NC0003760_Response to Notice_20230321

c/z)vAT i on B i OTM
March 21, 2023
Mr. Robert Tankard
Division of Water Resources
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
[e-mail]
RE: Notice of Violation Response (NOV-2023-LV-0154)
Covation Biomaterials Kinston Site (NC0003760)
Dear Mr. Tankard,
The Covation Biomaterials Kinston Site received a Notice of Violation ("NOV") for the January 2023
Discharge Monitoring Report ("DMR") due to an exceedance of the permit limits for copper at Outfall 003.
On January 23, 2023, the copper concentration in a composite sample collected at Outfall 003 exceeded
the applicable daily maximum and monthly average permit limits. As noted in the comments to the
January 2023 DMR, the only non -routine activity occurring during the sample time frame was demolition
and removal work.
Upon receipt of the copper results, Covation Biomaterials conducted additional sampling to investigate
the exceedance. The required monthly composite sample at Outfall 003 was collected on February 1,
2023. A voluntary grab sample was collected at Outfall 003 on February 10, 2023. The copper
concentration for the composite sample was well below permit limits, and the copper concentration for
the grab sample was non -detect. These readings are consistent with previous results collected at Outfall
003. Surface soil samples were also collected from the area where non -routine demolition and removal
work was taking place. Eurofins Lancaster Laboratories Environment Testing analyzed the surface soil
samples for copper at the demolition and removal work area, and results were 64 mg/kg and 84 mg/kg.
These concentrations are consistent with background soil concentrations and are not indicative of a
contributing source.
The Kinston Site does not anticipate further issues with copper concentrations at Outfall 003. Covation
Biomaterials is committed to working with the Division of Water Resources ("DWR") and operating the
site consistent with the NPDES permit.
Please do not hesitate to contact me at [phone] if you have any questions or need any additional
information.
Sincerely,
Shelby Arellano
Environmental Engineer
Covation Biomaterials LLC
cc: Robbie Bullock, Division of Water Resources
David Suggs, Covation Biomaterials
Covation Biomaterials LLC • Kinston Site • 4693 Hwy 11 N, Grifton, NC 28530