NC0003760_More Information (Received)_20220624

GOVATIOfl B I OTM
June 24, 2021
Mr. Amirhossein Adaryani
North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Permitting Section
1617 Mail Services Center
Raleigh, North Carolina 27699
RE: Additional Information Request Response (NPDES Permit No. NC0003760)
Dear Mr. Amirhossein Adaryani,
Enclosed please find the initial response to the additional information requested by the Division of Water
Resources (DWR) on May 5, 2022, pursuant to Section B of Part III of National Pollutant Discharge Elimination
System (NPDES) Permit No. NC0003760. The DWR requested the DuPont Kinston Site to sample and analyze
monitoring wells MW-10, MW-11, MW-17A, MW-21, MW-52, MW-19, MW-20, MW-22, and MW-25 one time for
the following pollutants:
• Acrolein and all parameters in Condition A.2 of the current NPDES permit
• Per- and Polyfluorinated Alkyl Substances (PFAS):
o PFBA
o PFPeA
o PFHxA
o PFHpA
o PFOA
o PFNA
o PFDA
o PFDoA
o PFBS
o PFHxS
o PFOS
o 6:2 FTSA
o 8:2 FTSA
o HFPO-DA
Ownership of the site was transferred to Covation Biomaterials, LLC (CovationBio) on May 31, 2022. CovationBio is
committed to controlling sources of groundwater contamination to protect human health and the environment.
For the reasons delineated in the enclosed responses, the Kinston Site is providing a revised groundwater
monitoring plan for this one-time sampling event scheduled to be conducted on June 29, 2022.
Please feel free to contact me at [phone] or [e-mail] if there are any question.
Sincerely,
Shelby Arellano
Environmental Engineer
WE ARE A FORCE OF NATURE
Covation Biomaterials LLC • 800 Prides Crossing, Suite 201 • Newark, Delaware 19713

Additional Information Request Response —Groundwater Monitoring
Covation Biomaterials Kinston Site (Formerly DuPont)
Permit No. NC0003760
There are multiple areas of impacted soil and groundwater on the Kinston Site's property due to historic activity.
The site's assessment, remediation, and monitoring activities related to historic releases have been carried out under
the direction of Hazardous Waste Section (HWS) of the Division of Waste Management (DWM) of the North Carolina
Department of Environmental Quality (NCDEQ). Groundwater contamination at the Kinston Site has been
comprehensively investigated over the past 30 years. The Kinston Site has been working with NCDEQ about the
presence and extent of groundwater contamination.
The site is currently in the RCRA Facility Investigation (RFI) phase of the Corrective Action Program. As documented
in the Final RFI Field Report submitted to NCDEQ in 2018, the Kinston Site has been fully characterized and the
presence, movement, fate, and risks associated with groundwater contamination have been identified. Following
approval of the Final RFI Field Report, CovationBio will prepare a Corrective Measures Study (CMS) report or a risk -
based Remedial Action Plan (RMP) to identify, evaluate, and propose appropriate corrective measures to holistically
address groundwater contamination at the site. The Kinston site is eligible to enter the Risk Program or to remain in
the existing Corrective Action Program to complete obligations. A chronological summary of events (investigations,
interim remedial measures, compliance monitoring) that have taken place at the site over the years is provided
following this response. All information regarding groundwater sampling and investigation can be found in the
various associated RFI workplans and reports.
As concluded during the RFI phase, noticeable decreases in groundwater constituent concentrations, presence of
degradation products, presence of microbially produced dissolved gases, and geochemical changes in groundwater
indicate that biodegradation is occurring. Monitored natural attenuation is a potential remediation strategy that
will be further evaluated during the CMS or RMP. CovationBio understands that sources which continue to
contribute to groundwater contamination must be addressed apart from natural attenuation. CovationBio will work
with the Division of Water Resources (DWR) and the DWM to develop an agreed upon remediation strategy that
meets the applicable requirements of both divisions. CovationBio is committed to controlling sources of
groundwater contamination to protect human health and the environment.
The emergency holding ponds, aeration basin, and sand beds are regulated Solid Waste Management Units (SWMUs)
requiring CMS in the site's current Hazardous and Solid Waste Amendments (HSWA)-only Permit. In addition, these
units are regulated wastewater treatment units in the site's current National Pollutant Discharge Elimination System
(NPDES) permit. CovationBio understands DWR's request for additional sampling upgradient and downgradient of
these units. CovationBio does not find it necessary to conduct sampling at all the requested monitoring wells for the
following reasons:
• MW-17A, MW-10, MW-11, and MW25 are located upgradient of the wastewater treatment plant (WTP).
Of these monitoring wells, MW-25 will be sampled to provide a reference for the groundwater quality
directly upgradient of the WTP.
• There is no potential for current operations to impact groundwater in the vicinity of MW-17A, MW-10, and
MW-11. These monitoring wells are in SWMU areas where groundwater conditions have been fully
characterized during RCRA investigations and any contamination will be remedied as per the CMS.
CovationBio does not believe additional sampling of these wells is warranted.
• Shallow groundwater in the vicinity of MW-17A is collected in a man-made ditch where the flow is
continuously rerouted to the WTP for treatment. In addition, MW-17A is sampled on an annual basis as
part of the landfill monitoring plan.
• Shallow groundwater in the vicinity of MW-10 and MW-11 is collected in a concrete sump and routed to
the WTP or discharges to a man-made ditch which drains away from the WTP.
Covation Biomaterials LLC 1

• MW-19, MW-20, MW-21, MW-22, and MW-52 are located downgradient of the WTP. Of these monitoring
wells, MW-20 will be sampled to provide a reference for the groundwater quality downgradient of the WTP.
• Potential impacts from the aeration basin and the south emergency holding pond would not be fully
captured in MW-19, MW-21, or MW-52 based on the direction of groundwater flow. In addition, there is
no reason to believe that any of the requested pollutants would be detected in these monitoring
wells based on the RCRA investigations.
• Potential impacts from the aeration basin and the emergency holding ponds would be captured in
MW-20. CovationBio does not believe it is necessary to include MW-22 in the initial sampling event.
• CovationBio believes that sampling MW-20 and MW-25 will provide sufficient data to determine the extent
to which the aeration basin and the emergency holding ponds are impacting groundwater.
CovationBio will sample MW-20 and MW-25 for acrolein and all the parameters in Condition A.2 of current NPDES
permit. However, sampling for Per- and Polyfluorinated Alkyl Substances (PFAS) is unwarranted. PFAS are not used
in manufacturing, and aqueous film -forming foams (AFFFs) are not used or stored on -site. The Kinston Site has only
been used for the manufacture of Dacron® (polyethylene terephthalate [PET]) polymer and fibers and for the
manufacture of Sorona® (polytrimethylene terephthalate [PTT or 3G]) polymer. There is no information to suggest
that PFAS compounds were ever used in finishing operations associated with Dacron® fiber production. An
exhaustive list of ingredients used in finish oils was provided to NCDEQ in the RCRA Facility Assessment. PFAS
compounds are not a raw material, catalyst, additive, product, byproduct, degradation product, or waste product of
these polymer production processes.
CovationBio has contracted with Parsons to complete this sampling event. The sampling event is currently scheduled
for June 29, 2022. A monitoring report including a summary of the procedures, the analytical results, and an NCDEQ
Form GW-59 for each monitoring well will be submitted as soon as results are received from the lab. Hard copies of
the monitoring report will be mailed to the NPDES Industrial Permitting Unit and the Washington Regional Office.
Electronic copies will be emailed to the requested email addresses.
Covation Biomaterials LLC 2

Historical Chronology of RCRA Assessments and Investigations
Covation Biomaterials Kinston Site (Formerly DuPont)
Investigation
Date
Investigation Objective/Description
Investigation Work Plans and Reports
Phase 1 Groundwater
Assessment
1987
Determine the potential impacts of waste handling and disposal
practices on the quality of site groundwater.
Groundwater Assessment— Phase 1(CH2M Hill 1987)
Phase 2 Groundwater
Assessment
1988
Collect and evaluate groundwater and surface water samples to
determine whether shallow site groundwater was impacted from
historical waste handling practices.
Groundwater Assessment— Phase 2 (CH2M Hill 1988)
Manufacturing Area
Investigation
1992
Investigate the source of TCE detected in groundwater samples
collected from the manufacturing area.
Manufacturing Area Investigation for Du Pont Fibers Kinston Plant
(DERS 1992)
Phase 3 Groundwater
Assessment
1992
Investigate site groundwater quality and evaluate potential COPC
sources in the non- manufacturing areas of the Site.
Kinston Groundwater Assessment— Phase 3: Volume 1(CH2M Hill
1992a); Kinston Groundwater Assessment— Phase 3: Volume 2
(CH2M Hill 1992b)
Literature Review Phase
1992
Review data and reports from US Geological Survey, North Carolina
State agencies, and the site to gain insight into the groundwater
conditions in the vicinity of the site.
Kinston Area Groundwater Study: Literature Review Phase (CONOCO
1992)
RCRA Facility Assessment
1993
Identify SWMUs and AOCs for further evaluation in the RFI.
RCRA Facility Assessment for DuPont Kinston Plant (CH2M Hill 1993)
AOC 86 Interim Measures
1995 1999
Install a groundwater pump and treat system for the TCE plume
(AOC 86) in 1995. Install a permeable reactive barrier wall
downgradient of the source area in 1999 as an alternative to the
pump and treat system.
Kinston Plant Manufacturing Area Corrective Action Plan (DERS 1994);
Baseline Condition Report TCE Remediation System (DERS 1995); Plan
for Implementing Zero Valent Iron Treatment in the Central
Manufacturing Area (DuPont CRG 1998)
Landfill Evaluation
1996
Evaluate transport of landfill leachate to assess the impact on
groundwater in the underlying aquifer from various chemical
compounds that could potentially be leached from the landfill.
Evaluation of Landfill Impact on Groundwater (DERS 1996)
H dro eolo is Study1997
g g
Summarize regional and site environmental settings and the
hydrogeology in the vicinity of the ash landfill (SWMU 10).
H dro eolo is SummaryReport (DERS 1997)
y g g p
Confirmatory Sampling
1997
Collect soil and groundwater samples at eight SWMUs and two
AOCs to determine if further evaluation in the RFI is required.
Confirmatory Sampling Work Plan, Kinston Plant (DERS 1996);
Confirmatory Sampling Report, Kinston Plant (DERS 1997)
Phase I RFI
2000-2001
Evaluation of potential impacts to human health and the
environment through comparison of data to risk -based screening
criteria. Collected soil, sediment, groundwater, and surface water
samples to evaluate potential exposure pathways and identify the
need and priority for further investigation or CA.
RCRA Facility Assessment Investigation: Phase I Work Plan (DuPont
CRG 1999); RCRA Facility Investigation Prioritization Data Summary (DuPont
CRG 1999); RCRA Facility Investigation Phase I Report Volume 1
(DuPont CRG 2001a); RCRA Facility Assessment Investigation: Phase I
Report Volume 2 (DuPont CRG 2001a)
SWMU 10 Interim
Measure
2002 2005
Formally close (cap) the ash landfill (SWMU 10).
Construction and Demolition Landfill Soil Cover— Final Design Report
(DuPont CRG 2002); Ash Landfill Soil Cover — Final Design Report
(DuPont CRG 2003); Construction Certification Report DuPont Kinston
Ash Landfill Cap Construction Project (DuPont CRG 2005)
Page 1 of 3

Historical Chronology of RCRA Assessments and Investigations
Covation Biomaterials Kinston Site (Formerly DuPont)
Investigation
Date
Investigation Objective/Description
Investigation Work Plans and Reports
Phase II RFI
2003
Collect soil and groundwater samples from the SWMUs and AOCs
to characterize potential releases to environment, evaluate human
health and ecological risks, and determine if further
investigation/corrective action is needed the extent of COPC
concentrations. Collect surface water samples to evaluate surface
water quality. Use the data to refine the CSM.
Revised RCRA Facility Investigation Phase II Work Plan (DuPont CRG
2001b); Phase II RFI Quarterly Report for the October — November
2001 Sampling Event (DuPont CRG 2002b); Phase II RFI Quarterly
Report, January— March 2002 (DuPont CRG 2002c); Phase II RFI 3rd
and 4th Quarterly Letter Report April —June 2002 and July —
September 2002 (DuPont CRG 2003); Revised Phase II RCRA Facility
Investigation Report (DuPont CRG 2003)
Annual Groundwater
Monitoring
2004-2021
Monitor contaminant concentrations in the TCE area (AOC 86) and
the Ash Landfill area (SWMU 5).
2004 Annual TCE Monitoring Report (DuPont CRG 2005); 2005
Annual TCE Monitoring Report (DuPont CRG 2006); 2006 Annual TCE
Monitoring Report (DuPont CRG 2007); 2007 Annual TCE Monitoring
Report (DuPont CRG 2008a); 2008 Annual TCE Monitoring Report
(DuPont CRG 2009); 2009 Annual TCE Monitoring Report (DuPont
CRG 2010); 2010 Annual TCE Monitoring Report (DuPont CRG 2011);
2011 Annual TCE Monitoring Report (DuPont CRG 2012); 2012
Combined Annual Groundwater Monitoring Report (DuPont CRG
2013); 2013 Combined Annual Groundwater Monitoring Report
(DuPont CRG 2013); 2014 Annual Groundwater Monitoring Report
(DuPont CRG 2014); 2015 Annual Groundwater Monitoring Report
(Parsons 2015); 2016 Annual Groundwater Monitoring Report
(Parsons 2016); 2017 Annual Groundwater Monitoring Report
(Parsons 2017); 2018 Annual Groundwater Monitoring Report
(Parsons 2018); 2019 Annual Groundwater Monitoring Report
(Parsons 2019); 2020 Annual Groundwater Monitoring Report
(Parsons 2020); 2021 Annual Groundwater Monitoring Report
(Parsons 2021)
SWMU 33 Closure
2006-2009
Formally close the hazardous waste storage pad (SWMU 33).
Hazardous Waste Pad Closure Sampling and Analysis Plan (DuPont
CRG 2005); Hazardous Waste Pad Clean Closure Confirmation Report
(DuPont CRG 2006); Hazardous Waste Pad Closure Follow Up
Sampling (DuPont CRG 2007); SWMU 33 Demolition Work Plan
(DuPont CRG 2008); Hazardous Waste Pad Demolition Closure
Report (DuPont CRG 2009)
SWMU 65 Remedial Action
Plan
2007-2009
Investigate previous releases of number 6 fuel oil from two above-
ground storage tanks (ASTs) and underground piping. Delineate
the lateral and vertical extent of contamination. Excavate and
dispose of 289 tons of impacted soil.
SWMU 65 Fuel Oil Delineation Investigation Work Plan (DuPont CRG
2006); SWMU 65 Fuel Oil Delineation Report (DuPont CRG 2007);
SWMU 65 Remedial Action Plan (DuPont CRG 2008); SWMU 65
Remedial Action Report (Parsons 2010).
Page 2 of 3

Historical Chronology of RCRA Assessments and Investigations
Covation Biomaterials Kinston Site (Formerly DuPont)
Investigation
Date
Investigation Objective/Description
Investigation Work Plans and Reports
SWMU 65 Remedial Action
Plan
2007-2009
Investigate previous releases of number 6 fuel oil from two above-
ground storage tanks (ASTs) and underground piping. Delineate
the lateral and vertical extent of contamination. Excavate and
dispose impacted soil.
SWMU 65 Fuel Oil Delineation Investigation Work Plan (DuPont CRG
2006); SWMU 65 Fuel Oil Delineation Report (DuPont CRG 2007);
SWMU 65 Remedial Action Plan (DuPont CRG 2008); SWMU 65
Remedial Action Report (Parsons 2010).
New AOC (SWMU 90)
Supplemental Investigation
2004-2010
Perform an investigation at a newly identified AOC (buried drum).
Remove the identified drums and sample groundwater to
determine the extent of contamination. Conduct a geophysical
survey to determine if there were any other buried drums or
metal debris.
Surface Geophysical Survey at New Area of Concern (AOC) (DuPont
CRG 2004); New Area of Concern (AOC) Revised Investigation Work
Plan (DuPont CRG 2006); Revised Trench investigation and Surface
Geophysical Survey Report at New Area of Concern (AOC) (DuPont
CRG 2007); New Area of Concern (AOC) Supplemental Investigation
Work Plan (DuPont CRG 2008b); New Area of Concern Supplemental
Investigation Report (Parsons 2010b)
SWMU 56 Interim Measure
2010
Decommission coal pile located south of SWMU 56.
Phase III RCRA Facility Investigation Report (Stage II; Parsons 2014)
Phase III: Stage I RFI
2012
Collect groundwater samples to fill data gaps in the west and
southwest part of the Site, create a potentiometric map, evaluate
groundwater quality to confirm there are no impacts to the
shallow and Peedee Aquifers in the west and southwest area of
the Site, monitor groundwater to surface water interactions on
the perimeter of the Site, and calculate groundwater velocity.
Phase III RCRA Facility Investigation Work Plan (Stage I) (Parsons
2011); Phase III RCRA Facility Investigation Report (Stage I; Parsons
2012a); Phase III RCRA Facility Investigation Report (Stage 1)
Comments (DuPont CRG 2012)
Phase III: Stage II RFI
2014
Investigate soil and groundwater in 14 SWMUs and two potential
new units. Collect a round of Site -wide groundwater samples.
Phase III RCRA Facility Investigation Work Plan (Stage II; Parsons
2012b); Addendum to Phase III RFI Work Plan (Stage II) (DuPont CRG 2013);
Phase III RCRA Facility Investigation Report (Stage II; Parsons 2014);
Response to Comments for Phase III (Stage II) RFI Report (DuPont
CRG 2015)
Environmental Indicator
Determination
2014
Evaluate the RCRIS El code for corrective action pertaining to
"migration of contaminated groundwater under control" (CA750).
Environmental Indicator Determination Report Migration of
Contaminated Groundwater Under Control (CA750) (Parsons 2014a)
Final RFI Investigation
2018
Collect surface water and sediment samples at Beaverdam Branch
and drainage channels, and soil gas samples near occupied
buildings. Install and sample a temporary monitoring well for 1,4-
dioxane, perform a groundwater elevation MW survey, abandon
temporary MWs, evaluate SWMU covers, and perform a biological
survey in drainage channels and Beaverdam Branch.
Final RFI Work Plan (PIONEER 2016); Addendum to the Final RFI Work
Plan (PIONEER 2017); Final RFI Field Report (Parsons 2018: See
Appendix A); Responses to DEQ Comments on Final RFI Report (DuPont
CRG 2020)
Confirmatory Sampling
2021
Collect groundwater samples in the vicinity of SWMU 82 and
evaluate for 6 PFA compounds (PFHxS, PFOS, PFOA, PFNA, 6:2 FTS,
8:2 FTS) which are common indicators of firefighting foam.
SWMU 82 Confirmatory Sampling (CS) Work Plan (Parsons 2021);
SWMU 82 Confirmatory Sampling (CS) Work Plan — Revision 1
(Parsons 2021); SWMU 82 Confirmatory Sampling (CS) Report
(Parsons 2021); SWMU 82 Confirmatory Sampling (CS) Report —
Revision 1 (Parsons 2022)
Page 3 of 3