NC0003760_More Information (Received)_20220729

C,OVATIOfl B I OTM
Via Email and Certified Mail (7019 2280 0001 2298 1671)
July 29, 2022
Mr. Doug Dowden
Supervisor, NPDES Industrial Permitting
North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
RE: NPDES Renewal Application Correspondence
NC0003760 - Covation Biomaterials Kinston Site (Lenoir County)
Dear Mr. Dowden,
Covation Biomaterials LLC (CovationBio) submits this letter in response to correspondence it received
from the Division of Water Resources (DWR) on July 15, 2022. CovationBio understands that DWR
believes the following information is needed to proceed with the National Pollutant Discharge
Elimination System (NPDES) permit renewal for the Kinston Site:
1. Analysis of acrolein, parameters in condition A2 of the current NPDES permit, and Per- and
Polyfluoroalkyl Substances (PFAS) in nine (9) listed groundwater monitoring wells.
2. Analysis of PFAS in process wastewater, stormwater, and groundwater/leachate separately
prior to release to the wastewater treatment plant, as possible.
3. Analysis of PFAS in all NPDES wastewater outfalls (existing and proposed).
For clarification, please confirm the three (3) items summarized above cover all analysis gaps that are
preventing DWR from determining that CovationBio's NPDES renewal application is complete. In
addition, please verify whether: (1) CovationBio needs to prepare another revised application package
(before the Kinston Site was acquired by CovationBio, DuPont Industrial Biosciences USA, LLC ("Dupont
Biosciences") submitted the first revised application on May 6, 2022); or (2) if submission of the above
sample results, laboratory analyses, and the applicable GW-59 Groundwater Quality Monitoring Report
Forms will be sufficient.
We believe a phone conversation might be helpful to discuss the currently pending renewal application,
the additional items that DWR is seeking, and a sampling plan acceptable to DWR. Given the long history
of the Kinston Site, historical information helpful for DWR's consideration may be available. We
appreciate your patience and understanding as CovationBio steps into the renewal application initiated
by Dupont Biosciences.
CovationBio notes that DWR's decision to deem the first NPDES renewal application incomplete appears
to rely upon authority delegated by the Environmental Management Commission ("EMC") to DWR to
conduct any investigations that DWR deems necessary in accordance with 15A NCAC 02H .0117. Please
note, however, that the authority delegated by the EMC to DWR is subject to a rule of reasonableness
and necessity. Specifically, 2H .0117 provides that DWR "may conduct any investigations as provided in
G.S. 143-215.3(a)(2), (7), and (9) for the purpose of determining compliance with water quality
standards, effluent limitations, permit conditions and these Rules." The pertinent statutory authority
Covation Biomaterials LLC • Kinston Site • 4693 Hwy 11 N, Grifton, NC 28530 1

under G.S. 143-215.3(a)(2) limits such investigations to those that DWR "may reasonably deem necessary
to carry out its duties..." (emphasis added).
As Dupont Biosciences attempted to convey in the initial and first NDPES renewal application, the
Kinston Site has a long history of environmental investigation. RCRA Facility Investigation (RFI)
activities began at the Kinston Site in 1983 and were completed with a final RFI field investigation in
2018. As a result, the site is well -studied and existing contamination has been adequately delineated
and defined. CovationBio hopes to utilize existing information to reduce duplicative and unnecessary
analysis whenever possible and appropriate.
CovationBio notes three (3) remaining items in response to DWR's July 15, 2022 letter.
First, the additional information request states that analysis for PFAS should be done with EPA's draft
method 1633 or similar. CovationBio is proposing to utilize EPA Method 537 Modified for PFAS
analysis. Please confirm that EPA Method 537 Modified is acceptable to DWR.
Second, CovationBio is requesting a sixty (60)-day extension to the sixty (60) calendar days given to
complete the requested sampling, even if DWR agrees to reduce the sampling from a total of nine (9)
monitoring wells and all NPDES wastewater outfalls (existing and proposed) to a number deemed
reasonable and necessary. No matter how many wells and outfalls are sampled, the requested analyses
require extensive coordination with external contractors and certified laboratories. In addition, flow in
almost all NPDES wastewater outfalls is heavily dependent on rain events. A total of 120 calendar days
provides an adequate timeline given the constraints that are beyond CovationBio's control. CovationBio
is not seeking needless delay —it is already in the process to secure a contract for the requested
sampling and analyses.
Third, Groundwater Monitoring Well No. 19 has been damaged by a fallen tree and is not currently
available for sampling. CovationBio will have a certified well contractor assess the extent of the damage.
CovationBio is unable to provide a timeline for the repairs until this assessment is complete.
In closing, CovationBio is proactively improving the monitoring of potential pollutant discharges from
legacy DuPont activity at the Kinston Site. CovationBio is committed to operating the Kinston Site in
compliance with water quality standards, effluent limitations, and permit conditions to ensure
conditions remain protective of human health and the environment. CovationBio was unaware that
DWR apparently considers information obtained from Resource Conservation and Recovery Act (RCRA)
Kinston facility investigations over the past thirty (30) years as insufficient for the purposes of this
NPDES permit renewal. We remain hopeful that some of that information may help satisfy DWR's needs.
Thank you for your patience in working with us during this renewal process. We look forward to our
continued work with DWR and the Department of Environmental Quality as a whole.
Sincerely,
,5WeleN 44-.ik..I'„d
Shelby Arellano
Environmental Engineer
CC: Amirhossein Adaryani, PhD, North Carolina Department of Environmental Quality
David May, North Carolina Department of Environmental Quality
Robert Bullock, North Carolina Department of Environmental Quality
Robert Tankard, North Carolina Department of Environmental Quality
Emily Price, Covation Biomaterials LLC
Alex Torres, Covation Biomaterials LLC
Covation Biomaterials LLC • Kinston Site • 4693 Hwy 11 N, Grifton, NC 28530 2