NC0006564_Corrective Action Plan_20240903

Baxter
August 30, 2024
NC Division of Water Resources RECEIVED
NPDES Industrial Permitting Unit
Attention: Sergei Chernikov
1617 Mail Service Center SEP 0 3 2024
Raleigh, NC 27699-1617
NCDEQ/DWR/NPDES
NCDEQ, Division of Water Resources
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
RE: NC0006564 Revised Corrective Action Plan Submittal
To NC Division of Water Resources Industrial Permitting Unit:
Please find enclosed the Revised Corrective Action Plan required per Part I A. (3.) of Baxter
Healthcare Corporation's National Pollutant Discharge Elimination System (NPDES)
permit(NC0006564). Please contact me with any questions or comments pertaining to this
submittal or any other compliance matter for the facility.
Sincerely
, j,
eztsi_ ____ ige-AA-6L--- ____
Derek Bouchard
Environmental Manager
Baxter Healthcare Corporation
65 Pitts Station Road,Marion,NC 28752
T 828.756.4151

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
REVISED
Corrective Action Plan
NPDES Permit # NC0006564
for:
Baxter Healthcare— North Cove
65 Pitts Station Road
Marion, NC 28752

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
Page Intentionally Blank

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
Table of Contents
SECTION 1: SUMMARY 1
1.1 Introduction 1
1.2 WWTP Facility History 1
1.3 Schedule of Compliance—Temperature 1
1.4 Previous CAP Submittal 2
1.5 Components of the Revised CAP Submission 2
SECTION 2: SUMMARY OF OPTIONS ANALYZED 4
2.1 Outfall Relocation 4
2.2 Forcemain Construction 7
2.3 Wastewater Cooling 8
2.4 Sampling Point Relocation 8
2.5 Biological Reactivation Review 8
2.6 Analysis Summary 9
SECTION 3: PREFERRED ALTERNATIVE AND PROGRESS 10
3.1 Effluent Cooling Tower 10
3.2 Outfall Relocation 10
3.3 Summary 11
SECTION 4: SCHEDULE 13
ATTACHMENTS:
Attachment 1 — Wastewater Temperature Reduction Technology Assessment:Class C Options—Salas O'Brien
Attachment 2—Biological Reactivation Review Presentation—Baxter Healthcare
FIGURES (11"x 17"):
Figure 1 —Summary view of examined discharge pipeline alignments
Figure 2—Property owners associated with examined discharge pipeline alignments
Figure 3—Coats(aka American Thread) property near planned discharge point
iii

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
SECTION 1 : SUMMARY
1.1 Introduction
Baxter Healthcare Corporation's North Cove Facility has operated in McDowell County for over
50 years and employs nearly 3,000 people. The facility is a top provider of intravenous (IV)
solutions in the U.S. and operates as a Standard Industrial Classification (SIC) Code 2834, Class
III facility.
1.2 WWTP Facility History
The North Cove Facility is located in a geographical region with limited public infrastructure to
support operations, resulting in the facility operating a private wastewater treatment facility for
proper handling of facility domestic and industrial wastewater. The wastewater treatment facility
is a National Pollutant Discharge Elimination System (NPDES) permitted facility, number
NC0006564.
Baxter Healthcare has operated wastewater treatment operations for the life of the facility. In
2017 the facility completed a significant upgrade, installing new wastewater treatment systems
including two new equalization basins, screening, pH neutralization, activated sludge bioreactors,
membrane bioreactors (MBR), and ultraviolet (UV) disinfection. These upgrades have resulted in
no exceedances of permit limits and over 85 percent of all Discharge Monitoring Report (DMR)
parameters being reported below the detection limit (BDL).
In 2021, the facility submitted for renewal of the NPDES permit in a timely manner. The final
permit renewal was issued on October 17, 2022 and included a change to the temperature
requirements for the facility from "monitor and report" to a required maximum temperature and
upstream to downstream temperature differential, located in Part I A.(3.) of the permit, titled
Schedule of Compliance Temperature Outfall 001 and Instream.
1.3 Schedule of Compliance— Temperature
Requirements as stated in the Final NPDES Minor Modification Schedule of Compliance issued
August 16, 2023, are as follows:
1. Effective no later than May 1, 2023, the Permittee shall submit to the Division of Water
Resources a temperature study analyzing the impacts of each waste stream on the
facility's effluent temperature under diverse operating and ambient conditions and
characterizing the impacts of the facility's effluent on receiving stream temperature under
diverse operating and ambient conditions.
2. Within eight months of completion of the temperature study and no later than December
30, 2023, the Permittee shall submit to the Division, a Corrective Action Plan (CAP) for
approval that summarizes the actions to be taken to achieve compliance with 15A NCAC
028 0211(18) and .0219. The time to compliance shall be no longer than two years and
six months from the date of submission of the CAP. The CAP shall include, at a minimum,
a summary of the options analyzed, a detailed analysis of the Permittee's preferred
alternative, including preliminary design engineering and a schedule for procurement of
funds and/or approvals, construction, and necessary operation changes. The CAP shall
propose a schedule for completion of critical milestones until compliance is achieved. The
Division will provide comments and direction, if deemed necessary, within ninety(90) days
of CAP submittal. If no such direction is provided, the CAP shall be considered approved.
1

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
3. Effective no later than September 1, 2024, the Permittee shall submit a progress report to
the Division summarizing the actions taken in accordance with CAP and schedule,
including procurements, construction, installation, or other measures.
4. Effective no later than September 1, 2025, the Permittee shall submit a progress
report to the Division summarizing the actions taken in accordance with CAP and
schedule, including procurements, construction, installation, or other measures.
5. Effective no later than March 1, 2026, the Permittee shall achieve compliance with
temperature limits specified in condition A. (1.).
In addition to steps 1 through 5, upon approval of the CAP by the Division, the milestones
outlined in the CAP become an enforceable part of the permit. Any modification to the schedule
for these milestones must be requested to the Division at least ninety(90) days before
scheduled deadline. Modifications more than four(4) months or more than one 4-month
modification request to the schedule will be subject to public notice.
To satisfy these requirements Baxter Healthcare contracted assessment and analysis services
from Jacobs Engineering, ERM, and PCl/Salas O'Brien.
Jacobs Engineering performed the initial Temperature Study as required in the first condition,
submitted by Baxter on May 1, 2023.
In June 2023 Baxter Healthcare submitted for an extension of the Corrective Action Plan submittal
deadline from September 1st, 2023, to December 30th, 2023, as a minor modification. Approval
for this modification was granted on August 16, 2023. The submittal of Sections 2-4 of this
document satisfies the second condition of the Schedule of Compliance.
Baxter Healthcare submitted the Corrective Action Plan on December 29, 2023, as required by
the second condition of the Schedule of Compliance.
NCDEQ issued the CAP Response on March 25,2024, stating that the CAP was not approved,
recommending further discussion of alternatives.
1.4 Previous CAP Submittal
The previous CAP provided an assessment of eight cooling options, with none demonstrating
satisfactory compliance with Class B Coldwater trout temperature standards for the receiving
section of the North Fork Catawba River without support from a 316(a) variance. The CAP
outlined a preferred and feasible option which included a combination of a raw water heat
exchanger, sampling point relocation, and a 316(a) thermal variance.
1.5 Components of the Revised CAP Submission
The NCDEQ Response cited significant reservations with a 316(a) proposal. In order to resolve
these reservations Baxter Healthcare proposed submittal of a revised CAP exploring an
alternative including outfall relocation to a receiving stream with Class C temperature standards.
This option was previously considered not a viable alternative as access commitments could not
be secured within the timeline provided for the CAP submittal.
2

Corrective Action Plan
Baxter Healthcare Corporation-NC0006564
This revised Corrective Action Plan submission satisfies condition 3 of the Schedule of
Compliance. Assessments performed by consulting groups will be summarized within the text and
included as attachments where relevant.
3

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
SECTION 2: SUMMARY OF OPTIONS ANALYZED
(For Condition 2. in the Schedule of Compliance)
2.1 Outfall Relocation
Prior to 1994 the treatment facility at Baxter discharged through a largely subsurface forcemain
to a location south of Armstrong Creek where the classification of the North Fork changes from
Class B Cold Water Trout to Class C. At this location, the temperature standards change to a no
greater than 29 degrees C and an induced temperature change of no more than 2.8 degrees C
from ambient conditions. The facility has made significant effort to explore the viability of
relocating to this historic discharge location, with the following conclusions:
1. The remnants of the existing forcemain are not of sufficient condition to be
restored/rehabilitated.
2. Documentation for legal easements/access rights was not available, and this option will
require Baxter to obtain new access rights prior to installing a new pipeline.
3. New construction pathways through the railroad corridor on the eastern side of the North
Fork and along State Highway 221 on the western side of the North Fork have been
preliminarily assessed. The facility has had preliminary conversations with the railroad
owner (CSX), additional private property owners, and the NC Department of
Transportation regarding the viability of a new construction low-pressure forcemain.
Specific alignments that have been explored are (with colors corresponding to Figure 1.):
a. From the existing WWTP at the Baxter facility approximately west to State Highway
221 approximately south to Old US 221 N, then approximately east to American
Thread Road, then approximately south to Good Road, then approximately east to
pre-1994 outfall location. ( _ 1 alignment)
i. Material list: 21,500 linear feet (If) — 12" Standard Dimension Ratio (SDR)
17 High Density Polyethylene (HDPE) pipe
b. From the existing WWTP at the Baxter facility approximately west to State Highway
221 then approximately south to the Oak Valley property, then approximately east
and then south (via easement)to American Thread Road, then approximately east
along the north or south side of American Thread Road to Good Road, then
approximately east to pre-1994 outfall location. ( alignment)
i. Material list: 26,400 If— 12" SDR 17 HDPE pipe
c. From the existing WWTP at the Baxter facility approximately west to State Highway
221 approximately south to American Thread Road, then approximately east to
Good Road, then approximately east to pre-1994 outfall location. (_
alignment)
i. Material list: 28,600 If— 12" SDR 17 HDPE pipe
d. From the existing WWTP at the Baxter facility approximately west to State Highway
221 approximately south to County Road 1559, then approximatel south to Good
Road, then approximately east to pre-1994 outfall location. (I Mci l'!!.',t; alignment)
i. Material list: 18,200 If— 12" SDR 17 HDPE pipe
4

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
e. From the existing WWTP at the Baxter facility approximately east to the CSX rail
line, then approximately south to a point near the pre-1994 outfall. (Yellow
alignment)
i. Material list: 16,500 If— 12" Ductile Iron pipe with wastewater compatible
Liner
See Figure 1 for a summary view of these alignments. (A larger version of Figure 1 appears at
the end of this report under"FIGURES".)
s '"". �'. "a' SNP` ,
, .y., Jr--. ,„-,tr-ii..., i, ' ." 4,,,A. t..< ' . ,,
/F !„,
`"gym,
Y
I .,
pen. Dale:52212924
11. Cn.M*a, t Gins An...CpUn l -�—On akan TMead:oath ASpmne%f scale
c-+aa �x.ao,a Proposed Alignment Plan
610111xearpmn, ®12.nAdgMea4Cp.,2 ---•� a 1.250 ''90 O North Core Facility
North Cove McDowell County.NC
Feet
ERM
•
Figure 1 —Summary view of examined discharge pipeline alignments
Each of these alignments presented the Baxter team with various challenges:
• The CSX alignment was determined to not be viable as in reviewing CSX technical
specifications for parallel infrastructure and an aerial review of the available corridor with
sufficient off-set for construction appears to intersect the boundaries of the North Fork in
multiple locations. This alignment would also require additional easements along
American Thread Road and down to the discharge point via Good Road.
• All of the road only alignments required multiple easements with different property owners.
Baxter was able to get a written commitment from NCDOT that if easements could be
gained from other property owners along a given alignment, NCDOT would grant a similar
easement to complete a pathway for the proposed outfall pipeline. (Figure 2.)
• All reasonable identified alignments of the discharge pipeline to the relocated outfall would
need to pass through property, via easement, owned by Coats (aka American Thread).

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
(A larger version of Figure 2 appears at the end of this report under"FIGURES".)
SMr1H KRD MAW RAV ELTOINLLESx' "Pk. IN!.I I W,�1 Nt N P N INI RS,i""
.411P
•.
YW YJIQiMIII ij. Ilcute.2l�yaL I4111 ivAY lnl 4nY Pl,r,l N
ZW Yll R NIOfrd UIC _ - :z 1,QOY�v "i'. Jk�
11WA os<x xm'�reun m O w .,..,,,aw+n.r'r, "� v w 8` ti"�
Y ilrlfNVESA1M1 °< l
IRW7xrantWk # DANV 4„ xgxon mut 111 M ..,, 4'
5.1 IN PART Ml xI D,1 IW Mw h'rw C _
Vie
1 ti NtaOWWJJEY 1 W.R'y �1U1111<IIWt1 U'll
Oy. E1 /• Mt y(� .N Ih111
MI A 1 r ''rytF � 1 FJ,E.?�'x
k ffi ,;..,4r1��14�
Nlr PQ b`.`4,�
'}'y \7\� •RON 1
}IN 1 111111 NIIfUMNI • •�x 1 ~ wMOr r
•
1Nwr1Yw lNlannx '^* �, 1 b
+� .x is a
+ro I ' 3W
:.r. �` s��p z o
� 47
.•. II.Nnkt)WIIUI • 2��d[41 ,,yW"�Ax �Y b...n
lik s CiRt EN H]/1 p1" •t � !
°.. V� �'r`' �N1S n lrr!
' F . x RACill _k R�I l� Nt, *
' *^ rn.. 1,Q if
. :4,1"'[+ �
c eml u) 1/
"
' � Y C% NA�` 'E `S
. � / 4 .0. QOJ C. ,�„.
Ar
T `a.NRADODDM+q 46."y • G4FV/,yNFGpSq ORFER~1OY J M/11Uk INLx
p NMII GU NH
gj MEUN
a STE`"D _
V NJII.f`1 A
Lagand
I-_E�a?Rbymzst -Wrc.i44.ntd
s•.n`. Property Owners
inn a "e,'. No Scale cility
North Cove,McDavell County NC
04
L ; �..:: .= ERM
Figure 2-Property owners associated with examined discharge pipeline alignments
The following table presents a summary of the easement acquisitions that would need to occur
as a result of each discharge pipeline alignment.
Scenario Private Parcels Public Private Driveways Other
(from Crossed Roadway Crossed Considerations
above) Intersections
Crossed
a. a)North Bound 221- 18 3 a)North Bound Most utilities are
(9 Landowners) 221-11 running along
b)South Bound 221- 14 b)South Bound southside of Rt
(12 Landowners) 221-5 1558. May need
to use both sides
c)North Bound 1558-5 c)North Bound of the road. Steep
(4 Landowners) 1558-4 rocky terrain on
d)South Bound 1558-6 d)South Bound the Northside in
(5 Landowners) 1558-0 areas and creek
close to road
edge on the
southside.
Substation
property at the
intersection of rt
1558/1559.
b. a)North Bound 221-6 2 a)North Bound
b)Southbound 221-4 221-3
b)Southbound
221-3
6

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
Scenario Private Parcels Public Private Driveways Other
(from Crossed Roadway Crossed Considerations
above) Intersections
Crossed
c. a)North Bound 221-35 4 a)North Bound Maintenance of
b)South Bound 221-27 221-35+ traffic and
c)South Bound 1559-3 b)South 221-15+ increased
stakeholders.
c)South 1559-9
d. a)North Bound 221- 18 3 a)North Bound Steep side slopes
(8 Landowners) 221-11 on west side of
b)South Bound 221-11 b)South Bound road may
(9 Landowners) 221-5 increase
construction
c) East Bound 1559-5 c)East 1559-0 costs.Avoid
(3 Landowners) d)West 1559-0 private property
d)West Bound 1559-3 where
(3 Landowners) transmission lines
are present
(ROW crossing
permit required).
e. 2 1 1 CSX-easement
fee required
Table 1 -Required Easement Acquisitions for examined discharge pipeline alignments
As evident from the table above, all considered and reasonable/constructable scenarios require
an easement from Coats.
2.2 Forcemain Construction
The proposed discharge relocation method is via an underground pipeline, conveying the
wastewater under low pressure (less than 100 psi) from the wastewater treatment plant to the
relocated outfall point. This would be constructed using industry standard forcemain construction
techniques and materials primarily consisting of butt fusion of HDPE pipe. Preliminary design for
this indicates that 12-inch pipe would provide sufficient capacity for effluent discharge rate.
Material specifications have been assessed in accordance with NCDOT requirements and best
engineering design practices for forcemain construction. Effluent would enter the forcemain via a
lift station located on the wastewater treatment plant property, with redundant pumping systems
and overflow control into existing storage ponds.
Piping would be installed via a combination of trenching and directional bore, in compliance with
NCDOT requirements and best construction practices.
Preliminary materials quantities have been calculated, initial field reconnaissance for utility
considerations, private access roads/drives, and geographic restrictions has been performed and
taken into consideration in route selection.
7

Corrective Action Plan
Baxter Healthcare Corporation-NC0006564
2.3 Wastewater Cooling
The relocated outfall proposal would discharge into Class C waters with a temperature standard
of 29 degrees C and a temperature rise standard of 2.8 degrees C. As a result, Baxter
requested that PCI, a Salas O'Brien company (PCI), revisit the wastewater cooling study to
meet the updated water temperature standards for Class C waters, and to include two additional
options, a mechanical cooling via cooling tower to the Class C compliance requirements and
cooling of effluent via inclusion of pumped groundwater.
1. Cooling Effluent with Groundwater—This option proposes cooling the combined
wastewater effluent stream using groundwater pumped from either of two new wells
located on the site, utilizing an inline mixer. Rate of well water addition would be
adjusted based on temperature after mixing.
2. Mechanical Cooling via Cooling Tower—The WWTP effluent would be passed through a
cooling tower and, using evaporative cooling, reduce the discharge temperature to the
required 29 degrees C.
The assessments for both options are included in Attachment 1 — Wastewater Temperature
Reduction Technology Assessment: Class C Options— Salas O'Brien
2.4 Sampling Point Relocation
The current discharge permit for Baxter Healthcare requires temperature monitoring at three
points, three times a week:
• Upstream at least 100 feet upstream from the outfall location
• Effluent temperature at discharge
• Downstream at NCSR 1552
With the proposed relocation of the outfall Baxter proposes to modify these to the following:
• Upstream - monitored at least 100 feet upstream from the new outfall location, with
consideration for ease of access.
• Effluent— monitored after mechanical cooling and prior to entry into the forcemain.
• Downstream—demonstrated by a modeled mixing zone meeting the maximum 2.8 degree
C temperature differential.
A modeled mixing zone would provide a practical way to demonstrate compliance that is
protective of North Fork Catawba River's temperature standards and remove the need for an
alternate downstream sampling point that would require additional property owner access
agreements and practical challenges due to ground considerations.
2.5 Biological Reactivation Review
During initial discussion of a pipeline relocation alternative, NCDEQ stated that other regulatory
agencies had previously stated concern about potential reactivation of bacterial population within
a discharge pipeline.
Baxter evaluated the potential for reactivation of biological contaminants based on multiple factors
specific to the North Cove facility. As the facility uses a membrane bioreactor filtration system,
capable of removing contaminants larger than 0.01 micrometers, the bioreactor will remove most,
8

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
if not all, of the bacteria and viruses. This is further supported by 5-day BOD analytical test results.
The estimated residence time within the pipeline is approximately 2.5 hours at full pipe flow.
Literature previously shared with NCDEQ via presentation on this system is included as
Attachment 2.
2.6 Analysis Summary
During assessment of the above Baxter determined that relocation to a Class C receiving stream
with supplemental cooling presented a viable alternative to the previously submitted CAP and
initiated pursuit of the necessary access agreements. This process was initiated in the first quarter
of this year.

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
SECTION 3: PREFERRED ALTERNATIVE AND PROGRESS
(For Condition 2. in the Schedule of Compliance)
3.1 Effluent Cooling Tower
Of the options evaluated and in combination with relocating the outfall to Class C waters, the
effluent cooling tower was found to be the most sustainable and effective means by which
Baxter is able to consistently meet the required discharge temperature. This option carries the
following advantages over the groundwater cooling option:
1. Proven technology
2. Lower power requirements
3. Lower environmental impacts (no substantial additional power use, no groundwater
requirements)
4. Construction needs limited to available space currently on the Baxter plant site
5. Can be used as needed (based on ambient conditions) without loss of effectiveness
A second cooling tower, with associated infrastructure, pumps, etc., will be constructed for
redundancy and continued permit compliance should the need arise to shut down the cooling
tower that is in use.
3.2 Outfall Relocation
Based on multiple analyses and extensive research and conceptual design, including costs,
access, constructability, number of required easements and the ability to acquire those
easements, and schedule, Baxter had deemed alignment 2. noted in Section 2.2 (State Highway
221 to the Oak Valley Property to American Thread Road and then Good Road) as the most
sensible pathway due the requirement of a limited number of non-NCDOT easements.
In pursuit of this alignment Baxter reached out to the current property owners, Oak Valley and
Coats, regarding granting of easements. Baxter contacted Coats early in the process via an
existing professional connection and received positive initial response. This was the
understanding when Baxter provided a proposed access agreement, receiving response from
Coats indicating that upon further consideration they were unable to facilitate the request, citing
a number of concerns that did not include the payment for the easement. However, Baxter has
continued further dialogue with Coats in an effort to address those concerns.
During the process of evaluating the various routings of the discharge pipeline, it became clear
that in order to complete this discharge relocation an easement, or easements, would need to be
granted for the Coats property regardless of the route taken. Coats currently owns property on
both the north and south sides of American Thread Road as well as all properties surrounding
Good Road, the only viable access for Baxter's pre-1994 discharge point. This effectively blocks
any and all access to the planned discharge point regardless of the pipeline alignment selected.
See Figure 3.
10

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
(A larger version of Figure 3 appears at the end of this report under"FIGURES".)
b ,,tom
a
s ✓ 'Te ^r a ids ;b*^', Jd'
{ r "�gFy
"�A �+1°� 1'✓"�q"qpp�L �� �µ`� ? y c`» " / P a ,..v' ,3 l?)‘'
ytry
Daft:5220024
Legend
4 _.Rad�a a MM mread�� kale: Proposed Alignment Plan
Roads 0OO Oan Thnud Moment o a.;a ]co O North Cove Facility
North Cove McDowell County NC
ree,
`..... .,,rsu w.0 w.a., — _. ER M
�.„.� ris ne i
Figure 3—Coats(aka American Thread)property near planned discharge point
The initial response from Oak Valley expressed willingness to grant an easement following
discussions and upon the owner returning to the country in August. However,following that return,
the Oak Valley property owners informed Baxter that they would not be willing to grant an
easement across the property for reasons other than the cost of the easement. Baxter attempted
to re-engage the Oak Valley property owners for further discussions, but those attempts were
declined.
Baxter remains committed to finding a reasonable route for the proposed discharge pipeline and
will revisit the previously discussed alternatives to the Oak Valley property in addition to
formulating other alignments and/or solutions while pursuing a positive result with Coats.
However, it should be noted that these continuing efforts will jeopardize future milestones within
the current Schedule of Compliance.
3.3 Summary
Baxter Healthcare has engaged a significant amount of internal and external subject matter
experts to assess the viability of relocation from Class B coldwater trout waters to Class C waters,
enabling supplemental cooling of the effluent to meet compliance requirements without variance.
The preferred alternative proposed in this Revised CAP and Progress Report would consist of
mechanically cooling effluent to meet Class C temperature maximums prior to entering a
forcemain and demonstrating a sufficient mixing zone at discharge suitable to aquatic life within
the section of the North Fork receiving discharge. Preliminary design of all infrastructure
components has been completed to the extent possible without final route determination.
11

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
Baxter proposes to continue pursuit of a viable pathway to Class C waters and will provide
NCDEQ with an update on this effort within 30 days of securing all necessary access agreements
or by the next milestone in the schedule of compliance, September 1, 2025.
12

Corrective Action Plan
Baxter Healthcare Corporation-NC0006564
SECTION 4: SCHEDULE
(For Condition 2. in the Schedule of Compliance)
The proposed schedule of compliance is dependent upon securing the necessary access
agreements, and is therefore provided in time from securing agreement:
Q1 Year 1 (first full year after securing necessary access agreements):
Submit a revised CAP with the secured alignment
Q2 Year 1:
Internal Project Charter Issuance
Scope of Work or Design
Q3 Year 1:
Design Cooling Tower System
Coordination of Permits for River Crossings and Land Disturbance (as applicable)
Q4 Year 1:
Bid Construction
Procurement Process on Components
Qi-Year 2:
Receive Capital
Review Bids and Component Procurement
Award Construction
Q2 Year 2:
Begin Prelim. Construction Planning and Preparation
Order Long Lead Parts
Q3 Year 2:
Begin Active Construction/Installation
Q1 Year 3:
Construction Complete
Cooling Tower System and Lift Station Tie-In During Facility's December Prey. Maintenance.
Shutdown
Startup of Cooling System and Pipeline Discharge
Submittal of Mixing Zone Demonstration

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
ATTACHMENTS

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
ATTACHMENT 1 :
Wastewater Temperature Reduction Technology
Assessment: Class C Options - Salas O'Brien

0 Salas O'Brien.
Baxter Healthcare
Wastewater Temperature Reduction
Technology Assessment:
Class C Discharge Location Options
Prepared by:
PCl/Salas O'Brien
20 N.W. First Street
Evansville, Indiana
salasobrien.com

0
PCI Project No. 2023-04575-01
Date of Issue: 8-20-2024
Derek Bouchard
Baxter Healthcare Company
65 Pitts Station Rd
Marion, NC 28752
Dear Derek,
Thank you for the opportunity to evaluate the wastewater system at the North Cove facility.
The following report evaluates 2 additional options for cooling the wastewater effluent at the site to meet North
Carolina Department of Environmental Quality (NCDEQ) temperature requirements for the Wastewater Treatment
Plant(WWTP) permit requirements if it is discharge downstream through a pipieline. PCI has provided concepts,
and estimated annual operating costs, to ensure the discharge temperature would meet the temperature
requirements downstream.
We appreciate the opportunity to serve as your partner on this project. Please feel free to contact me at
812.480.0279 or [e-mail] should you have any questions.
Energetically yours,
//MX
Allen Koester, PE, PMP
Senior Project Manager
PCI (A Salas O'Brien Company)
20 N.W. First St.
Evansville, IN 47708, United States
Phone [phone]
Mobile [phone]
CC : Jason Roberts
salasobrien.com 2

0
Contents
Class C Discharge Options 4
Executive Summary 4
BACKGROUND 4
Project Description 5
Objective 5
Assumptions 5
Analysis 8
Option 1: Cooling the WWTP Effluent with Groundwater 8
Option 2: Mechanical Cooling of the WWTP Effluent 9
Evaluation 10
Option 1: Cooling the WWTP Effluent with Groundwater 10
Option 2: Mechanical Cooling of the WWTP Effluent 13
Additional options 15
salasobrien.com 3

a
Wastewater Temperature Reduction
Assessment: Class C Discharge Location
Options
EXECUTIVE SUMMARY
Baxter Healthcare is evaluating options to discharge the North Cove, NC Baxter Wastewater Treatment
Plant (WWTP) effluent to the North Catawba River via pipeline. The proposed discharge point is
approximately 3 miles downstream of the site. At this location, the maximum discharge temperature is
29°C (84.2°F).
This report details options for cooling the WWTP effluent to 29°C (84.2°F) prior to discharge to the
Catawba River at the end of the pipe. Options for cooling the WWTP effluent include adding ground
water pumped from the aquifer below the facility, cooling the effluent with evaporation and/or
refrigeration, and/or implementing heat recovery options within the facility.
BACKGROUND
The Baxter North Cove facility (Figure 1) operates a National Pollutant Discharge Elimination System
(NPDES) permitted wastewater treatment plant (WWTP) with direct discharge into the North Fork of the
Catawba River. The current WWTP has operated continuously since 2017, following completion and
startup of a WWTP utilizing best available wastewater treatment technologies. The replacement WWTP
was permitted under the existing WWTP permit with discharge conditions largely unchanged. This
permit did not include a temperature compliance requirement. This condition was changed in 2022 with
issuance of the permit renewal from North Carolina Department of Environmental Quality (NCDEQ).
These conditions for temperature require the facility to not raise the river temperature by 0.5°C (0.9 °F)
temperature between a point upstream of the plant and a point downstream of the plant. The NCDEQ
has specified a maximum site outfall temperature of 20 °C (68 °F). If the upstream (background)
monitoring point exceeds 20 °C (68 °F) the facility will not be out of compliance if it does not cause any
increase in background temperature.
Baxter Healthcare Corporation (Baxter) reached an agreement with the NCDEQ in April of 2022
requiring Baxter to assess thermal effects on the North Fork of the Catawba River and within their
facility, as well as proposing operational changes or capital projects to ensure compliance with the
temperature requirements within the new permit. Baxter is engaged in an ongoing assessment of
thermal effects on the North Fork of the Catawba River. Review of Catawba River discharge
requirements found that the river's classification changed approximately 3 miles downstream from the
plant. In that downstream section of the river, the requirement is to normally discharge at less than
29°C (84.2°F). The State of North Carolina also requires that the discharge cannot result in a 2.8°C
(5.0°F) or greater impact between upstream and downstream monitoring points.
salasobrien.com 4

a
A previous study evaluated the capital and operating expenses to cool the site's effluent temperature to
20°C (68°F) through a variety of options. Due to the 20°C effluent temperature, many of them required
refrigeration that is impractical. Baxter Healthcare identified an opportunity to discharge warmer water
into the Catawba River further downstream of the plant. This study supports efforts to design a viable
process to keep WWTP effluent temperature below 29°C and satisfy wastewater discharges into the
river.
PROJECT DESCRIPTION
The scope of this project is to propose and access potential processes to reduce the plant's WWTP
outfall temperature to 29°C at the end of the pipeline. Options evaluated in this project will become a
component of the Corrective Action Plan (CAP) for collaborative assessment with NCDEQ on the best
combination of operational changes, technological controls, and permit condition modifications to
ensure the North Cove WWTP remains compliant with all of the terms of its NPDES permit. The results
of this assessment will be incorporated into the environmental and ecological assessments to present a
CAP that proposes the best comprehensive method for meeting the regulatory needs of the facility.
The entire study is based on the North Cove Water Balance provided by Baxter (Figure 2). Well water
enters the plant (shown in blue) on the left side of the figure. The wastewater from the plant (shown in
red) drains into one of 5 main sumps (Orange). Two primary drain lines collect water from
manufacturing processes and domestic usages and are pumped to the WWTP through the Pump
House located between the main plant and WWTP. Four spray ponds cool water from the sterilization
lines. The ponds are pumped through a separate line to the WWTP. As the cooling pond water is
heated (essentially sterilized water) and biologically inactive, it typically bypasses the WWTP and
combines with the WWTP outflow. All water discharge passes through a final UV treatment before
flowing into a tributary of the Catawba River.
OBJECTIVE
The objective of this project is to evaluate process options to limit the WWTP effluent to a maximum
temperature of 29°C (84.2°F) at the end of the pipeline. Baxter specifically requested that Salas O'Brien
evaluate how much groundwater was required to cool the effluent stream and designing a process
using best available technologies to cool the WWTP effluent stream to 29°C prior to pumping it to the
downstream discharge location. Full analysis of these two options is included in this report.
ASSUMPTIONS
The following assumptions were used in the analysis:
1. The analysis is based on average and maximum temperatures at each sump as
shown in Figure 2.
2. The desired discharge temperature is a maximum of 29°C (84.2°F).
3. Negligible cooling will occur in the line from the site to the downstream discharge
location.
salasobrien.com 5

a
4. For equipment design, maximum stream temperatures will be used.
5. For this analysis, it is assumed that no heat is gained or lost in the wastewater
treatment facility.
6. It is assumed the wastewater temperature from the Boiler Room and 5A sumps is
consistent year-round.
7. A cooling tower can reduce the temperature of the water passing through it to within
7°F of the Outside Air Wet Bulb Temperature.
8. The design wet bulb temperature for the North Cove Site is 75.3°F. This is based on
available design information for Ashville, NC, and SPX Cooling Technologies.
Figure 1: Baxter Healthcare's North Cove Site
It
9 .w
4a ► 0 . te e, 1 A. x ,, , ' , 1.
.f A 1 i41
i
,•r ' .. + s"df .aY .Sau"A •ii'
4
K 1
wiw - ,
•
Nam FDA CataNCi Ravi*
voir
salasobrien.com 6

a
Figure 2: North Cove Water/Temperature Balance
North Cove Water Balance
Avl.a*r Yredt*1f.Days(101)1
ii
.r^�C'4•wxw Y wrtrot awrr,Yrr'r
s.... HI Alma arwwwrl<leaf 0001*
t..d A',t•r ir'K(f.e/M Mt r•$•••
1•ew
N*t1AxA..r�
v: :.tv. Ot 1 rr, k le 1711 4 r..v.l
1..1,40.1 11.4wt,f, loc... t**lW<rww t Mw Char.
TI ds 191
{. 1 . 1 A x1
tr."en *V..r 1
71.. .......1
M sr+k.d�'t•+
J.M. :W
arte�. . 1•.
,,nK,a,.a:ry • ik
T
•wf•rr .n vf.^ ,....Ctra.•..Yr
I1 J f IG i,-- ,;-:
Sri
lvq<•rr.w w..
:v1 1$1 r �,5
...wrw(rs.rr W b•w tem.,Ptre C..••/v t•.WWI:,
Ila ..�..... 1•e,ln.. x+
I I
I, aa
..:ivy.....,. ........�_._........�_Sr--.x
MI
iti
1: -I ...• ,
I
ff. 77
1V ufu:
4
1
.:I
4
To Waite Tleannent Plant
salasobrien.com 7

a
Table 1: Water Balance for North Cove Facility
Source Flow (kgal/Day) Discharge Temp (F)**
ischarg
o Wast
WFI System 587
Total Discharge (BR Sump) 261 110 168 95
Steam Production 327
Total Discharge (BR Sump) 134 110 168 95
Product Sterilization 310
Discharge (Cooling Ponds) 268 78 93 50
Discharge (5A Sump) 68 89 ! 116 60
Softener Regen (North Manway) 16 65
Cooling Towers 150
Regeneration (North Manway) 75 Varies
Sanitary 32
Sanitary Discharge (South 32 75 81 60
Manway)
Production Waste and SW 60
Intrusion
Prod. Waste Discharge (South 60 75 81 60
Manway)
Total Discharge 914 92*
* Calculated - based on average sump temperatures and mixed flow rates from cooling
ponds, and North and South Manways.
** Temperatures are based on temperature data collected between 5-22-2023 and 6-12-2023.
ANALYSIS
Option 1 : Cooling the WWTP Effluent with Groundwater
Baxter requested that Salas O'Brien evaluate cooling the WWTP effluent by adding groundwater
sourced from wells on the Baxter site. The WWTP effluent and the groundwater would be mixed at the
Baxter site and then pumped through a pipeline to the downstream discharge point three miles from the
site. Calculations will be made concerning the amount of water needed to cool the WWTP effluent.
salasobrien.com 8

a
Figure 3: WWTP Effluent Cooling with Groundwater
ww,..,i,,,,„„ >
f I
1 ,:oole,43 Ponnt 0.Alow Abaft .4--. .„:3 ,.....,.,
..
1
// .. SI
I Groundwater Wells
,
i
m t.+ Site Effluent 1
-----__ --------_ Pipeline •
Tank
North Fork of Catawba River dall -r
C ►r ►4 Mr
Option 2: Mechanical Cooling of the WWTP Effluent
Salas O'Brien will evaluate the climatological conditions for the North Cove site and evaluate suitable
cooling technologies to cool the WWTP stream prior to its discharge into the North Fork of the Catawba
River 3 miles downstream of the plant site. Local meteorological conditions will be evaluated to identify
and estimate cost to implement that technology.
Figure 4: Wastewater Effluent Cooling by Mechanical Cooling
Artk
sr
lov ,,
i►
.lw 1111,
06,
WV
._._....__ _...._. IN Trae+mera
b —....-- *
W astewatm Treme,ni,1 "`'"�
pares Tr.atm.rt Slap .
iedcoui uanxNMa Zmai
__Site Effluent Lineto
Clo..,ratreafn Outflow
salasobrien.com 9

0
EVALUATION
Option 1: Cooling the WWTP Effluent with Groundwater
This option proposes to cool the combined wastewater effluent stream using groundwater pumped from
either of two new wells located on the site. A low-pressure drop inline mixer quickly mixes the two
streams together and the temperature is measured prior pumping the site's effluent to its discharge
point. The rate of well water addition is adjusted based on the temperature after mixing. Salas O'Brien
was asked to evaluate the amount of ground water needed for this option.
Figure 5 shows the temperature of the wastewater treatment plant effluent including the cooling ponds.
Hourly temperature data was obtained from the Grandfather, NC weather station and averaged over
each month. Based on the Phase 1 study, the cooling pond outflow temperature is approximately 20°F
warmer than the wet bulb temperature and the WWTP plant effluent is fixed at 89°F based on plant
data recorded in May 2023. Using flows in Figure 2, the calculation spreadsheet developed for the
Phase 1 study was setup to calculate the ground water flow requirements for both normal groundwater
temperature (65°F) and for an elevated temperature of 68°F. Analysis of the WWTP effluent
temperature data captured in May 2023 found it fluctuated from 79.8 to 89.0°F. Likewise, the cooling
pond outflow varied between 77.0 and 90.3°F. To cool the site's effluent to 29°C (84.2°F) at the highest
temperature from both effluents would require 202 gpm (291,000 gpd). At average temperatures, 170
gpm is needed. Higher groundwater flow rates are required when the cooling pond temperature
fluctuates based on wet bulb temperature.
Figure 5 shows monthly estimated waste wastewater effluent temperature over a day. Ground water
addition is required in all months except January, February, March, and December. The amount of
groundwater needed to cool to 29°C is graphed in Figure 6. Continuous ground water addition is
required in May, June, July, August, and September. Groundwater usage is predicted to exceed 250
gpm during the evenings of July and August. Table 2 summarizes the estimated energy and cost for
blending groundwater to the WWTP and cooling pond effluent stream.
It is recommended that the groundwater well pumps be able to provide 275 to 300 gpm of groundwater
to adequately cool the site's effluent temperature. An inline static mixer is recommended to quickly
blend the cool groundwater with the WWTP and cooling water streams; the mixer should be capable of
handling 1000 gpm. Finally, a lift station is required. Its size will depend on the hold time Baxter deems
necessary.
salasobrien.com 10

a
Figure 5: Estimated Temperature of Combined WWTP and Cooling Pond Effluent
4'
W
ML° 90 --+r--
rii
44
3
w 85 - -- -
19"L;61.7`F-Ma.murr Permitted Site Outflow temp. '- ""
C
°
-
c
0
o
75
0 2 4 6 8 10 12 14 16 18 20 22 24
Time of Day(Hour)
Figure 6: Hourly Groundwater Required to Cool Effluent to 29°C by Month.
250
E '
200 4N
u
VI
•'m 150 -----4—*-----4—\\
C
°
-E 100
c
c
0
50
-o
a 01 .-.mil' ':.
9 .
D �.n. .
C
0 2 4 6 8 10 12 14 1r, 18 22
0 Time of Day(hour)
salasobrien.com 11

0
Table 2: Energy Usage and Utility Cost for Groundwater Addition
Daily Flow Monthly Flow Power Cost ($)
11.1
(gpd) (gal/mon) (kWh)
January -
February - - - -
March - - - -
April 43,885.79 1,316,574 8,276 709
May 120,472.89 3,734,660 23,475 2,012
June 230,505.70 6,915,171 43,467 3,726
July 256,753.25 7,959,351 50,031 4,288
August 249,242.19 7,726,508 48,567 4,163
September 173,297.11 5,198,913 32,679 2,802
October 18,351.32 568,891 3,576 306
November 8,257.54 247,726 1,557 133
December - - - -
Total 33,667,793 211,629 $18,139
Table 3 Estimated Well Water Blending Operational Cost
Description Annual Capital Maint Cost Amortization Annual Costs**
Energy Operating Cost* Costs
Usage Cost($)
KWH
Well Water 259,135 $ 18,139 $ 987,000 $39,480 $ 65,800 $ 123,419
Blending
*This includes the cost for 2 wells.
**This does not include the value of the water being dumped.
salasobrien.com 12

0
Option 2: Mechanical Coolingof the WWTP Effluent
p
There are primarily two technologies suitable for cooling the WWTP and cooling pond effluents to 29°C,
those being a cooling tower and a chiller. First, the cooling tower vaporizes a small fraction of water to
lower overall water temperature. Finally, a chiller system utilizes a refrigeration system to further cool
the streams.
A cooling tower is capable of lowering water temperature to within 5 to 7°F of the wet-bulb temperature.
The maximum wet bulb temperature determines the highest temperature of the water leaving the tower.
To determine the design maximum wet bulb temperature, meteorological records at Christmas
Mountain, NC were retrieved, and design guidelines published by ASHRAE (American Society of
Heating, Refrigerating, and Air-Conditioning Engineers)for Asheville, NC were reviewed. The ASHRAE
recommends 74.3°F as the design wet bulb temperature (Table 4). Finally, SPX/ Marley Cooling
Towers recommends using 75.3°F (24.1°C) as the design temperature. Based on these guidelines, a
cooling tower with a 7°F approach can cool water to 82.3°F (27.9°C), below the maximum discharge
temperature for the section of river Baxter proposes to discharge into. As a result, a cooling tower is
sufficient for cooling the site's effluent to 29°C.
Figure 7 shows the cooling water temperature based on the monthly ASHRAE wet bulb data.
Figure 7: ASHREA Monthly Wet Bulb Temperatures for Asheville, NC, and Predicted Cooling Tower
Outlet Temperature.
10o
95
90
Mean Dry Bulb Tema
85 Tar Bet Site ENtuent Temperature(29°C 8.4 2'F.
ti 80 Coating Towel Outlet Temp
A 75
r70 Wet Sulb lemo
65
60
55
so
\A�J� Q�+�a� �cr ��.• �a� lava �y+ ¢�F• I O``°
4` aQa Qet.
—Design Wet BuiC Mean Dry Bulb —Design —CT Outlet
salasobrien.com 13

0
Table 4: ASHRAE Systems Published Data for Asheville, NC
Latitude / Longitude / Elevation: 35.43N 82.54W 2169 ft ASL
Evaporation Design Data
0.4% Wet Bulb — 76.9°F (maximum design wet bulb with 99.6% confidence)
0.4% Mean Coincident Dry Bulb Temperature — 86.5°F.
1% Wet Bulb — 76.0°F (maximum design wet bulb with 99% confidence)
1% Mean Coincident Dry Bulb Temperature — 85.5°F.
Calculations determined that the maximum temperature combining the cooling ponds' effluent and the
WWTP effluent was 90.5°F. Based on an average site flow of 635 gpm, a cooling tower capable of
cooling 2.15 MBTU/h or 143 tons was necessary. It is recommended to specify a cooling tower capable
of at least 150 tons. For redundancy, two cooling towers are also recommended.
Figure 8: Hourly Cooling Water Effluent Temperature by Month
90
LL
}
E
r.
O — ............
80 •
O
75
70
0 2 4 G 8 10 12 14 16 18 20 22 24
Time of Day(Hours)
�.n -
�—;u. —♦—.n tAtm s u
„ i
salasobrien.com 14

0
The anticipated design is shown in Figure 4. The system consists of a covered basin, pumps to lift
water to the cooling tower, two cooling towers (one as backup), and a second covered basin to hold
water prior to being discharged to the effluent pipeline. Specifically, the covered basin has three or
more sump pumps. The pumps are rated for a head of 35-40 ft, depending on the sump's depth. For a
sump with three pumps (two operating pumps, one standby), each pump requires approximately 5 HP.
Pump operation could be tiered to sump level. The pumps lift water to the water distribution system of
an
d cooling tower. Water passes through the cooling tower i n a single pass a d flows into the final
basin. The design of the effluent pipeline is outside the scope of this work.
Table 5: Estimated Cooling Tower Operating Costs
Description Annual Capital Cost Maint Cost Amortization Annual
Energy Operating Costs Costs
Usage (KWH) Cost($)
WWTP
Cooling 66,026 $4,622 $1,300,000 $ 52,000 $86,667 $143,288
Tower Only
Additional options
In addition to evaluating the addition of ground water or cooling the site's effluent by evaporation, a
previous study evaluated heat recovery within the site by warming the water fed to the site's steam
boilers and WFI generators. The previous study recommended collecting hot water from Sump 5A and
the Boiler Room Sump, storing it in an insulated tank and then pumping the hot water to warm the
treated water for WFI generation and steam production. Calculations indicate heat recovery would
eliminate the need for either groundwater or evaporative cooling. It would require investment in an
insulated holding tank, pumps, and heat exchangers. Concern has been expressed about the potential
for contaminating water fed to the WFI generation system. For this project, only a preliminary
assessment was made, and no further development work was undertaken.
salasobrien.com 15

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
ATTACHMENT 2:
Biological Reactivation Review Presentation - Baxter
Healthcare

Baxter Wastewater Treatment Facility
State of the art WWT facility was constructed and brought online in 2017
• Membrane Bioreactor System which has the capability to filter water
containments down to the virus size.
• The system is design with redundancy in the treatment processes
Baxter

WWT Process Flow
()STERILIZER WATER > H
AREA
TO/ I �P _ t1u0N % '...
Ir , CONVEYOR
p1FWFNT SAMPIF �' FLOATING AERATORS
EMI = f.,,fly r_I % _ pROCE55 AR ; -
AMPLER PRIMARY — —
/ DRUM SCREEN \ ��— ^ �(1+1)P5 /DRUM SCREEN \ SAMPLER
-
_ c ...,\THC1 PRIMARY ED 0TRADE&SANITARY _
SEWER > FLOATING AERATORS 1
INFLUENT fZS7 v��
WE �_ -9-
iWELL I I I LJ/) - o
o
., TRANSFER
PUMPS(1+1) A Jll HIGH-STRENGTH /DRUM SCREEN \
A, SCREENINGS FEED PUMPS I� /,N17FOAM }-+ •
(1+1) SCREENINGS
INFLUENT WETWELL & ---- L •
----
pH MIX
HIGH-STRENGTH ED ADJUSTMENT TANK
TANK •
IANTIFOAM
RAS
Baxter 2

WWT Process Flow
Membrane Bioreactors
UV Banks
3----- .--..
_ '1TP011lE >--
a�w C�tli ^ ITO HOLDING POND
1. J FFFl IIFNT SALIPI F
AMPLER Mlba
FILTRA1 AER'PULSE
PH
- e O
Y
&ONEACTOR 1 TER 1 4M
R''�k��Ps CT FILTRATE
OU1FALL
_.,,_ T r --)
IL1RArE ruin UV DISINFECTION UV DISINFECTION //'��
Rx
RIOREACTOR 2 YEW l,�
.---4„,_ T ....
---
I-
RIOREACTOR S LOT S
TO PR ADJUST AND\
MIT TANK
/
YIOREAC`CR BLONFAS Y0R(DLLO RS
Baxter I 3

Membrane Bioreactors
Membrane submerged directly in process, :
outside toinside flow under Nacuum Air iil ' •
Permeate 41, "' ►
Matter
,Permeab'r tt ' Membrane
.f
biemlxataer"u ..*,• °• •,• Fiber
•
m
Mt, Membrane
Cassette
Aeration
Membrane Bioreactors Mixed Liquor
I
•
Membrane fibers have
..s of • Weans of micrescopic ,, • '€$g g
j�Z•rt+.• ` pores on the surface
• • t
•• i•••••w • The pores form a barrier to
` a'41," impa wit es>while allowing
pure water molecules to
�a we pass
• Water is drawn through the
pores using a gentle
suction I
•
w, � �`''�r4 ,
rates
xessr
Baxter

Membrane Bioreactor Filtration Ability
ST Microscope Scanning Electron Microscope Optical Microscope Visible To Naked Eye
Micrometers I I I I I I I
(Log Scale) Ionic Range Molecular RangeMacro Molecular Range Micro Particle Range Macro Particle Range
0.Opl o.Q1 0.` 1A 1p 1Q0 1000
Angstorm Units 1I01 10. 103 104I 1I 5 106I 107I
(Log Scale) I ( I
Approx.Molecular
Weight 100 200 100010,000 20 000 100,000 500,000
Cr di m
;___A.q a Carbon Black; L Paint Pigment I I HurnanHair
S It 1 Beach Sand
Metal Iogt1111111111111111111111,11
' Mist
Relative 1 Coal Dust
Size of Gelatin Pin
Common -
Materials [flue Indigo Dye Pollen.__
- _
Sugar- Cclloidal Silica
Granular
Atomic A.C. fine Test Dust Activated
Radius _Carbon
Asbestos _ Milled Flour 1
Process Rever>cOsmosis 1111Ir,-"ri-177717111 Particle Hitl-ation
for f :.
Separation Nanofiltratior Microfiltration
•
Zee Weed®
Baxter

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
FIGURES

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
FIGURE 1 :
Summary view of examined discharge pipeline alignments

I
•
., .,
lir'
. ._ � -
4. it �t<,+�V k � fir ; a 3 —. •.r r t
5 t + 1. ' "q F�' ' ,y 1y a'r4. ( j _i��: '%i� t:' „rz-�'k;- gy '? i 7Y, m• h t , y,+. wy
%'' t-' ''' . t ,
1
.•�:.a .a,..' •• ''' .a.: .,, ...:d. °' 2 F..I;'n,• A" 4}y „•Y 4';3 " '� '}Y. • �� " e 'Rr,, `' '''''-`1''Y �':�`otor
.n
y 1
• 1.,• fr.,. t r �. ..4 w�n 'ram": lY A 4 ,;r Y,,�, . _ - , 1 r Rom- rt .
e,
i.
•
•
„., •.. ,.1�0. •,,,..,,_ o " w, .rk i`4 ,a ......41- g' •y .1'• . , '��"' „#,"'`,•�,.'�{�... Y wry ,
r I aft" ,.
t �.,Y.. ?' �': to �1 . ,.. S y: : _• "� lfr n,•_ t"" 4
•
1. '�„ M. :�� .,w ,' d
c
'" -
.. ':'''.
:'t 1:''.''
e.
iIlig4,4:. .40, ......_____
F
., .' ' •, 1‘,.;.::,
" '� 0.6a
�. ` •ia '4311 '.•4- '"A : ��J *' - 4::''''*1'''-._ ' te- ::::"
. :1-'
e.
,� .q: i r'" f ` . Old(inwi/!e Road - _.
::::: .
,, •W . •to
��Y
A .� F
.r `i y ;p 'k.°'. `R :.,+ :+ems"° max. "- �, a ..a
'!" a 4 s t /
` 7. r
, " / • + ! :r i fr Jr' P
•<. $ - ' '+.�Y ,,, 't y. M *.> . -.1 ✓
IN
I.
\, } " Yam„ .,"; r. a M `IV f� #i y �,.:.Y`. e,r. *Y ,,.,.,
d•, • • •^+� 4• • 'W.. ( • '/l,./,' ,...1'... 0 M ♦ 1 '� •�, i> !- • s' {• 'aYa a- :+'
1 g jg' si �h r
'"'`r;" b,- ,
. ..,, 'ti` :: 8a _ • F , 1 •`a, ..k ':'4a AE ,.'"a° r.. w.i r:E „ •fl,,. .,GYF\ f: •M ,.y 1, '?: '� 'R{ .'a'�r, ^. Y ,
r• C+
r. ti Yd•d+. is i. t1t
', 7°Lam, d .n ", �•;% 2:.
# • mow" • + ,
r' ° ••• '.i;; .�'-1 ya qE ,� Bay f�.* ,. •>a`" •,,,r. • c N., .� }� `rt_ „ �y rr R '�l� -' " ., "• ,., rk r
lea - �\4 r. s, .4 �� ° ,: �'� :dti„ `�\ " ! �
♦ G Ye l �y.
=xIL •
A °p i ^ w
•.yam '" ..,� _ .t., M, , 'Ili,'f • „i.
i? '.f
." -•asp$ s "+•Of - .,
•
it r -Y _ q .r •�[' , •., 4.
•
Legend Date: 5/22/2024
CSX Alignment ammo,Coats Alignment Option 1 ----American Thread South Alignment
Scale: 0 4
Proposed Alignment Plan
'CSX RR Alignment " +—r• Railroad
0 1,250 2,500 North Cove Facility
DOH Alignment ®Coats Alignment Option 2 - - Roads Eimmom North Cove, McDowell County, NC
/irk
Notes: Feet
1.)Aerial Imagery: ESRI World Imagery E R M
reproduced under license in ArcGIS Pro 1:18,000
Coordinate System:GCS WGS 1984 DRAWN BY•TJB

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
FIGURE 2:
Property owners associated with examined discharge
pipeline alignments

_ ,I .,4 zzi , ,. ,timrrED7-1941TNERSHIP '. '''' ' ' ' -
,77 4t"
-,,. - -----,-,,- -
SMITH BYRD JIMMY RA , -,2''' POWE* ---LLT-CilARLES .`-'44* - T,',. PrWINSIAW-' 7,CENT,E.R1PARTNERS .
illARID B iii,
Clqr ,
=1 C--- V TRUST , .,,,
'"' ** 4 , 00 3 /#'4 • 4,
,
it. Af:t, Afc.
." - -..., ,. ..., 1 °t• -, l'
7 t i lot;r:'•:,.;[?.r1CR- -- ---_ ---'-'7.- ---
ZAwADI•YA . 6 ',4, \MST i •,,.... , :.....4,‘ ,
IA frfr
'
: '4.1Visc , *
MUNGU 1,...L.CN .,. * (1, It
''' ,44,4'
'AC. 14 1146 V. V' /•10
''''' , 221.4"-- STEVENS ISAIAH '
' ilur MORGAN ROULL i I E
7ilt ”....,,,, , , ''• *: '* .''' *. ,
,
a NORTH'CAROLINA - ' ---. '''' ik DAKNALLEY C * ' "
""At • ' 11, , .2,,,, tr, _ .
,.. a .
exios'tic
4 , MUM 44)7. . ,
, _ . t., .
'.-, .- A « • - «
,
• fifikm4b4.
i - • \ '1 .:' '
A. •Ali '-`• ' ..., 'NA, , di°k'k•AN • ' 11144 •41.,!"‘ .7GREENLEE 2/3 .It 1 t 10M PKIN.WITHRICM "•--- ,Z1 A , • f4 C ‘S ,I. •. ,
0,,,...., _16,0 481k N . r PAMI tAtT.VTR ', pAut.j , '. -ITN, ../ ''''''
• 1,‘ .
, f
0 1003
.0.. _
WARD JOSE ill,,%-,,,.,_ ,414,•-• • . *"` ' , . $ -
DAVON E I tlX ill. ‘01111L
• * • -17_ . ,* Illp . r'•/ 4 k* ' - . '"'''. , WOODY MyR014 3 •-,, . . $r -
-, 4 - , „ . .
' .° 4 . ,.... IP , /
/7
` ' '
.. ''
1110111FIEID ROXANNE P AP .*,. .0410 ' ' .." i 6., t '
B(IYD MAX R
. ,.....A , 446% 'Ir 4''',••:. / -,4',,,. " 1 cr
,. jt.
Z• Oftt, / ,, ' --.) 4,-ti . -.:,„
• ..* . . ' . „
'S,DEPT Cif 44* .• .444, 1**,,,%.. • ,. i. . ,0
iiiri.i. TRANSPORIE ATI!
,to
'-' 6
e ..,
/ s,.....r, o N Ir \
, At
.P 11 . -
, 1,,S
crrol:
4 , 4 .,'''
l'''is\ 1674
, , 4',0 cc:0 ,ii, \
lik '15 4.'n ' . it 01.4
eAR-,,, i
\ ,
' L2
, .' 44 /
, ii. kOk. ,.._______. „,„.---' --•-v., , u
IF,
„ .
. , .
. , I
CARTER CHARLOT7E ..-• :
GREENLEE 2/3 ,„,,,,„, „, ...i 4„., ,
go
ir A. 1' • '.
..
. . a•
/ .
DIXO' "IX°N.lip t
0 g ,a0101.
,•,
0.. •
MICHAEL E CHAEL E
..
w .
Iv- lor-,„,,,,5,,,,,,,
/ assk .,....6.4,1AMISEttANT HATTIE
11$:
, COILIS PATRICIA"....., , -. ,. or,-4 .,• A (DECEASED)
.„,, • , 4 .**4. ''' ''.• ‘Ntk**AC. '.
7--------o , ,A,,,,, ._ ,. . ... - ok‘• .^''''''• 14,!*1
' *ii,.. . , TRUSTEE . • -
,...,,_ (kit., 0,e_ -
It• - ''''' AY 61 i
•,,,,,,,, , •
tt* 11 17# ' „,"" ..1 ...1 '
• '''
4"ctc,,,,s4,
.„.„, 'Kt ‘ r ; ELEC MEM CORPfr '
' (4
lia
3ENNIt' - 0 s
y HICKS
t- . 1 ' . • t .,-
2) 0 \1/4 „„orsal
-' 1, REBECCA A . 41 •
- ---„,
AMERICA..
-----.4' A,if 174
riii...4.
_..•
1/0«, ;.:010t•* , THREAD CO DBA , ' tiLNILKIE THOMAS.
A
*; .BOTROS)
Enw
., .„. , ,
A.. —-•4 00 °(Afziti_ ,.. - ...„, .... . ,
, , . , *
_ ., 4 %, . CA NT EY4PATSY 1•04•RisS ur .- .. . , . .. .,
• . - mow MARIE GUINN
4.---)it'ir‘k's'."'''
.0 or
.''' 41
., -
„. igjhb„ - • •,Ak"fp, ' , 734
#-. - --" • ''' , '• MELO',
,• - * ':.xliik. --w- '
US FOREST • - : .
• :- 41103 , , 8. ! stEvis 0 ,
:...,.._ ,_.,...-, ,,,,,..
SERVICE
Legend Date: 5,222024
CR 1559 Alignment Coats Alignment
Scale: Property Owners
I ,(SX RR Aiignment I--i- Railroad
North Cove Facility
IMMIDOH Ahpment - — - Roads No Scale
ItP10 North Cove, McDowell County, NC
--- American Thread Road Alignment
Notes:
I)Aerial Imagery: ESRI'Norid Imagery ER M
reproduced under-license in ArcGIS Pro
------„ --

Corrective Action Plan
Baxter Healthcare Corporation—NC0006564
FIGURE 3:
Coats (aka American Thread) property near planned
discharge point

Y A
4014
r 0
y 117F.2-
• ✓., • 1.- • I
y!
!c tira ti
. .,
s �.
•.
.
IUD: .. \ ` t. a "'Y"' "Y
r.
a�•' riYf
f . Y
lMA µ a
. \-�, , 4i' i
411V...),
' ill 1
r.
j i
to
` .. /
,...‘I/Pir.-Ire A 17 — . , , tr ,
•
•
try tar' "-R4.•,�:: `• .1R •• ,
Date: 5/22/2024
Legend
Scale: Proposed Alignment Plan
Railroad American Thread Parcel p 350 700 North Cove Facility /''"
- - - - Roads American Thread Alignment ...mom. 0
North Cove, McDowell County, NC �i\
Notes: Feet `'
ERM
1.)Aerial Imagery: ESRI World Imagery
reproduced under license in ArcGIS Pro 1:4 303
Coordinate System:GCS WGS 1984 DRAWN B TJB
1