NCS000608_Fact sheet binder_20231018

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 10/9/2023
Permit Number NCS000608
Owner/Facility Name Covation Biomaterials,LLC/Covation Biomaterials
Kinston Site
2821 (325211)/Plastics Materials, Synthetic Resins,
SIC(NAICS) Code/Category and Nonvulcanizable Elastomers(Plastics Material
and Resin Manufacturing)
Basin Name/Sub-basin number Neuse/03-04-05
Receiving Stream/HUC UT to Beaverdam Branch/030202020307
Stream Classification/Stream Segment C; Sw,NSW/27-83
Is the stream impaired on 303 d list]? No
Any TMDLs? No
Any threatened and/or endangered species? See Section 2 below
Any compliance concerns? See Section 2 below
Any permit mods since last ermit? N/A
New expiration date 10/31/2028
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The Covation Biomaterials,LLC Kinston Site produces polytrimethylene terephthalate (PTT), a bio-based
polymer widely used in textile and other woven goods. The process uses purified TPA and 1,3-
propanediol (PDO), with water, allyl alcohol, acrolein, and n-butanol as byproducts of the production
process. Manufacturing operations at the facility began in 1953. Historical manufacturing operations
included the production of polyethylene terephthalate (PET)polyester resin and fibers,which was
produced using either dimethyl terephthalate (DMT) and ethylene glycol or terephthalic acid(TPA) and
ethylene glycol. All filament and fiber manufacturing lines have been discontinued, and the
decommissioned and abandoned in-place facilities have been removed down to the concrete slab. The
facility repairs and maintains the site-owned and CSX-owned railroad tracks located onsite. Work
conducted on the CSX-owned tracks are by request from CSX.
Ancillary activities onsite include raw material and product storage, combustion sources, and wastewater
treatment. Materials stored onsite include terephthalic acid(TPA) 1,3-propanediol (PDO), titanium
dioxide anatase (Ti02), organic titanate catalyst(TnBT), diesel fuel, gasoline, Therminol VP-1, water
treatment chemicals, aqueous ammonium hydroxide, sodium bisulfate, sodium hypochlorite, clarifier and
wasting polymers,process wastewater, industrial process waste, and sludge waste. There are also solid
waste management units (SWMUs) and landfills onsite and contain significant materials from historical
operations.
The site currently has an NPDES wastewater permit(NC0003760) with stormwater outfalls identified in
the permit as 004, 005, and 006. Outfalls 005 and 006 are influenced by groundwater and will remain in
the NPDES wastewater permit. Outfall 004 and the new outfall 007 are stormwater only outfalls and
will be addressed in this new permit application.
Page 1 of 9

Outfall SW004:
Drainage area consists of transformers, creosote railroad ties (when maintenance is being performed),
railroad tracks, tank farm, truck shop,warehouse and storage buildings, switchyard, vehicle refill
station, concrete slab from demolition work, and grassy areas.
Outfall SW007:
Drainage area consists of railroad tracks, warehouse and storage buildings, shipping and receiving,
grassy areas, and paved parking lots.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading,transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• New stormwater permit—no benchmark or NOV data to review
• Review of NC0003760 monitoring data for outfall 004:
o No exceedances noted 12/2018 to 7/2021
Threatened/Endangered Species:
There are no threatened/endangered species at the discharge location, however, in the nearby vicinity
there are Atlantic Sturgeon (Acipenser oxyrinchus oxyrinchus; NC status: E; Federal status: E), West
Indian Manatee (Trichechus manatus;NC status: T; Federal status: T), and Neuse River Waterdog
(Necturus lewisi; NC status: SC; Federal status: T).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for a single storm event in November 2021. Quantitative sampling included pH, TSS, O&G,
BOD, COD, total phosphorus, TKN, total nitrogen, nitrate/nitrite, zinc, mercury, copper, iron, lead,
mercury, and total hardness.
Page 2 of 9

Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Covation Biomaterials Kinston Site.
Outfall SWO04
Total Suspended Solids Quarterly monitoring
(TSS) BASIS: Potential pollutant from drainage area and BMP effectiveness
indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Total Phosphorus BASIS: Discharge potential indicator
Quarterly monitoring
BASIS: Potential pollutant from drainage area
PCBs Note:Monitoring may cease after 4 consecutive samples are below
detection (PCB transformers were removed from site in 2015)
Quarterly monitoring
Total Mercury BASIS: Potential pollutant from drainage area (based on information
submitted with application)
Quarterly monitoring
Total Zinc BASIS: Potential pollutant from drainage area(based on information
submitted with application)
Total Hardness Quarterly monitoring
BASIS: Monitoring for hardness dependent metals present
Page 3 of 9

Outfall SWO07
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Total Phosphorus BASIS: Discharge potential indicator
Quarterly monitoring
Total Copper BASIS: Potential pollutant from drainage area(based on information
submitted with application)
Quarterly monitoring
Total Lead BASIS: Potential pollutant from drainage area(based on information
submitted with application)
Quarterly monitoring
Total Mercury BASIS: Potential pollutant from drainage area (based on information
submitted with application)
Quarterly monitoring
Total Zinc BASIS: Potential pollutant from drainage area (based on information
submitted with application)
Total Hardness Quarterly monitoring
BASIS: Monitoring for hardness dependent metals present
Page 4 of 9

Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan (SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Page 5 of 9

Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Total Nitrogen 30 mg/L TKN+Nitrate+Nitrite Benchmarks (Expressed in mg/L of
N
Total Phosphorus 2 m /L BPJ; Based on wastewater permit limits for NSW waters
There shall be The aquatic life standard is 0.001 µg/L. The detection limits
no discharge of for Arochlors 1016, 1221, 1232, 1242, 1248, 1254, 1260, and
PCBs PCB 1262 are 1 µg/L. Because we cannot quantify PCBs below the
compounds detection limit, any detection is considered an exceedance of
the benchmark.
Copper Total 10 /L Acute Aquatic Criterion, '/2 FAV
Lead Total 75 /L Acute Aquatic Criterion, '/2 FAV
Mercury(Total) 12 ng/L CCW/Coal Constituent; Chronic 02B standard
Zinc Total 126 /L Acute Aquatic Criterion, '/2 FAV
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BATBCT.
Mercury Monitoring Requirements: The proposed permit requires mercury to be measured in
stormwater samples by EPA Method 1631E,which can detect levels as low as 0.5 ng/l. This requirement
is consistent with recent federal rule-making that requires NPDES permittees to monitor discharges with
sufficiently sensitive test procedures approved under 40 CFR §136. Modifications to 40 CFR §122.44(i)
require a method that has a minimum level (ML) at or below the effluent limit(not applicable here), or
the lowest minimum level (ML) of EPA approved analytical methods for the measured parameter. Based
on results, Method 1631E will be required to quantify levels in these discharges. NC DEMLR
understands that this method is more costly and requires a more intensive sampling protocol than most
other parameters, and that fish tissue sampling will be provided during the permit cycle. Therefore, no
Page 6 of 9

benchmark applies that would trigger tiered response actions. Proposed permit provisions also allow the
permittee to use field blank and/or method blank concentrations to adjust reported mercury levels as
long as documented is submitted with the Data Monitoring Report DMR).
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP) requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Changes from previous permit to draft:
• N/A
Section 5. Changes from draft to final:
• Typo corrected in Condition I.La to reference B-8 instead of B-9
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 3/11/2022
Page 7 of 9

• Initial contact with Regional Office: 2/15/2022
• Draft sent to CO peer review: 8/25/2023
• Draft sent to Regional Office: 8/30/2023
• Final permit sent for supervisor signature: 10/11/2023
Section 7. Comments received on draft permit:
• Amir Rezaei Adaryani (Industrial Wastewater Permitting; via email 9/5/2023): I have reviewed
the draft permit. I think it would be good to mention in the permit and the cover letter that the
outfalls covered under SW permit used to be part of NPDES NC0003760. Also, starting with the
effective day of SW their monitoring will be different and therefore should be reflected on
BIMS/eDMR. I appreciate you for keeping me updated.
• Doug Dowden (Industrial Wastewater Permitting; via email 9/5/2023): The only thing I would
suggest is that since you mention Atlantic Sturgeon (Acipenser oxyrinchus oxyrinchus), West
Indian Manatee (Trichechus manatus), and Neuse River Waterdog (Necturus lewisi) as
endangered species, you may want to provide reference or a link to the corresponding
regulations. Nice that you included that detail though.
• Shelby Arellano (Covation Bio; via mail 9/29/2023):
o Part J provides a definition for a Section 313 water priority chemical. Based on Condition
b under this definition, it is CovationBio's understanding that a chemical is only a
Section 313 water priority chemical if the facility is required to report for that chemical in
their Toxic Release Inventory Report and the other conditions under(a) and(c) are met.
CovationBio requests confirmation of this understanding.
■ DEMLR response: Based on the definition, a Section 313 Water Priority
Chemical meets all the conditions set forth in the definition.
o Condition C.Lc states that visual inspections are not required to be performed outside of
the facility's normal operating hours. CovationBio requests confirmation that"normal
operating hours" are defined as normal business hours. CovationBio requests
confirmation that visual inspections are not required to be performed outside of normal
business hours or during adverse weather conditions.
■ DEMLR response: Normal operating hours are defined as the time when facility
staff are present onsite. For example, if staff are onsite from 8am-5pm Monday
through Friday, those would be normal business hours. If staff were onsite from
lam to 5pm Monday through Thursday, that would be defined as normal business
hours. Visual inspections and quantitative sampling are not require outside of the
facility's normal business hours.
o Condition D.3.e states that sampling is not required to be performed outside of the
facility's normal operating hours or during adverse weather conditions. Again,
CovationBio requests confirmation that sampling is not required outside of normal
business hours or during adverse weather conditions.
■ DEMLR response: Visual inspections and quantitative sampling are not require
outside of the facility's normal business hours. Sampling and inspections do not
need to be conducted during adverse weather conditions when staff safety could
be at risk.
o Condition I.La provides a compliance schedule for operating facilities applying for first-
time permit coverage. CovationBio requests confirmation that the compliance schedule
applies as this is the first permit issued by the Division of Energy, Mineral, and Land
Resources to the Kinston Site.
Page 8 of 9

■ DEMLR response: CovationBio shall follow all requirements as stated in the
permit as this is first time permit coverage under the Stormwater Program.
o Condition I.La states that secondary containment, as specified in B-9 of this permit, shall
be accomplished within 12 months of the effective date of the initial permit issuance.
However, Section B-8 of this draft permit provides secondary containment requirements,
and Section B-9 of this draft permit provides spill prevention and response procedures.
Please explain.
■ DEMLR response: This is a typo and has been corrected to reflect the correct
permit condition citation.
o Section B-8 requires secondary containment for bulk storage of liquid materials including
petroleum products, storage in any amount of water priority chemicals listed in Section
313 of Title III of the Superfund Amendments and Reauthorization Act("SARA"), and
storage of hazardous substances in any amount. Part J defines secondary containment as
spill containment for the contents of the single largest tank within the containment
structure plus sufficient freeboard to contain the 25-year, 24-hour storm event.
CovationBio requests approval for the use of alternative secondary containment methods
for the bulk storage of nonhazardous liquid materials with a low risk of release due to
tank integrity failure. The tanks are made of 304 stainless steel, in non-corrosive service
and tank integrity is maintained and reviewed by CovationBio using American Petroleum
Institute Standard 653 guidance. The tanks contain non-hazardous materials, and active
management practices will sufficiently contain any spill due to flange leaks, etc., and
prevent the contamination of stormwater runoff. CovationBio proposes the use of active
management(i.e., spill prevention and response procedures) for these low-risk materials.
Active management practices include,but are not limited to, the identification of possible
spill scenarios, conducting inspections to discover any potential spills, and having
sufficient spill containment equipment in place.
■ DEMLR response: Any bulk storage of materials stored outside that have
addition and/or withdrawal of material must follow appropriate secondary
containment requirements. Alternative forms of monitoring or containment are
not allowed.
Page 9 of 9

Affidavit of Publication
STATE OF NORTH CAROLINA PUBLIC NOTICE
NORTH CAROLINA
BEAUFORT & HYDE COUNTIES ENVIRONMENTAL
MANAGEMENT COMMISSION
INTENT TO ISSUE
Ashley Vansant, being duly sworn, says: NPDES STORMWATER
That he is Publisher of the Washington Daily News, DISCHARGE PERMITS
a dailynewspaper of general circulation, printed and Environmental North Carolina
9 P Environmental Management
published in Washington, Beaufort& Hyde Coun- commission proposes to issue
ties, North Carolina;that the publication, a copy of NPDES stormwater discharge
which is attached hereto, was published in the said permit(s)to the person(s)listed
newspaper on the following dates: below. Public the
comment or
9 objection to the draft permits
is invited. Written comments
regarding the proposed permit
will be accepted until 30 days
09/O6/23 after the publish date of this
notice and considered in the
final determination regarding
That said newspaper was regularly issued and permit issuance and permit
circulated on those dates. provisions. The Director of the
- - - - - - NC Division of Energy, Mineral,
and Land Resources (DEMLR)
The sum charged by the Newspaper for said publi- may hold a public hearing
cation does not exceed the lowest rate paid by com- should there be a significant
mercial customers for an advertisement of similar degree of public interest.
size and frequency in the same newspaper in which Please mail comments and/or
4 Yinformation requests to DEMLR
the public notice appeared. at 1612 Mail service center,
Raleigh,NC 27699-1612.
There are no agreements between the Washington Covation Biomaterials, LLC
[46Dail News and the officer or attorney charged with NC 2 NC Hwy 11 N, ed new
Y Y 9 NC 28530] has requested new
the duty of placing the attached legal advertising permit NCS000608 for the
notices whereby any advantage, gain or profit ac- covation Biomaterials Kinston
crued to said officer or attorney.
Site in LenoirCounty.Thisfacllity
discharges toan unnamed
tributary to Baaverdam Branch de-13
SIGNED: in the Neuse River Basin.
Interested persons may visit U;''. 4&1
DEMLR at 512 N. Salisbury
street, Raleigh, NC 27604
to review information on file. VOrjh lr7T�
Additional information on !ydf
NPDES permits and this notice
may be found on our website: •r
https://deq.nc.gov/about/
divisions/energy-mineral-and- y0
Ashley Vansant, Publisher land-resources/stormwater/
stormwater-program/
Subscribed and sworn to before me this stormwater-public-notices, or
6th Da of September, 2023 by contacting Brianna Young at
Y P [e-mail] or
919-707-3647.
i� Washington Daily News:
g PF Sm 6,2023
�J`u � 3 NOTARY Q Of PERMITS
PUBLIC' m
P
9f P
BARGE
Mary Jo Eskridge, Notary Public
State of Alabama at Large
My commission expires 03-02-2026
Account#304614
Ad# 1704134
NCDEQ
1612 MAIL SERVICE CENTER
RALEIGH NC 27699

Young, Brianna A
From: Dowden, Doug
Sent: Tuesday, September 5, 2023 4:38 PM
To: Adaryani, Amir; Young, Brianna A
Subject: Re: Covation Biomaterials, LLC draft stormwater permit NCS000608
Hi Brianna,
The only thing I would suggest is that since you mention Atlantic Sturgeon (Acipenser oxyrinchus
oxyrinchus), West Indian Manatee (Trichechus manatus), and Neuse River Waterdog (Necturus
lewisi) as endangered species, you may want to provide reference or a link to the corresponding
regulations. Nice that you included that detail though.
Sincerely,
Douglas Dowden
Environmental Program Supervisor II
Division of Water Resources / Permitting
Department of Environmental Quality
Office: Archdale Building, 9t" Floor (925Q)
512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3605
[e-mail] (formerly doug.dowden(.ncdenr.gov)
From:Adaryani, Amir<[e-mail]>
Sent:Tuesday, September 5, 2023 3:54 PM
To:Young, Brianna A<[e-mail]>
Cc: Dowden, Doug<[e-mail]>
Subject: RE: Covation Biomaterials, LLC draft stormwater permit NCS000608
Hi Briana,
I have reviewed the draft permit. I think it would be good to mention in the permit and the cover letter that the outfalls
covered under SW permit used to be part of NPDES NC0003760. Also, starting with the effective day of SW their
monitoring will be different and therefore should be reflected on BIMS/eDMR. I appreciate you for keeping me updated
Doug, please feel free to add any comments.
Thank you
Amirhossein(Amir) Rezaei Adaryani, PhD
1

Environmental Engineer, Division of Water Resources, Permitting
North Carolina Department of Environmental Quality
Office: 919-707-3704
D_ E
tjA�
NORTH CAROLINA
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From:Young, Brianna A<[e-mail]>
Sent: Wednesday,August 30, 2023 9:37 AM
To: Dowden, Doug<[e-mail]>; Adaryani,Amir<[e-mail]>
Subject: Covation Biomaterials, LLC draft stormwater permit NCS000608
Good morning,
We are submitting the draft stormwater permit for Covation Biomaterials, LLC (NCS000608)to public notice. Please
review and let me know if you have any comments on the draft permit by 9/29/2023. Amir,you previously reviewed the
draft permit for us many months back. Not much change from then, but we would appreciate your review again. Please
let me know if you have any questions.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

GOVATIonBio _
Via Email and Certified Mai] S a��ipco9�c�
September 27,2023 fivw�S �
Ms. Brianna Young
North Carolina Department of Environmental Quality
Division of Energy,Mineral,and Land Resources
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, NC 27699-1612
Re: Covation Biomaterials Draft NPDES Stormwater Permit Response
NPDES Permit NCS000608—Covation Blomaterials Kinston Site (Lenoir County)
Dear Ms.Young,
Covation Biomaterials LLC ("CovationBio') received draft National Pollutant Discharge Elimination
System ("NPDES") Stormwater Permit NCS000608 on August 30, 2023 for stormwater discharges from
the Covation Biomaterials Kinston Site. For your review, CovationBio submits this letter with the
following comments on the draft NPDES stormwater permit:
1. Part]provides a definition for a Section 313 water priority chemical.Based on Condition b tinder
this definition, it is CovationBio's understanding that a chemical is only a Section 313 water
priority chemical if the facility is required to report for that chemical in their Toxic Release
Inventory Report and the other conditions under (a) and (c) are met. CovationBio requests
confirmation of this understanding.
2. Condition C.1.c states that visual inspections are not required to be performed outside of the
facility's normal operating hours. CovationBio requests confirmation that "normal operating
hours" are defined as normal business hours. CovationBio requests confirmation that visual
inspections are not required to be performed outside of normal business hours or during adverse
weather conditions.
3. Condition D.3,e states that sampling is not required to be performed outside of the facility's
normal operating hours or during adverse weather conditions. Again, CovationBio requests
confirmation that sampling is not required outside of normal business hours or during adverse
weather conditions.
4. Condition I.I.a provides a compliance schedule for operating facilities applying for first-time
permit coverage. CovationBio requests confirmation that the compliance schedule applies as this
is the first permit issued by the Division of Energy, Mineral,and Land Resources to the Kinston
Site.
5. Condition 11.a states that secondary containment, as specified in B-9 of this permit, shall be
accomplished within 12 months of the effective date of the initial permit issuance. However,
Section B-8 of this draft permit provides secondary containment requirements,and Section B-9
of this draft permit provides spill prevention and response procedures.Please explain.
6. Section B-8 requires secondary containment for bulk storage of liquid materials including
petroleum products, storage in any amount of water priority chemicals listed in Section 313 of
Title III of the Superfund Amendments and Reauthorization Act ("SARA"), and storage of
hazardous substances in any amount. Part j defines secondary containment as spill containment
for the contents of the single largest tank within the containment structure plus sufficient
Covation Bioniaterials LLC•Kinsto«Site-4693 Hwy 11 N,Grifton,NC 28530

freeboard to contain the 25-year,24-hour storm event. CovationBio requests approval for the use
of alternative secondary containment methods for the bulk storage of nonhazardous liquid
materials with a low risk of release due to tank integrity failure.The tanks are made of 304
stainless steel, in non-corrosive service and tank integrity is maintained and reviewed by
CovationBio using American Petroleum Institute Standard 653 guidance. The tanks contain
non-hazardous materials,and active management practices will sufficiently contain any spill due
to flange leaks,etc.,and prevent the contamination of stormwater runoff. CovationBio proposes
the use of active management(i.e.,spill prevention and response procedures) for these low-risk
materials. Active management practices include, but are not limited to, the identification of
possible spill scenarios, conducting inspections to discover any potential spills, and having
sufficient spill containment equipment in place.
CovationBio appreciates this opportunity to provide comment on the draft NPDES stormwater permit and
looks forward to continuing to work with the Division of Energy,Mineral,and Land Resources. If you have
any questions or need additional information, please contact Shelby Arellano at [phone] or
[e-mail].
Sincerely,
Shelby Arellano
Environmental Engineer
CC: Amirhossein Adaryani,North Carolina Department of Environmental Quality
Emily Price,Covation Biomaterials LLC
Alex Torres,Covation Biomaterials LLC
David Suggs,Covation Biomaterials LLC
Covation Biomaterials LLC-Kinston Site-4693 Hwy 11 N,Grifton,NC 2BS30

Young, Brianna A
From: Shelby Arellano <[e-mail]>
Sent: Wednesday,April 26, 2023 4:03 PM
To: Young, Brianna A
Subject: [External] RE: Solar panel follow-up for NCS000608
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hi Brianna,
Thank you for following up on this question. I appreciate your guidance.
Thanks,
Shelby Arellano
Environmental Engineer, CovationBio
Office: [phone]
[e-mail]
From:Young, Brianna A<[e-mail]>
Sent: Wednesday,April 26, 2023 2:30 PM
To: Shelby Arellano<[e-mail]>
Subject: Solar panel follow-up for NCS000608
Good afternoon Shelby,
I am following up on our previous conversation concerning the addition of solar panels to the Covation site (formerly
DuPont) (stormwater permit application NCS000608). I apologize for the delay in getting back to you. A permit
modification request will not be needed for the addition of solar panels as they are not part of the industrial activity
onsite, but a notification of when the project would be appreciated. However,you may need to apply for an NCGO10000
construction permit. Please reach out to Kieu Tran ([e-mail] or 919.707.3640) or Brooklyn Broussard
([e-mail] or 984-302-0213)for more information on the NCG010000.
Please let me know if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
1

e:-o- D E
C,��
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
2

Young, Brianna A
From: Young, Brianna A
Sent: Thursday, September 29, 2022 8:49 AM
To: Shelby Arellano
Cc: Emily Price
Subject: RE: [External] Covation Biomatierals Kinston Site stormwater permit application
NCS000608
Thank you for this information. I will reach out if I have any additional questions.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Shelby Arellano<[e-mail]>
Sent: Wednesday, September 28, 2022 4:09 PM
To:Young, Brianna A<[e-mail]>
Cc: Emily Price<[e-mail]>
Subject: RE: [External] Covation Biomatierals Kinston Site stormwater permit application NCS000608
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hi Brianna,
The following table provides the requested information on the tanks located in the drainage area for Outfall SW004.
Tank Description Volume(gal) Type of Containment Drains to Process Sewer?
Tank#1 -Virgin PDO Tank 65,000 Common Concrete Block Dike Yes
(Tanks 1,2, 3, 5, 7,8,and 9)
Tank#2-Virgin PDO Tank 65,000 Common Concrete Block Dike Yes
(Tanks 1,2, 3, 5,7,8,and 9)
Tank#3-Spent PDO Tank 65,000 Common Concrete Block Dike Yes
(Tanks 1,2, 3, 5,7,8,and 9)
Tank#5-Spent PDO Tank 65,000 Common Concrete Block Dike Yes
(Tanks 1,2, 3, 5,7,8,and 9)
1

Tank#7-Virgin PDO Tank 150,000 Common Concrete Block Dike Yes
(Tanks 1,2, 3, 5,7,8,and 9)
Tank#8-Virgin PDO Tank 150,000 Common Concrete Block Dike Yes
(Tanks 1,2, 3, 5,7,8,and 9)
Tank#9-Virgin PDO Tank 300,000 Common Concrete Block Dike Yes
(Tanks 1,2, 3, 5,7,8,and 9)
Tank#23-Wastewater Retention Tank 170,000 Common Concrete Block Dike Yes
(Tanks 23 and 24)
Tank#24-Wastewater Retention Tank 170,000 Common Concrete Block Dike Yes
(Tanks 23 and 24)
Tank#25-Refined PDO Tank 20,000 Common Concrete Block Dike Yes
(Tanks 25 and 26)
Tank#26-Refined PDO Tank 20,000 Common Concrete Block Dike Yes
(Tanks 25 and 26)
Tank#61 -Virgin PDO Tank 500,000 None No
Tank#62-Virgin PDO Tank 500,000 None No
Therminol VP-1 (Dow)Tank 18,000 Concrete Block Dike Yes
Diesel Fuel Storage Tank 500 Double Walled with Leak Detection No
Gasoline Fuel Storage Tank 500 Double Walled with Leak Detection No
Thanks,
Shelby Arellano
Environmental Engineer, CovationBio
D+1 [phone] 1 M [phone]
[e-mail]
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, September 28, 2022 3:05 PM
To: Shelby Arellano<[e-mail]>
Cc: Emily Price<[e-mail]>
Subject: RE: [External] Covation Biomatierals Kinston Site stormwater permit application NCS000608
Thank you, Shelby. Could you provide more information on the tank farm? What chemicals are stored there? Is there
secondary containment? If so, what type?
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
2

From: Shelby Arellano<[e-mail]>
Sent:Wednesday, September 28, 2022 9:54 AM
To:Young, Brianna A<[e-mail]>
Cc: Emily Price<[e-mail]>
Subject: RE: [External] Covation Biomatierals Kinston Site stormwater permit application NCS000608
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
Thank you for the clarification.Acrolein and allyl alcohol are a byproduct of the polymerization process.These
constituents end up in the site's process wastewater and eventually the waste treatment plant. Stormwater associated
with Outfalls SWO04 and SWO07 is not exposed to process wastewater. In addition, sample results during the originally
permitting of Outfall SWO04 confirmed that stormwater associated with this outfall does not contact acrolein or allyl
alcohol.
The drainage area for Outfall SWO04 includes transformers, railroads, grassy areas,tank farm,truck shop,warehouse
and storage buildings, switchyard,vehicle refill station, and concrete slab from demolition work.The drainage area for
Outfall SWO07 includes railroads,grassy areas, warehouse and storage buildings, shipping and receiving, and paved
parking lots.
Please let me know if you need any additional information.
Thanks,
Shelby Arellano
Environmental Engineer, CovationBio
D+1 [phone] 1 M [phone]
[e-mail]
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, September 27, 2022 4:15 PM
To: Shelby Arellano<[e-mail]>
Cc: Emily Price<[e-mail]>
Subject: RE: [External] Covation Biomatierals Kinston Site stormwater permit application NCS000608
Hello Shelby,
Thank you for correcting your email address! I'll make sure It's updated in our database. In regards to your questions,
yes I am asking specially about the two stormwater outfalls 004 and 007.The drainage area descriptions I currently have
are below:
Outfall SWO04:
Drainage area consists of transformers, creosote railroad ties (when maintenance is being performed), and grassy areas.
Outfall SWO07:
Drainage area consists of railroad tracks (owned by CSX), grassy areas, and paved parking lots.
3

Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Shelby Arellano<[e-mail]>
Sent:Tuesday, September 27, 2022 4:01 PM
To:Young, Brianna A<[e-mail]>
Cc: Emily Price<[e-mail]>
Subject: [External] Covation Biomatierals Kinston Site stormwater permit application NCS000608
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hi Brianna,
I hope you're doing well. It looks like the email address you have for me is incorrect. My apologies for any confusion.
Emily shared with me your follow-up questions regarding the stormwater permit application for the Covation
Biomaterials Kinston Site. We would like to request some clarification regarding these questions.
• Question 1 -Are you specifically asking about stormwater discharges for outfalls SW004 and SW007?
• Question 2 -Can you please share the lists you are referring to?
Thanks,
Shelby Arellano
Environmental Engineer, Kinston Site
covAT i o n B1 OT.
4693 Hwy 11 N, Grifton, NC 28530
D+1 [phone] 1 M [phone]
[e-mail]
4

5

DocuSign Envelope ID:8B17DAF8-8387-453D-8CB1-33F2810F6993
. STATE
y
ROY COOPER o
Governor
ELIZABETH S.BISER �
x l+ivn nxi r
Secretary ` vua,vm
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
July 14, 2022
Ms. Emily Price
Plant Manager
CovationBio Kinston Site
4693 Hwy 11 North
Grifton,NC 28530
Subject: NC0003760 -NPDES Renewal Application
CovationBio Kinston Site
County - Lenoir
Issued via US Mail and Email
Dear Ms. Price,
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.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1611
NORTH CARCLINA
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,
EP
DocuSigned by:
6LAJ 06WA,lt
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
North Carolina Department of Environmental Quality I Division of Water Resources512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1611
919.707.9000
NCRTH CARCLINA ^
gaparMeM of EmironmanW quay

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 <d [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���� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1 6 1 1
NORTH CAROLINA 919.707.9000
Depe mm Emimnmen quay

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.
Thankyou
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���� North Carolina Department of Environmental Quality I Division of Water Resources
z:5:J512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1 6 1 1
NORTH CAROLINA ^ 919.707.9000
geparhneM of Emironmanfal quay

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/l for trout waters; for non-trout waters, not less than a daily average
of 5.0 mg/l with an instantaneous value of not less than 4.0 mg/l; 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.
D���� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
oepe .m m Emi.n wquay

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 GUMS 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.)
D���� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
oepe .m m Emi.—w quay

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 SWO04 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.
D���� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
oepe .m m Emi.—w quay

DocuSign Envelope ID:8B17DAF8-8387-453D-8CB1-33F2810F6993
Thankyou
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���� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1611
NCRTH CAROLINA 919.707.9000
nepa .m m Emi.—w quay

Young, Brianna A
From: Adaryani, Amir
Sent: Wednesday, March 16, 2022 2:38 PM
To: Arellano, Shelby Kaye
Cc: Dowden, Doug; PRICE, EMILY ANN;TORRES, ALEX; Young, Brianna A
Subject: RE: [External] RE: Extra information request_NPDES Permit Renewal NC0003760
Shelby,
Sounds good and looking forward to the finalized application package.
Thank you
If you should have any questions and 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
From:Arellano, Shelby Kaye<[e-mail]>
Sent: Wednesday, March 16, 2022 1:19 PM
To:Adaryani, Amir<[e-mail]>
Cc: Dowden, Doug<[e-mail]>; PRICE, EMILY ANN <[e-mail]>;TORRES,ALEX
<[e-mail]>; Young, Brianna A<[e-mail]>
Subject: [External] RE: Extra information request_NPDES Permit Renewal NC0003760
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hi Amir,
Thank you for providing comments and questions on the initial renewal application,the first addendum, and the
stormwater program in your email on 3/11/2022. DuPont Kinston will provide a timely and thorough response to each
item. DuPont Kinston will submit an application package that includes the initial application with incorporated
addendums with proper corrections and additional information. In addition, sample results for the remaining outfalls
will be included in this submission. Samples were collected for Outfalls 008 and 010 on 1/10/2022 and results were
received on 2/4/2022.There was insufficient flow to collect samples for Outfalls 009, 011, and 012 at that time.The Site
was able to collect samples for Outfalls 009, 011, and 012 on 3/12/2022 and 3/13/2022.
Thanks,
Shelby Arellano
1

Environmental Engineer, Kinston Site
4 0U ONT ►
Office Phone: [phone]
4693 Hwy 11 N., Grifton, NC 28530
shelby.k.arellano(cdupont.com
From:Adaryani, Amir<[e-mail]>
Sent: Friday, March 11, 2022 12:54 PM
To:Arellano, Shelby Kaye<[e-mail]>
Cc: Dowden, Doug<[e-mail]>; PRICE, EMILY ANN <[e-mail]>;TORRES,ALEX
<[e-mail]>; Young, Brianna A<[e-mail]>
Subject: [EXTERNAL] Extra information request_NPDES Permit Renewal NC0003760
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/I for trout waters; for non-trout waters, not less
than a daily average of 5.0 mg/I with an instantaneous value of not less than 4.0 mg/l; 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.
2

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. 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.
3

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.)
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.
4

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.
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
This communication is for use by the intended recipient and contains information that may be Privileged, confidential or
copyrighted under applicable law. If you are not the intended recipient,you are hereby formally notified that any use,
copying or distribution of this e-mail,in whole or in part, is strictly prohibited. Please notify the sender by return e-mail
and delete this e-mail from your system. Unless explicitly and conspicuously designated as "E-Contract Intended", this e-
mail does not constitute a contract offer, a contract amendment, or an acceptance of a contract offer.This e-mail does
not constitute a consent to the use of sender's contact information for direct marketing purposes or for transfers of data
to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
https://www.dupont.com/email-disclaimer.html
5

Young, Brianna A
From: Adaryani, Amir
Sent: Friday, March 11, 2022 12:54 PM
To: Arellano, Shelby Kaye
Cc: Dowden, Doug; [e-mail]; [e-mail];Young, Brianna A
Subject: Extra information request_NPDES Permit Renewal NC0003760
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/I for trout waters; for non-trout waters, not less
than a daily average of 5.0 mg/I with an instantaneous value of not less than 4.0 mg/l; 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. Also, PFAS analysis
1

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.
2

12. Please provide lab sheets for presented values of pollutants in EPA forms (including lab certification,
methods and QA/QC etc.)
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 SWO04 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.
3

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.
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
4

9/23/22, 11:54 AM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Limited Liability Company
Legal Name
Covation Biomaterials LLC
Information
Sosld: 2430072
Status: Current-Active O
Date Formed: 6/7/2022
Citizenship: Foreign
State of Incorporation: DE
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: Corporation Service Company
Addresses
Reg Office Reg Mailing Mailing
2626 Glenwood Ave Ste 550 2626 Glenwood Ave Ste 550 800 Prides Crossing Suite 201
Raleigh, NC 27608 Raleigh, NC 27608 Newark, DE 19713-6110
Principal Office
800 Prides Crossing Suite 201
Newark, DE 19713-6110
Company Officials
All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20.
Feifeng You Ruonan You
800 Prides Crossing, Suite 201 800 Prides Crossing, Suite 201
Newark DE 19713-6110 Newark DE 19713-6110
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2

9/23/22, 11:54 AM North Carolina Secretary of State Search Results
hftps://www.sosnc.gov/onIine_services/search/Business_Registration_ResuIts 2/2

di STATE
ROY COOPER
Governor V - 0
ELIZABETH S.BISER M ar
Secretary
BRIAN WRENN NORTH CAROLINA
Director Environmental Quality
March 4, 2022
Emily Price, Plant Manager
DuPont Industrial Biosciences USA, LLC
4693 NC Hwy 11 N
Grifton,NC 28530
Subject: NPDES Permit Renewal Application
Permit NCS000608
E.I. DuPont Kinston Plant
Lenoir County
Dear Permittee:
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number
NCS000608 on January 27, 2022. Please continue to comply with all conditions and
monitoring requirements in your expired NPDES stormwater permit. As long as you have
submitted a complete renewal request package and maintain compliance with those permit
conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action.
No additional information is required at this time,but we may contact you in the future. Please
notify us if any significant changes have taken place at this facility since you submitted the renewal
package. If you have any questions about this matter,please contact me at
[e-mail] or 919-707-3647.
Sincerely,
Brianna Young, Environ ental Program Consultant
DEMLR Stormwater Pro ram
cc: Washington Regional Office
DEMLR Stormwater Permitting Program Files
Shelby Arellano, DuPont Industrial Biosciences USA, LLC
D E Q�� North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh,North Carolina 27699-1612
NORTH CARO�INA _
ueaa—t of I=.o.imamenfai goanry 919.707.9200

4 D U P O N T ! DuPont Kinston Site
4693 Hwy 11 North
Griffon, NC: 28530
May 5, 2022
Mr. Doug Dowden
North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699
Re: NPDES Permit No. NC0003760
Revised NPDES Permit Renewal Application
Dear Mr. Dowden,
As requested by the Division of Water Resource (DWR) in the email dated March 11 , 2022,
DuPont Industrial Biosciences USA, LLC (DuPont) herein provides responses to comments
concerning the renewal application package for National Pollutant Discharge Elimination
System (NPDES) Permit No. NC0003760. To facilitate corrections to the original application
dated October 1 , 2021 and the application addendum dated January 28, 2022, DuPont is
submitting a complete application that will replace the existing application and application
addendum.
DuPont has entered into an agreement with another company to purchase DuPont' s Biomaterials
business. The sale of the business includes the DuPont Kinston Site. The acquisition is expected
to close on or about June 1 , 2022, and ownership of the site will transfer to the new company as
of the close date. Post-close, the new company intends to operate the site as it was operated by
DuPont and consistent with the current NPDES Permit. The new company is aware that a Permit
Name/Ownership Change Form and proof of ownership will need to be provided promptly after
the sale is closed.
If there any questions, please feel free to contact me at (252) 559-7043 or Shelby Arellano at
(252) 559-7044.
Sincerely,
Emily A. Price
Plant Manager
DuPont Kinston Site
DuPont Industrial Biosciences USA, LLC

NPDES Permit Renewal Application — Response to Comments
DuPont Kinston Site
Permit No. NC0003760
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/l; 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.
Response: DuPont requests clarification on this comment and the implications this comment has
on the Site's discharges. It is DuPont's understanding that the Division has made the decision
there would not be any more flow increases for facility discharges into waters classified as
swamp waters. DuPont is not requesting any flow increases to Beaverdam Branch as a part of
this permit application.
2. For clarification,please define "OSC" in section 4.1.
Response: Clarification was provided for the Organic Stripping Column (OSC). See Section 4.1
of the revised permit application.
3. In Figure 1 (water balance diagram) include input/output flows and any possible water loss
(in mgd).
Response: A revised water balance diagram is provided in Attachment C.3 of the revised permit
application.
4. Specify the chemicals that are in use in water treatment. This would apply to polymers
mentioned in sections 4.4 and 4.5.
Response: The permit application was updated to specify these polymers. See Section 4.4 and
Section 4.5 of the revision permit application. Additional information regarding water treatment
chemicals is provided in Section 5.3 of the revised permit application.
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
DuPont Industrial Biosciences USA,LLC i

analysis of PFAS in process wastewater, stormwater and groundwater/leachate separately
prior to release to treatment plant, as possible. 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
Response: In response to a request from the Hazardous Waste Section (HWS), DuPont
submitted a Confirmatory Sampling Report for Per- and Polyfluorinated Alkyl Substances
(PFAS) in groundwater samples at Solid Waste Management Unit (SWMU) SWMU 82. SWMU
82 is the former fire training area located in an open lot on the south side of the manufacturing
area. Perfluoro-hexanesulfonate (PFHxS),perfluorooctane-sulfonate (PFOS), and perfluoro-
octanoic acid(PFOA) were detected; however, the measured individual concentrations and their
sum were less than the established USEPA health advisory level of 70 ng/L. As noted in DEQ
Comments on SWMU 82 Confirmatory Sampling (CS)Report, the HWS is not requiring any
additional investigative action at this time.
PFAS have not been identified as a potential constituent of concern for any of the other SWMUs
or Areas of Concern (AOCs) at the Kinston Site. PFAS are not used in manufacturing
operations, and aqueous film forming foams (AFFFs) are not used or stored on-site at the
Kinston Site. Sampling for PFAS outside of SWMU 82 is unwarranted.
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.
Response: There are no anticipated changes in quality or quantity of discharge to Outfall 002.
Fire protection water and impacted groundwater have historically discharged to Outfall 002.
Discharges of fire protection water for routine testing is not an indication of the possible
presence of AFFF with PFAS. Aqueous film forming foams (AFFFs) are not used or stored on-
site at the Kinston Plant. The fire pumps discharge uncontaminated water to Outfall 002 for 30
DuPont Industrial Biosciences USA,LLC ii

minutes each week for testing. The main fire pumps take suction from the groundwater storage
tank. The secondary fire pump is equipped with a water storage tank that is filled by North
Lenoir Water Corporation.
7. Provide clarification on outfall 012 which is missing from section 9.1 despite its designation
as new outfall in section 8.2.
Response: Section 9.1 has been revised to include Outfall 012. In addition, an outfall
modification summary table was added to Section 9.3 of the revised permit application.
8. Provide details on wells marked in topographic map (Appendix A). There's no mention of
these wells in the narrative section.
Response: The wells marked on the topographic map are the groundwater production wells.
These wells are regulated under Central Coastal Plain Capacity Use Area (CCPCUA)Permit
No. CU3022 listed in Section 6 of the application narrative. Section 5 of the permit application
was revised to include a discussion of the water sources for the Kinston Site and to provide
additional information on the groundwater production wells. See Section 5.1 and Section 5.2 of
the revised permit application for additional information on the groundwater production wells.
9. Define the details and marked items for the SWMU location map and Final RFI locations
(Appendix C and D).
Response: Attachment A.1 of the revised application package was added to provide the current
regulatory status and a description of the solid waste management units and aeras of concern
located at the Kinston Site. Additional information regarding the drainage channel evaluation
conducted as a part of the Final RFI was added to Section 7.1 and Attachment A.3 of the revised
permit application.
10. In form 2C, elaborate on part 3.1 description of treatment units following the form's
instructions.
Response: Form 2C has been revised to include a more detailed description of each treatment
unit.
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 GUMS
fractions are required for this facility and therefore, Table B needs to be filled accordingly.
Instructions of EPA's form 2C should be consulted.
Response: Pursuant to 40 CFR Part 122,21(g)(7)(v) and Page 2C-3 of Form 2C Instructions,
the analysis and reporting of all GC/MS fractions is only required for outfalls containing process
wastewater. DuPont Kinston has revised application Form 2C for Outfall 001 to include results
for all GC/MS fractions are required. Outfalls 002, 005, 006, 008, 009, 010, 011, and 012 are
non process wastewater outfalls.
12. Please provide lab sheets for presented values of pollutants in EPA forms (including lab
certification, methods and QA/QC etc.)
DuPont Industrial Biosciences USA,LLC M

Response: Lab sheets are provided for all sampling conducted solely for the purposes of this
application. See Attachment D.1 of the revised permit application.
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.
Response: Section 4.2 of Form 2C was updated to include the intermittent groundwater
discharges. Attachment C.5 of the revised permit application includes the basis for the
stormwater and groundwater flow estimates.
2. In attachment 2, for provided flows,basis of estimation should be given. Referring to RFI
report is not simply sufficient.
Response: The permit application was updated to include basis of estimation for all provided
flows in Section 4.2 of Form 2C. See Attachment C.4 and Attachment C.6 of the revised permit
application.
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).
Response: The values provided for Outfall 002 in the flow table under Section 3.1 of Form 2C
are estimated averages based on historical observations at a v-notch weir installed at the revised
Outfall 002 location. The value provided in Table A of Form 2C is the estimated actual flow rate
observed during the sampling for the permit renewal application.
4. In tables A, B and C of form 2C (outfalls 002 and 005), mass loading of all present pollutants
should be provided.
Response: Form 2C was updated to include all mass loading values. DuPont Kinston is
requesting that DWR waive the requirement to test for flow rate for these outfalls. Therefore,
mass loading for Outfalls 005, 006, 008, 009, 010, 011, and 012 were calculated using the
estimated flow rates provided in Attachment C.4 of the revised permit application.
5. Please clarify on concentration units of row 2.22 of table B of form 2C (outfall 006).
Response: Row 2.22 of Table B of Form 2C for Outfall 006 was updated to specify
concentration units.
6. Please clarify for application of less than sign(<) for all corresponding values in forms 2C.
Response: Non-detectable sample results were reported as less than (<) the applicable detection
limit.
DuPont Industrial Biosciences USA,LLC iv

7. In general, for any of the comments on forms 2C or 2A, instructions of those should be
consulted.
Response: Form instructions were consulted during the preparation of the permit application.
Comments were provided for clarification purposes due to the complexity of this permit
application.
8. Please elaborate on presence of Formaldehyde and Vanadium in table D (form 2C, outfall
002 and 006) in relation to past investigations.
Response: All outfalls associated with an on-site drainage channel were analyzed for the
constituents identified during the surface water channel evaluations conducted for the RCRA
investigations. The constituents included in these evaluations were present in at least one surface
water channel. Additional information regarding vanadium detections during the surface water
channel evaluations is provided in Attachment A.3 of the revised permit application. Vanadium
was non-detectable in the samples pulled for this permit application.
The current permit includes a benchmark value for formaldehyde in the discharge at Outfall 006.
This benchmark was established due to detections of formaldehyde in past sampling events.
Please refer to historical DMR reports for additional details.
Please note that there was a typo in the application addendum submitted on January 28, 2022.
Formaldehyde was non-detectable in the sample collected at Outfall 006 on July 20, 2021. Sampling at
Outfall 006 for this permit application was conducted on December 8, 2021, and formaldehyde
concentration of 34,ug/L were detected. The results from July were inadvertently reported as the
December results in the application addendum. This was corrected in Form 2C of the revised permit
application.
9. Please provide lab sheets for presented values of pollutants in EPA forms (including lab
certification, methods and QA/QC etc.)
Response: Lab sheets are provided for all sampling conducted for the purposes of this
application in Attachment D.1 of the revised application package.
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.
Response: DuPont is submitting a complete application that will replace the existing application
and application addendum.
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.
DuPont Industrial Biosciences USA,LLC v

Response: Railroad tracks in the vicinity of SW007 belong to CSX and are not used by the
Kinston Site. Please contact CSX to confirm what is transported on these tracks. DuPont is not
aware of any spills having occurred on these tracks.
2. Verify if/when PCBs are/were used in the transformers in the SWO04 drainage area.
Response: The Kinston Site complies with the PCB recordkeeping and reporting requirements
located in 40 CFR Part 761.180. Based on the annual notifications of PCB activity, the
remaining six (6)PCB transformers were removed from the Kinston Site in 2015.
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.
Response: The Kinston Site facilitates repairs and maintenance on the site-owned railroad
tracks and on CSX-owned railroad tracks located on-site. Work conducted on CSX tracks are by
request from CSX based on track inspections. The Kinston Site contracts with Lewis Brothers
Construction for all railroad repairs and maintenance. Upon completion of the work, Lewis
Brothers Construction or other external parties manage the disposal of railroad ties. The
railroad ties identified during the site visit were from a recent maintenance job, and they have
since been removed from the site.
DuPont Industrial Biosciences USA,LLC vi

DuPont nston
,. 44693 Hwy. 11 Northnt
Grifton, NC 28530
January 24, 2022
Ms. Brianna Young
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
NPDES Stormwater Program
1612 Mail Service Center
Raleigh, NC 27699- 1612
Re: DuPont Kinston NPDES Industrial Stormwater Permit Application
Dear Ms. Young,
The DuPont Kinston Site is a polytrimethylene terephthalate (PTT) manufacturing facility owned
and operated by DuPont Industrial Biosciences USA, LLC (DuPont). Stormwater discharges
from the Kinston Site are currently authorized under National Pollutant Discharge Elimination
System (NPDES) Industrial Wastewater Permit No. NC0003760 issued by the Division of Water
Resources (DWR) on December 12, 2018 and expiring on March 31 , 2022. ,Pursuant to Permit
Proviso A.24. of the current permit, DuPont Kinston submitted a NPDES industrial stormwater
permit application package to the Division of Energy, Mineral, and Land Resources (DEMLR)
on October 1 , 2021 . The original hard copy application was sent via mail, and an electronic copy
was emailed to Ms . Suzanne McCoy and Ms. Bethany Georgoulias . DuPont Kinston was notified
by email on October 25 , 2021 that the Stormwater Division was unable to locate the original
application submission. The Stormwater Division requested a resubmission with revisions to the
original application and the applicable new permit application fee. DuPont Kinston understands
that the application will be processed as an application for a new individual stormwater permit
and not a stormwater permit renewal. DEMLR confirmed via email on January 21 , 2022 that the
applicable application fee of $860 was received.
If there any questions, please feel free to contact me at (252) 559-7043 or Shelby Arellano at
(252) 559-7044.
Sincerely,
Emily A. Price
Plant Manager
DuPont Kinston Site
i
DuPont Industrialo Biosciences USA LLC _

TABLE OF CONTENTS
.....................................................................................................................................................................................................................................................
1. Introduction
2. Site Location
3. Manufacturing Process
4. Water Treatment Chemicals
5. Environmental Permits
6. RCRA Facility Investigation
7. Requested Permit Updates
8. Proposed Outfall Designations
9. Corrective Action Plan
10. Significant Changes in Industrial Activities
11. Best Management Practices
12. Analytical Monitoring Results
13. Visual Monitoring Results
Appendix A. Topographic Map
Appendix B. Site Drainage Maps
Appendix C. SWMU Location Map
Appendix D. Final RFI Channel Surface Water Sample Locations
Appendix E. Form 1
Appendix F. Form 2C
Appendix G. Renewal Application Form
DuPont Industrial Biosciences USA LLC 1

1. Introduction
DuPont Industrial Biosciences USA, LLC (DuPont) owns and operates the DuPont Kinston Site
for the production of Sorona®pellets. This permit application is for industrial stormwater
discharges from the Site.
2. Site Location
The DuPont Kinston Site is located at 4693 Highway 11 North, Grifton,North Carolina, in
Lenoir County, approximately 11 miles northeast of Kinston. Appendix A includes a topographic
map that shows the location of the site, the facility boundary, and the outfall locations.
The DuPont Kinston Site is composed of two general areas, the Manufacturing Area and the
South Disposal Area. The Manufacturing Area is located south of Beaverdam Branch, in the
north-central portion of the Site. The South Disposal Area is in the southern portion of the Site
and includes the wastewater treatment plant (WWTP). This area has been used historically for
waste management.
Effluent from the WWTP discharges to the Neuse River. All other discharges from the DuPont
Kinston Site are to Beaverdam Branch or wetlands adjacent to the Neuse River. The wetlands are
separated from the Neuse River by a natural riparian berm. Beaverdam Branch and the Neuse
River are designated as Class C,Nutrient Sensitive Waters (NSW) in the Neuse River Basin; in
addition, Beaverdam Branch has a supplemental classification as Swamp Waters (SW).1 DuPont
Kinston maintains membership with the Lower Neuse Basin Association(LNBA) and the Neuse
River Compliance Association (NRCA).
3. Manufacturing Operations
Manufacturing operations at the DuPont Kinston Site began in 1953. Historical manufacturing
operations included the production of Dacron® (polyethylene terephthalate [PET])polyester
resin and fibers. Dacron polyester was produced using either dimethyl terephthalate (DMT) and
ethylene glycol or terephthalic acid(TPA) and ethylene glycol.
Current manufacturing operations include the production of Sorona® (polytrimethylene
terephthalate [PTT]), a renewable bio-based polymer. The Sorona process uses purified TPA and
1,3-propanediol (PDO). Water, allyl alcohol, acrolein, and n-butanol are all byproducts of the
polymer production process. However, none of these are products for sale or for use in
production. All filament and fiber manufacturing lines have been discontinued at the DuPont
Kinston Site. Current manufacturing operations are covered by Standard industrial Classification
(SIC) Code 2821 —Plastics Materials, Synthetic Resins, and Nonvulcanizable Elastomers and
North American Industry Classification System(NAICS) Code 325211 —Plastics Material and
Resin Manufacturing.
The change in manufacturing operations resulted in several inactive or decommissioned
production areas. The DuPont Kinston Site has completed numerous D&R projects to
' Surface water classifications for Stream Index Nos.27-75.7 and 27-83 from the Neuse River Basin Classification
Schedules.
DuPont Industrial Biosciences USA LLC 2

proactively safeguard against impacts to the surrounding environment from these areas. Several
decommissioned and abandoned in-place facilities have been completely removed down to the
concrete slab. D&R work at the DuPont Kinston Site will continue through 2021.
4. Water Treatment Chemicals
The following water treatment chemicals are used at the DuPont Kinston Site:
o ChemTreat CL6859
o ChemTreat CL4132
o ChemTreat CL41
o ChemTreat CL49
o ChemTreat CL6034
o ChemTreat BL1345
o ChemTreat BL1253
o ChemTreat BL1581
o ChemTreat P874L
o ChemTreat P846E
o Vitec 3000
o Liquid Caustic Soda 25%, Membrane Grade
o Sodium Hypochlorite Solution
o Sodium Bisulfite
DuPont Kinston will notify the Division in writing no later than ninety days prior to planned use
of any additional biocide which may be toxic to aquatic life.
5. Environmental Permits
The DuPont Kinston Site is currently operating under the following environmental permits:
o Synthetic Minor Operating Permit (Permit No. 03878R42)—This permit was issued for
the operation of air emissions sources located at the DuPont Kinston Site. This permit is
effective from August 20, 2021 to July 31, 2029.
o National Pollutant Discharge Elimination System(NPDES) Permit (Permit No.
NC0003760)—This permit was issued for discharges of wastewater and stormwater from
the DuPont Kinston Site. This permit is effective from December 12, 2018 to March 31,
2022.
o Central Coastal Plain Capacity Use Area(CCPCUA) Permit(Permit No. CU3022)—This
permit is for groundwater withdrawal for the purpose of industrial use in the CCPCUA in
Lenoir County. This permit is effective from February 19, 2019 to September 30, 2023.
o Hazardous and Solid Waste Amendments (HSWA)-only Permit(EPA ID No.
NCD003190386)—This permit is for correction action under the Federal Resource
Conservation and Recovery Act (RCRA). This permit is effective from April 22, 2021 to
April 22, 2031.
DuPont Industrial Biosciences USA LLC 3

o Inactive Solid Waste Landfill Permit(Permit No. 54-04 ISWLF)—This permit is for the
closed construction and demolition(C&D) and industrial solid waste landfill located at
the DuPont Kinston Site. This permit is no longer active as the landfill was formally
closed(capped) in 2005.
o Inactive Solid Waste Transfer Facility Permit(Permit No. 44-07T)—This permit is for
the closed solid waste transfer station previously located at the DuPont Kinston Site. This
permit is no longer active as the transfer station was formally closed in 2009.
6. RCRA Facility Investigation
The DuPont Corporate Remediation Group (CRG) has been performing investigation activities at
the Site as part of a RCRA Corrective Action Program and in accordance with Dupont's HSWA-
only Permit. The overall goal of the RCRA Facility Investigation(RFI)was to characterize the
nature and extent of potential releases from Solid Waste Management Units (SWMUs) and
Areas of Concern (AOCs) at the DuPont Kinston Site and to identify corrective action objectives
that address the risks associated with complete and potentially-complete exposure pathways.
CRG is currently working with the Division of Waste Management (DWM) to receive approval
of the Final RFI Report.
Per discussions with DWM, additional surface water sampling events and an ecological
assessment for these onsite surface water drainage channels, Beaverdam Branch, and the Neuse
River were included in the Final RFI in order to more fully assess discharges of potentially
impacted groundwater to surface water. Drainage Channels 1, 2, 3, 4, 5, 6, 7, and 24 are man-
made ditches that receive surface water runoff and open into wetlands adjacent to the Neuse
River. The upstream reach of Channel 7 also collects leachate and impacted groundwater from
upgradient SWMUs, and this flow is continuously rerouted to the WWTP. Appendix E contains
a map of the Final RFI Channel Surface Water Sample Locations. Results from the final RFI
include the following:
o Impacted groundwater from SWMUs/AOCs is entering channels that drain to wetlands
adjacent to the Neuse River. Discharges are intermittent as flow in these channels is
dependent on rain events.
o There was no evidence of adverse ecological effects due to potential Site-related
constituent concentrations in the Neuse River or Beaverdam Branch.
o The total calculated concentrations in the Neuse River were all less than the associated
screening levels indicating that current groundwater and drainage channel surface water
conditions are protective of the Neuse River.
o The only potentially complete exposure pathway for contaminants from SWMUs/AOCs
to reach Beaverdam Branch is via groundwater. Groundwater does not reach the surface
in any of the outfalls discharging to Beaverdam Branch.
DuPont Industrial Biosciences USA LLC 4

o No water quality concerns were identified for sediment or surface water in Beaverdam
Branch.
o As a part of the CMS, CRG is recommending drainage channel surface water monitoring
to ensure conditions remain protective of the Beaverdam Branch, the Neuse River, and
the surrounding wetlands.
7. Requested Permit Updates
As a part of this permit renewal application, DuPont Kinston is proposing several permit
modifications to ensure all discharges of potentially impacted groundwater and all discharges of
stormwater associated with industrial activity are being sufficiently monitored.
1. Although the Final RFI Report concludes that current conditions are protective of surface
waters, data obtained during the RCRA investigations indicates that discharges of
leachate, impacted groundwater, and stormwater runoff are comingled in the surface
water drainage channels. Therefore, DuPont Kinston is requesting to add impacted
groundwater as a permitted wastewater discharge from the applicable outfalls. Impacted
groundwater includes any potential leachate from the SWMUs.
2. DuPont Kinston is requesting to add five new wastewater outfalls (Outfalls 008, 009,
010, 011, and 012) for intermittent discharges of impacted groundwater and stormwater
runoff from Channels 1, 2, 3, 4, and 6 to the wetlands adjacent to the Neuse River.
3. DuPont Kinston is requesting to include impacted groundwater as an intermittent
discharge from Outfalls 005 and 006. Outfalls 005 and 006 are no longer deemed to be
stormwater only outfalls.
4. DuPont Kinston is requesting semi-annual grab samples for the monitoring of discharge
characteristics at Outfalls 005, 006, 008, 009, 010, 011, and 012. Although these are
permitted as wastewater outfalls, sampling of these outfalls will need to be managed
similarly to stormwater sampling. Discharges from these outfalls are composed of
stormwater runoff and impacted groundwater; therefore, discharges are intermittent and
heavily dependent on rain events. In addition, these outfalls can be dry for extended
periods of time.
5. DuPont Kinston is requesting to remove non-contact cooling water from Outfall 002 as
the powerhouse cooling tower and water cooled freon units were removed and replaced
with air cooled chillers. All cooling water from the Factory Engine Room Cooling Tower
and the 3G4 Cooling Tower is sent to the process sewer. In addition, DuPont Kinston is
requesting to add fire protection water and impacted groundwater as intermittent
discharges from Outfall 002.
6. DuPont Kinston is requesting to move the currently permitted Outfall 002 back to the
previously permitted location. The current location is in a canal that also collects surface
DuPont Industrial Biosciences USA LLC 5

runoff from the adjoining farmland. In addition, the current location presents hazardous
sampling conditions due to extensive washout. Pursuant to the permit modification
application submitted on November 9, 2005, Outfall 002 was relocated to the
downstream location in order to incorporate additional stormwater runoff from the C&D
and Ash landfills that enter the canal from Channels 4 and 6. As previously stated,
DuPont Kinston is requesting to add 2 new outfalls for Channels 4 and 6 (Outfalls 011
and 012). The currently permitted Outfall 002 will be broken down into 3 individual
outfalls. The revised outfall designations provide safe and accessible sampling points that
are more representative of the discharges from the DuPont Kinston Site.
7. DuPont Kinston is requesting to maintain approval for constant time/constant volume
composite sampling for Outfall 002.
8. DuPont Kinston is requesting to revise the receiving water designated for Outfalls 002,
005, and 006. Upon further review of surface water hydrology at the DuPont Kinston
Site, it was determined that Outfalls 002, 005, and 006 are man-made ditches that
ultimately discharge to wetlands adjacent to the Neuse River. These outfalls do not
discharge directly to the Neuse River as a natural berm separates the wetlands from the
river.
9. DuPont Kinston is requesting to add one new stormwater outfall (Outfall 007). Upon
further review of engineering drawings, it was determined that stormwater from industrial
activity potentially discharges from this outfall to a man-made ditch to Beaverdam
Branch.
10. DuPont Kinston is requesting to remove Outfall 003 as a permitted outfall. All steam
condensate discharges have been removed or rerouted to Outfall 002, and all stormwater
discharges from this outfall no longer meet the definition of stormwater associated with
industrial activity. The only discharges from this outfall are stormwater runoff from an
administrative building and the accompanying parking lot, uncontaminated air
conditioning condensate, and stormwater runoff from D&R areas where significant
materials no longer remain. Although DuPont is not required to monitor stormwater
outfalls that are not associated with industrial activity, DuPont will include these outfalls
in the Kinston Site's SWPPP.
11. In addition to the requested permit updates, DuPont Kinston is providing revised flowrate
information for discharges from Outfall 001 and Outfall 002.
8. Proposed Outfall Designations
NPDES Wastewater Permit Outfalls
Outfa11001: Treated Wastewater(Sanitary Wastewater, Process Wastewater,Non-Contact
Cooling Water, Boiler Blowdown, Groundwater, and Stormwater)
DuPont Industrial Biosciences USA LLC 6

Outfall 002: Steam Condensate, Fire Protection Water, Groundwater, and Stormwater
Outfall 005: Stormwater and Groundwater
Outfall 006: Stormwater and Groundwater
Outfall 008: Stormwater and Groundwater
Outfall 009: Stormwater and Groundwater
Outfall 010: Stormwater and Groundwater
Outfall 011: Stormwater and Groundwater
NPDES Stormwater Permit Outfalls
Outfall 004: Stormwater Only
Outfall 007: Stormwater Only
9. Corrective Action Plan
The current NPDES permit includes future numerical metals limits for Outfalls 002 and 003 with
an effective date of April 1, 2022. DuPont Kinston developed a Corrective Action Plan (CAP)
that summarizes actions to be taken to achieve compliance for the new total zinc and total lead
limits at Outfall 002 and the new total copper, total lead,total silver, and total zinc limits at
Outfall 003.
Outfall 002
The DuPont Kinston Site has demonstrated compliance with the new total zinc limit at Outfall
002 since the effective date of the current NPDES permit. However, data indicates the potential
for Outfall 002 to periodically exceed the new total lead limit. Based on the investigative
sampling performed in 2017, 2018, and 2019,process wastewaters contributing to Outfall 002
are not a significant source of lead. RCRA investigations indicated that impacted groundwater
from SWMUs is discharging to Channel 4, Channel 6, and Outfall 002. Additional time is
required to further investigate metals concentrations from the discharges of impacted
groundwater. It is possible that the surface runoff from the adjoining farmland is the source of
lead. The revised outfall designations will provide more representative sample data.
Additional considerations need to be given to the CAP and the schedule of compliance for
Outfall 002 based on the revised outfall designations and discharge information. As such,
DuPont Kinston is requesting a two-year extension to the effective date of the new metal limits
to Outfall 002. A revised CAP will be submitted in an application addendum by December 31,
2021 with the sample results.
Outfall 003
DuPont initially proposed relocating the monitoring point for Outfall 003 as part of the CAP.
However, D&R activities from 2017 to 2021 have completely removed the sources of
stormwater from industrial activity. In addition to the D&R work, all steam condensate lines
have been removed or rerouted. As previously stated, the only remaining discharges from Outfall
003 are stormwater runoff from an administrative building and the accompanying parking lot,
uncontaminated air conditioning condensate, and stormwater runoff from D&R areas where
significant materials no longer remain. Although Outfall 003 is currently subject to a compliance
schedule, the substantial alterations associated with discharges to this outfall justify removal of
this outfall from the permit. Sample data results clearly demonstrate the decrease in metal
DuPont Industrial Biosciences USA LLC 7

concentrations. DuPont Kinston has showed continued compliance with the new metal limits
over the past two years.
10. Significant Changes in Industrial Activities
Provided below is a summary of the changes in industrial activity since the last NPDES permit
renewal.
o The DuPont Kinston Site has stopped using DMT, which produced methanol as a
byproduct. TPA and PDO are the primary ingredients on all Sorona®production lines.
The esterification and the polycondensation reactions are catalyzed with an organic
titanate, and titanium dioxide (TiO2) is an additive that can be used. Water, allyl alcohol,
acrolein, and n-butanol are all byproducts of the polymer production process.
o A third production line (3G4)was added to increase production capacity using the same
primary ingredients as the first two production lines (3G2 and 3G3). The 3G4 cooling
towers were brought online with the addition of this production line. No new process
chemicals have been added to the production areas. The permitted production capacities
are as follows:
o 3G2 Production Line—3,400 lb. pellets/hr
o 3G3 Production Line— 18,000 lb. pellets/hr
o 3G4 Production Line— 16,000 lb. pellets/hr
o Two new double-walled fuel tanks (one gasoline tank and one diesel tank)were installed
to replace five single-walled fuel tanks (two gasoline tanks, two diesel tanks, and one
kerosene tank) and its secondary containment.
o The secondary fire pump was replaced in 2017.
o A new LPG/natural gas-fire emergency generator was installed in 2020 solely for backup
power for the fire protection system jockey pumps.
o The powerhouse cooling tower and water cooled freon units were removed and replaced
with air cooled chillers in 2020.
o Piedmont Natural Gas is currently constructing a new natural gas line to replace the
existing natural gas supply lines to the DuPont Kinston Site.
o D&R work at the DuPont Kinston Site will continue into 2022. The removal of
warehouses,production lines, tanks, cooling towers, and the entire Research Lab
Complex have significantly improved our environmental footprint by eliminating the
potential for exposure due to deteriorating unused facilities.
DuPont Industrial Biosciences USA LLC 8

11. Best Management Practices
The DuPont Kinston Site utilizes various best management practices (BMPs)to prevent or
minimize exposure of significant materials to stormwater. The following sections provide a
summary of the BMPs utilized at the DuPont Kinston Site.
Good Housekeeping
Good housekeeping practices help to reduce the possibility of pollutants impacting the
environment. Good housekeeping practices employed at the Site include:
o Chemicals are stored in an orderly manner;
o Chemicals are stored consistently (i.e., like chemicals are stored in the same location each
time they are delivered to the site);
o Small spills, when they occur, are promptly addressed;
o Refuse from the site is stored in dumpsters;
o Refuse is collected and disposed at regular intervals and is scheduled frequently to avoid
over-filling the dumpsters; and
o Equipment maintenance activities are performed on a regular basis.
Preventative Maintenance
Preventative maintenance activities can be effective at reducing the possibility of pollutants
impacting the environment. Preventative maintenance activities performed at the Site include:
o Facility equipment is properly maintained; and
o Chemical storage locations, equipment, and process tanks at the Facility are inspected on
a regular basis to identify conditions that could result in an impact to the environment.
Response Reporting Procedures and Contingency Plan
Rapid response and mitigation of a release can be an effective BMP. To assist this effort, the Site
has prepared and implemented response procedures.
Spill Equipment
Total spill equipment inventory was increased to help contain accidental spills at the Site. Spill
kits are located near finished product shipping, raw material receiving, off-spec product shipping
stations, and cooling tower chemical storage. Bulk liquid transfer stations associated with the
aboveground storage tanks and process storage tanks are similarly equipped with spill kits as
well as block mats.
Secondary Containment
Secondary containment dikes are provided to tanks and areas where the highest risk of release is
present, even when that risk is indoors. Secondary containment pallets are provided for all drums
containing greater than or equal to 55 gallons of significant materials to help prevent these
materials from being conveyed to the storm drainage system during an accidental release during
storage and transport. This includes materials such as boiler and cooling tower chemicals, waste
oil, lubricants, and cleaners stored on-site. Secondary containment contains the volume of the
DuPont Industrial Biosciences USA LLC 9

largest container plus enough freeboard for the 24-hour/25-yr storm event(7.48 inches). Drip
pans are used when filling equipment to prevent minor release of chemicals stored on Site.
Vehicle and Forklift Maintenance
Vehicle maintenance activities related to over-the-road trucks are performed at the Truck Shop
designed to mitigate releases. Forklift maintenance activities involving fluid transfers occur
indoors.
Loading and Unloading Operations
Specific procedures for loading and unloading operations were developed to minimize
significant exposure of materials to stormwater. These procedures include the following:
o All fuel and bulk liquid transfer operations are required to be operator attended;
o A member of operations will be present during the initial hookup and perform startup
verification during bulk liquid, raw material, and significant material transfers; and
o Wheel blocks and/or emergency brakes will be utilized during loading/unloading
operations.
Inspections
Inspections help to identify potential problems before they occur and help to prevent problems
that do occur from impacting the environment. DuPont Kinston conducts routine inspections on
the following equipment: containment areas, drip boxes,process tanks, storage tanks, spill kit
contents,waste storage areas, sumps, and catch basins. DuPont Kinston conducts monthly
inspections of oil-containing equipment in accordance with the Spill Prevention, Control, and
Countermeasure (SPCC) Plan.
Training
Employee training is provided for release prevention, release reporting, release response
procedures, review of the Stormwater Pollution Prevention Plan (SWPPP), review of BMPs,
identification of potential sources of stormwater pollution, and proper use of spill kits.
Recordkeeping and Internal Communication
Good recordkeeping procedures and internal communication are employed by DuPont to ensure
that potential and actual problems do not go unnoticed. DuPont Kinston also maintains Safety
Data Sheets (SDS) for the chemicals purchased/used at the Site. Maintaining up-to-date SDS is a
recordkeeping procedure that helps identify chemicals that could impact stormwater and assists
with determining appropriate storage conditions.
Security
By restricting access to authorized personnel, the possibility of an accidental or intentional
release occurring is greatly reduced. A chain link fence surrounds accessible portions of the Site.
Guards are on duty 24 hours a day and conduct plant security and surveillance. In addition, the
plant entrances are continually manned by Site security. Only authorized personnel are allowed
entry to the Site.
DuPont Industrial Biosciences USA LLC 10

Bioretention and Vegetative Filter Strips
DuPont employs an extensive array of vegetative filter strips, swales, rip-rap, and buffer zones
along the perimeter of the manufacturing area to reduce surface water runoff and potential
pollutants from entering surface waters at the site. In addition, large areas of forestation and
vegetation are maintained on undeveloped portions of the site to further reduce the potential for
silt and sediment discharge to the various ditch-lines and culverts.
Location-Specific BMPs
DuPont Kinston employs the following BMPs at specific outfalls at the Site:
o Outfall 002 is equipped with an earthen dike containment basin with valves in case of
spills in the drainage area.
o The duck pond located at Outfall 003 was originally part of the Wildlife Habitat Program
in the late 1980's. Although the duck pond does not meet current design criteria for
stormwater control measures, the pond does facilitate sedimentation.
o Per recommendation from DWR, a grassed Swale was installed for Outfall 004 in 2013.
The grassed Swale was designed in accordance with the minimum design criteria for
stormwater control measures.
o A synthetic and concrete lined settling basin is employed on a sloped embankment just
north of the truck gate at the entrance to the facility. This serves to control erosion and to
minimize the potential for off-site releases of sediment. Runoff from this area drains
towards Outfall 007.
o The Outfall 006 channel is a designated SWMU under the RCRA Corrective Action
Program. The channel is currently dammed at the WWTP, and water collected behind the
damn is continuously pumped to the WWTP. The diversion structure was installed as a
proactive measure during the RFI work. Although the diversion structure was not
installed to meet the minimum design criteria for stormwater control measures, it does
greatly reduce water pollution.
o The DuPont Kinston Site operates collection systems for surface water runoff, impacted
groundwater, and leachate from SWMUs. These discharges are collected in concrete
sumps and pumped to the WWTP. The collections systems are monitored as part of the
RCRA Corrective Action Program, in accordance with DuPont Kinston's HSWA-only
permit. Although the collection systems were not installed to meet the minimum design
criteria for stormwater control measures, they greatly reduce water pollution.
DuPont Industrial Biosciences USA LLC 11

12. Analytical Monitoring Results
Table 1 provides a summary of the analytical monitoring results for the currently permitted
stormwater outfalls, Outfalls 004, 005, and 006. Please note that the samples for Outfall 004
were historically collected from the catch basin located inside the fence line at the end of the
bioswale. Moving forward samples for Outfall 004 will be collected from the catch basin located
outside the fence line at the coordinates provided in this application.
Table 1. Analytical Monitoring Results
Outfall Gate pH BOG T55 Total P Acrolein COO Formaldehyde NO26NO3 Total KJEL Oil-GRSE Rainfall Zinc Mercury o-Cresol
[su] (mglL] (mglL] [mglL] [mgfL] (mgfL) (mglL) [mglL] (mg]L] (mg]L] [in] [uglL] [ngfL] [uglL]
004 12120118 6.99 <2 <4.17 - - <10 - 0.53 <1 <5 0.85 41 - -
004 06112119 7.06 2.3 7.7 - - <10 - 0.36 1.37 <5 0.75 <5 - -
004 12117119 7.11 2.01 <4.17 - - 31.4 - 0.26 <1 <5 0.55 17 - -
004 OU15120 7.05 2 8.4 - - 12 - 1.26 2.4 <4.85 0.9 <20 - -
004 12114120 7.06 2.39 8.5 - - 46.5 - 0.23 <1 <4.85 0.75 8 - -
004 04107121 - - - 0.15 - - - - - - - - - -
004 06102121 7.11 4.19 <6.25 - - 23.2 - <1 <1 <5 0.75 <20 - -
004 07127121 - - - - - - - - - - - - 2.08 -
005 12120118 6.92 <2 <4.17 - - <10 - 0.65 1.4 <5 0.85 - - -
005 06112119 7.03 3.76 11.7 - - 50 - 0.47 2.13 <5 0.75 - - -
005 12117119 7.01 2.46 5.7 - - 40.4 - 0.25 1.46 <5 0.55 - - -
005 06115120 7.04 2.69 11.9 - - 36 - <1.5 <1 <4.85 0.9 - - -
005 12114120 7.03 6.83 18.6 - - <10 - 0.27 <1 <4.93 0.75 - - -
005 04107121 - - - 0.19 - - - - - - - - - -
005 06102121 7.03 4 5.8 - - 26.2 - <1 <1 <5 0.75 - - -
005 07127121 - - - - - - - - - - - - 3.13 -
006 12120118 6.89 <2 <4.17 1.5 <0.01 15.7 <0.125 0.54 4.2 <5 0.85 - - -
006 06112119 6.99 15.8 15.2 0.31 <0.01 24.2 <0.125 0.52 1.2 <5 0.75 - - 15.1
006 12117119 6.94 26.4 10 0.93 <0.01 64.4 <0.05 0.17 <1 <5 0.55 - - -
006 06115120 7.01 3.1 16.7 0.33 <0.01 49 21.7 <1.5 2.24 <4.85 0.9 - - -
006 12114120 6.99 8.8 12.1 1.6 <0.01 35.4 <0.019 0.64 3.88 <4.93 0.75 - - -
006 06102121 7.01 7.28 6.2 1.4 <0.01 26.2 <0.06 <1 3.3 <5 0.75 - - -
006 07127121 - - - - - - - - - -
DuPont Industrial Biosciences USA LLC 12

13.Visual Monitoring Results
Table 2 provides a summary of the visual monitoring results for the currently permitted
stormwater outfalls, Outfalls 004, 005, and 006. In addition, a qualitative monitoring report was
completely for the new stormwater outfall, Outfall 007. Please note that visual monitoring of
Outfall 004 was historically conducted at the catch basin located inside the fence line at the end
of the bioswale. Moving forward visual monitoring for Outfall 004 will be conducted at the catch
basin located outside the fence line at the coordinates provided in this application.
Table 2. Visual Monitoring Results
t Floating Suspended Deposition Erosion at
Outfall Date Color Odor Clarity Z 3 Foam Oil Sheen Comments
Solids Solids at Outfall Outfall
004 05/03/16 Very light Brown None 2 2 2 No No No No
004 07/20/16 Clear None 1 1 1 No No No No
004 12/12/16 Light Brown None 2 1 2 No No No No
004 05/23/17 Very Light Brown None 2 1 2 No No No No
004 10/09/17 Light Brown None 5 2 1 5 No No No No I leavy rainfall,2.7 inches
004 05/28/18 Very Light Brown None 1 1 1 No No No No
004 12/20/18 Light Brown None 1 I I No No No No
004 06/12/19 Light Brown None 1 1 1 No No No No
004 12/17/19 Light Brown None 1 1 2 No No No No
004 06/15/20 Light Brown None 2 1 1 No No No No
004 12/14/20 Very Light Brown None 2 1 2 No No No No
005 05/03/16 Clear Woodsey 1 2 1 No No No No
005 07/20/16 Clear None 1 2 1 No No No No Leaves and woods debris
005 12/12/16 Light Brown Earthy 2 2 2 No No No No Woods debris
005 05/23/17 Medium Brown Earthy 4 2 4 No No No No Leaflitterfromwoods
005 10/09/17 Light Brown None 3 2 3 No No No No Wooded area-detritus from
woods present in flow
005 05/28/18 Light Brown Earthy 2 2 2 No No No No
005 12/20/18 Light Brown Woodsey 2 2 2 No No No No
005 06/12/19 Light Brown None 1 2 1 No No No No
005 12/17/19 Light Brown Earthy 2 3 2 No No No No Floating solids were leaves
and woods debris
005 06/15/20 Light Brown None 2 2 2 No No No No
005 12/14/20 Light Brown Earthy 3 3 3 No No No No
006 05/03/16 Light Brown Woodsey 2 3 2 No No No No Floating leaves and woods
debris
006 07/20/16 Clear Woodsey 1 2 1 No No No No Some sediment from
washout further up ditch
006 12/12/16 Light Brown Earthy 3 3 4 No No No No Woods debris
006 05/23/17 Light Brown Earthy 2 2 2 No No No No
006 10/09/17 Medium Brown Earthy 5 3 5 No No No No Mediumamountofleaflitter
fromwoods
006 05/28/18 Light Brown Earthy 2 3 2 No No No No
006 12/20/18 Light Brown Earthy 2 2 2 No No No No
006 06/12/19 Light Brown Earthy 2 2 2 No No No No
006 12/17/19 Medium Brown Earthy 1 3 3 3 No No No No
006 06/15/20 Light Brown Earthy 2 2 2 No No No No
006 12/14/20 Light Brown Earthy 2 2 2 No No No No
007 9/23/2021 Clear None I 1 1 No No No No
1.Clarity of the discharge is on a scale of 1(clear)to 10(very cloudy).
2.Floating solids in the discharge is on a scale of 1(none)to 10(surface is covered).
3.Suspended solids in the discharge is on a scale of 1(none)to 10(extremely muddy).
DuPont Industrial Biosciences USA LLC 13

APPENDIX A. TOPOGRAPHIC MAP
....................................................................................................................................................................
DuPont Industrial Biosciences USA LLC

SCALE:.1:48'000
1 °a v N
VV
S
O
Facility Boundary
Downstream
4
13
12
• / .. _ � - ,'rem./
9
ca
_-5" Upstream
Coordinate System GCS North_Amerlc_an 1983. 'V. O
Datum: North American 1983 -r?
Units: Degree V = -a„ _- ,a, / Copyright:©2013 National Geographic Society, i-cubed
Map Number Name Latitude Longitude
1 DuPont Kinston WWTP 35°19'30.000"N 77°28'13.700"W Facility Location
2 WW Outfal1 001 35°19'28.400"N 77°27'57.600"W
3 WW Outfall 002 35°19'34.971"N 77°28'50.310"W
4 1 SW Outfal1 004 35°20' 6.900"N 77°28'31.000"W
5 WW Outfal1 005 35'19'39.920"N 77'28' 4.900"W
6 WW Outfal1 006 35°19'20.400"N 77°28'10.600"W
7 SW Outfal1 007 35°19'51.000"N 77°29' 2.000"W
8 WW Outfal1 008 35°19'14.855"N 77°28'38.975"W USGS Quad: Grifton, N.C.
9 WW Outfal1 009 35'19'14.902"N 77°28'28.463"W Receiving Streams:
10 WW OutfaII010 35°19'16.914"N 77°28'23.200"W -Beaverdam Branch, Class C, NSW, Sw
11 1 WW Outfall 011 35°19'16.667"N 77°28'47.694"W - Neuse River and Adjacent Wetlands, Class C, NSW
12 WW Outfal1 012 35°19'29.251"N 77°28'41.730"W
13 Well 7 35°19'55.200"N 77°28'20.464"W
14 Well 35'19'46.412"N 77°28'37.200"w NC0003760 - Dupont Kinston,
15 Well 9 35°19'37.200"N 77°28'31.404"W
16 Well10 35°19'48.000"N 77°28'31.404"W Lenoir County
17 1 Well 14 35°19'45.430"N 77°28'58.958"W
Notes:
1.Currently permitted sampling location for Outfall 002:35°19'14.9"N,77°28'49.3"W
2.Outfall 003 was removed due to no industrial exposure.
3.SW=Stormwater,WW=Wastewater

APPENDIX B. SITE DRAINAGE MAPS
....................................................................................................................................................................
DuPont Industrial Biosciences USA LLC

DuPont KinstonS *1te Drainage Map (Revised 9/30/2021 )
Outfall 004
Basin G r Basin F i � t�
j
Basin H
Li
Tank Far
LJ
Area � I Y � tom"�{y�`�- f Ou[fa11005
Parking Manufacturing �„ � � BasinA � I iy/ � A i� i II I ill
Warehouse � l , `-. �I ,-., I � '� ,��N id � it I i u
Basin FIT �� o fa11001
Loading
�
� Manufacturing � � I � 001 Monitoring
-=� \� , � � �� � � III ��I 4 �
Basin s
�ctau om � � _ � . - , � � ` 11�� wwTP
r � � ► . � �� \��
w TP Influent
Bann E �i/ � �\ ,�' � / '�ti,\ = Diversion Structure
Basin D � . ,i i� `- � / ' ;'f I
Outfall 006 Fl
If
IJ�
r
Outfall 002 ;��. . \ Outfall 012 �;� ii , �r`cfi�l, � ice,� � ... p Ou[tall 010
Key: r / �
Basin C'
X NPDES Stormwater OutfallOutfall 009
i
X NPDES Wastewater Outfall
�( Outfall with No Exposure to Industrial Activity Outfall oil ,-
i
Outfall 008
Central Accumulation Area
tip? Satellite Accumulation Area
Essential Materials Loading and Unloading
Structural BMP
Outfa11002 - Containment Basin /
Outfa11004 - Grassed Swale
Outfa11006 - Diversion Structure
Outfa11007 - Settling Basin
Drainage Areas:
Outfall 004 Drainage Area = 31 .96 acres, Impervious = 12. 52 acres
Outfall 007 Drainage Area = 10. 15 acres, Impervious = 7.60 acres

DuPont Kinston - Previous Site Drainage Map
OUTFACE 004
OUTFALL 005
r / BASINS
G �zIBASIN/ �BA
BASIN
� fir ..
NP S o h
003
.m
c` OUTFACE
BASIN -BASIN�(���Ill� �� �,; I� �� oo,
. $ A �A-'I I I 1
00000LIU. —
A
BASI \ Ll
BASIN 14 i
of
BASIN
OUTFALL 006
� � �
FORMER
OUTFALL
002 0
oaAwINo I—s
RELOCATED
OUTFALL 002 ���
UNIFI KINSTON LLC
KINSTON,NORTH CAROLINA
OUTFALL LOCATION MAP
®CONESTOGA-ROVERS 8 ASSOCIATES
"'m .A.1.2-00 p g..i Figure 2

APPENDIX C. SWMU LOCATION MAP
....................................................................................................................................................................
DuPont Industrial Biosciences USA LLC

Nn SMWU orAOC
W E � � Drainage Channel
S Beaverdam Branch(creek)
1 ✓
r Railroad
! ' Site Road
Sanitary Sewer
�; �• Process Sewer(SMWU 13)
Building or Structure
Site Boundary
f e ► .; ,Manufacturing Area
South Disposal Area
Manufacturing
� S Mu 56
Area
AOC107-OS
SWMU 40 SWMU 84
SWMU 55
SWMU 37 o SWMU 33 b
• e �� SWM�U33a
0
-��N35°1s;56.000" ,� AOC 103A SWMU 29 SWMU 4
f•" W77'28 56.000" M (�
� � � °� AOC 1036 SWMU 36 SWMU 65
AOC 103C SWMU 38 SWMU 70
SWMU 57 0 AOC 70.3E SWMU 43 SWMU 71
AOC 1D5 SWMU�4 �SWM r 72
SWMU 45 of/� AOC 106 SWMU 49i SWMU 73
- Q SWMU 46 AOC`103D SWMU 51 SWMU 77
0 y 4 n SWMU 67 �o o MUM SWMU
AOC107-03 SWMU 58 S 79
SW
C �- _ P � AOC107-04 SWMU 60 SWMU 80 .,
SWMU 47 l 6 1 -
�� SWMU 66" Mu'" 1, U •-
S SWMU 48 $.WMU 59 -
AOc107-01 /J� SWMU 8.
AO-_C�7107-02 J SWMU 11 "
� SWMU 27
—SWMU 31 SWMU 82 SWMU+28� -r.
\ �
AOC SWMU��
3 � �O
a SWMU 90 c� SWMU 17 x�.
_ South ram
Disposal swmu zz
H SWMU 16
_ Area SWMU 23 l —SWMU 21
SWMU 1
o
x _
SWMU 2 S1'NMu15� SWMU 19 -
p SWMU7
�tli+r�I
M 52
_ v SWMU 10 SWMU 5
SWMU4 •cm
SWMU
c SWMU 8
`�°o S1NMU 5
y % Ili
`o
Summary
� L SE6135
Missllla:6636
-
w Canaea[aW D6Hr]019 + ayq`+V//d:5.5 mpry
0 250 500 1,000
i Feet
Drawn: Date: DuPont Project No.:
PAR S a N S Site Overview P.Sorensen 11/27/2019 504337
Revision: Figure No.: Parsons Project No.:
Parsons Environment&Infrastructure
DuPont Kinston Plant 451760
Kinston, North Carolina 2
4701 Hedgemore Dr. File Name: Kin_Fig2_SiteOverview
Charlotte,NC 28209 Aerial Source:ESRI Webservice,NC CGIA
NC911 Ortho Pro ram 3/16/2016

APPENDIX D. FINAL RFI CHANNEL SURFACE WATER SAMPLE LOCATIONS
....................................................................................................................................................................
DuPont Industrial Biosciences USA LLC

DuPont,Kinston Facility
r
Legend
Historical Surface Water
Sample Location
Surface Water Sample
0 Collected During Final RFI
! i Field Sampling Event
f
Other Site Features
Site Boundary
Road
Fence
Railroad
Drainage Channels
Beaverdam Branch
SWMU orAOC
Building or Structure
Neuse River
10
CHAN-05
�S/
MU24-D
SWMU24-U
SW11MMU�12-U r
C -3 CHANNEL 24
o
C C7-4�
CHAN-06 C7-2
co co
f
r
0 C7-1
j a CHAN07-02
CHAN-04 f
o !1
w 3 CHAN03-01
Q C7-5
a CHAN02-01
E CHAN03-02
co
O
o CHAN01-01 �i I
-i CHAN07-03
m
4
CHAN01-02 CHAN03-03
C/) CHAN01-03
N CHAN 02-02 CHAN 03-04
J
p� CHAN02-04
4 CHAN02-03
o \`
D;
LL
D;
m
c
iz
O N
N
h
Q
m
g w E
0
0 500 1,000 1,500
co
S Feet
Y
ti
U
a
Final RFI Channel Surface Water
m ■ `r. Sample Locations
P 1 4 N E E R
Final RFI Report Figure L-2
TECHNOLOGIES CORPORATION DuPont Kinston Facility
U
O

APPENDIX E. FORM 1
....................................................................................................................................................................
DuPont Industrial Biosciences USA LLC

United States Office of Water EPA Form 3510-1
Environmental Protection Agency Washington, D.C. Revised March 2019
Water Permits Division
C10,
EPA Application Form 1
General Information
NPDES Permitting Program
Note: All applicants to the National Pollutant Discharge Elimination System(NPDES) permits
program, with the exception of publicly owned treatment works and other treatment works treating
domestic sewage, must complete Form 1. Additionally, all applicants must complete one or more of the
following forms: 213, 2C, 2D, 2E, or 2F. To determine the specific forms you must complete, consult the
"General Instructions" for this form.

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant OMB No.2040-0004
Form U.S.Environmental Protection Agency
t .-/EPA Application for NPDES Permit to Discharge Wastewater
NPDES GENERAL INFORMATION
SECTION • •D i
1.1 Applicants Not Required to Submit Form 1
Is the facility a new or existing publicly owned Is the facility a new or existing treatment works
1.1.1 treatment works? 1.1.2 treating domestic sewage?
If yes, STOP. Do NOT complete ❑✓ No If yes, STOP. Do NOT ✓❑ No
Form 1. Complete Form 2A. complete Form 1. Complete
Form 2S.
1.2 Applicants Required to Submit Form 1
.- 1.2.1 Is the facility a concentrated animal feeding 1.2.2 Is the facility an existing manufacturing,
operation or a concentrated aquatic animal commercial,mining,or silvicultural facility that is
a production facility? currently discharging process wastewater?
o ❑ Yes 4 Complete Form 1 ❑✓ No ❑✓ Yes 4 Complete Form No
a and Form 2B. 1 and Form 2C.
z
1.2.3 Is the facility a new manufacturing,commercial, 1.2.4 Is the facility a new or existing manufacturing,
mining,or silvicultural facility that has not yet commercial, mining,or silvicultural facility that
commenced to discharge? discharges only nonprocess wastewater?
Cr d Yes 4 Complete Form 1 ❑✓ No Yes 4 Complete Form �✓ No
4)
and Form 2D. 1 and Form 2E.
1.2.5 Is the facility a new or existing facility whose
discharge is composed entirely of stormwater
a associated with industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
✓❑ Yes 4 Complete Form 1 No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x)or
b (15).
SECTIONDD- • • i
2.1 Facility Name
DuPont Kinston Plant
0 2.2 EPA Identification Number
R
C>
C NCDO03190386
J
2.3 Facility Contact
U;
d Name(first and last) Title Phone number
L
Emily Price Plant Manager [phone]
Q
Email address
[e-mail]
cc
d 2.4 Facility Mailing Address
ZStreet or P.O.box
4693 INC Hwy 11N
City or town State ZIP code
Grifton INC 28530
EPA Form 3510-1(revised 3-19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant OMB No.2040-0004
N 2.5 Facility Location
rStreet, route number,or other specific identifier
Q 0 4693 INC Highway 11N
�U
0 County name County code(if known)
Lenoir
E City or town State ZIP code
z R Grifton NC 28530
SECTION •D 1
3.1 SIC Code(s) Description(optional)
2821 Plastics materials,synthetic and resins,and nonvulcanizable elastomers
d
0
0
U
N
U
Z 3.2 NAICS Code(s) Description(optional)
m 325211 Plastics Material and Resin Manufacturing
U
N
4.1 Name of Operator
DuPont Kinston Plant
0 4.2 Is the name you listed in Item 4.1 also the owner?
M
R
E ❑ Yes ❑✓ No
0
w
7 4.3 Operator Status
❑ Public—federal ❑ Public—state ❑ Other public(specify)
o ❑✓ Private ❑ Other(specify)
4.4 Phone Number of Operator
[phone]
4.5 Operator Address
r Street or P.O.Box
M
E 4693 NC Highway 11N
r City or town State ZIP code
i0 Grifton INC 28530
Cc
Q Email address of operator
O [e-mail]
SECTIONI
R 5.1 Is the facility located on Indian Land?
a co
❑Yes ❑✓ No
EPA Form 3510-1(revised 3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant OMB No.2040-0004
SECTION . EXISTING ENVIRONMENTALI
R 6.1 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each)
❑ NPDES(discharges to surface ❑ RCRA(hazardous wastes) ❑ UIC(underground injection of
r_ water) fluids)
o r NC0003760 EPA ID No.NCDO03190386
'> E
w a ❑ PSD(air emissions) ❑ Nonattainment program(CAA) ❑ NESHAPs(CAA)
c
r
x ❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) ❑✓ Other(specify)
w
See Attached
SECTION1
7.1 Have you attached a topographic map containing all required information to this application?(See instructions for
C specific requirements.)
✓❑ Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 213.)
SECTIONOF I
8.1 Describe the nature of your business.
DuPont Industrial Bioscienses USA,LLC owns the DuPont Kinston Site that occupies approximately 650 acres near
Kinston,North Carolina.DuPont Kinston manufactures PTT polyester(Poly-trimethylene terephthalate),which is
cwidely used in textiles and other woven goods.Ancillary activities at the site include raw material and product
storage,combustion sources,and wastewater treatment.
ca
0
L
ca
Z
SECTION •• 1
9.1 Does your facility use cooling water?
❑✓ Yes ❑ No 4 SKIP to Item 10.1.
9.2 Identify the source of cooling water. (Note that facilities that use a cooling water intake structure as described at
' 40 CFR 125, Subparts I and J may have additional application requirements at 40 CFR 122.21(r). Consult with your
rn�
oY NPDES permitting authority to determine what specific information needs to be submitted and when.)
o U The source of cooling water is groundwater supplied by wells regulated under CCPCUA Permit No.CU3022.
In the event that the wells are not functioning(emergency situation),potable water from North Lenoir Water
Corporation can be used as the source of cooling water.
SECTION1 VARIANCE REQUESTS1 I
10.1 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)?(Check all that
y apply.Consult with your NPDES permitting authority to determine what information needs to be submitted and
when.)
❑ Fundamentally different factors(CWA ❑ Water quality related effluent limitations(CWA Section
Section 301(n)) 302(b)(2))
R ❑ Non-conventional pollutants(CWA ❑ Thermal discharges(CWA Section 316(a))
Section 301(c)and(g))
❑✓ Not applicable
EPA Form 3510-1(revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
NCD003190386 DuPont Kinston Plant ONE No. 2040-0004
11 . 1 In Column 1 below, mark the sections of Form 1 that you have completed and are submitting with your application.
For each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note
that not all applicants are required to provide attachments.
Column 1 Column 2
❑✓ Section 1 : Activities Requiring an NPDES Permit ❑ wl attachments
❑✓ Section 2: Name, Mailing Address, and Location ❑ w/ attachments
✓❑ Section 3: SIC Codes ❑ w/ attachments
❑✓ Section 4: Operator Information ❑ w/ attachments
❑ Section 5: Indian Land ❑ w/ attachments
❑✓ Section 6: Existing Environmental Permits ❑✓ wl attachments
E w/ topographic
w ❑✓ Section 7: Map ❑✓ ma ❑ w/ additional attachments
a ❑✓ Section 8: Nature of Business ❑ wl attachments
✓❑ Section 9: Cooling Water Intake Structures ❑ wl attachments
f
n ❑ Section 10: Variance Requests ❑ w/ attachments
N ❑✓ Section 11 : Checklist and Certification Statement ❑ wl attachments
Y .
11 .2 Certification Statement
U
I certify underpenalty of law that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name (print or type first and last name) Official title
Emily Price Plant Manager
Signature Date signed
r "A ..e� t' — Z q ' zOZ
EPA Form 3510-1 (revised 3-19) Page 4 III,

Form 1 Section 6.1
Other Permits:
• Synthetic Minor Operating Permit(Permit No. 03878R42)
• Central Coastal Plain Capacity Use Area(CCPCUA) Permit(Permit No. CU3022)
• Inactive Solid Waste Landfill Permit(Permit No. 54-04 ISWLF)
• Inactive Solid Waste Transfer Facility Permit(Permit No. 44-07T)

..........................................................................................................................................................................APPENDIX F. FORM 2F
-----------------------------------
DuPont Industrial Biosciences USA LLC 19

United States Office of Water EPA Form 3510-21F
Environmental Protection Agency Washington, D.C. Revised March 2019
Water Permits Division
:.EPA Application Form 2F
Stormwater Discharges
Associated with Industrial
Activity
NPDES Permitting Program
Note: Complete this form and Form 1 if you are a new or existing facility whose discharge is composed
entirely of stormwater associated with industrial activity, excluding discharges from construction
activity under 40 CFR 122.26(b)(14)(x) or(b)(15). If your discharge is composed of stormwater and
non-stormwater, you must complete Forms 1 and 2F, and you must complete Form 2C, 21), or 2E, as
appropriate. See the"Instructions"inside for further details.

Paperwork Reduction Act Notice
The U.S. Environmental Protection Agency estimates the average burden to collect and complete
Form 2F to be 28.1 hours. The estimate includes time for reviewing instructions, searching existing data
sources, gathering and maintaining the needed data, and completing and reviewing the collection of
information. Send comments about the burden estimate or any other aspect of this collection of
information, including suggestions for reducing the burden, to the Chief, Information Policy Branch
(PM-223), U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue,NW, Washington, DC
20460, and to the Office of Information and Regulatory Affairs, Office of Management and Budget,
725 17th Street,NW, Washington, DC 20503, marked"Attention: Desk Officer for EPA."

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCDO03190386 DuPont Kinston Site OMB No.2040-0004
Form U.S Environmental Protection Agency
2F EPA Application for NPDES Permit to Discharge Wastewater
NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
SECTIONOUTFALL LOCATION
1.1 Provide information on each of the facilit 's outfalls in the table below
Outfall Receiving Water Name Latitude Longitude
Number
004 Unnamed tributary to 35.00' 20.00' 6.90" 77.00' 28.00' 31.00"
Beaverdam Branch
007 Unnamed tributary to
a 35.00° 19.00 51.00" 77.00' 29.00 2.00"
o Beaverdam Branch
R
0
SECTION
• I
2.1 Are you presently required by any federal,state,or local authority to meet an implementation schedule for constructing,
upgrading,or operating wastewater treatment equipment or practices or any other environmental programs that could
affect the discharges described in this application?
❑✓ Yes ❑ No 4 SKIP to Section 3.
2.2 Briefly identify each applicable project in the table below.
Brief Identification and Affected Outfalls Source(s)of Discharge Final Compliance Dates
Description of Project (list outfall numbers)
Required Projected
Schedule of compliance for 002 and 003 Outfall 003-Stormwater not 4/1/22 See
new metal limits. See Section associated with industrial activity Section 9
9 of the application narrative Outfall 002-Steam Condensate, of the
application
for additional information. Fire Protection Water, narrative.
Groundwater, and Stormwater
c
a�
E
d
0
L
Q
E
2.3 Have you attached sheets describing any additional water pollution control programs(or other environmental projects
that may affect your discharges)that you now have underway or planned?(Optional Item)
❑ Yes ❑✓ No
EPA Form 3510-2F(Revised 3-19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCDO03190386 DuPont Kinston Site OMB No.2040-0004
SECTION1 ' I
a� 3.1 Have you attached a site drainage map containing all required information to this application?(See instructions for
a; M C specific guidance.)
N R �
c` ® Yes ❑ No
SECTIONPOLLUTANT SOURCESI
4.1 Provide information on the facility's pollutant sources in the table below.
Outfall Impervious Surface Area Total Surface Area Drained
Number (within a mile radius of the facility) (within a mile radius of the facility)
specify units specify units
004 12.52 Acres 31.96 Acres
specify units specify units
007 7.60 Acres 10.15 Acres
specify units specify units
specify units specify units
specify units specify units
specify units specify units
4.2 Provide a narrative description of the facility's significant material in the space below.(See instructions for content
requirements.)
Raw materials at the facility include terephthalic acid(TPA)1,3-propanediol(PDO),titanium dioxide anatase(Ti02),and organic titanate
catalyst(TnBT).Manufactured products include polytrimethylene terephthalate(PTT)pellets and molten PTT polymer.Other materials
N stored on-site include: diesel fuel,gasoline,Therminol VP-1,water treatment chemicals,aqueous ammonium hydroxide,sodium bisulfite,
sodium hypochlorite,clarifier and wasting polymers,QA/QC laboratory reagents,process wastewater,industrial process waste,and sludge
waste.Pesticides,herbicides,soil conditioners,and fertilizers are applied by a contractor in limited amounts.In addition,numerous solid
0 waste management units(SWMUs)including landfills are on-site and contain significant materials from historical operations.
Majority of the materials are stored in above ground storage tanks with secondary containment.However,water treatment chemicals,
R clarifier and wasting polymers,sodium hypochlorite,and sodium bisulfite are stored in 30 gal or 55 gal drums or in 400 gal totes.Therminol
VP-1 can also be stored in 30 or 55 gal drums.The Site has several docks and off-loading stations for transfer of materials.The Essential
o Materials Loading and Unloading Area is used for the transfer of office supplies,maintenance supplies and equipment,water treatment
a chemicals,Ti02,QA/QC laboratory reagents and wastewater treatment chemicals.Warehouse space is for final product storage in
enclosed bulk bags.Truck docks at the warehouse are primarily for final product load-out.Industrial materials and activity are not exposed
to stormwater at the warehouse truck docks.
4.3 Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in
stormwater runoff. See instructions forspecificguidance.)
Stormwater Treatment
Codes
Outfall from
Number Control Measures and Treatment Exhibit
2F-1
list
Site-Wide Good housekeeping,preventative maintenance,secondary containment,inspections,training, N/A
security,spill prevention plan,and procedures are non-structural controls employed at the Site.
004 Grassed swale for sediment control. 1-U
007 A synthetic settling basin located just north of the truck gate for sediment control. 1-U
*The Site utilizes additional structural BMP's at the combined wastewater and stormwater outfalls to minimize or prevent
exposure of significant materials to stormwater. See Section 11 of the application narrative for additional details.
EPAForm3510-2F(Revised3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCDO03190386 DuPont Kinston Site OMB No.2040-0004
SECTION •N STORMWATER 1 I
5.1 I certify under penalty of law that the outfall(s) covered by this application have been tested or evaluated for the
presence of non-stormwater discharges. Moreover, I certify that the outfalls identified as having non-stormwater
discharges are described in either an accompanying NPDES Form 2C, 2D,or 2E application.
Name(print or type first and last name) Official title
Emily Price Plant Manager
Signature Date signed
H
5.2 Provide the testing information requested in the table below.
cc
Outfall Onsite Drainage Points
N Description of Testing Method Used Date(s)of Testing Directly Observed
o Number
L During Test
d
Visual monitoring for color,odor,solids,clarity,foam,oil
3004 Semiannually Ditch,grassed swale
E sheen,deposition,and erosion.
L
0
N 007 Visual monitoring for color,odor,solids,clarity,foam,oil 9/23/2021 Ditch
o sheen,deposition,and erosion.
z
SECTION
•-
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
Q On 5/10/2020 497 Ibs of 1,1 Biphenyl (Therminol VP1)from a day tank overfill.
N (NCR#1277155)
0
Y
R
N
J
C
R
V
w
T
co
SECTIONDISCHARGE INFORMATIONI
See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must
o com lete. Not all applicants need to complete each table.
E7.1 Is this a new source or new discharge?
o ❑ Yes 4 See instructions regarding submission of No 4 See instructions regarding submission of
= estimated data. actual data.
d
Tables A,B,C,and D
y 7.2 Have you completed Table A for each outfall?
❑✓ Yes ❑ No
EPA Form 3510-2F(Revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
NCDO03190386 DuPont Kinston Plant OMB No.2040-0004
7.3 Is the facility subject to an effluent limitation guideline(ELG)or effluent limitations in an NPDES permit for its process
wastewater?
❑✓ Yes ❑ No 4 SKIP to Item 7.5.
7.4 Have you completed Table B by providing quantitative data for those pollutants that are(1)limited either directly or
indirectly in an ELG and/or(2)subject to effluent limitations in an NPDES permit for the facility's process wastewater?
*Pollutants with an ELG exclusively for process
El Yes ❑✓ NO
wastewater were not analyzed.
7.5 Do you know or have reason to believe any pollutants in Exhibit 2F-2 are present in the discharge?
❑✓ Yes ❑ No 4 SKIP to Item 7.7.
7.6 Have you listed all pollutants in Exhibit 2F-2 that you know or have reason to believe are present in the discharge and
provided quantitative data or an explanation for those pollutants in Table C?
❑✓ Yes ❑ No
7.7 Do you qualify for a small business exemption under the criteria specified in the Instructions?
❑ Yes +SKIP to Item 7.18. ❑✓ No
7.8 Do you know or have reason to believe any pollutants in Exhibit 2F-3 are present in the discharge?
❑✓ Yes ❑ No 4 SKIP to Item 7.10.
7.9 Have you listed all pollutants in Exhibit 2F-3 that you know or have reason to believe are present in the discharge in
Table C?
❑✓ Yes ❑ No
0 7.10 Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greater?
P
E ❑✓ Yes ❑ No 4 SKIP to Item 7.12.
0
7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in
rn concentrations of 10 ppb or greater?
❑✓ Yes ❑ No
7.12 Do you expect acrolein, acrylonitrile, 2,4-dinitrophenol,or 2-methyl-4,6-dinitrophenol to be discharged in concentrations
of 100 ppb or greater?
❑ Yes ❑✓ No 4 SKIP to Item 7.14.
7.13 Have you provided quantitative data in Table C for the pollutants identified in Item 7.12 that you expect to be
discharged in concentrations of 100 ppb or greater?
❑ Yes ❑ No
7.14 Have you provided quantitative data or an explanation in Table C for pollutants you expect to be present in the
discharge at concentrations less than 10 ppb(or less than 100 ppb for the pollutants identified in Item 7.12)?
❑✓ Yes ❑ No
7.15 Do you know or have reason to believe any pollutants in Exhibit 21`4 are present in the discharge?
❑ Yes ❑✓ No 4 SKIP to Item 7.17.
7.16 Have you listed pollutants in Exhibit 2F-4 that you know or believe to be present in the discharge and provided an
explanation in Table C?
❑ Yes ❑ No
7.17 Have you provided information for the storm event(s)sampled in Table D?
❑✓ Yes ❑ No
EPA Form 3510-2F(Revised 3-19) Page 4

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCDO03190386 DuPont Kinston Site OMB No.2040-0004
Used or Manufactured Toxics
7.18 Is any pollutant listed on Exhibits 2F-2 through 2F-4 a substance or a component of a substance used or
manufactured as an intermediate or final product or byproduct?
O
a ❑✓ Yes ElNo 4 SKIP to Section 8.
O
7.19 List the pollutants below,including TCDD if applicable.
E
O
1.Acrolein 4. 7.
as
2•Allyl Alcohol 5. 8.
0 3. 6. 9.
SECTION • •GICAL TOXICITY TESTING DATA i
8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
any of your discharges or on a receiving water in relation to your discharge within the last three years?
c
:r
❑ Yes ✓❑ No 4 SKIP to Section 9.
N
8.2 Identify the tests and their purposes below.
Submitted to NPDES
Tests) Purpose of Test(s) Date Submitted
x Permitting Authority?
O
~ ❑ Yes ❑ No
R
V
tm
0
❑ Yes ❑ No
m
❑ Yes ❑ No
SECTION • •- • i
9.1 Were any of the analyses reported in Section 7(on Tables A through C)performed by a contract laboratory or
consulting firm?
❑✓ Yes ❑ No 4 SKIP to Section 10.
9.2 Provide information for each contract laboratory or consulting firm below.
Laboratory Number 1 Laboratory Number 2 Laboratory Number 3
Name of laboratory/firm
Environmental 1,Incorporated Microbac Laboratories Inc.
c (NC Lab Certification#10) (NC Lab Certification#11)
w
R
E:
i
O
C
MnLaboratory address
•N 114 Oakmont Drive 2592 Hope Mills Rd.
Greenville,INC 27835 Fayetteville,NC 28306
c
a
cc
R
L
o Phone number
v [phone] ([phone]
Pollutant(s)analyzed All pollutants for Outfall 007 All pollutants for Outfall 004
and mercury for Outfall 004 except mercury
EPA Form 3510-2F(Revised 3-19) Page 5

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
NCDO03190386 DuPont Kinston Site OMB No. 2040-0004
® t e ® t
10. 1 In Column 1 below, mark the sections of Form 2F that you have completed and are submitting with your application. For
each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note that not
all applicants are required to com fete all sections or provide attachments.
Column 1 Column 2
�✓� Section 1 ❑ w/ attachments (e.g, , responses for additional outfalls)
❑✓ Section 2 ❑ wl attachments
❑✓ Section 3 ✓❑ w/ site drainage map
❑ Section 4 ❑ w/ attachments
✓❑ Section 5 ❑ wl attachments
✓❑ Section 6 ❑ w/ attachments
d ❑✓ Section 7 ✓❑ Table A ❑ w/ small business exemption request
rn
c ElTable B ❑ wl analytical results as an attachment
❑✓ Table C ❑✓ Table D
r
❑ Section 8 ❑ w/attachments
� Section 9 ❑ w/attachments (e.g., responses for additional contact laboratories or firms)
✓❑ Section 10 ❑
a 10,2
Certification Statement
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible
for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine
and imprisonment for knowing violations.
Name (print or type first and last name) Official title
Emily Price Plant Manager
Signatur Date signed
EPA Form 3510-2F (Revised 3-19) Page 6

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant 004 OMB No.2040-0004
TABLE A.CONVENTIONAL AND NON CONVENTIONALI
You must provide the results of at least one anal sis for every pollutant in this table.Complete one table for each outfalI.See instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Grab Sample Taken (new source/new
During First Flow-Weighted During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
1. Oil and grease <4.82 mg/L 1
2. Biochemical oxygen demand(BOD5) 5.06 mg/L 1
3. Chemical oxygen demand(COD) 54.6 mg/L 1
4. Total suspended solids(TSS) 31.7 mg/L 1
5. Total phosphorus 0.15 mg/L 1
6. Total Kjeldahl nitrogen(TKN) <1.00 mg/L 1
7. Total nitrogen(as N) 0.49 mg/L 1
pH (minimum) 7.19 1
8.
pH(maximum) 7.19 AN
1 Sampling shall be conducted according to sufficiently sensitive test procedures(i.e., methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
"Please note that the samples for Outfall 004 were historically collected from the catch basin located inside the fence line at the end of the bioswale. However,this location does not
capture all of the industrial stormwater discharging to Outfall 004. Moving forward, samples for Outfall 004 will be collected from the catch basin located outside the fence line at the
coordinates provided in this application. Sample results in Table A were collected at this location.
EPA Form 3510-21F(Revised 3-19) Page 7

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EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant 004 OMB No.2040-0004
TABLE B.CERTAIN CONVENTIONAL AND NON CONVENTIONAL POLLUTANTS(40 CFR 122.26(c)(1)(i)(E)(4)and 40 CFR 1122.211(g)(7)(vi)(A))'
List each pollutant that is limited in an effluent limitation guideline(ELG)that the facility is subject to or any pollutant listed in the facility's NPDES permit for its process wastewater(if the
facility is operating under an existing NPDES permit).Complete one table for each outfall.See the instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new source/new
During First Flow-Weighted During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
N/A-See note below.
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e., methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
*Outfall 004 discharges exclusively stormwater that is not subject to an ELG. Pollutants with an ELG exclusively for process wastewater were not analyzed.
EPA Form 3510-21F(Revised 3-19) Page 9

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EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant 004 OMB No.2040-0004
TABLE C.TOXIC POLLUTANTS,CERTAIN HAZARDOUS SUBSTANCES,AND ASBESTOS(40 CFR 122.26(c)(1)(l)(E)(4)and 40 CFR 122.21(g)(7)(vi)(B)and(vii))'
List each pollutant shown in Exhibits 2F-2,2F-3,and 2F-4 that you know or have reason to believe is present.Complete one table for each outfall.See the instructions for additional
details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
s eci units s eci units Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new source/new
Composite During First Flow-Weighted During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes p codes in instructions)
Zinc 0.115 mg/L 1
Nitrate/Nitrite Nitrogen 0.49 mg/L 1
Mercury 9.2 ng/L 1
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e., methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
*Please note that the samples for Outfall 004 were historically collected from the catch basin located inside the fence line at the end of the bioswale. However,this Page 11
location does not capture all of the industrial stormwater discharging to Outfall 004. Moving forward, samples for Outfall 004 will be collected from the catch basin
located outside the fence line at the coordinates provided in this application. Sample results in Table C were collected at this location.

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EPA Identification Number NPDES Permit Number Facility name Outfall Number Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant 004 OMB No.2040-0004
STORMTABLE D. • ' • I
Provide data for the storm event(s)that resulted in the maximum daily discharges for the flow-weighted composite sample.
Number of Hours Between
Total Rainfall During Maximum Flow Rate
Duration of Storm Event Beginning of Storm Measured and Total Flow from Rain Event
Date of Storm Event (in hours) Storm Event End of Previous Measurable Rain During Rain Event (in gallons or specify units)
(in inches) Event (in gpm or specify units)
12/08/2022 5.02 hours 1.22 inches >72 hours N/A-See note below. N/A-See note below.
Provide a description of the method of flow measurement or estimate.
Flow weighted composite sampling was not performed at Outfall 004. Data provided in this permit application was collected as grab samples per the requirements in the
current permit.
EPA Form 3510-21F(Revised 3-19) Page 13

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant 007 OMB No.2040-0004
TABLE A.CONVENTIONAL AND NON CONVENTIONALI
You must provide the results of at least one anal sis for every pollutant in this table.Complete one table for each outfalI.See instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Grab Sample Taken (new source/new
During First Flow-Weighted During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
1. Oil and grease <5.0 mg/L 1
2. Biochemical oxygen demand(BOD5) 2.8 mg/L 2.8 mg/L 1
3. Chemical oxygen demand(COD) 22 mg/L 25 mg/L 1
4. Total suspended solids(TSS) 4.3 mg/L 3.7 mg/L 1
5. Total phosphorus 0.58 mg/L 0.56 mg/L 1
6. Total Kjeldahl nitrogen(TKN) 0.86 mg/L 0.81 mg/L 1
7. Total nitrogen(as N) 1.23 mg/L 1.20 mg/L 1
pH (minimum) 7.23 1
8.
pH(maximum) 7.23 1
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e., methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-21F(Revised 3-19) Page 7

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EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant 007 OMB No.2040-0004
TABLE B.CERTAIN CONVENTIONAL AND NON CONVENTIONAL POLLUTANTS(40 CFR 122.26(c)(1)(i)(E)(4)and 40 CFR 1122.211(g)(7)(vi)(A))'
List each pollutant that is limited in an effluent limitation guideline(ELG)that the facility is subject to or any pollutant listed in the facility's NPDES permit for its process wastewater(if the
facility is operating under an existing NPDES permit).Complete one table for each outfall.See the instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new source/new
During First Flow-Weighted During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
N/A-See note below.
Sampling shall be conducted according to sufficiently sensitive test procedures i.e., methods)approved under 40 CFR 136 tor the analysis ot pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
*Outfall 007 discharges exclusively stormwater that is not subject to an ELG. Pollutants with an ELG exclusively for process wastewater were not analyzed.
EPA Form 3510-21F(Revised 3-19) Page 9

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EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant 007 OMB No.2040-0004
TABLE C.TOXIC POLLUTANTS,CERTAIN HAZARDOUS SUBSTANCES,AND ASBESTOS(40 CFR 122.26(c)(1)(l)(E)(4)and 40 CFR 122.21(g)(7)(vi)(B)and(vii))'
List each pollutant shown in Exhibits 2F-2,2F-3,and 2F-4 that you know or have reason to believe is present.Complete one table for each outfall.See the instructions for additional
details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
s eci units s eci units Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new source/new
Comosite
During First Flow-Weighted During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes p codes in instructions)
Nitrate/Nitrite Nitrogen 0.37 mg/L 0.39 mg/L 1
Zinc 213 ug/L 198 ug/L 1
Mercury 2.8 ng/L N/A-See note below. 1
Copper 2 ug/L 3 ug/L 1
Iron 224 ug/L 218 ug/L 1
Lead <2.0 ug/L <2.0 ug/L 1
Total Hardness 10 mg/L 10 mg/L 1
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e., methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
'Pursuant to guidance provided by DWQ, a single grab sample was collected and analyzed for mercury using EPA Method 1631.
Page 11

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EPA Identification Number NPDES Permit Number Facility name Outfall Number Form Approved 03/05/19
NCDO03190386 DuPont Kinston Plant 007 OMB No.2040-0004
STORMTABLE D. • ' • I
Provide data for the storm event(s)that resulted in the maximum daily discharges for the flow-weighted composite sample.
Number of Hours Between
Total Rainfall During Maximum Flow Rate
Duration of Storm Event Beginning of Storm Measured and Total Flow from Rain Event
Date of Storm Event (in hours) Storm Event End of Previous Measurable Rain During Rain Event (in gallons or specify units)
(in inches) Event (in gpm or specify units)
11/22/2021 5.68 hours 0.34 inches >72 hours 305.2 gpm 43,407 gallons for the first
3 hours of the storm event.
A flow weighted
composite sample was
taken only for the first 3
hours of the storm event.
Provide a description of the method of flow measurement or estimate.
Float method for open channel flow per Section 3.2.2 of the EPA's NPDES Storm Water Sampling Guidance Document(EPA 833-8-92-001).
EPA Form 3510-21F(Revised 3-19) Page 13

APPENDIX G. RENEWAL APPLICATION FORM
.........................................................................................................
DuPont Industrial Biosciences USA LLC 20

Permit Coverage
AAene al ADDllcata®n Egran
c®ENR National Pollutant Discharge Elimination System NP®ES Permit Number�
Stormwater Individual Permit NCS
Please provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to which permit correspondence will be mailed
Owner / Organization Name : DuPont Industrial Biosciences USA LLC
Owner Contact: Emily Price
Mailing Address 4693 NC Hwy 11 North
Grifton, NC 28530
Phone Number: (252) 559-7043
Fax Number:
E-mail address: [e-mail]
Facility Information
Facility Name: DuPont Kinston Site
Facility Physical Address: 4693 NC Hwy 11 North
Grifton, NC 28530
Facility Contact: Emily Price
Mailing Address: 4693 NC Hwy 11 North
Grifton, NC 28530
Phone Number: (252) 559-7043
Fax Number:
E-mail address: [e-mail]
Permit Information
Permit Contact: Emily Price
Mailing Address: 4693 NC Hwy 11 North
Grifton, NC 28530
Phone Number: (252) 559-7043
Fax Number:
E-mail address: [e-mail]
Discharge Information
Receiving Stream : Beaverdam Branch
Stream Class: C, Sw, NSW
Basin : Neuse River Basin
Sub-Basin : 03-04-05
Number of Outfalls: z
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
Please see Section 10 of the application narrative.
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is true, complete and accurate.
Signature �Lim Date /— 2 V � ZOZ Z
Emily Price Plant Manager
Print or type name of person signing above Title
Please return this completed application form SW Individual Permit Coverage Renewal
and requested supplemental information to: Stormwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete :
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
1 . A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
ZAP 2 . A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling) . Do not submit individual lab reports .
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
3 . A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
F/ 1i 4. A summary of the Best Management Practices utilized at the permitted facility .
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
5 . A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
'A "n 6 . Certification of the development and implementation of a Stormwater ;Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

ST WATER POLLUTION P VENI PL
DEVELOPMENT AND NIPLE RN TATIO
CER� IFICATION
A/orth Carolina Division of Energy, Mineral, and Land Resources Srormwater Permitting
Facility Name : DuPont Kinston Site
Permit Number:
Location Address : 4693-NC 11 North
Griller NC 28530
County: Lenoir County
I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system , or those persons directly responsible
for gathering the information , the information gathered is , to the best of my knowledge and belief, true,
accurate and complete. "
And
'9 certify that the SPPP has been developed , signed and retained at the named facility location , and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit. "
And
" I am aware that there are significant penalties for falsifying information , including the possibility of fines and
imprisonment for knowing violations . "
Sign (according to permit signatory requirements) and return' this Certification. DO NOT
SEND STORMWATE/R�POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Data IP Z4,
Emily Price Plant Manager
Print or type name of person signing above Title
*Please note that DuPont Kinston is in the procses of Updating the SPPP to be cens,steni with the rposions inc , ,ded in this peirri! application,
SPPP Certification 10/13