NC0006564_Compliance Evaluation Inspection_20240708

SENT VIA ELECTRONIC MAIL ONLY: NO HARDCOPY WILL BE MAILED

July 08, 2024

Derek Bouchard
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 6/27/2024. 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 Mikal Willmer with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-468 or via email at
[e-mail].

Sincerely,

Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: William Carter, Baxter
Brian Valiquette, Baxter
DocuSign Envelope ID: 87F3BD24-1109-405C-8D22-4F77F2F6218E
EPA
United States Environmental Protection Agency
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 Type Inspector Fac Type
1 N 52 NC0006564 24/06/27 C S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
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 Permit Effective Date
Exit Time/Date Permit Expiration Date
10:00AM 24/06/27 22/11/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Brian J Valiquette/ORC/828-756-6321/
Other Facility Data
11:00AM 24/06/27 27/10/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Derek Bouchard,65 Pitts Station Rd Marion NC 28752//828-756-6644/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Facility Site Review Compliance Schedules
Effluent/Receiving Waters
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
Richard Eguino DWR/ARO WQ/828-296-4500/
Mikal Willmer DWR/ARO WQ/828-296-4686/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Daniel J Boss DWR/ARO WQ/828-296-4658/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
DocuSign Envelope ID: 87F3BD24-1109-405C-8D22-4F77F2F6218E
7/8/2024
7/8/2024
7/8/2024
NPDES yr/mo/day
24/06/27
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Mikal Willmer and Richard Eguino, with the Asheville Regional Office, conducted a Compliance
Evaluation Inspection of Baxter’s WWTP on June 27, 2024. This inspection was conducted to
determine whether the system was being operated and maintained in compliance with NPDES Permit
#NC0006564. Brian Valiquette, ORC, Derek Bouchard, and William Carter with Baxter were present
and assisted in the inspection.
Overall, the facility appeared to be operated and maintained in compliance.
Permit: Baxter staff indicated they are in the process of revising their CAP and plan to resubmit by the
end of August 2024.
Mechanical Bar Screen: Process wastewater enters the facility through a mechanical bar screen and
is then distributed into the high-strength or low-strength Equalization (EQ) basin based on inline
Chemical Oxygen Demand (COD) results. The ORC reported the COD threshold to route the influent
to the high-strength EQ tank can vary based on plant production. Influent temperature, pH and
conductivity are also monitored.
EQ Basins: High and high-high water level pressure transducers are connected to the facility’s
SCADA system. These transducers are checked for operability monthly. Two surface aerators are in
each basin and run continuously. Anti-foam is added as needed. High and low-strength EQ effluents
are mixed to meet the ideal COD concentration (~1,000 mg/L).
pH and Nutrient storage: Baxter maintains sodium hydroxide storage containers onsite for pH
adjustment after the EQ basin. Staff report they rarely need to adjust pH. The Sodium hydroxide tanks
are in secondary containment and the nearby storm drain is valved off when the tanks are being filled.
Phosphate and Urea are dosed as needed for nutrient addition. A floor drain in the chemical addition
building enters a sump and is pumped back to the headworks of the facility.
Rotary Drum Fine Screens: EQ effluent flows through one of two 3mm rotary drum screens. The
screens are rotated weekly to allow for cleaning. The ORC reports a single screen can handle peak
flows and there are no reported issues with screens clogging or allowing pass-through debris.
Return Activated Sludge (RAS) Tank: Rotary drum screen effluent and RAS are mixed prior to the
aeration basins.
Aeration Basins: Three basins run in parallel prior to the Membrane Bioreactors (MBRs). Mr.
Valiquette stated mixed liquors are kept at a higher concentration compared to standard extended
aeration facilities (6,500 mg/L vs. 2,500 mg/L). Fine bubble diffusers maintain oxygen within the
system. Basins have not needed to be drawn down for cleaning since the new plant was brought
online.
MBRs: Effluent from the aeration basins enters the three MBR tanks run in parallel. The AB effluent is
pulled across a membrane filter under negative pressure. The permeate then flows to the UV banks
for disinfection. MBRs are cleaned via the clean in place system with citric acid three times a week.
No reported issues with tears in the membranes since being placed into service. ORC reports they
waste daily from the MBRs.
Solids: Wasted sludge is aerobically digested prior to the centrifuge where an approximately 20%
total solids cake is produced for land application under RLAP Permit #WQ0031725. US Biosolids land
applies to Baxter’s 80 permitted acres, as needed.
UV Banks: Two banks of UV bulbs are in use. One bank can handle daily flows. UV transmittance
and intensity are routinely monitored and serviced by the manufacturer as needed.
NC0006564 17 (Cont.)
Page#2
DocuSign Envelope ID: 87F3BD24-1109-405C-8D22-4F77F2F6218E
Permit:NC0006564
Inspection Date:06/27/2024
Owner - Facility:
Inspection Type:
Baxter Healthcare Corporation
Compliance Evaluation
Effluent: pH is monitored prior to discharge. If the pH is <6.2 or >9.8, flow is automatically routed to
one of three holding ponds to be re-treated before discharge to the river.
Outfall: The right-of-way is properly maintained for visual inspection. Staff noted the stream channel
has changed significantly over the years. The outfall discharges into a now bifurcated section of the
river due to bank and stream bed movement. The movement in the stream channel has reduced the
flow immediately below Baxter’s outfall.
Lab and Office: The building houses the MBR vacuum pumps and some chemical storage. ORC
reports all floor drains within the building drain to a sump that pumps to the EQ basins. DWR staff
reviewed laboratory logs for in-house parameters. Daily checks are documented on bench sheets
within the lab. TSS, COD, pH, conductivity, temperature, DO and fecal are analyzed in-house.
File Review: Flow meters are calibrated in-house, documented and kept on file. Meters appeared to
be within 10% of true value. Chains of Custody, laboratory data and eDMRs were available for
review. No transposition errors noted during spot checks. Mr. Valiquette demonstrated the Maximo
maintenance tracking system utilized by Baxter. The system is used to assign and track any required
maintenance.
Page#3
DocuSign Envelope ID: 87F3BD24-1109-405C-8D22-4F77F2F6218E
Permit:NC0006564
Inspection Date:06/27/2024
Owner - Facility:
Inspection Type:
Baxter Healthcare Corporation
Compliance Evaluation
Compliance Schedules Yes No NA NE
Is there a compliance schedule for this facility?
Is the facility compliant with the permit and conditions for the review period?
Condition A(3). Permittee is required to achieve compliance with temperature limits by
March 1, 2026.
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Analyze DO, pH, COD, conductivity, nutrients as process controls.Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
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:
Record Keeping Yes No NA NE
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?
Page#4
DocuSign Envelope ID: 87F3BD24-1109-405C-8D22-4F77F2F6218E
Permit:NC0006564
Inspection Date:06/27/2024
Owner - Facility:
Inspection Type:
Baxter Healthcare Corporation
Compliance Evaluation
Record Keeping Yes No NA NE
(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:
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?
Debris are disposed of in a dumpster near the screen.Comment:
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional?
Is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Is sampling performed according to the permit?
Influent sampler is flow-placed. Thermometers are verified in-house for accuracy.Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots?
Page#5
DocuSign Envelope ID: 87F3BD24-1109-405C-8D22-4F77F2F6218E
Permit:NC0006564
Inspection Date:06/27/2024
Owner - Facility:
Inspection Type:
Baxter Healthcare Corporation
Compliance Evaluation
Aeration Basins Yes No NA NE
Are surface aerators and mixers operational?
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/l)
ORC indicated he attempts to maintain a DO of approximately 3 mg/L. DO was not
checked separately by DWR staff.
Comment:
Solids Handling Equipment Yes No NA NE
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
See summary for details.Comment:
Aerobic Digester Yes No NA NE
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?
Facility utilizes two aerobic digesters.Comment:
Standby Power Yes No NA NE
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?
Page#6
DocuSign Envelope ID: 87F3BD24-1109-405C-8D22-4F77F2F6218E
Permit:NC0006564
Inspection Date:06/27/2024
Owner - Facility:
Inspection Type:
Baxter Healthcare Corporation
Compliance Evaluation
Standby Power Yes No NA NE
Is there an emergency agreement with a fuel vendor for extended run on back-up
power?
Is the generator fuel level monitored?
Generator was not tested during the inspection. Baxter staff report CAT services the
generator quarterly and exercises the generator underload. The facility maintains a
contract with a local vendor for fuel. Staff report the generator has only used
approximately 50 gallons of fuel since installed.
Comment:
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?
See summary for details.Comment:
Flow Measurement - Effluent Yes No NA NE
# 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?
Ultrasonic flow meter, parshall flume, auto-sampler and backup sampler are located in
a building downstream of the UV bank.
Comment:
Effluent Pipe Yes No NA NE
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?
See summary for details.Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Page#7
DocuSign Envelope ID: 87F3BD24-1109-405C-8D22-4F77F2F6218E
Permit:NC0006564
Inspection Date:06/27/2024
Owner - Facility:
Inspection Type:
Baxter Healthcare Corporation
Compliance Evaluation
Effluent Sampling Yes No NA NE
Is the tubing clean?
# 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
representative)?
ORC checks the 100 mL sample volume periodically. Please note, this is the minimum
volume for each sample pull and should be increased if the sampler begins to pull less
volume at the current setting.
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type,
and sampling location)?
All sampling performed as required by permit. The Downstream location is a significant
ways from the outfall and has several other contributing tributaries before the sampling
point.
Comment:
Page#8
DocuSign Envelope ID: 87F3BD24-1109-405C-8D22-4F77F2F6218E