NC0003760_Response to NOD-2023-LV-0010_20230210

C,OVATIOfl B I OTM
February 10, 2023
Mr. Robert Tankard
Division of Water Resources
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
[e-mail]
RE: Notice of Deficiency Response (NOD-2023-LV-0010)
Covation Biomaterials Kinston Site (NC0003760)
Dear Mr. Tankard,
The Covation Biomaterials Kinston Site received a Notice of Deficiency ("NOD") for the October 2022
Discharge Monitoring Report ("DMR") due to the pH readings at Outfall 002 falling below the daily
minimum limit on October 11, 2022, and October 18, 2022. As noted in the comments to the October 2022
DMR, the Kinston Site does not believe site discharges were a contributing source to the pH deviations at
the currently permitted monitoring point for Outfall 002.
In response to the pH deviations, the Kinston Site reviewed available pH data. The Kinston Site's domestic
water, demineralized water, boiler water, chilled water, steam condensate, and cooling water systems are
all analyzed for pH by an on -site contractor, ChemTreat. Table 1 provides the pH measurements from
the ChemTreat service report for October 10, 2022.
Table 1. Outfall 002 pH Analyses
Parameter
Domestic
Water
RO
Water
Boiler
Feeed
Boiler
No. 4
Boiler
No. 5
Combined
Condensate
3G4
Chilled
Water
FER
Cooling
Tower
3G4
Cooling
Tower
Chilled
Water
Target pH
--
6.0-8.1
8.5-10.0
9.8-10.6
9.8-10.6
8.0-9.0
7.5-8.9
8.0-9.2
8.0-9.2
7.5-8.5
Measured pH
8.03
6.70
9.08
10.56
10.68
8.77
8.73
8.82
8.47
8.87
The Kinston Site also conducted several pH analyses upgradient of the permitted monitoring point for
Outfall 002. All Kinston Site discharges to Outfall 002 tested within NPDES permit limits for pH. The
currently permitted monitoring point for Outfall 002 is in a ditch that also collects runoff from adjoining
farmland. Based on this contributing source, the Kinston Site has requested to move the monitoring point
for Outfall 002, as noted in the site's NPDES permit renewal.
Please do not hesitate to contact me at [phone] if you have any questions or need any additional
information.
Sincerely, ��
5i A4 44,4dia, gd
Shelby Arellano
Environmental Engineer
Covation Biomaterials LLC
cc: Robbie Bullock, Division of Water Resources
David Suggs, Covation Biomaterials LLC
Covation Biomaterials LLC • Kinston Site • 4693 Hwy 11 N, Grifton, NC 28530