbidity monitoring and a footnote to
effluent temperature monitoring was added, per 15A NCAC 02B .0211(18) and (21), and .0219, the
temperature for trout waters shall not be increased more than 0.5 C° due to the discharge of heated liquids.
2. Receiving Waterbodv Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001— North Fork Catawba River
Stream Segment:
11-24-(2.5)
Stream Classification:
B, Tr
Drainage Area (mi2):
31.5
Summer 7Q10 (cfs)
10.2
Winter 7Q10 (cfs):
15.2
30Q2 (cfs):
Average Flow (cfs):
63
IWC (% effluent):
16
303(d) listed/parameter:
No
Subject to TMDL/parameter:
Yes- Statewide Mercury TMDL implementation.
Basin/Sub-basin/HUC:
North Fork Catawba River/03-08-30/03050101
USGS Topo Quad:
D10SE
Page 2 of 10

3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of November 2017 to November 2021.
Table. Effluent Data Summary Outfall 001
Parameter
Units
Average
Max
Min
Permit
Limit
Flow
MGD
0.94
1.54
0.19
MA 1.2
BOD5, 20°C
lbs/day
19.39
124.66
<3.21
MA 460.9
DM 691.4
COD
lbs/day
38.71
154.69
<8.02
MA 1,292.8
DM 1,939.2
Total Suspended Solids
lbs/day
9.26
68.75
<1.6
MA 278
DM 417
Fecal Coliform
#/100mL
MA 200
DM400
Total Residual Chlorine4
µg/1
limits only apply if chlorine
is used
DM 28.0
< 50
compliance)
Temperature
° C
25.92
35
9.3
Monitor
3/week
Conductivity
µS/cm
1,283.14
2,397
429
Monitor
3/week
Dissolved Oxygen,
mg/1
7.64
12.2
5.7
Monitor
3/week
pH
SU
--
7.6
6.4
6.0 > pH <
9.0
Oil & Grease
lbs/day
39.90
84.99
<8.02
MA 47.7
DM 95.4
NH3-N
mg/1
0.15
3.1
<0.1
Monitor
2/month
Total Nitrogen
(NO2 + NO3 + TKN)
mg/1
7.40
23.4
0.85
Monitor
1/month
Total Phosphorus
mg/1
1.63
5.5
0.09
Monitor
1/month
Chronic Toxicity
pass/fail
Monitor
1 /quarter
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average
Page 3 of 10

4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when
model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to verify
model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream
concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions
established in several basins that conduct instream sampling for the Permittee (in which case instream
monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this permit
action: The current permit requires instream monitoring for dissolved oxygen, temperature, fecal coliform,
and conductivity for Class B, Trout Waters, per 15A NCAC 02B .0200. Review of instream data for the
past four years is summarized below.
Location
Dissolved Oxygen (mg/L)
Conductivity (µS/cm)
Temperature (°C)
Avg
Max
Min
Avg
Max
Min
Avg
Max
Min
Upstream
9.94
15
6
77.11
124
27
15.84
23.8
0
Downstream
9.28
16.9
6.2
86.33
151
36
16.5
24.3
0
Students t-tests were run at a 95% confidence interval to analyze relationships between instream samples.
A statistically significant difference is determined when the t-test p-value result is < 0.05.
Review of instream data from the last four years, indicates that statistical differences exist between
upstream and downstream samples for temperature, conductivity, and dissolved oxygen. Minimum
downstream dissolved oxygen reported was 6.0 mg/L. There were differences in temperatures upstream
and downstream reported which could violate standard 15A NCAC 02B .0211(18), which requires that the
temperature for trout waters shall not be increased by more than 0.5 °C above the background temperature
and not exceed 20 °C. Footnote will be added to the effluent temperature monitoring limit in the permit.
Quarterly upstream hardness will be added in the reissued permit, but no changes are proposed for instream
monitoring requirements.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): No
Name of Monitoring Coalition: NA
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported one
exceedance of the daily maximum limit for fecal coliforms; and one violation of the monitoring frequency
for fecal coliforms in 2017.
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past
5 years): The facility passed 16 of 16 quarterly chronic toxicity tests between January 2018 and November
2021.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
December 28, 2021, reported that the facility was well maintained and operated.
Page 4 of 10

6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): NA
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed: NA
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1 (summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from chronic criteria, utilizing
a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1 (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: The current permit
requires ammonia nitrogen monitoring twice per monthly, with no limits. Based on results from the WLA
conducted seasonal monthly average and daily maximum limits will be added to the reissued permit for the
protection of aquatic life in the receiving stream as follows:
Monthly Average
Daily Maximum
Summer
5.3 mg/L
26.4 mg/L
Winter
14.7 mg/L
No limit (> 35 mg/L)
Reasonable Potential Analysis (RPA) for Toxicants
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of Y2 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between November 2017
and November 2021. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
Page 5 of 10

• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water
quality standards/criteria: None
• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but
the maximum predicted concentration was >50% of the allowable concentration: None
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria
and the maximum predicted concentration was <50% of the allowable concentration: None
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions.
The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits,
using single concentration screening tests, with multiple dilution follow-up upon a test failure.
Describe proposed toxicity test requirement: The current permit requires quarterly chronic toxicity testing
at 16% using Ceriodaphnia dubia. No changes are proposed.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year) and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (M 4Ps) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will receive
an MMP requirement. Industrials are evaluated on a case -by -case basis, depending on if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value
of 47 ng/1
Describe proposed permit actions based on mercury evaluation: The current permit does not include limits
or monitoring requirements. Mercury is not expected to be present in effluent, no MMP or limit is required.
No changes are proposed.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit: The facility is currently required to monitor TN and TP monthly, no changes are proposed.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A
NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: NA
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: NA
Page 6 of 10

7. Technology -Based Effluent Limitations (TBELs)
Describe what this facility produces: Pharmaceuticals, sterile liquid in flexible bags.
List the federal effluent limitations guideline (ELG) for this facility: 40 CFR 439 Subpart D, 40 CFR 463
Subpart A, 40 CFR 133 secondary treatment standards, and BPJ.
If the ELG is based on production or flow, document how the average production/flow value was calculated:
This ELG is based on the following flows: cooling water from the extruders, non -contact cooling water,
boiler feed, process, and sanitary wastewater streams. The pollutant loading for each process are
summarized below. The information was provided by the facility in 2004, since there have not been any
significant changes in manufacturing, these data were used in the 2004, 2010, 2016, and this permit renewal.
Source flow
Extrusion
Boiler feed
Process
Sanitary
BOD5 (lb/day) COD (lb/day) TSS (lb/day)
106.2 174.2 97.1
0 0 84.1
1,900.9 3,088.8 28.9
666.7 1,092.9 229
For ELG limits, document the calculations used to develop TBEL limits:
• BOD5, COD, and TSS are based on 40 CFR 439 Subpart D and secondary treatment standards for
the sanitary wastewater component.
• Oil and Grease limits for the cooling water from the extruders are based on 40 CFR 463 Subpart
A, the sanitary wastewater limits are based on BPJ of 30 mg/L DM and 60 mg/L MA.
Comparison of the recalculated limits using current flow data and current permit limits are summarized
below for comparison. The calculated limits are less stringent than the current permit. Since the facility
has no current plans for expansion no changes are proposed.
Table. TBEL Development per 40 CFR 133, 40 CFR 439 Subpart D, 40 CFR 463 Subpart A
Pollutant
Daily Max
Limit
(lb /d)
Current Limit
(lb/d)
Monthly Average
Limit
(lb/d)
Current Limit
(lb/d)
BOD5
645.21
691.40
430.14
460.90
COD
1,766.79
1,939.20
1,177.86
1,292.80
TSS
1,123.48
417.00
748.99
278.00
O&G
95.86
95.40
47.93
47.70
If any limits are based on best professional judgement (BPJ), describe development: The allocation for Oil
and Grease for the sanitary wastewater are based on BPJ of 30 mg/L DM and 60 mg/L MA.
Document any TBELs that are more stringent than WQBELs: The TBELs limits for BOD, COD, Oil and
Grease, and TSS are more stringent than the 1994 model conducted by the Division.
Document any TBELs that are less stringent than previous permit: NA
Page 7 of 10

8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all cases,
existing instream water uses and the level of water quality necessary to protect the existing use is maintained
and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations
and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES
Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced
Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional
Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered
effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding
prohibitions would not be triggered by reductions in monitoring frequencies.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December
21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs)
electronically. While NPDES regulated facilities would initially be required to submit additional NPDES
reports electronically effective December 21, 2020, EPA extended this deadline from December 21, 2020,
to December 21, 2025. The current compliance date, effective January 4, 2021, was extended as a final
regulation change published in the November 2, 2020 Federal Register This permit contains the
requirements for electronic reporting, consistent with Federal requirements.
Page 8 of 10

12.Summary of Proposed Permitting Actions:
A. Table. Current Permit Conditions and Proposed Changes 1.2 MGD
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 1.2 MGD
No change
15A NCAC 2B .0505
BOD5, 20°C
MA 460.9 lbs/day
DM 691.4 lbs/day
No change
TBEL. 40 CFR 439 Subpart D /Secondary
treatment standards/40 CFR 133/15A
NCAC 2B .0406
COD
MA 1,292.8 lbs/day
DM 1,939.2 lbs/day
No change
TBEL. 40 CFR 439 Subpart D /Secondary
treatment standards/40 CFR 133/15A
NCAC 2B .0406
Total Suspended
Solids
MA 278.O lbs/day
DM 417.O lbs/day
No change
TBEL. 40 CFR 439 Subpart D /Secondary
treatment standards/40 CFR 133/15A
NCAC 2B .0406
NH3-N summer,
mg/L
Monitor 2/month
MA 5.3 mg/L
DM 26.4 mg/L
WQBEL. Based on protection of aquatic
life. 15A NCAC 2B.0200
NH3-N winter, mg/L
Monitor 2/month
MA 14.7 mg/L
WQBEL. Based on protection of aquatic
life. 15A NCAC 2B.0200
Fecal Coliform
MA 200 /100m1
DM 400 /100m1
No change
WQBEL. State WQ standard, 15A NCAC
2B .0200
Total Residual
Chlorine'
28 µg/L
No change
WQBEL. State WQ standard, 15A NCAC
2B .0200
Turbidity, NTU
None
DM 10 NTUs
WQBEL. State WQ standard, 15A NCAC
2B .0211(21)
Temperature, °C
Monitor 3/week
No change
WQBEL. State WQ standard, 15A NCAC
2B .0200 and 15A NCAC 02B .0500
Conductivity,
µS/cm
Monitor 3/week
No change
WQBEL. State WQ standard, 15A NCAC
2B .0200 and 15A NCAC 02B .0500
Dissolved Oxygen,
mg/L
Monitor 3/week
No change
WQBEL. State WQ standard, 15A NCAC
2B .0200 and 15A NCAC 02B .0500
pH
>6.0 and < 9.0 SU
No change
WQBEL. State WQ standard, 15A NCAC
2B .0200 and 15A NCAC 02B .0500
Oil & Grease
MA 47.7 lbs/day
DM 95.4 lbs/day
Monitor weekly
MA 47.7 lbs/day
DM 95.4 lbs/day
Monitor 2/month
TBEL. 40 CFR 463/BPJ/40 CFR 133 /15A
NCAC 2B .0406
Total Nitrogen
(NO2 + NO3 +
TKN), mg/L
Monitor 1/month
No change
WQBEL. State WQ standard, 15A NCAC
2B .0200 and 15A NCAC 02B .0500
Total Phosphorus,
mg/L
Monitor 1/month
No change
WQBEL. State WQ standard, 15A NCAC
2B .0200 and 15A NCAC 02B .0500
Chronic Toxicity
Monitor 1/quarter
No change
WQBEL. No toxics in toxic amounts. 15A
NCAC 2B.0200 and 15A NCAC 2B.0500
Total hardness as
CaCO3, mg/L
None
Monitor 1/quarter
Hardness -dependent dissolved metals WQ
standard, 2016
MGD - Million gallons per day, MA - Monthly Average, WA - Weekly Average, DM - Daily Max
Page 9 of 10

13. Public Notice Schedule:
Permit to Public Notice: 01/27/2021
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
14. NPDES Division Contact
If you have any questions regarding any of the above information or on the attached permit, please
contact Julia Byrd at [phone] or via email at [e-mail].
15. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
If Yes, list changes and their basis below:
1. Supplement to Permit Cover Sheet, item 2 was revised to remove authorization to discharge at the
location designated "Old Outfall" (35°50'15" N, 82°00'00" W) which was permanently closed.
See attached correspondences.
2. pH monitoring requirement revised from daily to three times per week. 15A NCAC 02B .0508 for
class III facilities with SIC codes 2800-2899.
3. Effluent turbidity monitoring three times per week was added per 15A NCAC 02B .0211(21)
4. Footnote 8 added to instream Temperature (A.1), the facility shall not exceed the instream water
temperature of 20°C and not exceed 0.5°C above the background temperature.
5. Correction made to TN and TP monitoring requirement, changed from quarterly to monthly.
16. Fact Sheet Attachments (if applicable):
• Monitor Violations Summary
• WET Testing and Self -Monitoring Summary
• Compliance Inspection Report December 2021
• NPDES Implementation of Instream Dissolved Metals Standards — Freshwater Standards
• NH3/TRC WLA Calculations
• TBELs limits calculations
• Correspondences: Old Outfall closure
• Affidavit of draft permit for public notice
• Public comments to draft permit and DWR responses: Baxter Health Corporation, Catawba
Riverkeeper Foundation, Lake James Environmental Association
Page 10 of 10

LOCATION PARAMETER VIOLATIONDATE FREQUENCY UNIT OF MEASURE LIMIT CALCULATED VALUE % OVER VIOLATION TYPE VIOLATION ACTION
Effluent Coliform, Fecal MF, MF 02/04/2017 3 X week #/100m1 Frequency Violatior No Action, Facility Rep,
Effluent Coliform, Fecal MF, MF 03/20/2017 3 X week #/100m1 400.0000 600.0000 50 Daily Maximum Exceec Proceed to NOV
Effluent Coliform, Fecal MF, MF 06/03/2017 3 X week #/100m1 Frequency Violatior Proceed to NOV

Whole Effluent Toxicity Testing and Self Monitoring Summary
Aurora WWTP NC0021521/001 County: Beaufort
Mysd24PF Begin: 1/1/2020 24hr p/f ac lim: 90% + NonComp: Single
Region: WARO
7Q10: TIDAL
Basin: TAR07 Mar Jun Sep Dec
PF: 0.12 IWC: NA Freq: Q
SOC JOC:
J F M A M J J A S 0 N D
2018 - - Pass - - Pass - - Pass - - Pass
2019 - - Pass - - Pass - - Pass - - Pass
2020 - - Pass - - Pass - - Pass - - Pass
2021 - - Pass - - Pass - - Pass - - Pass
Badin Business Park (Alcoa) NC0004308/011 County: Stanly Region: MRO Basin: YAD08 Mar Jun Sep Dec
Fthd24Ac Begin: 8/1/2019 24hr Fthd AC LC50 ep NonComp: 7Q10: NA PF: VAR IWC: NA Freq: 1x/Q
SOC JOC:
J F M A M J J A S 0 N D
2018 - - H H H H Invalid >100
2018 - Pass H - 95.2 H Fail Fail Fail Pass -
2019 - - - H - H >100
2019 - >100 Pass - - Pass - >100 >100
2020 - >100 - - >100 - >100 >100
2020 - >100 - - - -
2020 - >100 - >100 - - - - LC50>100% >100 -
2021 >100 - - - - - -
2021 INVALID >100 - >100 - - - >100 - >100
2021 H - - H >100 -
Bald Head Island Utilities NC0085553/001 County: Brunswick Region: WIRO Basin: CPF17 Jan AprJul Oct
Mysd24PF Begin: 1/1/2018 24hr p/f ac Monit 90 NonComp: 7Q10: Tidal PF: 0.087 IWC: NA Freq: Q
SOC JOC:
J F
2018 Invalid Pass
2019 Pass
2020 Pass -
2021 Pass -
M A M J J A S 0 N D
- Pass - - Pass - - H -
- Fail - - Pass - - Fail -
- Fail - - Pass - - Pass -
- Fail - - Pass - - Pass -
Baxter Healthcare Corp. NC0006564/001
Ceri7dPF Begin: 3/1/2010 chr lim: 16%
County: McDowell
NonComp: Single
Region: ARO
7Q10: 10.2
Basin: CTB30 Feb May Aug Nov
PF: 1.2 IWC: 15.5 Freq: Q
SOC_JOC:
J F M A M J J A S 0 N
2018 - Pass - - Pass - - Pass Pass - - Pass
2019 - Pass - - Pass - - Pass - - Pass
2020 - Pass - - Pass - - Pass - - Pass
2021 - Pass - - Pass - - Pass - - Pass
Bay Valley Foods, LLC NC0001970/001 County: Duplin Region: WIRO Basin: CPF22 Jan AprJul Oct
Cer7dChV Begin: 8/1/2011 Chr Monit (100,75,50 NonComp: 7Q10: 0.0 PF: 0.50 IWC: 100 Freq: Q
SOC JOC:
J
F M A M J J
A
S 0 N D
2018 61.2 - - 35.4 - - 35.4 - - 35.4
2019 61.2 - - 61.2 - - 35.4 - - 61.2
2020 35.4 - - 35.4 - - 35.4 - - 35.4
2021 35.4 - - 35.4 - - 61.2 - - 61.2
2022 35.4 - - - - - -
Legend: P= Fathead minnow (Pimphales promelas), H=No Flow (facility is active), s = Split test between Certified Labs
Page 6 of 100

DocuSign Envelope ID: 9B554326-D360-4F0A-A365-8C68B1D4FFD6
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.
January 05, 2022
Corey Carpentier
Baxter Healthcare Corporation
Email: [e-mail]
SUBJECT: Compliance Inspection Report
Baxter Healthcare Corporation
NPDES WW Permit No. NC0006564
McDowell County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Baxter Healthcare
Corporation on 12/28/2021. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES WW Permit No. NC0006564. 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 me at 828-296-4667 or via email at
[e-mail].
ATTACHMENTS: Inspection Report
Ec: Laserfiche
Brian Valiquette (ORC)
Stephen Gouge (EHS Manager)
Sincerely,
DocuSigned by:
(,aLMU& uViolUU
�CB17648770724E6...
Lauren Armeni, Environmental Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
D_EQ�
North Carolina Department of Entironmental Quality I Division of Water Pa.:o ces
AshElk Regional OM. 12090 US. Highway 70 I Swannanaa, Narth Carolina 28778
825.296.450E

DocuSign Envelope ID: 9B554326-D360-4F0A-A365-8C68B1D4FFD6
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 IN 1 2 E 3 I NC0006564 111 121 21/12/28 117
Type
181 c I
11111111111
Inspector Fac Type
19 I s I 2011
21111111 11111111111 1111111 1111111
166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 1 70I 1 711
1 72 I N I 731 I 174 71
I I I 1
III III 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Baxter Healthcare Corporation
65 Pitts Sta Rd
Marion NC 287527925
Entry Time/Date
09:15AM 21/12/28
Permit Effective Date
16/09/01
Exit Time/Date
10:45AM 21/12/28
Permit Expiration Date
20/01/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Anita Jensen, /// Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement • Operations & Maintenar Records/Reports
Self -Monitoring Progran Sludge Handling DispoE Facility Site Review Effluent/Receiving Wate
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Lauren E Armeni DWR/ARO WQ/828-296-4500/
-DocuSigned by: 1/5/2022
�,A.IAV't,l�, al�t,�.�
Ub I,B4,1/ ,U,C4tO...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
r__Docusgnedby:
,g1/5/2022
E397192DABFB4FF..
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

DocuSign Envelope ID: 9B554326-D360-4F0A-A365-8C68B1D4FFD6
31
NPDES yr/mo/day
NC0006564 111 121 21/12/28
I17
Inspection Type
18 [j
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lauren Armeni, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of
the Baxter Healthcare Corporation WWTP on December 29, 2021. This inspection was conducted to
determine whether the facility is being operated and maintained in compliance with NPDES Permit
No. NC0006564. Brian Valiquette (ORC), Corey Carpentier (Senior Environmental Engineer), and
Stephen Gouge (EHS Manager) were present and assisted in the inspection.
Overall, the facility is well -maintained and operated, and appears to be in compliance with NPDES
Permit No. NC0006564.
Equalization Basins:
At the time of the inspection, one surface aerator motor was broken in EQ Tank #2. The replacement
is on site and they are waiting on a crane service to swap out the motors. Surface aerators are
constantly running. Flow from the EQ basins enters a fine mesh screen (2 mm) and then goes into
the pH tank, where the two streams from the EQ basins are mixed together and pH levels are
adjusted as needed. It is crucial for any additional debris to be screened out of the wastewater in
order to protect the downstream membrane filters. Following the pH tank is the nutrient dosing tank,
which adds nutrients as needed.
Aeration Basins/Membrane Filtration:
Following the aeration basins, membrane filtration is the next step in the treatment process. The
filters are continuously aerated. These filters are cleaned twice a week with bleach and citric acid.
Sludge collects at the bottom and is either wasted to one of two digesters or returned to EQ Basin #1.
Sludge Handling:
Taken from Baxter's Sludge Management Plan, "The digested sludge is dewatered through a
centrifuge to a 14%- 20% cake. Drainage from the sludge and wash down water from the centrifuge is
pumped back to equalization basin #1 for recirculation through the aeration basins and membrane
filtration process. The cake is conveyed to a dump trailer positioned under a roof at the centrifuge
dewatering building. Once this trailer is filled, it is picked up by Southern Soil Builders, Inc.
and transported to Catawba County where it is land applied to four field sites totaling 80.8
net acres." The centrifuge is ran approximately four times per week. Their sludge land application
permit number is WQ0031725.
Page# 2

DocuSign Envelope ID: 9B554326-D360-4F0A-A365-8C68B1D4FFD6
Permit: NC0006564
Inspection Date: 12/28/2021
Owner - Facility: Baxter Healthcare Corporation
Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new ME ❑ ❑
application?
Is the facility as described in the permit? • ❑ ❑ ❑
# Are there any special conditions for the permit? ❑ • ❑ ❑
Is access to the plant site restricted to the general public? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑
Comment: The permit is currently in the renewal process.
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment:
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
•
•
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ • ❑
Yes No NA NE
• ❑ ❑ ❑
Page# 3

DocuSign Envelope ID: 9B554326-D360-4F0A-A365-8C68B1D4FFD6
Permit: NC0006564
Inspection Date: 12/28/2021
Owner - Facility: Baxter Healthcare Corporation
Inspection Type: Compliance Evaluation
Operations & Maintenance
Yes No NA NE
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable MD ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The facility is is well -maintained with excellent housekeeping. Process control
parameters include COD (influent autosampler), pH, FC, ammonia,
phosphate, conductivity, MLSS, membrane pressure, UV transmittance, and
DO.
Bar Screens Yes No NA NE
Type of bar screen
a.Manual ❑
b.Mechanical •
Are the bars adequately screening debris? • ❑ ❑ ❑
Is the screen free of excessive debris? ■ ❑ ❑ ❑
Is disposal of screening in compliance? ■ ❑ ❑ ❑
Is the unit in good condition? • ❑ ❑ ❑
Comment:
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: There are two EQ basins - one for high strength COD (2,500 mg/L or greater - EQ
Basin #2) and one for low strength COD (less than 2,500 mg/L - EQ Basin #1). When
mixed together, the ideal COD of approximately 1,000 mg/L is maintained. The EQ
basin with the high strength COD can be fed through at a slower rate to maintain this
ideal COD concentration. See summary for details.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots? • ❑ ❑ ❑
Are surface aerators and mixers operational? ❑ ❑ MI ❑
Page# 4

DocuSign Envelope ID: 9B554326-D360-4F0A-A365-8C68B1D4FFD6
Permit: NC0006564
Inspection Date: 12/28/2021
Owner - Facility: Baxter Healthcare Corporation
Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Are the diffusers operational? • ❑ ❑ ❑
Is the foam the proper color for the treatment process? • ❑ ❑ ❑
Does the foam cover less than 25% of the basin's surface? • ❑ ❑ ❑
Is the DO level acceptable? ❑ ❑ ❑ •
Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ ❑ •
Comment: Flow from the nutrient dosing tank enters one of three aeration basins, which run in
parallel. Mr. Valiquette said MLSS is kept around 6,500 mg/L, but wasting is increased
if MLSS exceeds this number. DO is auto-adiusted within the basins and is kept around
3.2 mg/L. See summary for details.
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: Activated sludge collects at the bottom of the membrane filters and is pumped to one of
two aerobic digesters as needed. See summary for details on how sludge from the
digester is handled.
Disinfection - UV Yes No NA NE
Are extra UV bulbs available on site? • ❑ ❑ ❑
Are UV bulbs clean? • ❑ ❑ ❑
Is UV intensity adequate? • ❑ ❑ ❑
Is transmittance at or above designed level? • ❑ ❑ ❑
Is there a backup system on site? • ❑ ❑ ❑
Is effluent clear and free of solids? • ❑ ❑ ❑
Comment: The UV system is maintained weekly by staff.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: The effluent flow meter was last calibrated on September 27, 2021.
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ •
Page# 5

DocuSign Envelope ID: 9B554326-D360-4F0A-A365-8C68B1D4FFD6
Permit: NC0006564
Inspection Date: 12/28/2021
Owner - Facility: Baxter Healthcare Corporation
Inspection Type: Compliance Evaluation
Flow Measurement - Effluent Yes No NA NE
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? • ❑ ❑ ❑
Is sample collected below all treatment units? • ❑ ❑ ❑
Is proper volume collected? • El El El
Is the tubing clean? • ❑ ❑ El
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 • ❑ ❑ ❑
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type • El El ❑
representative)?
Comment: At the time of the inspection, the thermometer read 4 degrees Celcius.
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up
power?
Is the generator fuel level monitored?
Yes No NA NE
▪ ❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
❑ ❑ ❑ •
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: The generator has been able to run the entire facility during power outages. At the
time of the inspection, the fuel gauge was full. The generator is tested quarterly by
Carolina Cat.
Page# 6

Permit No. NC0006564
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards as approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, 14/1
(Dissolved)
Chronic FW, 14/1
(Dissolved)
Acute SW, 14/1
(Dissolved)
Chronic SW, 14/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life standards
for Mercury and selenium are still expressed as Total Recoverable Metals due to bioaccumulative
concerns (as are all human health standards for all metals). It is still necessary to evaluate total
recoverable aquatic life and human health standards listed in 15A NCAC 2B.0200 (e.g., arsenic at
10 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for aquatic life
protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .021 Sub naraeranh (111(dl
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER*{1.1366724ln hardness](0.041838)} - e^{0.9151 [ln hardness]-3.1485}
Cadmium, Acute Trout waters
WER*{1.136672-[ln hardness](0.041838)} - e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER*{1.101672-[ln hardness](0.041838)} - e^{0.7998[In hardness]-4.4451}
Chromium III, Acute
WER*0.316 - e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 • e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 • e^{0.9422[ln hardness]-1.700}
Copper, Chronic
WER*0.960 • e^{0.8545[ln hardness]-1.702}
Lead, Acute
WER* {1.46203-[ln hardness](0.145712)} • e^{1.273[ln hardness]-1.460}
Lead, Chronic
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[ln hardness]-4.705}
Nickel, Acute
WER*0.998 • e^{0.8460[ln hardness]+2.255}
Nickel, Chronic
WER*0.997 • e^{0.8460[ln hardness]+0.0584}
Silver, Acute
WER*0.85 • e^{1.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 • e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 • e^{0.8473[ln hardness]+0.884}
Page 1 of 4

Permit No. NC0006564
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness -dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge -specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with established
methodology.
RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the discharge
has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If monitoring
for a particular pollutant indicates that the pollutant is not present (i.e. consistently below detection level),
then the Division may remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1Q10 using the formula 1Q10 = 0.843 (s7Q10, cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the hardness
value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and upstream
hardness samples over a period of one week. The RPA is rerun using the new data.
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
= (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) + (s7Q10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.
Page 2 of 4

Permit No. NC0006564
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any have
been developed using federally approved methodology.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
Cdiss = 1
Ctotal 1 + /KPA] [SSct+a)] /10 61
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q10 + Qw) (Cwqs) — (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q10)
s7Q10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q10 may be incorporated as applicable:
1Q10 = used in the equation to protect aquatic life from acute toxicity
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
Page 3 of 4

Permit No. NC0006564
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show reasonable
potential to violate the water quality standard, and a permit limit (Total allowable concentration) is
included in the permit in accordance with the U.S. EPA Technical Support Document for Water
Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on 40
CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and hexavalent
chromium Water Quality Standards. As a cost savings measure, total chromium data results may
be used as a conservative surrogate in cases where there are no analytical results based on chromium
III or VI. In these cases, the projected maximum concentration (95th %) for total chromium will be
compared against water quality standards for chromium III and chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are inserted
into all permits with facilities monitoring for hardness -dependent metals to ensure the accuracy of
the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25.00
Default value, no hardness data
available
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25.00
Default value, no hardness data
available
7Q10 summer (cfs)
10.2
NPDES Files
1 Q 10 (cfs)
8.46
Calculated in RPA
Permitted Flow (MGD)
1.2
NPDES Files
Date: 1/10/22
Permit Writer: Julia Byrd
Page 4 of 4

NH3/TRC WLA Calculations
Facility: Baxter Healthcare Corp
PermitNo. NC0006564
Prepared By: Julia Byrd
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
1.2
10.2
15.2
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/I)
IWC (%)
Allowable Conc. (ug/I)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
10.2
1.2
1.86
17.0
0
15.42
110
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
6.48 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
10.2
1.2
1.86
1.0
0.22
15.42
5.3
15.2
1.2
1.86
1.8
0.22
10.90
14.7
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Oil and Grease
40 CFR 463 Subpart A
Flow
Extrusion
Sanitary 60
-it
BOD5 (BPT)
40 CFR 439 Subpart D
Allocation DM MA Flow Allocation DM MA
29 20.80 10.40 Extrusion 26 18.65
Boiler 0
NonContact 0
95.86 47.93 Process 570.27
Secondary TS
Sanitary 45 56.30
5.21 430.14
BPJ
30 75.06 37.53
40 CFR 439 Subpart D
Flow Allocation DM MA
Extrusion 26 18.65
Boiler
NonContact
Process
Secondary TS
Sanitary 56.30 84.44
TSS
40 CFR 439 Subpart D (A)
Flow Allocation DM MA
Extrusion 19 13.63
Boiler 84.1
Process 570.27 969.46
Secondary TS
Sanitary 45 56.30
TSS limit 1123.48
748.99

Application Data
Flows (MGD)
BOD5
COD
TSS
GW (intake) 1.442
#/day
mg/L
#/day
mg/L
#/day
mg/L
Boiler feed 0.329
84.1
30.65
Sanitary 0.15
1092.9
873.62
Process 0.35
1900.9
651.22
3088.8
1058.17
Cooling Ponds 0.175
Extrusion 0.086
174.2
242.88

From: Armeni, Lauren E
Sent: Wednesday, February 16, 2022 11:08 AM
To: Byrd, Julia
Subject: FW: [External] RE: [ EXTERNAL ] Baxter Permit Renewal - Outfall Question
Lauren Armeni
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
828 782 0064 mobile
[e-mail] <mailto:[e-mail]>
2090 U.S. Hwv. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Depailiuent of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are
on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time.
From: Gouge, Stephen D [mailto:[e-mail]]
Sent: Wednesday, February 16, 2022 11:07 AM
To: Armeni, Lauren E <[e-mail]>
Cc: Valiquette, Brian <brian [e-mail]>; Carpentier, Corey <[e-mail]>
file:///C/...%20State%20o1%20North%20Carolina/NC0006564/NC0006564_2022%20renewal/Correspondences/old%20outfall%20closure.txt[4/4/2022 9:22:12 AM]

Subject: [External] RE: [ EXTERNAL ] Baxter Permit Renewal - Outfall Question
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam. <mailto:[e-mail]>
Lauren,
Sorry for the delay in getting back to you. I've included a photo which shows the location where our old outfall
pumphouse used to be. At the old site, the outfall pumphouse once sat inside this fenced area. Once the new plant was
online, we removed the building. Now, this empty area is all that remains. When the building was still standing, I
believe Tim Heim (and possibly Daniel Boss?) came to verify that the old outfall was decommissioned, but it's been
several years ago. If you need anything else, don't hesitate to ask.
Stephen Gouge
EHS Manager
Baxter Healthcare Corporation / North Cove Facility
65 Pitts Station Road / Marion, NC 28752
T +1.828.756.6608
[e-mail] <mailto:[e-mail]>
From: Armeni, Lauren E <[e-mail] <mailto:[e-mail]> >
Sent: Friday, February 11, 2022 3:41 PM
To: Valiquette, Brian <[e-mail] <mailto:[e-mail]> >
Cc: Gouge, Stephen D <[e-mail] <mailto:[e-mail]> >; Carpentier, Corey
<[e-mail] <mailto:[e-mail]> >; Byrd, Julia <[e-mail]
<mailto:[e-mail]> >
Subject: [ EXTERNAL ] Baxter Permit Renewal - Outfall Question
[EXTERNAL]
file:///C/...%20State%20o1%20North%20Carolina/NC0006564/NC0006564_2022%20renewal/Correspondences/old%20outfall%20closure.txt[4/4/2022 9:22:12 AM]

Good Afternoon,
After reviewing the draft permit renewal, I noticed that it mentioned an old outfall that was supposed to be permanently
closed during the last permit cycle. I was wondering if this outfall has been closed, and if so, if you have pictures or
documentation of it.
Thank you,
Lauren Armeni
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
828 782 0064 mobile
[e-mail]<mailto:[e-mail]>
2090 U.S. Hwv 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Depailiuent of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are
on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
file:///C/...%20State%20o1%20North%20Carolina/NC0006564/NC0006564_2022%20renewal/Correspondences/old%20outfall%20closure.txt[4/4/2022 9:22:12 AM]

appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time.
From: Armeni, Lauren E
Sent: Wednesday, February 16, 2022 11:01 AM
To: Byrd, Julia
Subject: FW: Baxter Outfall Closure
Lauren Armeni
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
828 782 0064 mobile
[e-mail]<mailto:[e-mail]>
2090 U.S. Hwv. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Depailiuent of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are
on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time.
file:///C/...%20State%20o1%20North%20Carolina/NC0006564/NC0006564_2022%20renewal/Correspondences/old%20outfall%20closure.txt[4/4/2022 9:22:12 AM]

From: Heim, Tim
Sent: Wednesday, February 16, 2022 11:01 AM
To: Armeni, Lauren E <[e-mail]>
Subject: Baxter Outfall Closure
Lauren,
This e-mail is verification that I performed a field visit to the Baxter Healthcare Facility in McDowell County and
confirmed that they had decommissioned their previous WWTP outfall. The new one discharges approximately 500
upstream.
-Tim
Tim Heim, P.E.
Environmental Engineer — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
email: [e-mail] <mailto:[e-mail]>
2090 U.S. Hwy 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Depailment of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are
on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time.
file:///C/...%20State%20o1%20North%20Carolina/NC0006564/NC0006564_2022%20renewal/Correspondences/old%20outfall%20closure.txt[4/4/2022 9:22:12 AM]

The McDowell News
Advertising Affidavit Account Number
3611028
PO Box 968
Hickory,NC 28603 Date
January 27,2022
NCDEQ/DWR
ATTN:WREN THEDFORD
1617 MAIL SERVICE CENTER
RALEIGH,NC 27699-1617
Date Category Description Ad Number Ad Size
01/27/2022 Legal Notices Public Notice North Carolina Environmental Management Comi 0000765397 2 x 30 L
Publisher of
The McDowell News
McDowell County
Before the undersigned,a Notary Public duly commissioned,qualified,
and authorized by law to administer oaths,personally appeared the
Publisher's Representative who by being duly sworn deposes and says:
that he/she is authorized to make this affidavit and sworn statement;that
the notice or other legal advertisement,a copy of which is attached hereto,
was published in the McDowell News on the following dates:
01/27/2022
and that the said newspaper in which such notice,paper document,or
legal advertisement was published,was at the time of each and every such
publication,a newspaper meeting all the requirements and qualifications
of Section 1-597 of the General Statutes of North Carolina.
Billing Representative
Newspaper reference:0000765397
Sworn to and subscribed before me,this 27th day of January, 2022.
Notary blic Linh Thuy Le
Notary Public
State of Virginia Commonwealth of Virginia
County of Hanover Reg. No 7953581
My commission expires: My Comm. Expires Nov. 30, 2025
THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU

Public Notice
North Carolina Environmental Management Commission/NPDES Unit
1617 Mail Service Center
Raleigh,NC 27699-1617
Notice of Intent to Issue a NPDES Wastewater Permit NC0006564 Baxter
Healthcare Corporation The North Carolina Environmental Management
Commission proposes to issue a NPDES wastewater discharge permit to
the person(s) listed below. Written comments regarding the proposed
permit will be accepted until 30 days after the publish date of this notice.
The Director of the NC Division of Water Resources(DWR)may hold a pub-
lic hearing should there be a significant degree of public interest.Please
mail comments and/or information requests to DWR at the above ad-
dress.Interested persons may visit the DWR at 512 N.Salisbury Street,Ra-
leigh,NC 27604 to review information on file. Additional information on
NPDES permits and this notice may be found on our website:
http://deq.nc.gov/about/divisions/water-resources water--
resources-permits]astewater-branch/npdes-wastewater/notices,or or by calling(919)707-3601. The Baxter Healthcare Corporation
[65 Pitts Station Rd,Marion,NC 28752}has requested renewal of permit
NC0006564 for its WWTP in McDowell County.This permitted facility dis-
charges treated process and sanitary wastewater to the North Fork Cata-
wba River in the Catawba River Basin.Currently some parameters are wa-
ter quality limited.This discharge may affect future allocations in this seg-
ment of the Catawba River.
Publish:January 27,2022.

Baxter
February 28, 2022
NCDEQ/DWR/NPDES
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Baxter Healthcare Corporation
P.O. Box 1390
Marion, NC 28752
RECEIVED
MAR 0 9 2022
NCDEQ/DWRINPDES
RE: Notice of Intent to Issue NPDES Wastewater Permit NC0006564 Baxter Healthcare Corporation
This comment is being provided by the Baxter Healthcare North Cove facility in support of NPDES Permit
NC0006564. Baxter thanks NCDEQ staff for its work on this permit renewal. We also appreciate your quick
response to address our effluent pH measurement frequency question to clarify that the monitoring
obligation listed in the Table in Part I.A will continue at three times a week.
Baxter has operated the North Cove facility for 50 years, employing 3000 people. Our facility is the number
one provider of lifesaving/sustaining I.V. solutions to the US market. A core principle at Baxter is that we
are committed to operating our facilities in an environmentally responsible manner; as such,
environmental compliance is at top priority at Baxter. At the North Cove facility, we have demonstrated
this by:
• Implementation and maintenance of Environmental Management Systems whereby the
facility maintains an ISO 14001 certification.
• Commitment to continued improvements, including $24 million in design and
construction of a state-of-the-art wastewater treatment facility that became operational
in 2017.
• Achieved a 94% zero to waste landfill rate.
Baxter Healthcare strives to eliminate any adverse impacts to our environment, including the North Fork
Catawba River, and we are exceptionally proud of our wastewater treatment facility and staff. The
Baxter Healthcare North Cove facility is supportive of the proposed permit and will continue to partner
with the DEQ to ensure our continued compliance.
Brian D Smith
EHS Director
Baxter Healthcare Corporation

CATAWBA
RIVERKEEPEW
February 28, 2022
NCDEQ/DWR/NPDES
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Julia Byrd,
The Catawba Riverkeeper Foundation is a member -funded environmental nonprofit that educates and
advocates forthe protection of the Catawba-Wateree River and all its tributaries. Our organization
represents over 6,000 active members who rely on the watershed for drinking water, recreation, and
electricity. The North Fork of the Catawba River is a majortributary to Lake James and is a designated
Class B trout water. We appreciate the opportunity to comment on the Baxter Healthcare Corporation's
NPDES permit (NC00006564) and make the following recommendations:
• Monitor and limit turbidity
The facility discharges into a designated trout water. Facility discharge should be monitored
to ensure stream turbidity does not exceed 10 NTUs.
• Place limits on discharge temperature
The facility discharges into a designated trout water. The draft permit does not include a
temperature limit despite the published fact sheet showing a0.67°C average increase and a
max downstream temp of 24.3°C. This appears to violate 15A NCAC 02B .0211(18) "...the
temperature for trout waters shall not be increased by more than 0.5 degrees C (0.9 degrees
F) due to the discharge of heated liquids, but in no case to exceed 20 degrees C (68 degrees
F.
• Monitor E. coli in addition to fecal coliform
The facility discharges into a designated Class B water. For the last 36 years, the EPA has
recommended using E. coli instead of fecal coliform as an indicator for pathogens. Last year
DWR finally proposed updatingthe standard and the Environmental Management
Commission is expected to vote on it in March. North Fork users should not have to wait
another 5 years fora more accurate measure of fecal contamination.
• Increased monitoring and reporting frequency of Total Nitrogen, Total Phosphorus, and
Hardness.
Data Collected by the Lake James Environmental Association (UEA) and a 2018 DWR
Catawba Nutrient Study indicates that the North Fork is a major contributor of nutrients into
Lake James. The 2017 DWR Lake James Survey and Dr. Mark Brennerof Warren Wilson
A WATERKEEPER ALLIANCE° Member
115 Willow Drive McAdenville NC 28211
Phone: [phone] Fax: [phone]
www.catawbariverkeeper.org

College have reported elevated densities of phytoplankton atthe lake'swestern end. An
increase in the monitoringfrequencywill allow a more accurate quantification of the
facility's contribution, if any. While the permitfact sheet lists a current and proposed
frequency ofl/month, the published draft permit decreases the requirement to quarterly
monitoring.
For the River,
f'" / f` .`
/
G-- +z 6' Iv
..,.--•
BrandonJones
Catawba Riverkeeper
A WATERKEEPER ALLIANCE° Member
115 Willow Drive McAdenville NC 28211
Phone: [phone] Fax: [phone]
www.catawbariverkeeper.org

NC0006564
DWR response to CRF Comments
The Catawba River Keeper Foundation submitted comments regarding the draft permit NC0006564 which
was received by the Division February 28, 2022. The comments and responses from the Division are
summarized below:
1. The facility discharges into a designated trout water. The discharge should be monitored to ensure
stream turbidity does not exceed 10 NTUs.
a. Effluent turbidity monitoring three times per week were added to the permit, per 15A
NCAC 02B .0211 (21) and .0219 (1).
2. The draft permit does not include a temperature limit which appears to violate 15A NCAC 02B
.0211 (18).
a. Footnote was added to effluent temperature requirement per 15A NCAC 02B .0211 (18)
and .0219 (1) [See A. (1.), Footnote 8].
3. Monitor E. coli in addition to fecal coliform.
a. The permit includes monitoring and limits for fecal coliform as an indicator of pathogens.
The Environmental Management Commission has not yet approved the use of E. coli as
an indicator for pathogens; and there is no standard promulgated for E. coli in the 02B
Surface Water and Wetland Standard. This request cannot be implemented in the permit
at this time. The Division of Water Resources is currently working to establish a statewide
standard that includes monitoring and total maximum daily loads E. Coli.
4. Increased effluent constituent monitoring requirements for Total Nitrogen, Total Phosphorous,
and Total Hardness.
a. Per 15A NCAC 02B .0508, for Class III facilities with SIC 2800-2899 and discharge of 1.0
MG or greater to the Catawba River Basin, monthly monitoring for Total Nitrogen and
Total Phosphorous is required and included in the permit. Per the 2016 NPDES
Implementation of Instream Dissolved Metals Standards guidance, upstream and effluent
monitoring for Total Hardness is required once per quarter and included in the permit

Lake James
Environmental
- Association
To protect and enhance the tong -term environmental health andnaturat beauty of Lake James and its watershed
P.O. Box 430, Nebo, NC 28761
Website: www.ljea.org Email: info((aljea.org Phone: [phone]
February 25,2022
S. Daniel Smith, Director
NC Division of Water Resources
NC Environmental Management Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Smith,
RE: Baxter Healthcare Corporation
NPDES Permit No. NC0006564
Lake James Environmental Association (LJEA) is a non-profit, volunteer -driven environmental
organization focused on the protection of the watershed of Lake James, which includes the North
Fork Catawba River. Established in 1973, LJEA has a long history of protecting the lakes, rivers and
streams flowing through the watershed, including many years of stream sampling and analyses and
participation in the Volunteer Watershed Information Network for the past 20 years. A main
tributary into the western end of Lake James, the North Fork Catawba River is directly impacted by
discharges; downstream, subsequent impacts on Lake James are concerning.
We appreciate the opportunity to comment on The Baxter Healthcare Corporation WWTP draft
NPDES Permit (NC0006564) renewal. At the direction of the LJEA Board of Directors, we make the
following requests which are further detailed on page 8 of the attached Addendum:
• Increase effluent constituent monitoring requirements. Include once per week sampling
and reporting of Total Nitrogen, Total Phosphorus, Orthophosphate, and Total Hardness.
• Consider impacts of discharges upon the North Fork Catawba River and Lake James. The
permit should not be renewed until these impacts have been studied, most notably impacts
on the impaired reach of the North Fork and upon nutrient enrichment in the west end of
Lake James. Intensive monitoring of the lower North Fork Catawba River and the west end
of Lake James should be conducted during 2022. This will determine impacts of the Baxter
discharge on the ecology of those waters and provide guidance for the establishment of
specific constituent discharge limits.
• Allow for adding discharge limitations. Stipulate in the permit that additional constituent
discharge limits may be imposed during the permit period and prior to a next renewal.

Attached as an Addendum is the LJEA Community Science Committee's comments on the proposed
Baxter NPDES permit renewal which is the basis for our recommendations. The data and analyses
demonstrate the issues and impacts found by LJEA and the serious concern for both the North Fork
Catawba River and Lake James.
Thank you for your consideration.
For the Watershed,
la,e/V--)7 r2u.)\-)
Todd Bell
President, Lake James Environmental Association
S4'iu ''''')
Sophie McCarthy
Executive Director, Lake James Environmental Association
Cc:
Julia Byrd, NC Div. of Water Resources, Industrial Permitting Unit
Doug Dowden, Div. of Water Resources, Supervisor, Industrial Permitting Unit
Craig Hesterlee, EPA Region 4, NPDES Permitting

ADDENDUM to LJEA Comments 02.25.22
Community Science Committee (CSC) comments on proposed
Baxter NPDES permit renewal
Lakes James Environmental Association (LJEA) has participated in the Volunteer Watershed
Information Network (VWIN) for the past twenty years. We currently sample 8 stream stations
on a monthly basis and five sites on Lake James monthly from May through October.
Laboratory analysis of the water quality samples is performed by The Environmental Quality
Institute located in Black Mountain, NC. Since 2018, we have been performing
macroinvertebrate sampling and analysis across the watershed. Field teams are led by, and
taxonomy conducted by, Reece
data has demonstrated
that the North Fork of
the Catawba River and
the west end of Lake
James are particular
areas of concern. For
years, the North Fork
below the Baxter
discharge has been an
outlier in comparison to
our monitoring sites
across the watershed.
For years, the west end
of Lake James has been
an outlier compared to
our other lake
monitoring sites.
Environmental Consulting located in Marion, NC. For years, our
The Environmental Quality Institute
Volunteer Water Information Network (VWIN)
Chemical stream monitoring since 1990
LJEAVWIN monitoring since May 2001
Chemical Monitoring Data — Stream and Lake James Sites
The following data and comments demonstrate a significant impact of the Baxter discharge on
the North Fork and provide an overview of LJEA concerns about the impact of the Baxter
discharges on the stream and downstream in Lake James.
1

Nitrate/N itriteN itrogen 2019 to 2021
Forested average median 0.2 mg/L
Regional average median 0.4 mg/L
NC limit: 10.0 mg/L for water supply
Throughout the years of
UEA monitoring,
Orthophosphate
concentrations downstream
of the Baxter discharge
(U13) have been the
hightest of all the stream
monitoring sites. That
remained true throughtout
the 2019 to 2021 period.
The median observed
concentration is double that
of the monitoring site
upstream of the discharge
(U17). The above graph also
illustrates that the
Orthophosphate levels at
the west end of Lake James
(U6) are significantly higher than other lake monitoring sites (U7,8, 9 and 11).
Ambient concentrations
of Nitrogen below the
Baxter discharge is an
outlier in comparison to
other UEA stream
monitoring sites. Note
the significantly higher
Nitrogen levels as
compared to the
Catawba River at US221
and to Armstrong Creek.
Orthophosphate 2019 to 2021
Forested average median 0.04 mg/L
Regional average median 0.07 mg/L
Below 0.15 mg/L orthophosphate is recommended to prevent eutrophication (excessive
plant/algae growth).
2

Alkalinity 2019 to 2021
Ca -a Ms side linvi Ile sib
O
t
r
K
V
1 4 s
• S 5 _ ,€
U G
Downstream
1
5
Forested average median 10.1 mg/L
Regional average median 21.0 mg/L
Varies geographically but is naturally very low in WNC
The North Fork of the Catawba
River has significantly increased
Conductivity below the Baxter
discharge. Note the signifinant
rise between monitoring sites
U17 (upstream of the Baxter
discharge) and LJ13
(downstream of the discharge).
Alkalinity in the North
Fork below the Baxter
discharge is consistently
higher than other sites
across the Lake James
watershed. It is the only
site monitored by UEA
where the median
Alkalinity concentration is
above the VWIN regional
average median. Note
the difference between
concentrations in the
Catawba River near US221
and Armstrong Creek, a
tributary to the North
Fork.
Conductivity 2019 to 2021
:,
.5 ,60
a 1W
Ca.awba
sole
liiwilleath
Dom
ream
e
I
in
t
° R
kA
"
o
.,
4
-
A '•
�'i
b
V
d
6
1
V
c4
54
V N
ii,
1 E
b,
i E
m
Forested average median 20.5 umhos/cm
Regional average median 69.2 umhos/cm
Varies geographically but is naturally very low in WNC
i
3

Lake James Monitoring
As indicated by our stream monitoring data, there is high loading of phosphorus from the North
Fork of the Catawba River into the far west end of Lake James. LJEA collects water quality
samples from Lake James from May through October at five sites. For the period from May
2020 through October 2021, the average Total Phosphorus (TP) concentration (expressed as
Orthophosphate) at LJ6 (west end of the lake) was 0.21 mg/I (n=12) with a high of 0.34 mg/I.
The median TP concentration at LJ6 was over 3 times the median concentration of the other
four sites. The Phosphorus input from the North Fork has obvious impacts on the abundance of
phytoplankton (algae) in the basin at that end of the lake, and as a result, on the water clarity.
To illustrate this, refer to the LJEA's lake monitoring stations map (figure 1).
LJ7 Big Island
•
•
LJ6 Plantation Point
Roa
ir+C 126
cFtauwaY
re
�� i V570
INVILLE
LJ8 Marion Lake Club
•
NC i 26I
LFs in
BBIBGrWATEV
„
NC ti6
LJ11 Lower Linville
•
LJ9 Paddy Creek Dam
Figure 1. Sampling locations on Lake James
4

Dr. Mark Brenner from Warren Wilson College has been monitoring phytoplankton using the
non -acidification fluorometric method (EPA Method 445.0) for chlorophyll a over the past 4
years from May to October. As shown in figure 2, the site nearest the inflow of the North Fork
of the Catawba River (LJ6 Plantation Point) has by far the highest summertime chlorophyll a
levels, and this has been consistent over the years.
2021 Chlr
Horizontal (Value) Axis Major Gridlinea
1
'1/21 5/21/21 6/10/21 6/30/21 7/20/21 8/9/21 8/29/21 9/18/21 10)8'21 IN
�u6(la/5 '/14/5 -L.—. CAN --u90xd4 to 111W/l)
Figure 2. Chlorophyll a concentrations at five lake sampling sites from May to Oct. 2021
The water clarity of the lake reflects this phytoplankton abundance and site LJ6 consistently has
the lowest visibility as measured by secchi disk depth (figure 3). Again, this is consistent over
the years, not just in 2021 (data available upon request)
Sushi Disk depth (m)
3.0
2.5
2.0
1.5
1.0
0.5
0.0
5/1/21 5/21/21 6/10/21 6/30/21 7/20/21 8/9/21 8/29/21 9/18/21 10/8/21 10/28/2I
�lSIOO/L1 -*l 7(URA) --I Na.,-)8IJ 91UPi1 1115Q/
Figure 3. Secchi disk depths at five lake sampling sites from May to Oct. 2021
5

Macroinvertebrate Sampling and Analysis
Long-term collection and analysis of benthic organisms provides valuable data measuring
ecological and water quality changes of features over time. Many aquatic macroinvertebrate
species are sensitive to changes and stressors in the environment which reflect short-term
alterations to the ecosystem and water quality. Community structure is slower to respond, and
the collection and analysis of communities can reflect any long-term changes in the
environment. (Plotkin, J. L., M. T. Barbour, K. D. Porter, S. K. Gross and R. M. Hughes. 1989. Rapid Bioassessment
Protocols for Use in Streams and Rivers. EPA/444/4-89-001)
The macro benthos of the North Fork of the Catawba River were most recently sampled at sites
off American Thread Rd and North Cove School Rd in November 2021, respectively below and
above the Baxter discharge. Additional sampling was performed on Armstrong Creek, just
above its confluence with the North Fork. The sampling procedures are a modified "Qual 4"
from the NCDWR SOP for the Collection and Analysis of Benthic Macroinvertebrates (NC
Department of Environmental Quality. 2016. Standard Operating Procedures for the Collection and Analysis of
Benthic Macroinvertebrates. Division of Water Resources. Raleigh, North Carolina. February 2016.). The
sampling, taxonomy, and analysis was conducted by biologist and certified macroinvertebrate
taxonomist, Levi Reece with Reece Environmental Consulting. A full taxa list was generated
(available upon request) with the summarized data below.
Stream Name
Armstrong Creek
NF Catawba
NF Catawba
Station Number
US 221
American Thread Rd
N Cove School Rd
Total Taxa Richness
29
7
22
EPT Taxa Richness
18
3
15
Total Abundance
77
16
85
EPT Abundance
62
11
72
Percent EPT
80.5%
68.8%
84.7%
Taxa < 2.5 Tolerance Value
14
1
10
NCB!
3.72
4.58
3.49
The data clearly shows a biological shift from upstream of the Baxter property to downstream
of the Baxter discharge. The benthic species diversity is 68% (7 versus 22) lower below the
Baxter discharge than upstream of the facility. Sensitive species diversity drops 90% (1 versus
10) below the discharge. Not only is ecological diversity highly impacted, but the benthic
population is also affected and reduced by 81% (16 versus 85) in the downstream site. These
data reflect that an input source between these two sample sites to the North Fork is negatively
affecting water quality and stream ecology.
Note that the North Fork is impaired for benthos in a reach approximately 1.5 miles
downstream of the Baxter discharge down to its confluence with Armstrong Creek
(NC 2020 Categorv5 303dlist.pdf). The fact that the Armstrong Creek benthic community is
significantly healthier than the North Fork community below the Baxter discharge suggests that
it is likely that the North Fork would be further impaired except for recruitment from Armstrong
Creek.
6

Impaired Waters
Although the draft Permit Fact Sheet correctly identifies that the discharge does not occur within a
reach of the North Fork that is recognized as impaired, an impaired reach begins approximately one and
a half mile downstream of the discharge. As noted in the previous section, the impairment is related to
conditions in the North Fork above its confluence with Armstrong Creek and would likely extend further
downstream except for macroinvertebrate recruitment from Armstrong Creek. There is no indication in
the draft Permit Fact Sheet that impacts of the permitting discharge on the impaired reach have been
considered.
Nutrient Enrichment in Lake James
As previously presented, there is evidence of significant nutrient enrichment in the west end of Lake
James, raising the concern of potential algal blooms and harmful algal blooms. Using the long-term data
from LJEA's VWIN ambient stream monitoring and the data presented in the draft Permit Fact Sheet, we
have prepared a nutrient input accounting for Total Phosphorus (TP) and Total Nitrogen (TN) based on
average daily flows and average concentrations. A spreadsheet summary of that accounting is attached.
In summary, our findings are:
• That, on an average daily basis, Baxter effluent is roughly 5% of the Total Phosphorus (TP)
delivered via the water column to the west end of the lake and roughly 3.6% for the entire
lake, and
• That Baxter effluent is roughly 6.7% of the Total Nitrogen (TN) delivered to the west end of the
lake and 4.8% for the entire lake.
Additionally, if the Baxter discharge averaged 1.2mgd and its concentrations were at the maximum
recorded in the prior permitting period (TP=5.5mg/I; TN=23.4mg/I), then:
• The TP contributed to Lake James by the Baxter discharge would raise to roughly 18% and 14%,
respectively, and
• The TN contributed to Lake James by the Baxter discharge would raise to roughly 23% and 17%,
respectively.
Any future loadings of this magnitude onto the west end of Lake James are very likely to cause algal
blooms, harmful algal blooms, degrade water quality, and lead to the Lake being recognized as an
impaired water.
Cawtaba River Basin Plan
The Catawba River Basin Plan is out-of-date and the upper basin has not received the type of intensive
study that would normally precede the completion of an update plan. The State must be very cautious
when renewing discharge permits in the absence of the up-to-date condition assessments required for
the Catawba River Basin Plan.
Other Considerations
Climate change over the next decades will likely increase the probability of algal blooms and
harmful algal blooms (HABs) in lakes and estuaries around the nation. (See: us Environmental
Protection Agency, Office of Water, Impacts of Climate Change on the Occurrence of Harmful Algal Blooms, EPA
820-S-13-01 and Algal Blooms (nih.gov)) The combination of warming waters and elevated nutrient
7

levels in the west end of Lake James is a concern. The warming of Lake James' waters will
reflect our continually warming climate. Our only plausible means to avoid future HABs is to
control the nutrient loads delivered by the Lake's tributaries.
Lake James is an important ecological and recreational resource, and its waters provide potable
water supplies for many downstream communities. It is essential that we do not wait until
additional reaches of the North Fork of the Catawba River, or any portion of Lake James, are
listed as an impaired waters before we take the action required to protect it.
Community Science Committee (CSC) Recommendations
CSC recommendations to LJEA's officers and directors are:
1) There should be increased effluent constituent monitoring requirements added to the
draft permit, including once per week sampling and reporting of: Total Nitrogen, Total
Phosphorus, Orthophosphate, and Total Hardness.
2) While the above monitoring should begin immediately, the permit should not be
renewed until the impacts of the discharge upon the impaired reach of the North Fork
of the Catawba and upon nutrient enrichment in the west end of Lake James are given
appropriate consideration.
3) LJEA should request intensive monitoring of the lower North Fork and the west end of
Lake James to determine the impacts of the Baxter discharge on the ecology of those
waters. The study objectives should include determining if specific constituent discharge
limits should be established for the Baxter NPDES permit in order to protect the
designated uses of the North Fork and Lake James, and the drinking water supply
provided by the Lake. The study should include examining the prevalence and species of
algae and cyanobacteria in Lake James.
4) That the renewed permit stipulate that constituent discharge limits may be imposed
prior to the next renewal.
8

Addendum
Nutrient Loading Estimates — Lake James
Estimated NH3+NO3 Loadings (as N) to Lake James
Observed or
Mean Daily
Drainage
Mean Daily
Estimated
Mean Daily
Estimated
Area (sq.
Flow /sq.
Mean Daily
Mean Daily
NH3+NO3
NH3+NO3
NH3+NO3 (as
Watershed
mi.)
mile (cfs)
Flow (cfs)
Flow (mgd)
(mg/I)
(pounds)
Convert
N)) (pounds)
North Fork above Baxter
31.5
2
63
40.72
0.24
81.56
1
81.56
Armstrong Creek
6.3
1.88
11.82
7.64
0.24
15.30
1
15.30
North Fork @ Lake James
84.7
1.89
160.08
103.47
0.25•
215.87
1
215.87
Catawba River @ Lake Jam
181
1.84
333.28
215.41
•
0.32
575.25
1
575.25
UT- Virginia Drive, Marion
1.47
2
2.94
1.90
0.35
5.55
1
5.55
Forsyth Creek, Marion
1.8
2
3.6
2.33
0.35
6.80
1
6.80
Total for west end of Lake James without Baxter effluent
803.46
Mean Daily TN
(pounds) Convert
Baxter Effluent (avg day/avg conc) from Draft Fact Sheet
0.94
7.4
58.05
1
58.05
Baxter Effluent (max day/max conc) from Draft Fact Sheet
1.20
23.4
234.34
1
234.34
Estimated NH3+NO3 (N) tributary to west end of Lake James - avg day & avg conc
Estimated NH3+NO3 (as N) tributary to west end of Lake James - max day & max conc
Estimated without Baxter discharge
Estimated without Baxter discharge
Linville River @ Lake Jame.
67.1
2.19
146.79
94.87
0.28•
221.69
1
221.69
Paddy Creek
7.51
1.82
13.64
8.82
0.14 1
10.30
1
10.30
White Creek
1.91
1.97
3.77
2.44
0.14 1
2.85
1
2.85
Balance of Lake James wat
34.51
1.82
62.68
40.51
0.35
118.33
1
118.33
Watershed NH3+NO3 (as N) without Baxter
1156.63
Baxter%
Estimated NH3+NO3 (as N) tributary Lake James - avg day & avg conc
1214.68
4.8%
Estimated NH3+NO3 (as N) tributary Lake James - max day & max conc
1390.97
16.8%

Estimated TP Loadings (as PO4) to Lake James
Watershed
Drainage
Area (sq. mi.)
Mean Daily
Flow/sq. mile
(cfs)
Mean Daily
Flow (cfs)
Mean Daily
Flow (mgd)
Observed or
Estimated PO4
(mg/I)
Mean Daily
PO4
(pounds)
TP/PO4
Mean Daily
Estimated TP (as
PO4)) (pounds)
Mean Daily
Estimated TP (as
P) (pounds)
North Fork above Baxter
31.5
2
63
40.72
0.04
13.59
4.36
59.26
19.32
Armstrong Creek
6.3
1.88
11.82
7.64
0.06
3.83
4.36
16.68
5.44
North Fork @ Lake James
84.7
1.89
160.08
103.47
0.05
43.17
4.36
188.24
61.37
Catawba River @ Lake James
181
1.84
1
333.28
215.41
0.07 1
125.84
4.36
548.64
178.89
UT- Virginia Drive, Marion
Forsyth Creek, Marion
1.47
1.8
2
2
1
1
2.94
3.6
1.90
2.33
0.1
0.1
1
1
1.59
1.94
4.36
4.36
6.91
8.47
2.25
2.76
Total for west end of Lake James without Baxter effluent
752.26
245.27
Mean Daily Convert to
P (pounds) PO4
Baxter Effluent (avg day/avg conc) from Draft Fact Sheet
Baxter Effluent (max day/max conc) from Draft Fact Sheet
0.94
1.20
1.63
5.5
12.79
55.08
3.067
3.067
39.22
168.93
12.79
55.08
Estimated P (as PO4) tributary to west end of Lake James - avg day & avg conc
Estimated P (as PO4) tributary to west end of Lake James - max day & max conc
791.47
258.06
921.19
484.25
Linville River@ Lake James
Paddy Creek
White Creek
67.1
7.51
1.91
2.19
1.82
1.97
1
146.79
13.64
3.77
94.87
8.82
2.44
0.03
0.09
0.06 1
23.75
6.62
1.22
4.36
4.36
4.36
103.56
28.87
5.32
Balance of Lake James watershed
34.51
1.82
1
62.68
40.51
0.10
1
33.81
4.36
147.41
33.77
9.41
1.73
48.06
Watershed PO4 without Baxter
Estimated P (as PO4) tributary Lake James - avg day & avg conc
Estimated P (as PO4) tributary Lake James - max day & max conc
1037.41
1076.63
1206.34
338.25
351.04
393.33
Where North Fork impaired water reach begin!
Estimated PO4 without Baxter discharge
Estimated PO4 without Baxter discharge
Baxter
5.0%
18.3%
Baxter
3.6%
14.0%

NC0006564
DWR response to UEA Comments
The Lake James Environmental Association submitted comments regarding the draft permit NC0006564
which was received by the Division February 25, 2022. The comments and responses from the Division
are summarized below:
1. Increased effluent constituent monitoring requirements for Total Nitrogen, Total Phosphorous,
and Total Hardness, from once per quarter to once per week; and include once per week effluent
monitoring for Total Orthophosphate.
a. Per 15A NCAC 02B .0508, for Class III facilities with SIC 2800-2899 and discharge of 1.0
MG or greater to the Catawba River Basin, monthly monitoring for Total Nitrogen and
Total Phosphorous is required. Per the 2016 NPDES Implementation of Instream Dissolved
Metals Standards guidance, upstream and effluent monitoring for Total Hardness is
required once per quarter. Orthophosphate is not a pollutant for which individual
monitoring is required; however, "Total Phosphorous" as defined in the section includes
all orthophosphates and condensed phosphates, both dissolved and particulate.
2. Delay issuance of the permit until impacts of the discharge on the impaired portion of the North
Fork of the Catawba and nutrient enrichment of Lake James are appropriately considered.
a. Per 15A NCAC 02H .0112, the Division is required to issue permits necessary to effectuate
the purposes of G.S. 143-215.1 and G.S. 143-215.67. The permit in question includes
effluent standards and limitations applicable to achieve current water quality standards
and legally applicable requirements.
3. Request for the Division to initiate an intensive monitoring study of the lower North Fork and west
end of Lake James to determine the extent of impacts from the permittee's discharge on the
ecology of the waters and identify constituents of the discharge to be limited in the permit.
a. The Water Planning section noted that the segment below the discharger on the North
Fork Catawba River is impaired for aquatic life for benthic macroinvertebrates, which is
likely due from both point and nonpoint sources of pollution. The current Catawba River
Basin Plan was implemented in 2018, and the plan is currently scheduled to begin in 2023.
However, ambient water quality samples are collected monthly and quarterly across the
state, for assurance that state water quality standards are met based on the waterbody's
classification. The Water Sciences Section - Intensive Survey Branch, which conducts the
Ambient Lake Monitoring program, confirmed that when the western part of Lake James
was assessed during the summer in 2012 and 2015, potentially harmful
algae/cyanobacteria increased in June and were dominate from July to September. The
Lakes Assessment Program will be monitoring Lake James this year with attention on
phytoplankton species.
4. The permit stipulates that additional monitoring and limits may be imposed prior to renewal.
a. Special Conditions can be added to the permit. Nutrient Re -opener. [G.S. 143-215.1] -
Pursuant to N.C. General Statutes section 143-215.1 and the implementing rules found in
North Carolina Administrative Code at 15A NCAC 2H.0112 (b)(1) and 2H.0114 (a), the
Director may reopen this permit to require supplemental nutrient monitoring of the
discharge. Monitoring will support water quality modeling efforts within the Catawba
River Basin and be consistent with a monitoring plan developed jointly by the Division and
affected stakeholders. In addition, the results of water quality modeling may require that
limits for total nitrogen and total phosphorous be imposed in this permit upon renewal.