NC0003760_More Information (Requested)_20220714

DocuSign Envelope ID: 8B17DAF8-8387-453D-8CB1-33F2810F6993
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Ms. Emily Price
Plant Manager
CovationBio Kinston Site
4693 Hwy 11 North
Grifton, NC 28530
Dear Ms. Price,
NORTH CAROLINA
Environmental Quality
July 14, 2022
Subject: NC0003760 - NPDES Renewal Application
CovationBio Kinston Site
County - Lenoir
Issued via US Mail and Email
The Division has reviewed the revised application for the subject permit submitted on May 5,
2022, and the response to additional information request submitted on June 24, 2022.
Unfortunately, the received information and submitted renewal package are insufficient and
therefore the renewal application is incomplete. We do appreciate the updated owner information
and change of ownership submittal of June 6, 2022.
Noteworthy is that investigations and corrective action plans completed by and on behalf of other
divisions, such as Division of Waste Management, are not necessarily deemed sufficient for the
purpose of NPDES permit renewal. Each division and its' permitting processes are regulated by
its own relevant regulations and policies. The Division has the authority to conduct any
investigations for the purpose of determining compliance with water quality standards, effluent
limitations, permit conditions (such as sampling by the staff for analysis) if we deem necessary
in accordance with 15A NCAC 02H .0117. Nevertheless, the facility is welcomed to submit any
sampling results as mentioned in the June 24, 2022 correspondence. To correct these deficiencies
please refer to the Additional Information Request included as Attachments 1 and 2 herein. In
order to timely process the application within the review period we will need complete and
thorough responses.
AROLINA
oep.m.m orEMr nment ou.i�
DE
NORTH C
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 8B17DAF8-8387-453D-8CB1-33F2810F6993
To enable us to complete the review in accordance with N.C.G.S. 143-215.1 and 15A NCAC
2H.0105, please provide all the information requested to this office during this renewal review
period. Please provide a response within 15 days of the date of this correspondence to
ensure the timely processing of the application.
As we work with you during the renewal process actions and efforts at the site must be taken and
implemented to ensure the site and facility is managed in a way to maintain compliance with
permit requirements. Failure to comply with conditions in a permit may result in a
recommendation of enforcement action to the Director of the Division of Water Resources who
may issue a civil penalty assessment of not more than twenty-five thousand ($25,000) dollars
against any "person" who violates or fails to act in accordance with the terms, conditions, or
requirements of a permit under authority of G.S. 143-215.6A. The Division will take proper
action as deemed necessary regarding this renewal application.
If no response is received within 60 calendar days [per 15A NCAC 2H.0107(b)], the project will
be deactivated and withdrawn from the review process and the documents recycled.
If you have any questions, please contact Amir Adaryani at: 919-707-3704 or via email at
[e-mail].
Sincerely,
p-DocuSigned by:
VO4 VOW AI&
�57287E56E81A40D...
Douglas Dowden
Environmental Program Supervisor II
Division of Water Resources/NCDENR
Ecopy: DWR Laserfiche files
DWR Amir Adaryani, PhD
Washington Reginal Office/Water Quality: David May, Robert Bullock, Robert
Tankard
CovationBio Kinston Site: Alex Torres, Shelby Arellano
D_E
NORTH CARCLINA
gaparMeM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 8B17DAF8-8387-453D-8CB1-33F2810F6993
ATTACHMENT 1
Additional Information / Clarification Request of May 5, 2022
From: Adaryani, Amir <[e-mail]>
Sent: Thursday, May 5, 2022 11:04 AM
To: Arellano, Shelby Kaye <[e-mail]>
Cc: TORRES, ALEX <[e-mail]>; Dowden, Doug <[e-mail]>; May,
David <[e-mail]>; Giri, Poonam a <[e-mail]>; Siedlecki, Mary
<[e-mail]>; Bullock, Robert <[e-mail]>
Subject: [EXTERNAL] Additional information request_ Groundwater_Dupont Kinston
Shelby,
Pursuant to "Section B. Groundwater monitoring" of 'Part III Other Requirements' of the current NPDES
permit, please sample and analyze (one-time) monitoring wells MW-10, MW-11, MW-17A, MW-21,
MW-52, MW-19, MW-20, MW-22, and MW-25 (see attached map from RFI report) for the following
pollutants:
-Acrolein and ALL parameters in condition A.(2.) of current permit
- PFAS compounds:
• PFBA
• PFPeA
• PFHxA
• PFHpA
• PFOA
• PFNA
• PFDA
• PFDoA
• PFBS
• PFHxS
• PFOS
• 6:2 FTSA
• 8:2 FTSA
• HFPO-DA
The analysis should be done for the PFAS compounds with EPA's draft method 1633 or similar. The
analysis should be done by a certified laboratory similar to those required by NPDES permits pursuant to
40 CFR 136.
According to division of waste management, the mentioned wells should be available for sampling. If
this is not the case, please inform the division and provide a proper plan to accommodate groundwater
sampling. Sampling data shall be reported with an accompanying GW-59 Groundwater Quality
Monitoring Report Form (attached) for each sampled well along with attached copies of laboratory
analyses and submitted to the following addresses.
NCDEQ/ DWR
NPDES Industrial Permitting Unit
Attn: Amirhossein Adaryani
D_E
NORTH CARCLINA
Deportment of Environmental quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 8B17DAF8-8387-453D-8CB1-33F2810F6993
1617 Mail Service Center
Raleigh, NC 27699-1617
and by email to: [e-mail]; [e-mail]
And to
NC Division of Water Resources
943 Washington Square Mall
Washington, North Carolina 27889
We appreciate your kind attention to these matters and look forward to continuing to work with you on
this permit renewal. To avoid unnecessary delays please remember per 15A NCAC 02H .0107(b),
additional information must be provided within 60 days of request. Pending review and evaluation of
provided information, further action or additional information may be required.
Thank you
If you should have any questions and/or concerns please feel free to reach out to me at your earliest convenience.
Sincerely,
Amirhossein (Amir) Rezaei Adaryani, Ph.D
Division of Water Resources / Permitting
Department of Environmental Quality
Office: Archdale Building, 9th Floor (925 Cubicle by Window) 512 North Salisbury Street, Raleigh, NC
27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3704
D_E
NORTH CARCLINA
Deportment of Environmental quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 8B17DAF8-8387-453D-8CB1-33F2810F6993
ATTACHMENT 2
Additional Information / Clarification Request of March 11, 2022
Adaryani, Amir
Fri 3/11/2022 12:54 PM
To: Arellano, Shelby Kaye <[e-mail]>
Cc: Dowden, Doug; [e-mail]
+2 others
Good afternoon,
The Industrial NPDES Permitting Unit of Division of Water Resources has reviewed the renewal
application of Dupont Kinston facility. Please see comments and questions below for initial
renewal application, first addendum and stormwater program. This office expects delivery
of the requested updates and information to the best capacity of the applicant. Timely and
thorough response from the applicant would greatly help the process of this application.
Please note that Stormwater program (DEMLR) personnel will also reach out to the facility
regarding the separate application submitted to their office, as they suit best.
Initial Renewal Application:
1. With Beaverdam Branch designated as Class C, Sw (swamp water), it could not be
used for any discharge. Based on 15A NCAC 02B .0211 (Water Quality Standards
for Class C Waters), the dissolved oxygen standard states "Dissolved oxygen: not
less than 6.0 mg/1 for trout waters; for non -trout waters, not less than a daily average
of 5.0 mg/1 with an instantaneous value of not less than 4.0 mg/1; swamp waters, lake
coves, or backwaters, and lake bottom waters may have lower values if caused by
natural conditions."
There is no "de minimus" provision in the North Carolina Water Quality standards;
no speculative limits or modeling review could be provided in Class C swamp waters
that do not meet the dissolved oxygen standard. In these circumstances permitting
any loading (regardless of the level of treatment provided) via an NPDES permit
would be precluded.
2. For clarification, please define "OSC" in section 4.1.
3. In Figure 1 (water balance diagram) include input/output flows and any possible
water loss (in mgd).
4. Specify the chemicals that are in use in water treatment. This would apply to
polymers mentioned in sections 4.4 and 4.5.
5. Considering the detection of PFAS in Confirmatory Sampling (CS) Report in
groundwater related, to Hazardous and Solid Waste Amendments (HSWA)-only
Permit (EPA ID No. NCD003190386), and priority of contamination control of Per -
and Polyfluoroalkyl Substances (PFAS) to NC DEQ (and EPA), division of water
resources request for one-time analysis of PFAS in process wastewater, stormwater
and groundwater/leachate separately prior to release to treatment plant, as possible.
DE
NORTH CAROLINA
gaparMeM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 8B17DAF8-8387-453D-8CB1-33F2810F6993
Also, PFAS analysis should be done in all wastewater NPDES outfalls (existing and
proposed), at discharge point. The analysis should be done for the following PFAS
compounds, (with EPA method 1663 or similar). The analysis should be done by a
certified laboratory similar to those required by NPDES permits pursuant to 40 CFR
136:
• PFBA
• PFPeA
• PFHxA
• PFHpA
• PFOA
• PFNA
• PFDA
• PFDoA
• PFBS
• PFHxS
• PFOS
• 6:2 FTSA
• 8:2 FTSA
• HFPO-DA
6. Provide any anticipated change in quality/quantity of discharge due to addition of
fire protection water and impacted groundwater to outfall 002. This should include
narratives on details of systems, possible presence of Aqueous Film Forming
Foams (AFFF) with PFAS etc.
7. Provide clarification on outfall 012 which is missing from section 9.1 despite its
designation as new outfall in section 8.2.
8. Provide details on wells marked in topographic map (Appendix A). There's no
mention of these wells in the narrative section.
9. Define the details and marked items for the SWMU location map and Final RFI
locations (Appendix C and D).
10. In form 2C, elaborate on part 3.1 description of treatment units following the form's
instructions.
11. Dupont Kinston plant is "Plastic and synthetic materials manufacturing"
facility and categorized as primary industry (see Exhibit 2C-3). Analysis and
report of all GC/MS fractions are required for this facility and therefore, Table
B needs to be filled accordingly. Instructions of EPA's form 2C should be
consulted.
12. Please provide lab sheets for presented values of pollutants in EPA forms
(including lab certification, methods and QA/QC etc.)
DE
NORTH CAROLINA
gaparMeM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 8B17DAF8-8387-453D-8CB1-33F2810F6993
Addendum 1:
1. In section 4, as defined in the form's instructions, groundwater discharge could be
intermittent and should be included in the part 4.2. Also, as all of outfalls (No.
002, 005, 006) have stormwater in them that is an exception to intermittent flow.
Therefore, stormwater in mentioned outfalls should be provided separately with
best estimation.
2. In attachment 2, for provided flows, basis of estimation should be given.
Referring to RFI report is not simply sufficient.
3. Please clarify on basis of flow amount (p. 9 of form 2C) for outfall 002. It does
not match with the estimated flow table (section 3.1).
4. In tables A, B and C of form 2C (outfalls 002 and 005), mass loading of all
present pollutants should be provided.
5. Please clarify on concentration units of row 2.22 of table B of form 2C (outfall
006).
6. Please clarify for application of less than sign (<) for all corresponding values in
forms 2C.
7. In general, for any of the comments on forms 2C or 2A, instructions of those
should be consulted.
8. Please elaborate on presence of Formaldehyde and Vanadium in table D (form
2C, outfall 002 and 006) in relation to past investigations.
9. Please provide lab sheets for presented values of pollutants in EPA forms
(including lab certification, methods and QA/QC etc.)
10. For easier processing of NPDES permit application, submittal of application
package that includes initial application with incorporated addendums with
proper corrections, and addition of any extra information is recommended.
Comments and question from Stormwater program (DEMLR):
1. During the site visit, Stormwater Permitting staff observed railroad tracks in the
vicinity of SW007. Please verify what is transported on these railroad tracks and
if any spills have occurred in the past.
2. Verify if/when PCBs are/were used in the transformers in the SW004 drainage
area.
3. During the site visit, Stormwater Permitting staff observed creosote railroad ties
in the drainage area of SW004. Please provide additional information on how
long these railroad ties have been sitting in place, how frequently they are
removed/replaced, and if there are any disposal procedures for them.
We appreciate your kind attention to these matters and look forward to continuing to work with
you on this permit renewal. To avoid unnecessary delays please remember per 15A NCAC 02H
.0107(b), additional information must be provided within 60 days of request.
DE
NORTH CAROLINA
gaparMeM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 8B17DAF8-8387-453D-8CB1-33F2810F6993
Thank you
If you should have any questions and/or concerns please feel free to reach out to me at your earliest convenience.
Sincerely,
Amirhossein (Amir) Rezaei Adaryani, PhD
Division of Water Resources / Permitting
Department of Environmental Quality
Office: Archdale Building, 9th Floor (925 Cubicle by Window) 512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3704
D_E
NORTH CAROLINA
gaparMeM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000