NC0002305_correspondence_20230214

SOUTHERN 601 West Rosemary Street, Suite 220 Telephone [phone]
ENVIRONMENTAL Chapel Hill, NC 27516 Facsimile 919-929-9421
LAW
CENTER
February 14, 2023
VIA Electronic Mail
Douglas Dowden
N.C. Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
Re: Southern Environmental Law Center Comments Regarding Lear
Corporation, NPDES Permit NC0002305
Dear Mr. Dowden:
The Southern Environmental Law Center submits this letter on behalf of Cape Fear River
Watch regarding Lear Corporation, NPDES Permit NC0002305 ("Lear"), in Duplin County,
North Carolina. We understand that on November 28, 2022, Lear submitted a National Pollutant
Discharge Elimination System ("NPDES") permit renewal application) and that the North
Carolina Department of Environmental Quality ("the Department") will soon begin drafting a
renewal permit for the company. As described in more detail below, Lear discharges per- and
polyfluoroalkyl substances ("PFAS") and the Department must control these toxic discharges in
its next NPDES permit.
The U.S. Environmental Protection Agency ("EPA") has made clear that state permitting
agencies have "existing authorit[y]" to control PFAS through NPDES permits and should be
doing so "to the fullest extent available under state and local law. ,2 The Department followed the
law embodied in EPA's guidance when it issued a recent NPDES permit to The Chemours
Company, FC ("Chemours") that imposed technology -based limits for certain PFAS
compounds.3 But Chemours is not the only source of PFAS pollution in North Carolina. The
Department cannot continue to focus its enforcement efforts solely on Chemours and treat other
industries that release toxic pollution into our waterways with leniency. Lear, like Chemours,
discharges high concentrations of PFAS and is not authorized to do so. The Department must use
its existing authority to control Lear's pollution and prevent it from continuing to release harmful
1 Steven Middlebrook, Lear Corporation, Wastewater Treatment Permit Renewal Application — Lear Corp., Permit
No. NC0002305 (Nov. 28, 2022) [hereinafter "Lear's NPDES Permit Application"], Attachment 1.
2 Memorandum from Radhika Fox, Assistant Administrator, U.S. Env't Prot. Agency, Addressing PFAS Discharges
in NPDES Permits and Through the Pretreatment Program and Monitoring Programs (December 5, 2022)
(emphasis added) [hereinafter " EPA's PFAS NPDES Guidance"], Attachment 2.
3 N.C. Dep't of Env't Quality, NPDES Permit NC0090042 (Sept. 15, 2022), https://perma.cc/WQV7-L8C4; N.C.
Dep't of Env't Quality, Fact Sheet NPDES Permit No. NC0090042 (Sept. 15, 2022), at 11-12,
https://perma.cc/EP5R-32A7.
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

chemicals into the Northeast Cape Fear River. Failure to do so is unlawful and prolongs North
Carolinians' exposure to toxic chemical pollution.
I. Lear discharges PFAS, a class of chemicals known to cause harm to human
health and the environment.
In 2019, the Department instructed Lear to collect samples and determine if the
company's wastewater contains PFAS. The results of that sampling confirm that Lear discharges
PFAS at concentrations as high as 1,863 parts per trillion ("ppt").4 The Department is aware of
Lear's PFAS pollution and has even informed EPA about the PFAS in Lear's discharge. s
PFAS are a group of man-made chemicals manufactured and used broadly by industry
since the 1940s.6 PFAS pose a significant threat to human health at extremely low
concentrations. Two of the most studied PFASperfluorooctanoic acid ("PFOA") and
perfluorooctane sulfonate ("PFOS")—are bioaccumulative and highly persistent in humans.
PFOA and PFOS have been shown to cause developmental effects to fetuses and infants, kidney
and testicular cancer, liver malfunction, hypothyroidism, high cholesterol, ulcerative colitis,
obesity, decreased immune response to vaccines, reduced hormone levels, delayed puberty, and
lower birth weight and size.$ Because of its impacts on the immune system, PFAS can also
exacerbate the effects of Covid-19.9 Studies show that exposure to mixtures of different PFAS
can worsen these health effects.10 Given these harms, EPA in June 2022 established interim
updated lifetime health advisories for PFOA and PFOS in drinking water of 0.004 ppt and 0.02
ppt, respectively.1l
4 2019 Industrial 1,4-dioxane & PFAS Sampling Results, N.C. Dep't of Env't Quality 8 (2020) [hereinafter "2019
Industrial PFAS Sampling"], Attachment 3.
5 See U.S. Env't Prot. Agency, Effluent Guidelines Program Plan 15 (January 2023), at 6-8, 8-2, Attachment 4
(explaining the Department provided data from a textile mill in North Carolina to the EPA and listing "2019 PFAS
Investigation Order Results for Lear Corporation Textile Mill in Wilmington, North Carolina (NPDES No.
NC0002305)").
6 Lifetime Drinking Water Health Advisories for Four Perfluoroalkyl Substances, 87 Fed. Reg. 36,848, 36,849 (June
21, 2022); Our Current Understanding of the Human Health and Environmental Risks of PFAS, U.S. ENV'T PROT.
AGENCY, https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas (last
visited Jan. 24, 2023).
7 87 Fed. Reg. at 36,849; U.S. Env't Prot. Agency, Interim Drinking Water Health Advisory: Perfluorooctanoic Acid
(PFOA) CASRN 335-67-1 (June 2022), at 3-4, available at https://www.epa.gov/Ustem/files/documents/2022-
06/interim-pfoa-2022.pdf; U.S. Env't Prot. Agency, Interim Drinking Water Health Advisory: Perfluorooctane
Sulfonic Acid (PFOS) CASRN 1763-23-1 (June 2022), at 3-4, available at
https://www. epa. goy/Ustem/files/documents/2022-06/interim-pfos-2022.pdf.
$ Arlene Blum et al., The Madrid Statement on Poly- and Perfluoroalkyl Substances (PFASs), 123 ENV'T. HEALTH
PERSP. 5, A 107 (May 2015); U.S. Env't Prot. Agency, Drinking Water Health Advisories for PFAS: Fact Sheet for
Communities, at 1-2 (June 2022), available at https://www.epa.gov/system/files/documents/2022-06/drinking-
water-ha-pfas-factsheet-communities.pdf.
9 See Lauren Brown, Insight: PFAS, Covid-19, and Immune Response —Connecting the Dots, BLOOMBERG LAW (July
13, 2020, 4:00 AM), https://news.bloomberglaw.com/environment-and-energy/insight-pfas-covid-l9-and-immune-
response-connecting-the-dots?context=article-related.
" Emma V. Preston et al., Prenatal Exposure to Per- and Polyfluoroalkyl Substances and Maternal and Neonatal
Thyroid Function in the Project Viva Cohort: A Mixtures Approach, 139 ENV'T INT'L 1 (2020),
https://perma.cc/DJK3-87SN.
" 87 Fed. Reg. at 36,848-49.
W

Other PFAS are similarly harmful. 12 In June 2022, EPA set a final lifetime health
advisory for GenX in drinking water of 10 ppt.13 Numerous states have acknowledged the
dangers of other PFAS compounds and proposed or finalized drinking water standards for
various PFAS at 20 ppt and lower. 14
PFAS are also harmful to wildlife and the environment. The chemicals have been shown
to cause damaging effects in fish,15 amphibians," reptiles,17 mollusks,18 and other aquatic
invertebrates 19 resulting in developmental and reproductive impacts, behavioral changes,
adverse effects to livers, disruption to endocrine systems, and weakened immune systems .20
Moreover, PFAS are extremely resistant to breaking down in the environment, can travel long
12 U.S. Dep't of Health and Human Servs., Toxicological Profile for Perfluoroalkyls (May 2021), available at
ho2s://perma.cc/AHF7-RLOD; see also U.S. Env't Prot. Agency, Technical Fact Sheet: Drinking Water Health
Advisories for Four PFAS (PFOA, PFOS, GenX chemicals, and PFBS) (June 2022), ho2s://perma.cc/95H2-P988.
13 87 Fed. Reg. at 36,848-49.
14 See Per- and Polyfluoroalkyl Substances (PFAS), INTEGRAL CORP., hops://www.inte rag 1-corp.com/pfas/ (last
visited Jan. 24, 2023).
15 Chen et al., Perfluorobutanesulfonate Exposure Causes Durable and Transgenerational Dysbiosis of Gut
Microbiota in Marine Medaka, 5 ENv'T SCI. & TECH LETTERS 731-38 (2018); Chen et al., Accumulation
of Perfluorobutane Sulfonate (PFBS) and Impairment of Visual Function in the Eyes of Marine Medaka After
a LifeCycle Exposure, 201 AQUATIC TOXICOLOGY 1-10 (2018); Du et al., Chronic Effects of Water -Borne PFOS
Exposure on Growth, Survival and Hepatotoxicity in Zebrafish: A Partial Life -Cycle Test, 74 CHEMOSPHERE 723-29
(2009); Hagenaars et al., Structure Activity Relationship Assessment of Four Perfluorinated Chemicals Using a
Prolonged Zebrafish Early Life Stage Test, 82 CHEMOSPHERE 764-72 (2011); Huang et al., Toxicity, Uptake
Kinetics and Behavior Assessment in Zebrafish Embryos Following Exposure
to Perfluorooctanesulphonicacid (PFOS), 98 AQUATIC TOXICOLOGY 139-47 (2010); Jantzen et al., PFOS, PFNA,
and PFOA Sub -Lethal Exposure to Embryonic Zebrafish Have Different Toxicity Profiles in terms of
Morphometrics, Behavior and Gene Expression, 175 AQUATIC TOXICOLOGY 160-70 (2016); Liu et al., The Thyroid -
Disrupting Effects of Long -Term Perfluorononanoate Exposure on Zebrafish (Danio rerio),
20 ECOTOXICOLOGY 47-55 (2011); Chen et al., Multigenerational Disruption of the Thyroid Endocrine System in
Marine Medaka after a Life -Cycle Exposure to Perfluorobutanesulfonate, 52 ENv'T SCI. & TECH. 4432-39
(2018); Rotondo et al., Environmental Doses of Perfluorooctanoic Acid Change the Expression of Genes in Target
Tissues of Common Carp, 37 ENV'T TOXICOLOGY & CHEM. 942-48 (2018).
16 Ankley et al., Partial Life -Cycle Toxicity and Bioconcentration Modeling of Perfluorooctanesulfonate in the
Northern Leopard Frog (Rana Pipiens), 23 ENv'T TOXICOLOGY & CHEM. 2745 (2004); Cheng et al., Thyroid
Disruption Effects of Environmental Level Perfluorooctane Sulfonates (PFOS) in Xenopus Laevis,
20 ECOTOXICOLOGY 2069-78 (2011); Lou et al., Effects
of Perfluorooctanesulfonate and Perfluorobutanesulfonate on the Growth and Sexual Development of
Xenopus Laevis, 22 ECOTOXICOLOGY 1133-44 (2013).
17 Guillette et al., Blood Concentrations of Per- and Polyfluoroalkyl Substances Are Associated with Autoimmune-
like Effects in American Alligators From Wilmington, North Carolina, FRONTEIR TOXICOLOGY 4:1010185 (Oct. 20,
2022), available at hops://www.frontiersin.org/articles/10.3389/ftox.2022.1010185/full.
" Liu et al., Oxidative Toxicity of Perfluorinated Chemicals in Green Mussel and Bioaccumulation Factor
Dependent Quantitative Structure -Activity Relationship, 33 ENv'T TOXICOLOGY & CHEM. 2323-32 (2014); Liu et
al., Immunotoxicity in Green Mussels under Perfluoroalkyl Substance (PFAS) Exposure: Reversible Response and
Response Model Development, 37 ENv'T TOXICOLOGY & CHEM. 1138-45 (2018).
"Houde et al., Endocrine -Disruption Potential of Perfluoroethylcyclohexane Sulfonate (PFECHS) in Chronically
Exposed Daphnia Magna, 218 ENv'T POLLUTION 950-56 (2016); Liang et al., Effects of Perfluorooctane Sulfonate
on Immobilization, Heartbeat, Reproductive and Biochemical Performance of Daphnia Magna,
168 CHEMOSPHERE 1613-18 (2017); Ji et al., Oxicity of Perfluorooctane Sulfonic Acid and Perfluorooctanoic Acid
on Freshwater Macroinvertebrates (Daphnia Magna and Moina Macrocopa) and Fish (Oryzias Latipes), 27 ENv'T
TOXICOLOGY & CHEM. 2159 (2008); MacDonald et al., Toxicity of Perfluorooctane Sulfonic Acid and
Perfluorooctanoic Acid to Chironomus Tentans, 23 ENv'T TOXICOLOGY & CHEM. 2116 (2004).
20 See supra notes 15-19.

distances, and bio-accumulate in organisms.21 PFAS have been found in fish tissue, and
consequently, the primarily low-income and minority communities that rely on subsistence
fishing have been found to have elevated PFAS levels in their blood.22 Due to these harms, EPA
has published draft recommended freshwater aquatic life criteria for PFOA and PFOS .23
Sampling in 2019 confirmed that Lear's wastewater contains incredibly high levels of
PFAS. Over three months, Lear's total PFAS concentrations ranged from 802 ppt to 1,863 ppt.24
PFOA and PFOS were detected at levels as high as 30.2 ppt and 29.4 ppt, respectively.2' These
concentrations are thousands of times higher than what EPA considers safe. Lear's wastewater
contains other PFAS compounds, including perfluorobutanoic acid ("PFBA"),
perfluorobutanesulfonic acid ("PFBS"), perfluorodecanoic acid ("PFDA"), perfluoroheptanoic
acid ("PFHpA"), perfluorohexanesulfonic acid ("PFHxS"), perfluorohexanoic acid ("PFHxA"),
perfluorononanoic acid ("PFNA"), and perfluoropentanoic acid ("PFPeA").26
Unfortunately, once released, Lear's pollution remains in the Northeast Cape Fear River.
On September 2, 2022, Cape Fear River Watch sampled a couple of miles downstream from
Lear's outfall and the sampling confirmed the presence PFAS at a total concentration of 71.7
ppt.27 The sampling showed the presence of at least ten types of PFAS compounds, including
PFOA and PFOS. PFOA was detected at 9.9 ppt (2,475 times the health advisory level), and
PFOS was detected at 13.6 ppt (680 times the health advisory level).28 Other PFAS detected
include perfluorobutanoic acid ("PFBA"), perfluoropentanoic acid ("PFPeA"),
perfluorohexanoic acid ("PFHxA"), perfluoroheptanoic acid ("PFHpA"), perfluorononanoic acid
("PFNA"), perfluorodecanoic acid ("PFDA"), n-methyl perfluorooctanesulfonamidoacetic acid
("NMeFOSAA"), and perfluorooctanesulfonamide ("PFOSA").29
Even though Lear's most recent effluent sampling was in 2019, it is nearly certain that
Lear's PFAS pollution continues today. Lear's industrial processes include the manufacturing of
lace and warp knit fabric and the production of motor vehicle seating and interior trim.30 Lear's
renewal application describes its business as "[w]arp knitting and weaving of synthetic fibers for
21What are PFAS?, Agency for Toxic Substances and Disease Registry, hops://www.atsdr.cdc.aov/pfas/health-
effects/overview.html (last visited Jan. 24, 2023); see also Our Current Understanding of the Human Health and
Environmental Risks of PFAS, supra note 66.
22 Patricia A. Fair et al., Perfluoralkyl Substances (PFASs) in Edible Fish Species from Charleston Harbor and
Tributaries, South Carolina, United States: Exposure and Risk Assessment, 171 ENv'T. RES. 266 (April
2019); Chloe Johnson, Industrial chemicals in Charleston Harbor taint fish — and those who eat them, POST &
COURIER (June 4, 2022), hLtps://www.postandcourier.com/enviromnent/industrial-chemicals-in-charleston-harbor-
taint-fish-and-those-who-eat-them/article_ b2bl4506-bcl9-1 lec-83e5-7f2a8322d624.html; Nadia Barbo, et al.,
Locally Caught Freshwater Fish Across the United States Are Likely a Significant Source of Exposure to PFOS and
Other Perfluorinated Compounds, 220 ENV'T RSCH. 115165 (2023),
hLtps://www.sciencedirect.com/science/article/Tii/SOO 13935122024926.
23 Draft Recommended Aquatic Life Ambient Water Quality Criteria for Perfluorooctanoic Acid (PFOA) and
Perfluorooctane Sulfonic Acid (PFOS), 85 Fed. Reg. 26,199, 26,200 (May 3, 2022).
2' 2019 Industrial PFAS Sampling, supra note 4 at 8.
25 Id.
26 Id.
21 Cyclopure, Water Test Kit Pro Results Report, Kit#1371 (Sept. 20, 2022), Attachment 5.
28 Id. at 1.
29 Id.
30 Lear's NPDES Permit Application, supra note 1 at 2-3.
4

the automotive industry. Dyeing, finishing, and flame lamination of knitted and woven synthetic
fabrics. ,31 Industries that work with synthetic fibers are a suspected point source category for
PFAS.32 EPA notes that this category:
includes a broad range of sectors, raw materials, and unit operations that may
manufacture or use PFAS ... some [organic chemicals, plastics, and synthetic fiber]
facilities use PFAS feedstocks as polymerization or processing aids or in the
production of...products. 33
Given these characteristics, EPA has found that this industry category is likely to generate
wastewater containing long -chain and short -chain PFAS including those that are well -studied
and known to be harmful to humans.34 Similarly, textile manufacturers like Lear have been
found to use PFAS to enhance products' resistance to water, oil, and heat.35 Depending on the
type of fabric production, HAS can be added to the fibers themselves or sprayed onto the
finished fabric to enhance performance and durability.36 As a result, EPA has determined that
PFAS "are present in wastewater discharges" from textile companies.37
Because Lear falls into the category of industries known to be associated with PFAS and
because prior sampling confirms the presence of PFAS in Lear's wastewater and downstream of
Lear's outfall, it's practically certain that the company continues to release the toxic chemicals
into the Northeast Cape Fear River today.
II. Lear's pollution threatens the Northeast Cape Fear River and those who use it.
Duplin County, where Lear discharges, is a rural area that has "long relied on an
agricultural economy."38 The communities downstream of Lear's discharge are predominantly
low-income, and between 73 and 80 percent of community members have less than a high-
school education.39 While the racial demographics of Duplin County residents vary, downstream
of Lear's discharge, the community is comprised predominantly of people of color.40 Many of
these residents turn to the River for its abundance of fish and recreational opportunities.
Indeed, Lear discharges into a portion of the Northeast Cape Fear River that is popular
for fishing, kayaking, and other recreational activities. Ecologically, the Northeast Cape Fear
River is an important waterbody for many species. For example, the river downstream of Lear's
31 Id. at 3.
3z U.S. Env't Prot. Agency, Multi -Industry Per- and Polyfluoroalkyl Substances (PFAS) Study -2021 Preliminary
Report 5-1 (Sept. 2021), available at h!Ws://www.ppa.gov/Ustem/files/documents/2021-09/multi-industry_pfas-
study preliminary-2021-report _508_2021.09.08.pdf [hereinafter "EPA PFAS Industry Preliminary Report"].
33 Id. at 5-2.
34 Id. at 5-8 to 5-9.
35 Id. at 8-3 to 8-4.
36 EPA PFAS Industry Preliminary Report, supra note 32 at 8-1 to 8-2.
37 Id. at 8-4.
38 The Julius L. Chambers Center for Civil Rights, Environmental Justice: Duplin County, NC (2018), available at
https://ncejn.files.wordpress.com/2018/10/duplin-ej-report-final.pdf.
39 U.S. Env't Prot. Agency, EJScreen, EPA's Environmental Justice Screening and Mapping Tool (Version 2.1),
https:Hejscreen.epa. og v/mapper/ (last visited Feb. 10, 2023).
40 Id.

discharge serves as protected critical habitat for the endangered Atlantic sturgeon.41
Additionally, expert agencies dedicated to ecological conservation have deemed this portion of
the Northeast Cape Fear River as one of the highest priority conservation areas in the
Southeast.42 This portion of the river also provides abundant habitat for largemouth bass, sunfish,
and American shad, and as a result, is a popular fishing destination.43 Many community
members in Duplin County and surrounding areas subsistence fish in this portion of the river —
meaning they rely on an abundance of healthy fish as a source of food. A recent study shows that
those who subsistence fish in the Cape Fear River basin tend to be low-income, people of color,
or individuals suffering from food insecurity.44
As described above, PFAS do not breakdown once released into the environment and
they will bioaccumulate in both the soil and organisms exposed to the chemicals, including fish.
A recent study has documented fish with detectable levels of PFAS in all 48 continental states.45
The results of this study confirm that PFOSa particularly harmful PFAS compound —was one
of the most prominent HAS found in fish.46 At the local level, scientists studying striped bass in
the lower Cape Fear River detected PFAS, including PFOS, PFNA, and PFDA, in more than 98
percent of fish sampled.47 The Department itself is currently studying HAS present in multiple
other fish species across the lower Cape Fear River, including those commonly fished for
subsistence like catfish, largemouth bass, striped bass, and American shad.48 With the data
known thus far, researchers ultimately conclude that "[w]idespread PFAS contamination of
freshwater fish in surface waters in the U.S. is likely a significant source of exposure to PFOS
and potentially other perfluorinated compounds for all persons who consume freshwater fish, but
especially for high frequency freshwater fish consumers. ,49
41 82 Fed. Reg. 39,160 (2017); 50 C.F.R. § 226.225(g) (listing critical habitat for Atlantic sturgeon); see also
Atlantic Sturgeon Critical Habitat Map and GIS Data, NAT'L OCEANIC AND ATMOSPHERIC ADMIN.,
hLtps://www.fisheries.noaa.,gov/resource/map/atlantic-sturgeon-critical-habitat-map-and- i� (last visited Feb. 7,
2023).
41 See The Southeast Conservation Blueprint, SOUTHEAST CONSERVATION ADAPTATION STRATEGY,
https://secassoutheast.or%blueprint (last visited Feb. 7, 2023); Southeast Conservation Blueprint Version 2022,
SOUTHEAST CONSERVATION ADAPTATION STRATEGY (2022), available at
hllps://fws.mgps.arcais.com/apps/mgpviewer/index.html?webmap=2968cfl e52f34b73b9bc2d336dl d8323.
43 N.C. Wildlife Res. Comm'n, Fishing Opps in the Coastal Region of NC,
https://www.ncwildlife.or /Fg ishing/Where-to-
Fish/FishingOpps in the Coastal_ Region_ of NC#:—:text=The%20Cape%2OFear%2ORiver%20provides,between
%201%C2%BD%20to%203%20pounds (last visited Feb. 6, 2023).
44 Elizabeth Shaprio-Garza, et al., Subsistence Fish Consumption on the Lower Cape Fear River, Duke Univ.
Superfund Rsch. and Oakland Univ. 21-22 (2022), available at
hLtps:Hsites.nicholas.duke.edu/sLiperfundcec/files/2022/10/Subsistence-Fish-Consumption-on-the-lower-Cape-Fear-
River_report.pdf.
41 Barbo, supra note 22 at 1.
46 Id.
47 T.C. Guillette, et al., Elevated Levels of per- and polyfluoroalkyl substances in Cape Fear River Striped Bass
(Morone saxatilis) are Associated with Biomarkers of Altered Immune and Liver Function, 136 Env't Int'l 105358
(Feb. 2020), available at hllps://www.research atg e.net/publication/339091901_Elevated_ levels_ of per -
and polyfluoroalkyl substances in Cape Fear _River _Striped _Bass _Morone_saxatilis_are _ associated_ with_biom
arkers of altered immune and liver function.
46 Frannie Nilsen, Summer 2022 Water and Fish Collection Event, N.C. Dep't of Env't Quality (Aug. 1, 2022),
hLtps:Hdeq.nc.gov/media/30793/download?attachment.
49 Barbo, supra note 22 at 9.
r%l

Given what we know about the chemical properties of PFAS and their long-lasting
impact on the environment and species that come in contact with them, Lear's pollution likely
poses a very real threat to North Carolinians who recreate and fish in the Northeast Cape Fear
River. Additionally, the Northeast Cape Fear River flows into the mainstem of the Cape Fear
River and Lear's pollution thus contributes to the overburden the Cape Fear River already faces
from HAS concentrations.
III. Lear's current permit does not authorize the company to discharge PFAS, and
each time the company releases the toxic chemicals, it is violating the law.
Lear is not authorized to release PFAS into the Northeast Cape Fear River because the
company did not disclose its PFAS discharges in its NPDES permit application,50 and the
Department did not consider the PFAS pollution when it issued Lear's prior NPDES permits.51
The Clean Water Act prohibits the discharge of any pollutant, including PFAS, without a
NPDES permit.52 The discharge of a specific pollutant (or group of pollutants) cannot be
permitted if it is not disclosed in a NPDES permit application. For decades, EPA has stressed the
need for disclosure of pollutants during the permitting process:
[D]ischargers have a duty to be aware of any significant pollutant levels in their
discharge. [... ] Most important, [the disclosure requirements] provide the
information which the permit writers need to determine what pollutants are likely
to be discharged in significant amounts and to set appropriate permit limits. [...]
[P]ermit writers need to know what pollutants are present in an effluent to
determine appropriate permit limits in the absence of applicable effluent
guidelines. 53
In December 2022, EPA confirmed that these disclosure requirements apply to PFAS
stating that "no permit may be issued to the owner or operator of a facility unless the owner or
operator submits a complete permit application" providing all information "that the permitting
authority may reasonably require to assess the discharges of the facility" including information
regarding PFAS.54 Disclosure is considered adequate under the Clean Water Act when the
applicant provides enough information for a permitting agency to "be[] able to judge whether the
discharge of a particular pollutant constitutes a significant threat to the environment. ,55 To meet
this burden, an applicant must include all relevant information, including the concentration,
50 See Norman Johnson, Application for Renewal of: NPDES Permit Number NC0002305 Guildford Mills, Inc.
(Aug. 3, 2016) (not acknowledging, listing, or otherwise disclosing the presence of PFAS in the wastewater from the
industrial plant).
51 See N.C. Dep't of Env't Quality, NPDES Permit No. NC0002305 (Oct. 1, 2018).
52 33 U.S.C. § 131 l(a).
53 Consolidated Permit Application Forms for EPA Programs, 45 Fed. Reg. 33,526-31 (May 19, 1980).
54 EPA's PFAS NPDES Guidance, supra note 2 at 2.
55 piney Run Pres. Assn v. Cty. Commis of Carroll Cty., Maryland, 268 F.3d. 255, 268 (4th Cir. 2001) ("Because
the permitting scheme is dependent on the permitting authority being able to judge whether the discharge of a
particular pollutant constitutes a significant threat to the environment, discharges not within the reasonable
contemplation of the permitting authority during the permit application process, whether spills or otherwise, do not
come within the protection of the permit shield.").
7

volume, and frequency of the discharge.56 The Clean Water Act places the burden of disclosure
on the permit applicant because they are in the best position to know what is in their discharge.57
Importantly, if a NPDES permit applicant does not adequately disclose its release of a
pollutant, the applicant does not have approval to discharge the pollutant.5' The EPA
Environmental Appeals Board's decision in In re: Ketchikan Pulp Company emphasized this
resu1t,59 and that decision has been adopted by the Fourth Circuit. For example, in Piney Run
Pres. Ass'n v. Cty. Comm'rs of Carroll Cty., Maryland, the Fourth Circuit stated:
The Ketchikan decision therefore made clear that a permit holder is in compliance
with the [Clean Water Act] even if it discharges pollutants that are not listed in its
permit, as long as it only discharges pollutants that have been adequately
disclosed to the permitting authority. [... ] To the extent that a permit holder
discharges a pollutant that it did not disclose, it violates the NPDES permit
and the [Clean Water Act].60
The Department has already acknowledged that disclosure of toxic PFAS is required by
the Clean Water Act and state water quality laws. In its enforcement action against Chemours for
the company's discharge of HAS into the Cape Fear River, the agency stated:
Part of the permit applicant's burden in this regard is to disclose all relevant
information, such as the presence of known constituents in a discharge that pose a
potential risk to human health. The permit applicant is required to disclose "all
known toxic components that can be reasonably expected to be in the discharge,
including but not limited to those contained in a priority pollutant analysis." 15A
N.C.A.C. 21-1.01050) (emphasis added). [... ] These disclosure obligations are
critical, in part, because they define the scope of the Clean Water Act's "permit
shield." While compliance with the express terms of an NPDES permit generally
"shields" the permittee from liability for violations of 33 U.S.C. § 1311, the
permit does not shield the permittee from liability where the pollutant being
discharged was not within the "reasonable contemplation" of the permitting
agency when it issued the permit due to nondisclosure by the permittee.61
56 See In re Ketchikan Pulp Co., 7 E.A.D. 605 (EPA) (1998) ("In explaining the provisions of 40 C.F.R. §
122.53(d)(7)(iii), which required dischargers to submit quantitative data relating to certain conventional and
nonconventional pollutants that dischargers know or have reason to believe are present in their effluent, the [EPA]
stated: `permit writers need to know what pollutants are present in an effluent to determine appropriate limits in the
absence of effluent guidelines."').
57 S. Appalachian Mountain Stewards v. A & G Coal Corp., 758 F.3d 560, 566 (4th Cir. 2014).
("The statute and regulations purposefully place the burden of disclosure on the permit applicant.").
58 See In re Ketchikan Pulp Co., 7 E.A.D. 605; Piney Run, 268 F.3d. at 268; S. Appalachian Mountain Stewards, 758
F.3d at 567.
" See In re Ketchikan Pulp Co., 7 E.A.D. 605.
60 Piney Run, 268 F.3d. at 268 (emphasis added).
61 Amended Complaint, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580, 6-7 (N.C. Super. 2018)
(citing 33 U.S.C. § 1342(k); Piney Run, 268 F.3d at 265), htt2s://perma.cc/ZT3U-7QJB.

Other states have reached similar conclusions. For example, the Tennessee Department of
Environment and Conservation has made clear in at least one NPDES permit that undisclosed
discharges of PFAS are unpermitted:
The facility's application did not report any forms of PFAS as chemicals that
there was the potential to discharge. The permittee has no permit shield for the
discharge of PFAS compounds because no such chemicals were disclosed in the
permit application or otherwise...62
The Department should treat Lear in the same manner as it did Chemours (and in the
same manner that EPA and Fourth Circuit precedent mandate). Lear discharges PFAS and the
company did not disclose that its wastewater contains the toxic chemicals. Because Lear failed to
disclose this critical information, each and every release of PFAS into the Northeast Cape Fear
River is a violation of the Clean Water Act subject to enforcement by the Department or a citizen
suit brought pursuant to 33 U.S.C. § 1365.
IV. The Department must address Lear's PFAS pollution in its renewal permit.
Lear's current NPDES permit expires on April 30, 2023,63 and the Department has
received a NPDES renewal application from the company.64 That permit renewal application,
once again, does not disclose the presence of PFAS in Lear's wastewater.65 The Department
must take the following actions to control PFAS in Lear's upcoming permit.
a. The Department must require Lear to update its application to disclose PFAS.
Lear must disclose any discharge of PFAS before the agency moves forward with
drafting a NPDES permit. As discussed above, the Department cannot authorize the discharge of
a pollutant not disclosed during the permit application process. In line with EPA's directives, the
Department should require Lear to analyze its effluent using draft method 1633 and disclose any
PFAS found through this sampling.66 Requiring sampling and disclosure before the Department
releases a draft permit will ensure that the Department has all of the information that it needs to
properly control Lear's PFAS pollution in the upcoming NPDES permit. The Department must
require disclosure to ensure Lear knows of its obligations with respect to PFAS and is aware of
the potential liability if it fails to do so.
62 TDEC, NPDES Permit NO. TN0002330 (2020), Holliston Holdings, LLC, Addendum to Rationale,
h1t2s://perma.cc/4RKY-PKFG (emphasis added).
63 N.C. Dep't of Env't Quality, NPDES Permit No. NC0002305, supra note 51 at 1.
64 See Lear's NPDES Permit Application, supra note 1.
65 See generally id.
66 EPA recommends the use these methods for NPDES permits. See EPA's PFAS NPDES Guidance, supra note 2 at
2 (recommending monitoring be conducted under draft method 1633 in the absence of a final published analytical
method for PFAS); see also Memorandum from Radhika Fox, U.S. Env't Prot. Agency to Water Division Directors
EPA Regions 1-10, Addressing PFAS Discharges in EPA -Issued NPDES Permits and Expectations Where EPA in
the Pretreatment Control Authority (Apr. 28, 2022), h1tps://perma.cc/5NMB-ME3L.
M

We understand that the Department has asked Lear to answer a questionnaire regarding
PFAS,67 but this form cannot replace the need for full disclosure. In its information request, the
Department asks Lear to provide any PFAS analytical results, if such sampling has already been
collected.68 This process —of only requiring information if it has already been collected —misses
the point of disclosure (to ensure the agency has full and complete information regarding
discharges) and creates the reverse incentive for Lear (and other industries) to abstain from
conducting PFAS sampling in the first place, as industries will likely want to avoid identifying
themselves as PFAS sources and/or permits with controls for the compounds. Additionally, this
process —at best —will result in Lear turning over the same 2019 sampling that the Department
already has, thereby aiding neither the Department nor the public in their understanding of Lear's
pollution.69
The Department cannot rely on a supplemental form and must instead require Lear to
conduct sampling to confirm the concentration and frequency of its PFAS pollution so that the
agency can ensure the Northeast Cape Fear River is protected. This information must be
incorporated into the permit application itself because the public relies on the information
submitted in the publicly available application in order to participate in the permitting process.70
b. The Department must impose effluent limits to control Lear's PFAS pollution.
EPA's PFAS NPDES Guidance instructs state agencies on how to address HAS through
existing NPDES authorities.71 Federal and state law, as well as EPA's guidance make clear that
the Department must analyze effluent limits to control Lear's PFAS pollution. Indeed, the
Department has already controlled PFAS in Chemours' NPDES permit, displaying the agency's
understanding of its responsibilities under the Clean Water Act and signaling that the agency has
the tools, authority, and knowledge of how to handle PFAS discharges through the NPDES
permitting scheme. Lear should be treated no differently.
The Clean Water Act requires permitting agencies to, at the very least, incorporate,
technology -based effluent limitations on the discharge of pollutants.72 When EPA has not issued
a national effluent limitation guideline for a particular industry,73 permitting agencies must
implement technology -based effluent limits on a case -by -case basis using their "best professional
67 Letter from Douglas Dowden, N.C. Dep't of Env't Quality, to Steven Middlebrook, Lear Corporation (Jan. 27,
2023) [hereinafter "More Information Request"], Attachment 6.
68 Id.
69 Indeed, we have seen this play out across the state. The Department has asked multiple facilities to provide PFAS
data and each entity has simply turned over the 2019 sampling the Department has previously instructed them to
collect and already had the results of. See, e.g., Letter from Elijah Williams, City of Greensboro, to Gary Perlmutter,
N.C. Dep't of Env't Quality (Jan. 27, 2022) (responding to the Department's request for information regarding
PFAS and 1,4-dioxane sampling and only attaching the 2019 PFAS sampling the department already had access to);
City of Sanford, Permit Renewal Application No. NCO024147 (Mar. 22, 2022), at Tab H (providing the Department
with the 2019 and 2020 PFAS sampling already mandated by the Department).
70 See 15A N.C. Admin. Code 2H.0109, 2H.0115.
71 EPA's PFAS NPDES Guidance, supra note 2.
72 40 C.F.R. § 125.3(a) ("Technology -based treatment requirements under section 301(b) of the Act represent the
minimum level of control that must be imposed in a permit..." (emphasis added)); see also 33 U.S.C. § 1311; see
also EPA's PFAS NPDES Guidance, supra note 2 at 2.
73 33 U.S.C. § 1314(b).
IR

judgment."74 EPA has confirmed that technology -based limits are the "minimum level of control
that must be imposed in NPDES permits" and that they should be calculated for PFAS .75
Effective treatment technologies for PFAS are available. Granular activated carbon is a
cost-effective and efficient technology that can reduce PFAS concentrations to virtually
nondetectable levels. A granular activated carbon treatment system at the Chemours' facility, for
example, has reduced PFAS concentrations as high as 345,000 ppt from a creek contaminated by
groundwater beneath the facility to nearly nondetectable concentrations.76 The Department must
treat Lear the same way that it treated Chemours. The Department must consider the feasibility
of using granular activated carbon or similar technologies to control Lear's PFAS pollution.
If technology -based limits are not enough to ensure compliance with water quality
standards, the Department must include water quality -based effluent limits in the permit.77 If the
Department finds there is a "reasonable potential" that water quality standards will be exceeded,
it must include water quality -based effluent limits in the permit .78 This obligation "may not be
waived," and requires the agency to incorporate a permit limit protective of water quality
standards regardless of "treatability" or analytical method detection levels.79 Additional
monitoring or data collection requirements "may not be substituted" for permit limits.80
North Carolina's toxic substances standard protects the public from the harmful effects of
toxic chemicals, like PFAS .81 For instance, the toxic substances standard mandates that the
concentration of cancer -causing chemicals shall not result in "unacceptable health risks," defined
as "more than one case of cancer per one million people exposed. ,82 As the Department itself
has recognized, PFAS meet the definition of "toxic substance" and the Department should
therefore analyze whether Lear's discharge will violate this water quality standard.83 EPA's
health advisories for PFAS and countless toxicity studies indicate that the chemicals pose
unacceptable health risks at extremely low levels. The Department must assess effluent limits in
74 40 C.F.R. § 125.3; see also 33 U.S.C. § 1342(a)(1)(B); 15A N.C. Admin. Code 213.0406.
75 EPA's PFAS NPDES Guidance, supra note 2 at 3.
76 See Parsons, Engineering Report — Old Outfall 002 GAC Pilot Study Results (Sept. 2019), available at
https://www. chemours. com/j a/-/media/files/corporate/ 12e-old-outfa11-2-gac-pilot-report-2019-09-
30.pdPrev=6el242091aa846f888afa895eff80e2e&hash=040CAA7522E3D64B9E5445ED6F96BOFB; see also
Chemours Outfall 003, NPDES No. NC0089915 Discharge Monitoring Reports (2020-2022), available at
https://perma.cc/8YND-XT5M.
77 40 C.F.R. § 122.44(d)(1)(i); see also 33 U.S.C. § 1311(b)(1)(C); 15A N.C. Admin. Code 2H.0112(c) (stating that
Department must "reasonably ensure compliance with applicable water quality standards and regulations"); EPA's
PFAS NPDES Guidance, supra note 2 at 3-4.
78 40 CFR § 122.44(d)(1)(i), see also 33 U.S.C. § 1311(b)(1)(C); (1)(i); 15A N.C. Admin. Code 2H.0112(c) (stating
that the Department must "reasonably ensure compliance with applicable water quality standards and regulations.");
EPA, CENTRAL TENETS OF THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES) PERMITTING PROGRAM 3 (2020), available at https://www.epa.,gov/npdes/central-tenets-npdes-
permitting=program (emphasis in original) [hereinafter "Central Tenets of NPDES Permitting Program"].
79 Central Tenets of NPDES Permitting Program, supra note 78 at 3.
80 Id.
81 15A N.C. Admin. Code 213.0208.
82 Id. at 213.0208(a)(2)(13).
Ss Amended Complaint, North Carolina v. The Chemours Company, FC, LLC, supra note 61 at ¶ 152 (explaining
that PFAS "meet the definition of `toxic substance' set forth in 15A N.C.A.C. 2B .0202").
11

Lear's permit based on EPA's health advisories and other available toxicity information for the
chemicals.
V. The Department must also address other pollution in Lear's renewal permit.
While Lear's HAS pollution is of utmost concern, there are other items that the
Department must address as it prepares Lear's renewal permit. First, prior sampling has
confirmed that Lear also discharges 1,4-dioxane, a likely human carcinogen.84 1,4-dioxane is a
clear, man-made chemical that is a byproduct of many industrial processes. 8' The chemical is
toxic to humans,86 causing liver and kidney damage.87 Like PFAS, 1,4-dioxane is highly
miscible in water and does not break down once released into the environment. In 2019, Lear
sampled its effluent and reported concentrations of 1,4-dioxane ranging between 12 parts per
billion ("ppb") and 29 ppb.88 Despite knowing that it released the toxic chemical into the
Northeast Cape Fear River, Lear did not disclose its 1,4-dioxane pollution in the company's most
recent permit application. As with PFAS, the Department must require disclosure of 1,4-dioxane,
evaluate applicable control technology, and then assess whether Lear's pollution has the
reasonable potential to cause or contribute to an exceedance of water quality standards.89 If so,
the Department must impose effluent limits.90
Second, Lear has routinely violated the terms of its permit. In 2022 alone, Lear exceeded
its whole effluent toxicity limit at least four times.91 In the same year, Lear exceeded its fecal
coliform limit at least three times.92 Lear also violated its permit condition prohibiting more than
a trace amount of foam from being released from its outfall.93 This violation is particularly
egregious as the company failed to self -report the prohibited discharge (as required by law),94
and the violation was only brought to the Department's attention after Cape Fear River Watch
84 2019 Industrial HAS Sampling, supra note 4 at 8.
" Technical Fact Sheet—1,4-Dooxane, EPA 1-2 (2017), hLtps://www.epa.gov/sites/production/files/2014-
03/documents/ffrro_factsheet contaminant_ 14-dioxane ianuary2014_fmal.pdf.
86Id. at 1.
87 Id.; EPA, Integrated Risk Information System, Chemical Assessment Summary: 1,4,-dioxane 2 (Aug. 11, 2010),
https:Hcfpub.epa.gov/ncea/iris/iris_documents/documents/subst/0326_summary.pdf.
88 2019 Industrial PFAS Sampling, supra note 4 at 8.
89 See 40 C.F.R. § 122.44(d)(1)(i); 15A N.C. Admin. Code 2H.0112(c) (stating that Department must "reasonably
ensure compliance with applicable water quality standards and regulations").
90 40 C.F.R. §§ 125.3(a) ("Technology -based treatment requirements under section 301(b) of the Act represent the
minimum level of control that must be imposed in a permit..." (emphasis added)); 122.44(d)(1)(i); see also 33
U.S.C. § 1311.
91 Letter from Cindy Moore, N.C. Dep't of Env't Quality, to Stephen Molino, Lear Corporation (Mar. 22, 2022) (NC
NOV-2022-TX-0018); Letter from Cindy Moore, N.C. Dep't of Env't Quality, to Stephen Molino, Lear Corporation
(Apr. 12, 2022) (NC NOV-2022-TX-0029); Letter from Cindy Moore, N.C. Dep't of Env't Quality, to Stephen
Molino, Lear Corporation (June 20, 2022) (NC NOV-2022-TX-0046); Letter from Cindy Moore, N.C. Dep't of
Env't Quality, to Stephen Molino, Lear Corporation (June 20, 2022) (NC NOV-2022-TX-0058).
92 Letter from Tom Tharrington, N.C. Dep't of Env't Quality, to Stephen Molino, Lear Corporation (Feb. 25, 2022)
(NOV-2022-LV-0 15 1); Letter from Tom Tharrington, N.C. Dep't of EnVt Quality, to Stephen Molino, Lear
Corporation (Aug. 5, 2022) (NOV-2022-LV-0527); Letter from Tom Tharrington, N.C. Dep't of Env't Quality, to
Stephen Molino, Lear Corporation (Sept. 6, 2022) (NOV-2022-LV-0619).
93 Letter from Morella Sanchez -King, N.C. Dep't of Env't Quality, to Stephen Molino, Lear Corporation (Jan. 17,
2023) (NOV-2023-PC-0006).
94 40 C.F.R. § 122.41(1).
12

discovered and reported the occurrence.95 The Department must impose conditions in Lear's
permit to ensure that these violations do not recur.
VI. Conclusion.
Lear currently and unlawfully releases incredibly high amounts of PFAS into the
Northeast Cape Fear River. The Department must require that Lear disclose its PFAS and 1,4-
dioxane pollution by providing sampling data that affords the Department the information it
needs to protect the river and those that use it. The Department has made impressive steps to
control the pollution at Chemours, but the work cannot end there. The Department must act now
to prevent Lear from continuing to release toxic PFAS into the Northeast Cape Fear River and
must incorporate limits and conditions necessary to protect the environment and surrounding
communities in Lear's upcoming NPDES permit. Thank you for considering these comments.
Please contact me at 919-967-1450 or [e-mail] if you have any questions regarding
this letter.
Sincerely,
4w"�AiAow
Hannah M. Nelson
Jean Zhuang
Geoff Gisler
SOUTHERN ENVIRONMENTAL LAW CENTER
601 W. Rosemary Street, Suite 220
Chapel Hill, NC 27516
cc: Kemp Burdette, Cape Fear River Watch, [e-mail]
Dana Sargent, Cape Fear River Watch, [e-mail]
95 See Email from Kemp Burdette, Cape Fear River Water, to Morella Sanchez -King, N.C. Dep't of Env't Quality
(Sept. 1, 2022).
13

ATTACHMENT 1

r
LEARO
CORPORATION
November 28, 2022
NC Department of Environmental Quality
Division of Water Resources / Permitting
1617 Mail Service Center
Raleigh, NC 27699-1617
Attention: Division of Water Resources - Water Quality Permitting
Lear Corporation
Guilford Performance Textiles by Lear
1754 NC Highway 903/11 North
Kenansville, NC 28349
USA
Phone [phone]
RE: Wastewater Treatment Permit Renewal Application — Lear Corp., Permit No. NC0002305
To Whom it May Concern,
Enclosed are two copies of the completed Wastewater Treatment Permit renewal applications
for Lear Corp. — Kenansville, Permit Number NC0002305. Also included are the laboratory
analyses, site maps, and WWT flow diagram.
Thank you in advance for your assistance with this application. If you have questions or need
additional information concerning this application, please contact our Operator In Responsible
Charge, George Yankay at 910-296-5201.
Yours sincerely,
Mr. Steven Middlebrook
Plant Manager
T [910] 372-8296
smiddlebrook(o-),lear.com

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCD058520016 NC0002305 Lear Corp. OMB No. 2040-0004
Form U.S. Environmental Protection Agency
1 480MAX Application for NPDES Permit to Discharge Wastewater
NPDES GENERAL INFORMATION
1.1,1 Is the facility a new or existing publicly owned
treatment works?
If yes, STOP. Do NOT complete No
Form 1. Complete Form 2A.
1.2.1 Is the facility a concentrated animal feeding
operation or a concentrated aquatic animal
production facility?
Yes -+ Complete Form 1 No
and Form 2B.
1.2.3 Is the facility a new manufacturing, commercial,
mining, or silvicultural facility that has not yet
commenced to discharge?
Yes -+ Complete Form 1 No
and Form 2D.
1.2.5 Is the facility a new or existing facility whose
discharge is composed entirely of stormwater
associated with industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
Yes -+ Complete Form 1 n✓ No
and Form 2F
unless exempted by
40 CFR
122,26(b)(14)(x) or
(b)(15).
2.1 1 Facility Name
1.1.2 Is the facility a new or existing treatment works
treating domestic sewage?
If yes, STOP. Do NOT 0 No
complete Form 1. Complete
Form 2S.
1.2.2 Is the facility an existing manufacturing,
commercial, mining, or silvicultural facility that is
currently discharging process wastewater?
F,71 Yes 4 Complete Form No
1 and Form 2C.
1.2.4 Is the facility a new or existing manufacturing,
commercial, mining, or silvicultural facility that
discharges only nonprocess wastewater?
Ej Yes 4 Complete Form �✓ No
1 and Form 2E.
Lear Corporation - Kenansville
2.2 EPA Identification Number
NCD058520016
2.3 Facility Contact
Name (first and last) Title Phone number
George Yankay Operator in Responsible Charge (OIRP) [phone]
Email address
[e-mail]
2.4 Facility Mailina Address
Street or P.O. box
1754 NC Highway 903
City or town State ZIP code
Kenansville �NC 128349
EPA Form 3510-1 (revised 3-19) Page 1

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03/05/19
NCD058520016
NC0002305
Lear Corp.
OMB No. 2040 0004
2.5
Facility Location
.,
Street, route number, or other specific identifier
Q 0
1754 NC Highway 903
o
County name
County code (if known)
Duplin
Not Known
0
E —' '
City or town
State ZIP code
z
Kenansville
NC 28349
SECTION•D
41
3.1
SIC Code(s)
Description (optional)
2258
Lace and warp knit fabric mills
U
m
0
U
N
U
z
3.2
NAICS''Code(s)
Description (optional)
1V
C
U
336360
Motor Vehicle Seating and Interior Trim Manufacturing
4.1
Name of Operator
Lear Corporation - Kenansville
0
4.2
Is the name you listed in Item 4.1 also the owner?
✓❑ Yes ❑ No
L
4.3
Operator Status
0
;�
❑ Public —federal ❑ Public —state ❑ Other public (specify)
CL
O
❑✓ Private ❑ Other (specify)
4.4
Phone Number of Operator
[phone]
4.5
0` erator Address
_
Street or P.O. Box
'a
m
1754 NC Highway 903
City or town
State
ZIP code
-0 0
Kenansville
NC
28349
:.IE
Q
Email address of operator
0
[e-mail]
SECTION40
5.1
Is the facility located on Indian Land?
❑ Yes ❑ No
EPA Form 3510-1 (revised 3-19) Page 2

EPA Identification Number
NPDES Permit Number Facility Name
Form Approved 03/05/19
NCD058520016
NC0002305 Lear Corp.
OMB No. 2040-0004
SECTION'•
41
6.1 Existing Environmental Permits (check all that apply and print or type the corresponding permit number for each)
4
❑ NPDES (discharges to surface
❑ RCRA (hazardous wastes)
❑ UIC (underground injection of
C
water)
fluids)
22
NC0002305
NCD058520016
None
w 4)
CL
❑ PSD (air emissions)
❑ Nonattainment program (CAA)
❑ NESHAPs (CAA)
02484 r24
None
40 CFR 63 Subpt JJJJJJ
�'
u'3
❑ Ocean dumping MPRSA ❑ Dredge or fill CWA Section 404 ❑ Other(specify)
p 9 ( ) g ( )
None None CCPCUA - CU3094
SECTIONA'
41
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 2B.)
SECTION;
NATURE
OF 41 ;
8.1
Describe the nature of your business.
Warp knitting and weaving of synthetic fibers for the automotive industry. Dyeing, finishing, and flame lamination of
N
knitted and woven synthetic fabrics.
a)
`m
0
L
Z
SECTION••
41
9.1 Does your facility use cooling water?
d
❑✓ 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
•o Y
NPDES permitting authority to determine what specific information needs to be submitted and when.)
V
Underground aquifer, as permitted in CCPCUA permit CU3094
SECTION1
VA'
• 41 1
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
N
apply. Consult with your NPDES permitting authority to determine what information needs to be submitted and
a
when.)
Cr
❑ Fundamentally different factors (CWA ❑ Water quality related effluent limitations (CWA Section
Section 301(n)) 302(b)(2))
C
❑ 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 03/05/19
NCD0585200)16
NC0002305
Lear Corp. OMB No. 2040-0004
SECTIONAND
CERTIFICATION STATEMENT1
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
❑ w/ 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
F,
❑✓ Section 6: Existing Environmental Permits
❑ w/ attachments
a�
❑✓ Section 7: Map
❑/ topographic ❑ w/ additional attachments
map
o
❑✓ Section 8: Nature of Business
❑ w/ attachments
ca
❑✓ Section 9: Cooling Water Intake Structures
❑ w/ attachments
_
❑✓ Section 10: Variance Requests
❑ w/ attachments
N_
❑✓ Section 11: Checklist and Certification Statement
❑ w/ attachments
Y
11.2
Certification Statement
U
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
Mff 6(%-
Signature
Date signed
EPA Form 3510-1 (revised 3-19) Page 4

40�
F-_
�rt
A?
0
CL
0
C:
0
m
E
0
top
"k,

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCD058520016 NC0002305 Lear Corporation OMB No. 2040-0004
Form U.S. Environmental Protection Agency
2CE0A Application for NPDES Permit to Discharge Wastewater
NPDES 481EXISTING MANUFACTURING, COMMERCIAL, MINING, AND SILVICULTURE OPERATIONS
9ECTION 1. OUTFALL LOCATION4i
1.1 1 Provide information on each of the facility's outfalls in the table below.
001 Northeast Cape Fear River 350 01' 00.4" N El -770 5Y 471' W El
is
O , »
O
O , » O , »
2.1 Have you attached a line drawing to this application that shows the water flow through your facility with a water
balance? (See instructions for drawing requirements. See Exhibit 2C-1 at end of instructions for example.)
F7 Yes ❑ No
3.1 IFor each outfall identified under Item 1.1, provide average flow and treatment information. Add additional sheets if
necessary.
See attached Operations Contributing to Flow Chart 0.437063 mgd
mgd
mgd
mgd
See Attached Operations Contributing to Flow Chart
EPA Form 3510-2C (Revised 3-19) Page 1

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03/05/19
NCD058520016
NC0002305
Lear Corporation
OMB No. 2040-0004
3.1
**Outfall Number** N/A
cont.Operations
_
`
toFlow
Operation `
Average Flow
NA
mgd
mgd
mgd
mgd
Treatment
Description
Units
Code from
Final Disposal of Solid or
(�Ig
(include size, flow rate through each treatment unit,
Table 2C-1
Liquid Wastes Other Than
retention time, etc.)
by Discharge
NA
0
m
E
ca
w
L
�
**Outfall Number** N/A
cc
Operations Contributing to Flow
o
Operation Average Flow
E
NA
mgd
i.
4)
mgd
mgd
mgd
Description
it Units
Code from
Final Disposal of Solid or
{�Ig
(include size, flow rate through each treatment unit,
Table 2C-1 ''
Liquid Wastes Other Than
retention time, etc.)
by Discharge
NA
3.2
Are you applying for an NPDES permit to operate a privately owned treatment works?
❑ Yes ❑✓ No -+ SKIP to Section 4.
co
3.3
Have you attached a list that identifies each user of the treatment works?
❑ Yes ❑ No
EPA Form 3510-2C (Revised 3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCD058520016 NC0002305 Lear Corporation OMB No. 2040-0004
SECTION• 41 •
4.1 Except for storm runoff, leaks, or spills, are any discharges described in Sections 1 and 3 intermittent or seasonal?
❑ Yes ❑✓ No 4 SKIP to Section 5.
4.2
Provide information
on intermittent or seasonal flows for each applicable outfall.
Attach additional pages, if necessary.
Outfall
Operation
Freq
uency
Flow Rate
Average
Average
Long -Term
Maximum
Number
(list)
Duration
Da sM(eek
MonthsNear
Average
Daily
days/week
months/year
mgd
mgd
days
oN/A
days/week
months/year
mgd
mgd
days
LL
.•r
days/week
months/year
mgd
mgd
days
E
as
days/week
months/year
mgd
mgd
days
days/week
months/year
mgd
mgd
days
N/A
days/week
months/year
mgd
mgd
days
days/week
months/year
mgd
mgd
days
days/week
months/year
mgd
mgd
days
N/A
days/week months/year mgd mgd days
SECTION"•D
• 41 •
5.1
Do any effluent limitation guidelines (ELGs) promulgated by EPA under Section 304 of the CWA apply to your facility?
R✓ Yes ❑ No 4 SKIP to Section 6.
5.2
Provide the following information on applicable ELGs.
CD
w
ELG Category
ELG Subcategory
Regulatory Citation
Textile Mills
Knit Fabric Finishing
40 CFR 410, Subpart E
Q
5.3
Are any of the applicable ELGs expressed in terms of production (or other measure of operation)?
❑✓ Yes ❑ No 4 SKIP to Section 6.
0
c
5.4
Provide an
actual measure of daily production expressed in terms and units of
applicable ELGs.
Outfall
Number
Operation, Product, or Material
Quantity per Day
Unit of
Measure
a�
Finishing of knit fabrics thru "complex manufacturing operations"
58,000
pounds
+ N
m001
c
0
0
a
EPA Form 3510-2C (Revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCD058520016 NC0002305 Lear Corporation OMB No. 2040-0004
SECTION• IMPROVEMENTS (40 •
6.1 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 -+ SKIP to Item 6.3.
6.2
Briefly identify each applicable project in the table below.
Affected
Final Compliance Dates
E
Brief Identification and Description of
Outfalls
Source(s) of
o
Project
(list outfall
Discharge
Required
Projected
CL
number
E
=
N/A
cu
w
a), ..
a.
6.3
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 ✓❑ Not applicable
SECTION.-. ,0
See the instructions to determine the pollutants and parameters you are required to monitor and, in turn, the tables you must
complete. Not all applicants need to complete each table.
Table A. Conventional and Non -Conventional Pollutants
7.1
Are you requesting a waiver from your NPDES permitting authority for one or more of the Table A pollutants for any of
your outfalls?
❑ Yes ❑✓ No 4 SKIP to Item 7.3.
7.2
If yes, indicate the applicable outfalls below. Attach waiver request and other required information to the application.
Outfall Number Outfall Number Outfall Number
1
7.3
Have you completed monitoring for all Table A pollutants at each of your outfalls for which a waiver has not been
N
requested and attached the results to this application package?
❑✓ Yes E]No; a waiver has been requested from my NPDES
permitting authority for all pollutants at all outfalls.
Table B.
Toxic Metals, Cyanide, Total Phenols, and Organic Toxic Pollutants
7.4
Do any of the facility's processes that contribute wastewater fall into one or more of the primary industry categories
listed in Exhibit 2C-3? (See end of instructions for exhibit.)
❑✓ Yes ❑ No 4 SKIP to Item 7.8.
7.5
Have you checked "Testing Required" for all toxic metals, cyanide, and total phenols in Section 1 of Table B?
w
Yes ❑ No
7.6
List the applicable primary industry categories and check the boxes indicating the required GC/MS fraction(s) identified
in Exhibit 2C-3.
Primary Industry Category
Required GC/MS Fraction(s)
Check applicable boxes.
Textile Mills, except Subpart C, Greige Mills
❑✓ Volatile 121 Acid © Base/Neutral ❑ Pesticide
❑ Volatile ❑ Acid ❑ Base/Neutral ❑ Pesticide
❑ Volatile ❑ Acid ❑ Base/Neutral ❑ Pesticide
EPA Form 3510-2C (Revised 3-19) Page 4

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03/05/19
NCD058520016
NC0002305
Lear Corporation
OMB No. 2040-0004
7.7
Have you checked "Testing Required" for all required pollutants in Sections 2 through 5 of Table B for each of the
GC/MS fractions checked in Item 7.6?
❑✓ Yes ❑ No
7.8
Have you checked "Believed Present" or "Believed Absent" for all pollutants listed in Sections 1 through 5 of Table B
where testing is not required?
❑✓ Yes ❑ No
7.9
Have you provided (1) quantitative data for those Section 1, Table B, pollutants for which you have indicated testing is
required or (2) quantitative data or other required information for those Section 1, Table B, pollutants that you have
indicated are "Believed Present" in your discharge?
✓❑ Yes ❑ No
7.10
Does the applicant qualify for a small business exemption under the criteria specified in the instructions?
❑ Yes -+ Note that you qualify at the top of Table B, ❑✓ No
then SKIP to Item 7.12.
7.11
Have you provided (1) quantitative data for those Sections 2 through 5, Table B, pollutants for which you have
o
determined testing is required or (2) quantitative data or an explanation for those Sections 2 through 5, Table B,
N
pollutants you have indicated are "Believed Present" in your discharge?
✓❑ Yes ❑ No
};
Table C. Certain Conventional and Non -Conventional Pollutants
L
7.12
Have you indicated whether pollutants are "Believed Present" or "Believed Absent" for all pollutants listed on Table C
for all outfalls?
❑✓ Yes ❑ No
7.13
Have you completed Table C by providing (1) quantitative data for those pollutants that are limited either directly or
indirectly in an ELG and/or (2) quantitative data or an explanation for those pollutants for which you have indicated
"Believed Present"?
a�
❑✓ Yes ❑ No
W
Table D.
Certain Hazardous Substances and Asbestos
7.14
Have you indicated whether pollutants are "Believed Present" or "Believed Absent" for all pollutants listed in Table D for
all outfalls?
❑✓ Yes ❑ No
7.15
Have you completed Table D by (1) describing the reasons the applicable pollutants are expected to be discharged
and (2) by providing quantitative data, if available?
❑✓ Yes ❑ No
Table E. 23,7,8-Tetrachlorodibenzo- -Dioxin 23,7,8-TCDD
7.16
Does the facility use or manufacture one or more of the 2,3,7,8-TCDD congeners listed in the instructions, or do you
know or have reason to believe that TCDD is or may be present in the effluent?
❑ Yes -+ Complete Table E. ❑✓ No -+ SKIP to Section 8.
7.17
Have you completed Table E by reporting qualitative data for TCDD?
❑ Yes ❑ No
SECTIONOR
MANUFACTURED TOXICS40
8.1
Is any pollutant listed in Table B a substance or a component of a substance used or manufactured at your facility as
an intermediate or final product or byproduct?
❑✓ Yes ❑ No 4 SKIP to Section 9.
U)
8.2
List the pollutants below.
1 Antimony, total 4 7
z..
0
2 Chromium, total 5 $
3. Copper, total 6 9
EPA Form 3510-2C (Revised 3-19) Page 5

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCD058520016 NC0002305 Lear Corporation OMB No. 2040-0004
SECTION• • • 4t
9.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made
within the last three years on (1) any of your discharges or (2) on a receiving water in relation to your discharge?
U) ❑✓ Yes ❑ No 4 SKIP to Section 10.
0
9.2
Identify the tests and their
Durposes below.
Z'
5
Test(s)
Purpose of Test(s)
Submitted to NPDES
Date Submitted
'x
Permitting Authority?
0
See attached Table
✓❑ Yes ❑ No
c.�
0
'm
❑ Yes ❑ No
❑ Yes ❑ No
SECTIONt
CONTRACT
ANALYSES (40
10.1
Were any of the analyses reported in Section 7 performed by a contract laboratory or consulting firm?
❑✓ Yes ❑ No 4 SKIP to Section 11.
10.2
Provide information for each contract laboratory or consulting firm below.
Laboratory Number 1
Laboratory Number 2
Laboratory Number 3
Name of laboratory/firm
Environmental Chemists Inc.
N/A
Laboratory address
6602 Windmill Way
QWilmington,
NC 28405
L
Phone number
[phone]
Pollutant(s) analyzed various
11.1
Has the NPDES permitting authority requested additional information?
_
❑ Yes ❑✓ No SKIP to Section 12.
o_
M
E
11.2
List the information requested and attach it to this application.
1. 4.
c
.0
2. 5.
-a
3. 6.
EPA Form 3510-2C (Revised 3-19) Page 6

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCD058520016 NC0002305 Lear Corporation OMB No. 2040-0004
SECTION•
41
12.1 In Column 1 below, mark the sections of Form 2C 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 complete all sections or provide attachments.
Column 1
Column 2
❑✓ Section 1: Outfall Location
✓❑ w/ attachments
❑✓ Section 2: Line Drawing
✓❑ w/ line drawing ❑ w/ additional attachments
Section 3: Average Flows and
w/ list of each user of
❑ w/ attachments ❑ privately owned treatment
Treatment
works
F/ Section 4: Intermittent Flows
❑ w/ attachments
❑✓ Section 5: Production
❑ w/ attachments
w/ optional additional
✓ Section 6: Improvements
❑
❑
❑ w/ attachments sheets describing anyadditional
pollution control
tans
❑ w/ request for a waiver and ❑ w/ explanation for identical
supporting information outfalls
El w/ other attachments
small business exemption El+;
request
request
`n
Section 7: Effluent and Intake
❑
❑✓ w/ Table A w/ Table B
Characteristics
0
ca
✓❑ w/ Table C ❑ w/ Table D
❑ w/ Table E w/ analytical results as an
attachment
Section 8: Used or Manufactured
❑
❑ w/ attachments
-�
Toxics
Section 9: Biological Toxicity
❑ w/ attachments
.c
Tests
'U
❑✓ Section 10: Contract Analyses
❑ w/ attachments
❑✓ Section 11: Additional Information
❑ w/ attachments
El Section 12: Checklist and
❑ w/ attachments
Certification Statement
12.2
Certification Statement
/ 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. l 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
Signature
Date signed
EPA Form 3510-2C (Revised 3-19) Page 7

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10
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C\j L-
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Chronic Toxicity Testing Results
Chronic Toxicity
Permit Compliance
X
07/22/2020
100
Chronic Toxicity
Permit Compliance
X
10/21 /2020
73.5
Chronic Toxicity
Permit Compliance
X
01/06/2021
100
Chronic Toxicity
Permit Compliance
X
04/07/2021
100
Chronic Toxicity
Permit Compliance
X
07/14/2021
100
Chronic Toxicity
Permit Compliance
X
10/13/2021
73.5
Chronic Toxicity
Permit Compliance
X
01/19/2022
19.1
Chronic Toxicity
Permit Compliance
X
02/09/2022
9.5
Chronic Toxicity
Permit Compliance
X
03/02/2022
38.2
Chronic Toxicity
Permit Compliance
X
03/09/2022
38.2
Chronic Toxicity
Permit Compliance
X
04/06/2022
19.1
Chronic Toxicity
Permit Compliance
X
05/04/2022
19.1
Chronic Toxicity
Permit Compliance
X
06/08/2022
100
Chronic Toxicity
Permit Compliance
X
07/20/2022
100
Chronic Toxicity
Permit Compliance
X
10/05/2022
100

ATTACHMENT 2

J��SED STq�s
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
5 w
u
= OFFICE OF WATER
0
1+Tq( PRO s
December 5, 2022
MEMORANDUM
SUBJECT: Addressing PFAS Discharges in NPDES Permits and Through the Pretreatment Program
and Monitoring Programs
FROM: Radhika Fox
Assistant Administrator
TO: EPA Regional Water Division Directors, Regions 1-10
The National Pollutant Discharge Elimination System (NPDES) program is an important tool
established by the Clean Water Act (CWA) to help address water pollution by regulating point sources
that discharge pollutants to waters of the United States. Collectively, the U.S. Environmental Protection
Agency (EPA) and states issue thousands of permits annually, establishing important monitoring and
pollution reduction requirements for Publicly Owned Treatment Works (POTWs), industrial facilities,
and stormwater discharges nationwide. The NPDES program interfaces with many pathways by which
per -and polyfluoroalkyl substances (PFAS) travel and are released into the environment, and ultimately
impact water quality and the health of people and ecosystems. Consistent with the Agency's
commitments in the October 2021 PFAS Strate zic Roadmap: EPA's Commitments to Action 2021-2024
(PFAS Strategic Roadmap), EPA will work in cooperation with our state -authorized permitting
authorities to leverage the NPDES program to restrict the discharge of PFAS at their sources. In addition
to reducing PFAS discharges, this program will enable EPA and the states to obtain comprehensive
information on the sources and quantities of PFAS discharges, which can be used to inform appropriate
next steps to limit the discharges of PFAS.
This memorandum provides EPA's guidance to states and updates the April 28, 2022 guidance' to EPA
Regions for addressing PFAS discharges when they are authorized to administer the NPDES permitting
program and/or pretreatment program. These recommendations reflect the Agency's commitments in the
PFAS Strategic Roadmap, which directs the Office of Water to leverage NPDES permits to reduce
PFAS discharges to waterways "at the source and obtain more comprehensive information through
monitoring on the sources of PFAS and quantity of PFAS discharged by these sources." While the
Office of Water works to revise Effluent Limitation Guidelines (ELGs) and develop water quality
criteria to support technology -based and water quality -based effluent limits for PFAS in NPDES
permits, this memorandum describes steps permit writers can implement under existing authorities to
reduce the discharge of PFAS.
Addressing PFAS Discharges in EPA -Issued NPDES Permits and Expectations Where EPA is the Pretreatment Control
Authority, httns•//www.epa.gov/system/files/documents/2022-04/nt)des pfas-memo.pdf.

This memorandum also provides EPA's guidance for addressing sewage sludge PFAS contamination
more rapidly than possible with monitoring based solely on NPDES permit renewals. States may choose
to monitor the levels of PFAS in sewage sludge across POTWs and then consider mechanisms under
pretreatment program authorities to prevent the introduction of PFAS to POTWs based on the
monitoring results.
EPA recommends that the following array of NPDES and pretreatment provisions and monitoring
programs be implemented by authorized states and POTWs, as appropriate, to the fullest extent available
under state and local law. NPDES and pretreatment provisions may be included when issuing a permit
or by modifying an existing permit pursuant to 40 CFR 122.62.
A. Recommendations for Applicable Industrial Direct DischarP-ers
1. Applicability: Industry categories known or suspected to discharge PFAS as identified on page 14
of the PFAS Strategic Roadmap include: organic chemicals, plastics & synthetic fibers (OCPSF);
metal finishing; electroplating; electric and electronic components; landfills; pulp, paper &
paperboard; leather tanning & finishing; plastics molding & forming; textile mills; paint formulating,
and airports. This is not an exhaustive list and additional industries may also discharge PFAS. For
example, Centralized Waste Treatment (CWT) facilities may receive wastes from the
aforementioned industries and should be considered for monitoring. There may also be categories of
dischargers that do not meet the applicability criteria of any existing ELG; for instance, remediation
sites, chemical manufacturing not covered by OCPSF, and military bases.
EPA notes that no permit may be issued to the owner or operator of a facility unless the owner or
operator submits a complete permit application in accordance with applicable regulations, and
applicants must provide any additional information that the permitting authority may reasonably
require to assess the discharges of the facility (40 CFR 122.21(e), (g)(13)).2 The applicant may be
required to submit additional information under CWA Section 308 or under a similar provision of
state law.
2. Effluent -and wastewater residuals monitoring: In the absence of a final 40 CFR Part 136 method,
EPA recommends using CWA wastewater draft analytical method 1633 (see 40 CFR
122.21(e)(3)(ii) and 40 CFR 122.44(i)(1)(iv)(B)). EPA also recommends that monitoring include
each of the 40 PFAS parameters detectable by draft method 1633 and be conducted at least quarterly
to ensure that there are adequate data to assess the presence and concentration of PFAS in
discharges. All PFAS monitoring data must be reported on Discharge Monitoring Reports (DMRs)
(see 40 CFR 122.41(1)(4)(i)). The draft Adsorbable Organic Fluorine CWA wastewater method 1621
can be used in conjunction with draft method 1633, if appropriate. Certain industrial processes may
generate PFAS-contaminated solid waste or air emissions not covered by NPDES permitting and
permitting agencies should coordinate with appropriate state authorities on proper containment and
disposal to avoid cross -media contamination. EPA's draft analytical method 1633 may be
appropriate to assess the amount and types of PFAS for some of these wastestreams.3
'For more, see NPDES Permit Writer's Manual Section 4.5.1.
s See https://www.epa.gov/water-research/pfas-analytical-methods-development-and-sampling-research for a list of EPA -
approved methods for other media.

3. Best Management Practices (BMPs) for discharges of PFAS, including product substitution,
reduction, or elimination of PFAS, as detected by draft method 1633: Pursuant to 40 CFR
122.44(k)(4), EPA recommends that NPDES permits for facilities incorporate the following
conditions when the practices are "reasonably necessary to achieve effluent limitations and standards
or to carry out the purposes and intent of the CWA: i4
a. BMP conditions based on pollution prevention/source reduction opportunities, which may
include:
i. Product elimination or substitution when a reasonable alternative to using PFAS is available
in the industrial process.
ii. Accidental discharge minimization by optimizing operations and good housekeeping
practices.
iii. Equipment decontamination or replacement (such as in metal finishing facilities) where
HAS products have historically been used to prevent discharge of legacy PFAS following
the implementation of product substitution.
b. Example BMP permit special condition language:
i. PFAS pollution prevention/source reduction evaluation: Within 6 months of the effective
date of the permit, the facility shall provide an evaluation of whether the facility uses or has
historically used any products containing PFAS, whether use of those products or legacy
contamination reasonably can be reduced or eliminated, and a plan to implement those steps.
ii. Reduction or Elimination: Within 12 months of the effective date of the permit, the facility
shall implement the plan in accordance with the PFAS pollution prevention/source reduction
evaluation.
iii. Annual Report: An annual status report shall be developed which includes a list of potential
PFAS sources, summary of actions taken to reduce or eliminate PFAS, any applicable source
monitoring results, any applicable effluent results for the previous year, and any relevant
adjustments to the plan, based on the findings.
iv. Reporting: When EPA's electronic reporting tool for DMRs (called "NetDMW) allows for the
permittee to submit the pollution prevention/source reduction evaluation and the annual
report, the example permit language can read, "The pollution prevention/source reduction
evaluation and annual report shall be submitted to EPA via EPA's electronic reporting tool
for DMRs (called "NetDMR" ).
4. BMPs to address PFAS-containing firefighting foams for stmrmwater permits: Pursuant to
122.44(k)(2), where appropriate, EPA recommends that NPDES stormwater permits include BMPs
to address Aqueous Film Forming Foam (AFFF) used for firefighting, such as the following:5
a. Prohibiting the use of AFFFs other than for actual firefighting.
b. Eliminating PFOS and PFOA -containing AFFFs.
c. Requiring immediate clean-up in all situations where AFFFs have been used, including
diversions and other measures that prevent discharges via storm sewer systems.
5. Permit Limits: As specified in 40 CFR 125.3, technology -based treatment requirements under
CWA Section 301(b) represent the minimum level of control that must be imposed in NPDES
permits. Site -specific technology -based effluent limits (TBELs) for PFAS discharges developed on a
best professional judgment (BPJ) basis may be appropriate for facilities for which there are no
applicable effluent guidelines (see 40 CFR 122.44(a), 125.3). Also, NPDES permits must include
water quality -based effluent limits (WQBELs) as derived from state water quality standards, in
4 For more on BMPs, see NPDES Permit Writer's Manual Section 9.1 and EPA Guidance Manual for Developing Best
Management Practices.
s Naval Air Station Whidbey Island MS4 permit incorporates these provisions.

addition to TBELs developed on a BPJ basis, if necessary to achieve water quality standards,
including state narrative criteria for water quality (CWA Section 301(b)(1)(C); 40 CFR 122.22(d)).
If a state has established a numeric criterion or a numeric translation of an existing narrative water
quality standard for PFAS parameters, the permit writer should apply that numeric criterion or
narrative interpretation in permitting decisions, pursuant to 40 CFR 122.44(d)(1)(iii) and
122.44(d)(1)(vi)(A), respectively.
B. Recommendations for Publicly Owned Treatment Works
1. Applicability: All POTWs, including POTWs that do not receive industrial discharges, and
industrial users (IUs) in the industrial categories above.
2. Effluent, influent, and biosolids monitoring: In the absence of a final 40 CFR Part 136 method,
EPA recommends using CWA wastewater draft analytical method 1633 (see 40 CFR
122.21(e)(3)(ii) and 40 CFR 122.44(i)(1)(iv)(B)). EPA also recommends that monitoring include
each of the 40 PFAS parameters detectable by draft method 1633 and be conducted at least quarterly
to ensure that there are adequate data to assess the presence and concentration of PFAS in
discharges. All PFAS monitoring data must be reported on DMRs (see 40 CFR 122.41(1)(4)(i)). The
draft Adsorbable Organic Fluorine CWA wastewater method 1621 can be used in conjunction with
draft method 1633, if appropriate.
3. Pretreatment program activities:
a. Update IU Inventory: Permits to POTWs should contain requirements to identify and locate all
possible IUs that might be subject to the pretreatment program and identify the character and
volume of pollutants contributed to the POTW by the IUs (see 40 CFR 403.8(f)(2)). As EPA
regulations require, this information shall be provided to the pretreatment control authority (see
40 CFR 122.440) and 40 CFR 403.8(f)(6)) within one year. The IU inventory should be revised,
as necessary, to include all Ns in industry categories expected or suspected of PFAS discharges
listed above (see 40 CFR 403.12(i)).6
b. Utilize BMPs and pollution prevention to address PFAS discharges to POTWs. EPA
recommends that POTWs:
i. Update IU permits/control mechanisms to require quarterly monitoring. These IUs should be
input into the Integrated Compliance Information System (ICIS) with appropriate linkage to
their respective receiving POTWs. POTWs and states may also use their available authorities
to conduct quarterly monitoring of the IUs (see 40 CFR 403.8(f)(2), 403.10(e) and (f)(2)).
ii. Where authority exists, develop IU BMPs or local limits. 40 CFR 403.5(c)(4) authorizes
POTWs to develop local limits in the form of BMPs. Such BMPs could be like those for
industrial direct discharges described in A.3 above.
iii. In the absence of local limits and POTW legal authority to issue IU control mechanisms, state
pretreatment coordinators are encouraged to work with the POTWs to encourage pollution
prevention, product substitution, and good housekeeping practices to make meaningful
reductions in HAS introduced to POTWs.
e ELG categories of airport deicing, landfills, textile mills, and plastics molding and forming do not have categorical
pretreatment standards, and therefore small -volume indirect dischargers in those categories would not ordinarily be
considered Significant Industrial Users (SIUs) and may not be captured on an existing IU inventory, IUs under the Paint
Formulating category are only subject to Pretreatment Standards for New Sources (PSNS), and existing sources may need to
be inventoried.

C. Recommended Biosolids Assessment
1. Where appropriate, states may work with their POTWs to reduce the amount of PFAS
chemicals in biosolids, in addition to the NPDES recommendations in Section B above,
following these general steps:7
a. EPA recommends using draft method 1633 to analyze biosolids at POTWs for the presence of 40
PFAS chemicals.8
b. Where monitoring and IU inventory per section B.2 and B.3.a above indicate the presence of
PFAS in biosolids from industrial sources, EPA recommends actions in B.3.b to reduce PFAS
discharges from IUs.
c. EPA recommends validating PFAS reductions with regular monitoring of biosolids. States may
also use their available authorities to conduct quarterly monitoring of the POTWs (see 40 CFR
403.10(t)(2)).
D. Recommended Public Notice for Draft Permits with PFAS-Specific Conditions
1. In addition to the requirements for public notice described in 40 CFR 124.10, EPA
recommends that NPDES permitting authorities provide notification to potentially affected
downstream public water systems (PWS) of draft permits with PFAS-specific monitoring,
BMPs, or other conditions:
a. Public notice of the draft permit would be provided to potentially affected PWS with intakes
located downstream of the NPDES discharge.
b. NPDES permit writers are encouraged to collaborate with their drinking water program
counterparts to determine on a site -specific basis which PWS to notify.
i. EPA's Drinking Water Mapping Application to Protect Source Waters (DWMAPS) tool may
be helpful as a screening tool to identify potentially affected PWS to notify.
c. EPA will provide instructions on how to search for facility -specific discharge monitoring data
in EPA's publicly available search tools.
7 EPA is currently evaluating the potential risk of PFOA and PFOS in biosolids and supporting studies and activities to
evaluate the presence of PFOA and PFOS in biosolids. This recommendation is not meant to supersede the PFOA and PFOS
risk assessment or supporting activities. The conclusions of the risk assessment and supporting studies may indicate that
regulatory actions or more stringent requirements are necessary to protect human health and the environment.
8 While water quality monitoring activities (including monitoring of PFAS associated with NPDES permit or pretreatment
requirements) at POTWs are generally not eligible for Clean Water State Revolving Fund (CWSRF), monitoring for the
specific purpose of project development (planning, design, and construction) is eligible. Monitoring in this capacity, and
within a reasonable timeframe, can be integral to the identification of the best solutions (through an alternatives analysis) for
addressing emerging contaminants and characterizing discharge and point of disposal (e.g., land application of biosolids).
Though ideally the planning and monitoring for project development would result in a CWSRF-eligible capital project, in
some instances, the planning could lead to outcomes other than capital projects to address the emerging contaminants.

ATTACHMENT 3

Facility Name: I Arclin NPDES #: I NC0000892
Stream Classification:
WS-Iv
Outfall 001 Effluent Grab (ng/L) - treated process and domestic wastewater
CAS Number
Analyte Name
Acronym
3/24/2020
Lab Qualifier(s)
4/23/2020
Lab Qualifier(s)
5/22/2020
Lab Qualifier(s)
335-67-1
Perfluorooctanoic acid
PFOA
11
13
7.2
1763-23-1
Perfluorooctanesulfonic acid
PFOS
13
15
4.7
375-22-4
Perfluorobutanoic acid
PFBA
12
21
18
375-73-5
Perfluorobutanesulfonic acid
PFBS
5.9
7.3
8.1
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (< 3.7)
ND
U (< 3.5)
ND
U (< 3.8)
335-76-2
Perfluorodecanoic acid
PFDA
ND
U (< 3.7)
ND
U (< 3.5)
ND
U (< 3.8)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (< 3.7)
ND
U (< 3.5)
ND
U (< 3.8)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (< 3.7)
ND
U (< 3.5)
ND
U (< 3.8)
375-85-9
Perfluoroheptanoic acid
PFHpA
15
22
15
355-46-4
Perfluorohexanesulfonic acid
PFHxS
5
5.2
ND
U (< 3.8)
307-24-4
Perfluorohexanoic acid
PFHxA
27
39
37
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (< 7.3)
ND
U (< 7.1)
ND
U (< 7.5)
375-95-1
Perfluorononanoic acid
PFNA
ND
U (< 3.7)
ND
U (< 3.5)
ND
U (< 3.8)
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (< 7.3)
ND
U (< 7.1)
ND
U (< 7.5)
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (< 7.3)
ND
U (< 7.1)
ND
U (< 7.5)
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-McFOSAA
ND
U (< 7.3)
ND
U (< 7.1)
ND
U (< 7.5)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
ND
U (< 3.7)
ND
U (< 3.5)
ND
U (< 3.8)
2706-90-3
Perfluoropentanoic acid
PFPeA
23
31
33
376-06-7
Perfluorotetradecanoic acid
PFTeA
ND
U (< 7.3)
ND
U (< 7.1)
ND
U (< 7.5)
72629-94-8
Perfluorotridecanoic acid
PFTriA
ND
U (< 3.7)
ND
U (< 3.5)
ND
U (< 3.8)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
U (< 3.7)
ND
U (< 3.5)
ND
U (< 3.8)
39108-34-4
11-11 1H, 2H, 21-1-perfluorodecane sulfonic acid
8:2 FTS
ND
U (< 7.3)
ND
U (< 7.1)
ND
U (< 7.5)
27619-97-2
1H, 1H, 2H, 21-1-perfluorooctane sulfonic acid
6:2 FTS
ND
U (< 7.3)
ND
U (< 7.1)
ND
U (< 7.5)
757124-72-4
1H,1H,2H,2H-perfluorohexane sulfonic acid
4:2 FTS
ND
U (< 7.3)
ND
U (< 7.1)
ND
U (< 7.5)
31506-32-8
N-methylperfluoro-l-octanesulfonamide
McFOSA
ND
U (< 15.0)
ND
U (< 15.0)
ND
U (< 15.0)
Sum of PFOA and PFOS
24
28
11.9
Total
111.9
153.5
123
Outfall 001 Effluent Grab (ug/L) - treated process and domestic wastewater
3/24/2020 Lab Qualifier(s) 4/23/2020 Lab Qualifier(s) 5/22/2020 Lab Qualifier(s)
1. 4 - Dioxane I ND U (< 2.0) ND U (< 2.0) ND U (< 2.0)
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
J - The reported value is an estimate. The value is less than the Reporting Limit.
Note: The facility used Modified EPA Method 537 to analyze PFAS compounds. DWR requested the facility monitor for both 1,4-dioxane and PFAS. All requested data has been received.
DWR will require that this facility perform additional effluent testing for PFAS compounds.

Facility Name:
Stream Classification:
Invista NPDES #: NC0001112
C,Sw Outfall 002 Effluent Grab (ng/L) -treated process wastewater, domestic wastewater, tank wash water, well purge
water, stormwater and groundwater purge
CAS Number Analyte Name Acronym 3/18/2020 Lab Qualifier(s) 4/14/2020 Lab Qualifier(s) 5/21/2020 Lab Qualifier(s)
335-67-1
Perfluorooctanoic acid
PFOA
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
1763-23-1
Perfluorooutanesulfonic acid
PFOS
ND
U (<8.0)
7.5
1
ND
U (< 7.7)
375-22-4
Perfluorobutanoic acid
PFBA
ND
U < 16.0)
ND
U < 17.0
ND
U (< 15.0)
375-73-5
Perfluorobutanesulfonic acid
PFBS
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
335-76-2
Perfluorodecanoic acid
PFDA
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
375-85-9
Perfluoroheptanoic acid
PFHpA
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
355-46-4
Perfluorohexanesulfonic acid
PFHxS
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
307-24-4
Perfluorohexanoic acid
PFHxA
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
375-95-1
Perfluorononanoic acid
PFNA
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<8.0)
ND
U (<7.7)
ND
U (< 7.7)
2991-50-6
2-(N-Ethyl perfluorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (< 16.0)
ND
U (< 15.0)
ND
U (< 15.0)
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-McFOSAA
ND
U (< 16.0)
ND
U (< 15.0)
ND
U (< 15.0)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
2706-90-3
Perfluoropentanoic acid
PFPeA
ND
U (<8.0)
3.9
1
ND
U (< 7.7)
376-06-7
Perfluorotetradecanoic acid
PFTeA
ND
U (<40.0)
ND
U (<8.3)
ND
U (< 7.7)
72629-94-8
Perfluorotridecanoic acid
PFTriA
ND
U (<40.0)
ND
U (<8.3)
ND
U (< 7.7)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
U (<8.0)
ND
U (<8.3)
ND
U (< 7.7)
Sum of PFOA and PFOS
0
7.5
0
Total
0
11.4
0
Outfall 002 Effluent Grab (ug/L) -treated process wastewater, domestic wastewater, tank wash water, well purge
5/7/2019 1 Lab Qualifier(s) 1 8/6/2019 i Lab Qualifier(s) 11/12/2019 Lab Qua
1, 4 - Dioxane 114 1 1 ND I U (<50) 104
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
1 -The reported value is an estimate. The value is less than the Reporting Limit.
Note: The facility used Modified EPA Method 537 to analyze PFAS compounds. DWR requested the facility monitor for both 1,4-dioxane and PFAS. All requested data has been received for Outfall 002.
The facility has begun sampling at Outfall 001.

Facility Name:
Stream Classification:
Invista
C,Sw
NPDES #: I N00001112
Influent Grab (ng/L) - River Water Intake
CAS Number
Analyte Name
Acronym
3/18/2020
Lab Qualifier(s)
4/14/2020
5.4
Lab Qualifier(s)
5/21/2020
Lab Qualifier(s)
335-67-1
Perfluorooctanoic acid
PFOA
3.9
1
1
5.8
1
1763-23-1
Perfluorooctanesulfonic acid
PFOS
8.5
12.6
12
375-22-4
Perfluorobutanoic acid
PFBA
ND
U (< 16.0)
4.6
1
5.4
1
375-73-5
Perfluorobutanesulfonic acid
PFBS
2.5
1
3.4
1
4.3
1
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
335-76-2
Perfluorodecanoic acid
PFDA
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
375-85-9
Perfluoroheptanoic acid
PFHpA
2.7
1
5.6
1
5.5
1
355-46-4
Perfluorohexanesulfonic acid
PFHxS
3.2
1
3.7
1
3.3
1
307-24-4
Perfluorohexanoic acid
PFHxA
4.2
1
7.6
1
9.3
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
375-95-1
Perfluorononanoic acid
PFNA
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<8.0)
ND
U (<7.7)
ND
U (<7.7)
2991-50-6
2-(N-Ethyl perfluorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (< 16.0)
ND
U (< 15.0)
ND
U (< 15.0)
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-McFOSAA
ND
U (< 16.0)
ND
U (< 15.0)
ND
U (< 15.0)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
2706-90-3
Perfluoropentanoic acid
PFPeA
5.9
1
9.1
8.7
376-06-7
Perfluorotetradecanoic acid
PFTeA
ND
U (<40.0)
ND
U (<8.3)
ND
U (<7.7)
72629-94-8
Perfluorotridecanoic acid
PFTriA
ND
U (<40.0)
ND
U (<8.3)
ND
U (<7.7)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
U (70)
ND
U (<8.3)
ND
U (<7.7)
Sum of PFOA and PFOS
12.4
18
17.8
Total
30.9
52
54.3
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
1 -The reported value is an estimate. The value is less than the Reporting Limit.
Note: The facility used Modified EPA Method 537 to analyze PFAS compounds. DWR requested the facility monitor for both 1,4-dioxane and PFAS. All requested data has been received for Outfall 002.
The facility has begun sampling at Outfall 001.

Facility Name:
Stream Classification:
Invista
C,Sw
NPDES #: NCO001112
Influent Grab (ng/L) - Well Water Intake
CAS Number
Analyte Name
Acronym
3/18/2020
Lab Qualifier(s)
4/14/2020
2.7
Lab Qualifier(s)
5/21/2020
Lab Qualifier(s)
335-67-1
Perfluorooecanoic acid
PFOA
2.7
1
1
3.3
1
1763-23-1
Perfluorooutanesulfonic acid
PFOS
4
1
6.3
1
6.7
1
375-22-4
Perfluorobutanoic acid
PFBA
ND
U (< 16.0)
ND
U (< 17.0)
3.9
1
375-73-5
Perfluorobutanesulfonic acid
PFBS
ND
U (<8.0)
ND
U (<8.3)
2.3
1
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
335-76-2
Perfluorodecanoic acid
PFDA
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
375-85-9
Perfluoroheptanoic acid
PFHpA
ND
U (<8.0)
2.5
1
2.9
1
355-46-4
Perfluorohexanesulfonic acid
PFHxS
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
307-24-4
Perfluorohexanoic acid
PFHxA
2.7
1
3.2
1
4.1
1
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
375-95-1
Perfluorononanoic acid
PFNA
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<8.0)
ND
U (<7.7)
ND
U (<7.7)
2991-50-6
2-(N-Ethyl perfluorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (< 16.0)
ND
U (< 15.0)
ND
U (< 15.0)
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-McFOSAA
ND
U (< 16.0)
ND
U (< 15.0)
ND
U (< 15.0)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
2706-90-3
Perfluoropentanoic acid
PFPeA
4.1
1
4.7
1
4.7
1
376-06-7
Perfluorotetradecanoic acid
PFTeA
ND
U (<40.0)
ND
U (<8.3)
ND
U (<7.7)
72629-94-8
Perfluorotridecanoic acid
PFTriA
ND
U (<40.0)
ND
U (<8.3)
ND
U (<7.7)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
U (<8.0)
ND
U (<8.3)
ND
U (<7.7)
Sum of PFOA and PFOS
6.7
9
10
Total
13.5
19.4
27.9
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
J - The reported value is an estimate. The value is less than the Reporting Limit.
Note: The facility used Modified EPA Method 537 to analyze PFAS compounds. DWR requested the facility monitor for both 1,4-dioxane and PFAS. All requested data has been received for Outfall 002.
The facility has begun sampling at Outfall 001.

Facility Name: GNF-A Wilmington Plant NPDES M
Stream Classification: C,Sw
1, 4 - Dioxane
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
Facility Name: GNF-A Wilmington Plant NPDES #:
Stream Classification: C,Sw
1, 4 - Dioxane
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
Note: DWR requested the facility monitor for 1,4-dioxane. All requested data has been received.
NC0001228
Outfall 001 Effluent Grab (ug/L) - treated pi
t/2019 Lab Qualifier(s) 110/24/20191 Lab Qualifier(s) 1 11/5/2
ND U (<200) 1 15 1 1 15
ess wastewater
9 Lab Qualifier(s) I ######## b Qualifi
ND I U (<2.0
NC001228
Outfall 002 Effluent Grab (ug/L) - treated domestic wastewater
0/20191 Lab Qualifier(s) 110/31/20191 Lab Qualifier(s) 111/13/20191 Lab Qualifier(s) I ######## b Qualifi
ND I U (<200) 1 ND I U (<1.0) I ND I U (<1.0) I ND I U (<1.0

Facility Name: Burlington Technologies jNPDES #: NC0001384
Stream Classification: WS-II, HQW, NSW I Effluent Grab (ug/L)
ENTER SAMPLE DATE I Lab Qualifier(s) I ENTER SAMPLE DATE I Lab Qualifier(s) I ENTER SAMPLE DATE I Lab Qualifier(s)
1, 4 - Dioxane I Ceased discharge in December 2019 after ownership change; monitoring waived until discharge commences.
Note: DWR requested the facility monitor for 1,4-dioxane. As the facility ceased discharge in December 2019 upon change in ownership, investigative monitoring has been waived until
continuation of discharge.

Facility Name:
Stream Classification:
Moncure Holdings
WS-Iv
NPDES #: NC0001899
Outfall 001 Effluent Grab (ng/L) - treated process, domestic, and filter backwash wastewater
CAS Number
Analyte Name
Acronym 11/20/2019
Lab Qualifier(s)
1/27/2020
Lab Qualifier(s) 2/13/2020
Lab Qualifier(s)
335-67-1
Perfluorooctanoic acid
PFOA
9.3
_
7.3
6
_ 7.4
5.9
8.7
1763-23-1
Perfluorooctanesulfonic acid
PFOS
8.2
375-22-4
Perfluorobutanoic acid
PFBA
11
9.5
375-73-5
Perfluorobutanesulfonic acid
PFBS
1.9
J
ND
U (<4.4)
ND
U (<3.8)
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<1.0)
ND
U (<4.4)
ND
U (<3.8)
335-76-2
Perfluorodecanoic acid
PFDA
2.8
J
ND
U (<4.4)
ND
U (<3.8)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<1.0)
ND
U (<4.4)
ND
U (<3.8)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (<1.0)
ND
U (<4.4)
ND
U (<3.8)
375-85-9
Perfluoroheptanoic acid
PFHpA
5.9
4.8
5.3
355-46-4
Perfluorohexanesulfonic acid
PFHxS 3.2
J
ND
U (<4.4)
ND
U (<3.8)
307-24-4
Perfluorohexanoic acid
PFHxA
15
11
11
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<2.1)
ND
U (<8.7)
ND
U (<7.6)
375-95-1
Perfluorononanoic acid
PFNA
2.4
J
ND
U (<4.4)
ND
U (<3.8)
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<2.0)
ND
U (<8.7)
ND
U (<7.6)
2991-50-6
2-(N- Ethyl perfIuorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (<2.0)
ND
U (<8.7)
ND
U (<7.6)
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-McFOSAA
ND
U (<2.0)
ND
U (<8.7)
ND
U (<7.6)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
ND
U (<1.0)
ND
U (<4.4)
ND
U (<3.8)
2706-90-3
Perfluoropentanoic acid
PFPeA
16
15
14
376-06-7
Perfluorotetradecanoic acid
PFTeA
ND
U (<2.0)
ND
U (<8.7)
ND
U (<7.6)
72629-94-8
Perfluorotrdecanoic acid
PFTriA
ND
U (<1.0)
ND
U (<4.4)
ND
U (<3.8)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
U (<1.0)
ND
U (<4.4)
ND
U (<3.8)
39108-34-4
1H, 1H, 2H, 2H-perfluorodecane sulfonic acid
8:2 FTS
ND
U (<8.7)
ND
U (<7.6)
27619-97-2
1H, 1H, 2H, 2H-perfluorooctane sulfonic acid
6:2 FTS
ND
U (<8.7)
ND
U (<7.6)
U (<7.6)
757124-72-4
1H,1H,2H,2H-perfluorohexane sulfonic acid
4:2 FTS
17.5
ND
U (<8.7)
ND
ND
13.3
31506-32-8
N-methylperfluoro-l-octanesulfonamide
McFOSA
_
ND
13.3
U (<17)
U (<15)
Sum of PFOA and PFOS
Total
75.7
53.6
52.3
Outfall 001 Effluent Grab (ug/L) - treated process, domestic, and filter backwash wastewater
191 Lab Qualifier(s) 11/21/20201 Lab Qualifier(s) 1 2/7/2020 1 Lab Qualifie
1, 4 - Dioxane 1 1 1.5
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
J - The reported value is an estimate. The value is less than the Reporting Limit.
Note: DWR requested the facility monitor for both 1,4-dioxane and PFAS. All requested data has been received.
ND I U (<2.0)
0NJ
U (<2.0)

Facility Name: Lear Corporation NPDE$ #:
Stream Classification: C,Sw
NC0002305
Outfall 001 Effluent Grab (ng/L) - treated process wastewater and sanitary wastewater
CAS Number
Analyte Name
Acronym
23-Ott-19 Lab Qualifier(s) 27-Nov-19 Lab Qualifier(s) 11-Dec-19 Lab Qualifier(s)
30.2 15.9 20.4
29.4 23.6 28.8
335-67-1
Perfluorooctanoic acid
PFOA
1763-23-1
Perfluorooctanesulfonic acid
PFOS
375-22-4
Perfluorobutanoic acid
PFBA
135
54.2
ND
U (<1.39)
375-73-5
Perfluorobutanesulfonic acid
PFBS
ND
U (<1.23)
ND
U (<1.23)
ND
U (<1.39)
335-77-3
Perfluorodecanesulfonic acid
PFDS ND
U (<1.23)
ND
U (<1.23)
ND
U (<1.39)
335-76-2
Perfluorodecanoic acid
PFDA 3.16
2.38
2.29
307-55-1
Perfluorododecanoic acid
PFDoA ND
U (<1.23)
ND
U (<1.23)
ND
U (<1.39)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS ND
U (<1.23)
ND
U (<1.23)
ND
U (<1.39)
375-85-9
Perfluoroheptanoic acid
PFHpA 308
158
367
355-46-4
Perfluorohexanesulfonic acid
PFHxS ND
U (<1.23)
1.68
ND
U (<1.39)
307-24-4
Perfluorohexanoic acid
PFHxA 417
132
214
68259-12-1
Perfluorononanesulfonic acid
PFNS ND
U (<1.226)
ND
U (<1.230)
ND
U (<1.39)
375-95-1
Perfluorononanoic acid
PFNA 2.76
2.94
5.35
754-91-6
Perfluorooctanesulfonamide
PFOSA 1.38
N-EtFOSAA 0.225
ND
U (<1.23)
ND
U (<1.39)
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
J
ND
U (<1.23)
ND
U (<1.39)
2355-31-9
2-(N-Methyl perfIuorooctanesulfonamido) acetic acid
N-McFOSAA
3.84
2.52
ND
U (<1.39)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
ND
U (<1.23)
ND
U (<1.23)
ND
U (<1.39)
2706-90-3
Perfluoropentanoic acid
PFPeA 933
409
457
376-06-7
Perfluorotetradecanoic acid
PFTeA ND
U (<1.23)
ND
U (<1.23)
ND
U (<1.39)
72629-94-8
Perfluorotridecanoic acid
PFTriA ND
PFUnA ND
59.6
U (<1.23)
ND
U (<1.23)
ND
U (<1.39)
2058-94-8
Perfluoroundecanoic acid
U (<1.23)
ND
U (<1.23)
ND
49.2
U (<1.39)
Sum of PFOA and PFOS
39.5
Total
1863.965
802.22
1094.84
10/23/2019
1, 4 - Dioxane 14.4
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
J - The reported value is an estimate. The value is less than the Reporting Limit.
Outfall 001 Effluent Grab (ug/L) - treated process wastewater and sanitary wastewater
Lab Qualifier(s) 11/13/2019 Lab Qualifier(s) 12/11/2019
12 29
Note: DWR requested the facility monitor for PFAS compounds. All requested data has been received. DWR will require that this facility perform additional effluent testing for PFAS compounds.
Lab Qualifier(s)

Facility Name:
Stream Classification:
International Paper - Riegelwood I NPDES M NC0003298 I
C, Sw
Outfall 001 Effluent Grab (ng/L) -treated process wastewater and stormwater
CAS Number
Analyte Name
Acronym
10/28/2019
Lab Qualifier(s)
11/20/2019
Lab Qualifier(s)
12/17/2019
Lab Qualifier(s)
335-67-1
Perfluorooctanoic acid
PFOA
21
32
23
1763-23-1
Perfluorooctanesulfonic acid
PFOS
43
23
19
375-22-4
Perfluorobutanoic acid
PFBA
8.4
16
8.7
375-73-5
Perfluorobutanesulfonic acid
PFBS
6.2
4.4
5.2
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<4.5)
ND
U (<4.4)
ND
U (<4.2)
335-76-2
Perfluorodecanoic acid
PFDA
2.6
J
ND
U (<4.8)
ND
U (<4.8)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U(<4.8)
ND
U (<4.8)
ND
U (<4.8)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
0.92
J
0.78
J
ND
U (<4.2)
375-85-9
Perfluoroheptanoic acid
PFHpA
23
26
25
355-46-4
Perfluorohexanesulfonic acid
PFHxS
6.4
7.2
59
307-24-4
Perfluorohexanoic acid
PFHxA
39
42
34
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<4.5)
ND
U (<4.4)
ND
U (<4.2)
375-95-1
Perfluorononanoic acid
PFNA
3.6
J
2.1
J
1.7
J
754-91-6
Perfluorooctanesulfonamide
PFOSA
1.1
J
ND
U (<4.4)
1.2
J
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
N-EtFOSAA
29
24
38
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-McFOSAA
1.2
J
ND
U (<4.4)
ND
U (<4.2)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
2.6
J
ND
U (<4.5)
ND
U (<4.5)
2706-90-3
Perfluoropentanoic acid
PFPeA
35
56
40
376-06-7
Perfluorotetradecanoic acid
PFTeA
3.7
J
4
J
ND
U (<4.8)
72629-94-8
Perfluorotridecanoic acid
PFTriA
ND
U (<4.8)
2.9
J
ND
U (<4.8)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
U (<4.8)
ND
U (<4.8)
ND
U (<4.8)
Sum of PFOA and PFOS
64
55
42
Total
226.72
240.38
254.8
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
J - The reported value is an estimate. The value is less than the Reporting Limit.
Note: DWR requested the facility monitor for PFAS compounds. All requested data has been received.

Facility Name:
Stream Classification:
Chemours
WS-Iv
NPDES #: F NC0003573
Outfall 002 Effluent (ug/L) - treated process wastewater, boiler condensate blowdown, non -contact river and
filtered water, and stormwater
CAS Number
Analyte Name
Acronym
October
Lab Qualifier(s)/Notes
November Avg.
Lab Qualifier(s)/Notes
December Avg. Lab Qualifier(s)/Notes
335-67-1
Perfluorooctanoic acid
PFOA
ND
U (<40) +
U (<37) +
11.4
+*
+*
+*
16.2
+*
+*
1763-23-1
Perfluorooctanesulfonic acid
PFOS
ND
12.1
133.1
11.8
13252-13-6
Hexafluoropropylene oxide dimer acid
HFPO-DA / GenX
95
+
187.1
+*
674-13-5
Perfluoro-2-methoxy acetic acid
PFMOAA
1002.11
*
113.98
+*
35.1
+*
Sum of PFOA and PFOS
0
23.5
28
Total
1097.11
270.58
250.2
Lab Qualifiers/Notes
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
+= DWR data
* = average value of 9 samples
Facility Name:
Stream Classification:
Chemours
WS-Iv
NPDES #:
NC0003573
Water Intake Grab (ug/L)
10/7/2019
Lab Qualifier(s)
11/11/2019
Lab Qualifiers)
12/9/2019
Lab Qualifier(s)
1, 4 - Dioxane
7.94
2.51
1.09
Facility Name:
Chemours
NPDES #:
NC0003573
Outfall 002 Effluent Grab (ug/L) - treated process wastewater, boiler condensate blowdown, non -contact river and filtered
Stream Classification:
WS-IV
water, and stormwater
110/7/20191 Lab Qualifier(s)
1 11/11/2019 Lab Qualifier(s)
12/9/2019 Lab Qualifier(s)
1, 4 - Dioxane
1 8.43 1
1 2.44
ND U (<1.0)
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
Note: DWR requested the facility monitor for 1,4-dioxane since the industry has already been sampling and reporting HAS data. Note that the HAS data shown here was collected by DWR. To
see all DWR collected PFAS data, view the "Download Sampling Results Spreadsheet" here.

Facility Name:
Stream Classification:
DAK Americas- Cedar Creek
C
NPDES #:
NC0003719
Outfall 002 Effluent Grab (ng/L) - treated process wastewater
CAS Number
Analyte Name
Acronym
10/23/2019
Lab Qualifier(s)
11/7/2019
Lab Qualifier(s)
12/5/2019
Lab Qualifier(s)
335-67-1
Perfluorooctanoic acid
PFOA
12.3
17.7
14.2
1763-23-1
Perfluorooctanesulfonic acid
PFOS
5.6
6.91
5.82
31.8
375-22-4
Perfluorobutanoic acid
PFBA
151
42.6
375-73-5
Perfluorobutanesulfonic acid
PFBS
12.3
13.4
10.5
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<1.69)
ND
U (<1.68)
ND
U (<1.71)
335-76-2
Perfluorodecanoic acid
PFDA
0.781
J
1.11
J
ND
U (<1.76)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<.1.74)
ND
U (<8.64)
ND
U (<1.76)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (<1.66)
ND
U (<1.64)
ND
U (<1.67)
375-85-9
Perfluoroheptanoic acid
PFHpA
19.3
28
17.1
355-46-4
Perfluorohexanesulfonic acid
PFHxS
7.22
9.07
10.6
307-24-4
Perfluorohexanoic acid
PFHxA
51.9
59.6
50.1
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<1.67)
ND
U (<1.66)
ND
U (<1.69)
375-95-1
Perfluorononanoic acid
PFNA
2.55
2.43
2.79
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<1.62)
ND
U (<1.73)
ND
U (<1.76)
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (<3.48)
ND
U (<3.46)
ND
U (<3.52)
2355-31-9
2-(N-Methyl perfIuorooctanesuIfonamido) acetic acid
N-McFOSAA
ND
U (<3.48)
ND
U (<3.46)
ND
U (<3.52)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
1.4
J
1.17
J
1.08
J
2706-90-3
Perfluoropentanoic acid
PFPeA
41.7
38.4
33.6
376-06-7
Perfluorotetradecanoic acid
PFTeA
ND
U (<8.71)
ND
U (<8.64)
ND
U (<8.8)
72629-94-8
Perfluorotridecanoic acid
PFTriA
ND
U (<1.74)
0.575
J
ND
U (<1.76)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
17.9
U (<1.74)
0.597
J
ND
U (<1.76)
Sum of PFOA and PFOS
24.61
20.02
Total
1 306.051
221.562
177.59
Outfall 002 Effluent Grab (ug/L) - treated process wastewater
91 Lab Qualifier(s) 11/7/20191 Lab Qualifier(s) 12/5/20191 Lab Qualifie
1, 4- Dioxane 1 1 3180 1 1 1030
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
J - The reported value is an estimate. The value is less than the Reporting Limit.
Note: DWR requested the facility monitor for both 1,4-dioxane and PFAS. All requested data has been received. DWR will require that this facility perform additional
effluent testing for 1,4 dioxane.
1470

Facility Name: Corning Inc. NPDES #: NC0003794
Stream Classification: C,Sw Outfall 001 Effluent Grab (ug/L) - non -contact cooling water, air -conditioner condensate, air -compressor cooling water
10/10/20191 Lab Qualifier(s) 110/31/20191 Lab Qualifier(s) 111/13/20191 Lab Qualifier(s) 112/5/20191 Lab Qualifier(s)
1, 4 - Dioxane ND I U (<200) 1 ND I U (<1.0) I ND I U (<1.0) I ND I U (<1.0)
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
Facility Name: Corning Inc. NPDES M NC0003794
Stream Classification: C,Sw Outfall 002 Effluent Grab (ug/L) - cooling -tower blowdown, air -conditioner condensate, stormwater, roof/yard drainage
10/10/20191 Lab Qualifier(s) 110/31/20191 Lab Qualifier(s) 111/13/20191 Lab Qualifier(s) 12/5/2019 Lab Qualifier(s)
1, 4 - Dioxane ND I U (<200) 1 ND I U (<1.0) I ND I U (<1.0) I ND U (<1.0)
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
Note: DWR requested the facility monitor for 1,4-dioxane. All requested data has been received.

Facility Name: Elementis Chromium NPDES #: NC0003875
Stream Classification: B,Sw,PNA Outfall 001 Effluent Grab (ug/L)
12/23/2019 Lab Qualifier(s) 11/7/20201 Lab Qualifier(s) 11/29/20201 Lab Qualifier(s)
1, 4 - Dioxane ND U (< 2.0) 1 ND I U (< 2.0) 1 ND I U (< 2.0)
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
Note: DWR requested the facility monitor for 1,4-dioxane. All requested data has been received.

Facility Name: Archer Daniels Midland NPDES #: NC0027065
Stream Classification: SC I Outfall 001 Effluent Grab (ug/L) - treated process wastewater, contaminated non -process
10/22/20191 Lab Qualifier(s) 12/24/2019 Lab Qualifier(s) 11/23/20201 Lab Qualifier(s)
1, 4 - Dioxane ND I U (<2.0) ND I U (<2.0) 1 ND I U (<2.0)
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
Note: DWR requested the facility monitor for 1,4-dioxane. All requested data has been received.

Brenntag Mid -South - Greensboro
Facility Name: Groundwater Remediation Site NPDE$ #:
Stream Classification: WS-IV,NSW
NC0078000
Outfall 001 Effluent Grab (ug/L) - treated, remediated groundwater
Lab Qualifier(s) 14/21/20201 Lab Qualifier(s) 15/19/20201 Lab Qualifier(s)
1 1, 4- Dioxane 1 1 8.2 1 1 9 1 1 8.3 1 1
Note: DWR requested the facility monitor for 1,4-dioxane. All requested data has been received. DWR will require that this facility perform additional
effluent testing for 1,4 dioxane.

Facility Name: Smithfield Tar Heel Plant NPDES #:
Stream Classification: C
NCO078344
Outfall 001 Effluent Grab (ng/L) - treated process wastewater
CAS Number
Analyte Name
Acronym
10/14/2019
Lab Qualifier(s) 11/13/2019
Lab Qualifier(s)
12/11/2019
Lab Qualifier(s)
335-67-1
Perfluorooctanoic acid
PFOA
ND
U (<5.8) 13
U (<5.8) ND
ND
U (<11)
U (<11)
1763-23-1
Perfluorooctanesulfonic acid
PFOS
ND
U (<8.5)
ND
375-22-4
Perfluorobutanoic acid
PFBA
18
33
39
375-73-5
Perfluorobutanesulfonic acid
PFBS
ND
U (<5.8)
ND
U (<8.5)
ND
U (<11)
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<5.8)
ND
U (<8.5)
ND
U (<11)
335-76-2
Perfluorodecanoic acid
PFDA
ND
U (<5.8)
ND
U (<8.5)
ND
U (<11)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<5.8)
ND
U (<8.5)
ND
U (<11)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (<5.8)
ND
U (<8.5)
ND
U (<11)
375-85-9
Perfluoroheptanoic acid
PFHpA
9.1
15
16
355-46-4
Perfluorohexanesulfonic acid
PFHxS
ND
U (<5.8)
ND
U (<8.5)
ND
U (<11)
307-24-4
Perfluorohexanoic acid
PFHxA
15
26
30
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<12)
ND
U (<17)
ND
U (<21)
375-95-1
Perfluorononanoic acid
PFNA
ND
U (<5.8)
ND
U (<8.5)
ND
U (<11)
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<12)
ND
U (<17)
ND
U (<21)
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
N-EtFOSAA ND
U (<12)
ND
U (<17)
ND
U (<21)
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-McFOSAA ND
PFPeS ND
U (<12)
ND
U (<17)
ND
U (<21)
2706-91-4
Perfluoropentanesulfonic acid
U (<5.8)
ND
U (<8.5)
ND
U (<11)
2706-90-3
Perfluoropentanoic acid
PFPeA
20
31
38
376-06-7
Perfluorotetradecanoic acid
PFTeA
ND
U (<12)
ND
U (<17)
ND
U (<21)
72629-94-8
Perfluorotridecanoic acid
PFTriA
ND
U (<5.8)
ND
U (<8.5)
ND
U (<11)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
U (<5.8)
ND
U (<8.5)
ND
U (<11)
13252-13-6
Hexafluoropropylene oxide dimer acid
GenX
30
54
41
39108-34-4
1H, 1H, 2H, 2H-perfluorodecane sulfonic acid
8:2 FTS
ND
U (<12)
ND
U (<17)
ND
U (<21)
27619-97-2
11-1, 11-1, 21-1, 21-1-perfluorooctane sulfonic acid
6:2 FTS
ND
U (<12)
ND
U (<17)
ND
U (<21)
120226-60-0
1H,1H,2H,2H-perfluorododecane sulfonic acid
10:2 FTS
ND
U (<12)
ND
U (<17)
ND
U (<21)
757124-72-4
1H,1H,2H,2H-perfluorohexane sulfonic acid
4:2 FTS
ND
U (<12)
ND
U (<17)
ND
U (<21)
4151-50-2
N-ethylperfluoro-l-octanesulfonamide
EtFOSA
ND
U (<12)
ND
U (<17)
ND
U (<21)
31506-32-8
N-methylperfluoro-l-octanesulfonamide
McFOSA
ND
U (<23)
ND
U (<34)
ND
U (<43)
Sum of PFOA and PFOS
0
13
0
Total
92.1
172
164
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
Note: DWR requested the facility monitor for PFAS compounds. All requested data has been received.

Facility Name:
Stream Classification:
IFortron Industries
C,Sw
NPDES #: NCO082295 I
Influent Grab (ng/L)
CAS Number
Analyte Name
Acronym 10/25/2019
Lab Qualifier(s)
11/18/2019
Lab Qualifier(s)
12/11/2019
Lab Qualifier(s)
335-67-1
Perfluorooctanoic acid
PFOA 4.35
2.29
4.77
1763-23-1
Perfluorooctanesulfonic acid
PFOS
7.24
3.25
6.85
375-22-4
Perfluorobutanoic acid
PFBA
9.61
ND
U (<1.3)
ND
U (<1.28)
375-73-5
Perfluorobutanesulfonic acid
PFBS
ND
U (<1.23)
ND
U (<1.3)
ND
U (<1.28)
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<1.23)
ND
U (<1.3)
ND
U (<1.28)
335-76-2
Perfluorodecanoic acid
PFDA
0.345
J
ND
U (<1.3)
0.142
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<1.23)
ND
U (<1.3)
ND
U (<1.28)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
0.229
J
0.092
J
ND
U (<1.28)
375-85-9
Perfluoroheptanoic acid
PFHpA
12.9
3.17
12.3
355-46-4
Perfluorohexanesulfonic acid
PFHxS
2.17
2.95
307-24-4
Perfluorohexanoic acid
PFHxA
21.8
5.83
22.8
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<1.23)
ND
U (<1.299)
ND
U (<1.28)
375-95-1
Perfluorononanoic acid
PFNA
0.44
J
0.143
J
0.592
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<1.23)
ND
U (<1.3)
ND
U (<1.28)
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (<1.23)
ND
U (<1.3)
ND
U (<1.28)
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-McFOSAA
ND
U (<1.23)
ND
U (<1.3)
ND
U (<1.28)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
0.693
J
ND
U (<1.3)
ND
U (<1.28)
2706-90-3
Perfluoropentanoic acid
PFPeA
22
ND
U (<1.3)
ND
U (<1.28)
376-06-7
Perfluorotetradecanoic acid
PFTeA
ND
U (<1.23)
ND
U (<1.3)
ND
U (<1.28)
72629-94-8
Perfluorotridecanoic acid
PFTriA
ND
U (<1.23)
ND
U (<1.3)
ND
U (<1.28)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
11.59
U (<1.23)
ND
U (<1.3)
ND
11.62
U (<1.28)
Sum of PFOA and PFOS
5.54
Total
79.61
16.95
50.404
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
J - The reported value is an estimate. The value is less than the Reporting Limit.

Facility Name: I Fortron Industries JNPDES #: NCO082295
Stream Classification: C,Sw Outfall 001 Effluent Grab (ng/L) - treated process water, sanitary wastewater, cooling
tower blowdown and stormwater
CAS Number
Analyte Name
Acronym 10/25/2019
Lab Qualifier(s)
11/18/20191 Lab Qualifier(s)
12/11/2019
Lab Qualifier(s)
335-67-1
Perfluorooctanoic acid
PFOA 2.92
1.2 J
0.687 J
2.29
1763-23-1
Perfluorooctanesulfonic acid
PFOS
1.12
J
0.791
J
375-22-4
Perfluorobutanoic acid
PFBA
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
375-73-5
Perfluorobutanesulfonic acid
PFBS
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
335-76-2
Perfluorodecanoic acid
PFDA
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
375-85-9
Perfluoroheptanoic acid
PFHpA
9.05
1.79
7.26
355-46-4
Perfluorohexanesulfonic acid
PFHxS
1.15
J
1.85
307-24-4
Perfluorohexanoic acid
PFHxA
14.3
3.92
15.5
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.215)
375-95-1
Perfluorononanoic acid
PFNA
0.106
J
0.062
J
0.0816
J
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
2355-31-9
2-(N-Methyl perfIuorooctanesulfonamido) acetic acid
N-McFOSAA
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
2706-90-3
Perfluoropentanoic acid
PFPeA
15.3
ND
U (<1.22)
12.8
376-06-7
Perfluorotetradecanoic acid
PFTeA
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
72629-94-8
Perfluorotridecanoic acid
PFTriA
ND
U (<1.21)
ND
U (<1.22)
ND
U (<1.22)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
4.04
U (<1.21)
ND
U (<1.22)
ND
3.1
U (<1.22)
Sum of PFOA and PFOS
1.9
Total
1 42.80
8.81
40.57
Outfall 001 Effluent Grab (ug/L) - treated process water, sanitary wastewater, cooling tower
10/29/20191 Lab Qualifier(s) 111/18/20191 Lab Qualifier(s) 112/16/20191 Lab Qualifier(s)
1, 4- Dioxane I I ND I U(<2.0) 1 ND I U(<1.0) I ND I U(<1.0
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
J - The reported value is an estimate. The value is less than the Reporting Limit.
Note: DWR requested the facility monitor for both 1,4-dioxane and PFAS. All requested data has been received. Note: The industrial surface water intake showed similar levels
for PFAS compounds as the discharge.

Daikin Applied Americas
Groundwater Remediation
Facility Name: Site NPDES #:
Stream Classification: C,Sw
1, 4 - Dioxane
NC0083658
undwater
10/15/20191 Lab Qualifier(s) i 11/2/2019 1 Lab Qualifier(s) 1 12/3/2019 j Lab Qualifier(s)
22.4
Outfall 001 Effluent Grab (u
Note: DWR requested the facility monitor for 1,4-dioxane. All requested data has been received.
33.9
- treated, remediated
35.4

Brenntag Mid -South - Durham
Facility Name' Groundwater Remediation Site NPDES #'
Stream Classification: WS-V,NSW
1, 4 - Dioxane
NC0086827
Outfall 001 Effluent Grab (ug/L) - treated, remediated groundwater
1/20201 Lab Qualifier(s) 14/21/20201 Lab Qualifie
27 1 1 ND I U (<1.0)
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
3.9
Note: DWR requested the facility monitor for 1,4-dioxane. All requested data has been received. DWR will require that this facility perform additional
effluent testing for 1,4 dioxane.
Lab Qua

NCDOT Asphalt Testing Site #6
Facility Name: Groundwater Remediation Site NPDES #:
Stream Classification: WS-IV,NSW
NC0087629
Effluent Grab (ug/L)
ENTER SAMPLE DATE I Lab Qualifier(s) I ENTER SAMPLE DATE I Lab Qualifier(s) I ENTER SAMPLE DATE I Lab Qualifier(s)
1, 4 - Dioxane I I No discharge since 2017; monitoring waived until discharge commences.
Note: DWR requested the facility monitor for 1,4-dioxane. As the facility has had no discharge since 2017, investigative monitoring has been waived until continuation of discharge.

Dow Silicones Corporation
Groundwater Remediation
Facility Name: Site NPDES #:
Stream Classification: WS-V,NSW
1, 4 - Dioxane
NCO088773
Effluent Grab (ug/L)
ENTER SAMPLE DATE I Lab Qualifier(s) I ENTER SAMPLE DATE I Lab Qualifier(s) I ENTER SAMPLE DATE I Lab Qualifier(s
No discharge since 2017; monitoring waived until discharge commences.
Note: DWR requested the facility monitor for 1,4-dioxane. As the facility has had no discharge since 2017, investigative monitoring has been waived until continuation of discharge.

PPD Groundwater Remediation
Facility Name: Site NPDES #: Ncoosssll
Stream Classification: SC,Sw i Outfall 001 Effluent Grab (ug/L) - treated, remediated groundwater
10/2/2019 Lab Qualifier(s) 11/5/2019 1 Lab Qualifier(s) 12/3/2019 Lab Qualifier(s)
1, 4 - Dioxane ND U (<2.0) i ND _j U (<2.0) ND U (<2.0)
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
U - Analyte was analyzed for, but not detected above the minimum detection level.
Note: DWR requested the facility monitor for 1,4-dioxane. All requested data has been received.

ATTACHMENT 4

EPA
United States
Environmental Protection
Agency
Effluent Guidelines
Program Plan 15
January 2023

THIS PAGE INTENTIONALLY LEFT BLANK

U.S. Environmental Protection Agency
Office of Water (4303T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
EPA-821-R-22-004

THIS PAGE INTENTIONALLY LEFT BLANK

Contents
TABLE OF CONTENTS
Page
1. EXECUTIVE SUMMARY................................................................................................................ 1-1
2. BACKGROUND............................................................................................................................. 2-1
2.1 The Clean Water Act and the Effluent Guidelines Program ................................................ 2-1
2.2 Effluent Limitations Guidelines and Pretreatment Standards Overview .............................. 2-1
2.3 Effluent Guidelines Review and Planning Process............................................................. 2-3
3. SUMMARY OF PUBLIC COMMENTS RECEIVED ON PRELIMINARY EFFLUENT GUIDELINES
PROGRAMPLAN 15............................................................................................................................. 3-1
4. SUMMARY OF ANNUAL REVIEW ACTIVITIES............................................................................... 4-1
5. REVIEWS OF INDUSTRIAL WASTEWATER DISCHARGES AND TREATMENT TECHNOLOGIES........ 5-1
5.1
DMR Pollutant Load Rankings Analysis............................................................................ 5-1
5.1.1 Data, Methodology, and Analysis Considerations ............................................. 5-1
5.1.2 Data Quality Review and Corrections............................................................... 5-2
5.1.3 Results of the DMR Pollutant Load Rankings Analysis .................................... 5-3
5.2
Leather Tanning and Finishing Point Source Category (40 CFR part 425) ......................... 5-6
5.3
Paint Formulating Point Source Category (40 CFR part 446)............................................. 5-7
5.4
Plastics Molding and Forming Point Source Category (40 CFR part 463) ........................
5-10
5.5
Industrial Wastewater Treatment Technologies Reviews .................................................
5-12
5.6
ELG Planning Tools........................................................................................................
5-12
5.6.1 Industrial Wastewater Treatment Technology Database ..................................
5-12
5.6.2 Effluent Limitations Guidelines and Standards Database ................................
5-13
5.7
Environmental Justice......................................................................................................
5-13
6. ONGOING ELG STUDIES............................................................................................................. 6-1
6.1 Electrical and Electronic Components Point Source Category (40 CFR part 469) .............. 6-1
6.2 Concentrated Animal Feeding Operations Point Source Category (40 CFR part 412)......... 6-2
6.3 PFAS Industrial Sources and Discharge Studies................................................................. 6-3
6.3.1 Airports............................................................................................................6-4
6.3.2 Textile Mills Point Source Category (40 CFR part 410).................................... 6-7
6.3.3 Landfills Point Source Category (40 CFR part 445)........................................ 6-12
6.3.4 Pulp, Paper and Paperboard Point Source Category (40 CFR part 430)........... 6-13
6.3.5 POTW Influent PFAS Study.......................................................................... 6-19
7. ONGOING ELG RULEMAKINGS................................................................................................... 7-1
7.1 Steam Electric Power Generating Point Source Category (40 CFR part 423)...................... 7-1
7.2 Meat and Poultry Products Point Source Category (40 CFR part 432)................................ 7-1
7.3 Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category: PFAS
Manufacturers and Formulators (40 CFR part 414)............................................................ 7-3
7.4 Metal Finishing (40 CFR part 433) and Electroplating (40 CFR part 413) Point Source
Categories......................................................................................................................... 7-3
8. REFERENCES FOR PLAN 15.......................................................................................................... 8-1
it

List of Appendices, Tables & Figures
LIST OF APPENDICES
Appendix A —Response to Remand of ELG Plan 14 in Food and Water Watch V. EPA (No. 21-
71084 9th Cir.)
LIST OF TABLES
Page
Table 2-1. Statutorily Prescribed Levels of Control............................................................................. 2-2
Table 3-1. Summary of Public Comments Received on Preliminary Plan 15....................................... 3-2
Table 5-1. 2021 Annual Review Discharge Ranking Results............................................................... 5-3
Table 6-1. System Type and Airport Count......................................................................................... 6-5
Table 6-2. Textile Mills Effluent PFAS Concentrations..................................................................... 6-10
Table 6-3. Pulp, Paper, and Paperboard Effluent PFAS Concentrations ............................................. 6-17
LIST OF FIGURES
Page
Figure 6-1. DOD and FAA Schedule for Replacing AFFF.................................................................. 6-6
iii

]—Executive Summary
1. EXECUTIVE SUMMARY
Under the Clean Water Act (CWA), EPA publishes Effluent Limitations Guidelines and Standards
(ELGs), which are national industry -specific wastewater regulations based on the performance of
demonstrated wastewater treatment technologies (i.e., "technology -based limitations"). The effluent
limitations guidelines apply to discharges from industrial facilities to water bodies (referred to as "direct
discharges"). Pretreatment standards apply to discharges from industrial facilities to publicly owned
treatment works (POTWs) (referred to as "indirect discharges"). CWA Section 304(m) contains
provisions requiring EPA to annually review the guidelines and standards and revise them if appropriate.
The CWA also requires EPA to biennially publish a plan that establishes a schedule for annual reviews,
revisions, and promulgation of any guidelines not previously established for industrial categories. This
Effluent Guidelines Program Plan 15 (Plan 15) fulfills these CWA requirements and thus furthers the
national work toward restoring and maintaining the chemical, physical, and biological integrity of the
nation's waters.
Through its Effluent Guidelines Program Plans, EPA seeks to provide transparent decision -making with
the benefit of stakeholder input throughout the planning process. EPA published and requested public
comments on Preliminary Effluent Guidelines Program Plan 15 (Preliminary Plan 15) on September 14,
2021 (86 FR 51155). Plan 15 provides a summary of the comments received on Preliminary Plan 15 as
well as updates on EPA's reviews of industrial wastewater discharges and treatment technologies. Plan
15 also presents EPA's 2021 annual review of effluent guidelines and pretreatment standards, including
the initial results from its preliminary review of the Plastics Molding and Forming (40 CFR part 463),
Leather Tanning (40 CFR part 425), and Paint Formulating (40 CFR part 446) Categories. With this
Plan 15, EPA continues to focus on and evaluate the extent and nature of per- and polyfluoroalkyl
substances (PFAS) discharges and assess opportunities for limiting those discharges from multiple
industrial categories, as outlined in EPA's 2021 PFAS Strategic Roadmap.
Plan 15 announces that EPA, pending resource availability, intends to initiate one new rulemaking and
several new studies. After collecting and analyzing data, as described throughout this Plan, EPA has
determined that revisions to the effluent limitations guidelines and pretreatment standards for the
Landfills Category (40 CFR part 445) are warranted, considering PFAS found in landfill leachate. EPA
also intends to expand the detailed study of the Textile Mills Category (40 CFR part 410) to gather
information on the use and treatment of PFAS in this industry and associated PFAS discharges. For this
expanded study, EPA intends to use a mandatory questionnaire issued to a nationally representative
sample of textile mills. Plan 15 also announces EPA's intent to initiate a POTW Influent Study of PFAS,
which will focus on collecting nationwide data on industrial discharges of PFAS to POTWs, including
categories recently reviewed. EPA intends to undertake this study to both verify sources of PFAS
wastewater and to discover new PFAS wastewater sources. Finally, Plan 15 announces EPA's intent to
undertake a detailed study of the Concentrated Animal Feeding Operations (CAFOs) Category (40 CFR
part 412), which will focus on collecting further information to enable the Agency to make an informed,
reasoned decision whether to undertake rulemaking to revise the ELG for CAFOs.
Plan 15 also announces that EPA is not pursuing further action for the Electrical and Electronic
Components (E&EC) Category (40 CFR part 469) at this time but will continue monitoring this category
for PFAS discharge data through the POTW Influent Study. EPA will also continue to monitor PFAS
use and discharges from the Pulp, Paper, and Paperboard Category (40 CFR part 430) and airports.
1-1

]—Executive Summary
Finally, Plan 15 provides updates of four ongoing rulemakings:
• Steam Electric Power Generating Category rulemaking (see Section 7.1 for additional
details) to strengthen certain wastewater pollution discharge limitations for coal power plants
that use steam to generate electricity.
• Meat and Poultry Products Category rulemaking to address nutrient discharges (see Section
7.2 for additional details).
• Organic Chemicals, Plastics & Synthetic Fibers Category rulemaking to address PFAS
discharges (see Section 7.3 for additional details).
• Metal Finishing Category and Electroplating Category rulemakings to address PFAS
discharges (see Section 7.4 for additional details).
The Agency intends to undertake the actions outlined in this Plan and summarized above. The
commencement and pace of these activities will depend on the agency's Fiscal Year 2023 appropriations
and operating plan.
1-2

2-Background
2. BACKGROUND
This section explains how the Effluent Guidelines Program fits into EPA's National Water Program,
provides an overview of the Effluent Guidelines Program, and summarizes EPA's procedures for
revising and developing ELGs (i.e., the effluent guidelines planning process).
2.1 The Clean Water Act and the Effluent Guidelines Program
The CWA focuses on two types of controls for point source discharges of pollutants to waters of the
United States: (1) technology -based controls, based on ELGs or, in the absence of applicable ELGs, best
professional judgement (BPJ) of permit writers, and (2) water -quality -based controls, based on
applicable water quality standards.
The CWA directs EPA to promulgate technology -based ELGs that reflect pollutant reductions
achievable by facilities in categories or subcategories of industrial point sources through implementation
of available treatment technologies.' ELGs apply to pollutants discharged from industrial facilities to
surface water (direct discharges) and to publicly owned treatment works (POTWs) (indirect discharges).
EPA's technology -based standards ensure that industrial facilities with similar characteristics will, at a
minimum, meet similar effluent limitations or pretreatment standards that represent the performance of
the "best" pollution control technologies, regardless of their location or the nature of the receiving water
or POTW into which they discharge.
The CWA also gives states the primary responsibility for establishing, reviewing, and revising water
quality standards. Effluent guidelines are not specifically designed to ensure that regulated discharges
meet the water quality standards of the receiving water body. For this reason, although technology -based
ELGs in discharge permits may be as stringent as or even more stringent than necessary to meet water
quality standards, where this is not the case, the CWA requires EPA and authorized states to establish
water -quality -based effluent limitations as stringent as necessary to meet water quality standards.2 Thus,
water -quality -based limitations may require industrial facilities to meet standards that are more stringent
than those in the ELGs.
To date, EPA has promulgated ELGs for 59 industrial categories. See EPA's Industrial Effluent
Guidelines webpage for more information.3 These ELGs apply to between 35,000 and 45,000 U.S.
direct dischargers, as well as to another 129,000 facilities that discharge to POTWs. Based on pollutant
reduction estimates from each ELG, EPA estimates that the regulations altogether prevent the discharge
of over 700 billion pounds of pollutants annually.4
2.2 Effluent Limitations Guidelines and Pretreatment Standards Overview
EPA promulgates ELGs that include technology -based limitations for conventional, toxic, and
nonconventional pollutants in accordance with six statutorily prescribed levels of control (Table 2-1).
i See 33 U.S.C. 1311(b) and 1314(b).
2 See 33 U.S.C. 1311(b)(1)(C).
s See https://www.epa.gov/eg/industrial-effluent-guidelines.
4 Based on the difference between discharges from each point source category before ELG promulgation and the estimated
(lower) volume of discharges from each point source category after promulgation (from review of ELG development
documents).
2-1

2-Background
The limitations are based on the performance of specific technologies, but the regulations do not require
a specific control technology to achieve the limitations. For more information, see EPA's Learn about
Effluent Guidelines webpage.5
The CWA specifies different levels of control based on the type of pollutant (i.e., conventional, toxic, or
nonconventional). CWA Section 304(a)(4) designates the following as conventional pollutants:
biochemical oxygen demand (BOD5), total suspended solids, fecal coliform, pH, and any additional
pollutants defined by the Administrator as conventional. The Administrator designated oil and grease as
an additional conventional pollutant on July 30, 1979.E At the direction of Congress, EPA has identified
65 pollutants and classes of pollutants as toxic, among which EPA has designated 126 specific
substances as priority toxic pollutants. All other pollutants are considered nonconventional.
Table 2-1. Statutorily Prescribed Levels of Control
Level of
CWA Statutory
Description
Control
Reference
CWA Sections
EPA develops effluent limitations based on BPT for conventional, toxic, and
Best Practicable
301(b)(1)(A) and
nonconventional pollutants. EPA establishes BPT effluent limitations based on the
Control
304(b)(1), 33
average of the best performance of facilities within an industry of various ages,
Technology
U.S.C.
sizes, processes, or other common characteristics. Where existing performance is
(BPT)
13 11 (b)(1)(A) and
uniformly inadequate, BPT may reflect higher levels of control than currently in
1314(b)(1)
place in an industrial category if the agency determines that the technology can be
practically applied.
Best
Conventional
CWA Sections
301(b)(2)(E) and
BCT addresses conventional pollutants from existing industrial point sources. EPA
Pollutant
304(b)(4), 33
establishes BCT limitations by considering the factors specified in
"cost
Control
U.S.C.
Section 304(b)(4)(B), including a two-part -reasonableness" test. This
Technology
13 11 (b)(2)(E) and
methodology was published in a Federal Register notice on July 9, 1986 (51 FR
(BCT)
1314(b)(4)
24974).
EPA develops effluent limitations based on BAT for toxic and nonconventional
pollutants. BAT represents the best available economically achievable performance
Best Available
CWA Sections
of plants in an industrial subcategory or category. Factors considered in establishing
Technology
301(b)(2)(A) and
BAT include the age of equipment and facilities involved, the process employed, the
Economically
304(b)(2), 33
engineering aspects of control techniques or process changes, the cost of achieving
Achievable
U.S.C.
such effluent reduction, non -water -quality environmental impacts (including energy
(BAT)
13 11 (b)(2)(A) and
requirements), and such other factors as the Administrator deems appropriate
1314(b)(2)
(33 U.S.C. 1314(b)(2)(B)). BAT limitations may be based on end -of -pipe
wastewater treatment or effluent reductions attainable through changes in a facility's
processes and operations.
EPA develops effluent limitations based on NSPS for conventional, toxic, and
Standards of
nonconventional pollutants. NSPS reflect effluent reductions based on the best
Performance for
CWA Section 306,
available demonstrated control technology (33 U.S.C. 1316(a)(1)). In establishing or
New Sources
33 U.S.C. 1316
revising NSPS, EPA considers the cost of achieving such effluent reduction and any
(NSPS)
non -water -quality, environmental impact, and energy requirements (33 U.S.C.
1316(b)(1)(B)).
s See https://www.epa.gov/eg/learn-about-effluent-guidelines.
6 44 FR 44501.
Appendix A to part 423, reprinted after 40 CFR part 423.17.
2-2

2-Background
Table 2-1. Statutorily Prescribed Levels of Control
Level of
Control
CWA Statutory
Reference
Description
EPA develops PSES for nonconventional and toxic pollutants. PSES are national,
Pretreatment
CWA Section
uniform, technology -based standards that apply to indirect dischargers. They are
Standards for
307(b), 33 U.S.C.
designed to prevent the discharge of pollutants that pass through, interfere with, or
Existing
1317(b)
are otherwise incompatible with the operation of POTWs (33 U.S.C. 1317(b)(1)).
Sources (PSES)
EPA considers the same factors for PSES as it does for BAT limitations (33 U.S.C.
1314(b)(2)(B)).
EPA develops PSNS for nonconventional and toxic pollutants. PSNS are national,
Pretreatment
uniform, technology -based standards that apply to new indirect dischargers. Like
Standards for
CWA Section
PSES, they are designed to prevent the discharges of pollutants that pass through,
New Sources
307(c), 33 U.S.C.
interfere with, or are otherwise incompatible with the operation of POTWs. PSNS
(PSNS)
1317(c)
are issued at the same time as NSPS (33 U.S.C. 1317(c)). EPA considers the same
factors in promulgating PSNS as it considers in promulgating NSPS (33 U.S.C.
1316(a)(1)).
EPA and states implement ELGs for point sources that discharge pollutants into surface waters through
National Pollutant Discharge Elimination System (NPDES) permits.$ POTWs, states, and EPA enforce
pretreatment standards for point sources that discharge to POTWs.9
2.3 Effluent Guidelines Review and Planning Process
The CWA contains multiple provisions requiring EPA to review and revise the limitations, standards,
and guidelines that apply to new and existing industrial facilities for both direct and indirect dischargers.
For existing direct dischargers, i.e., those that discharge into waters of the United States, the CWA
requires EPA to review effluent limitations "at least every five years and, if appropriate, revise" those
limitations.10 The CWA also requires EPA to publish regulations providing guidelines for effluent
limitations "and, at least annually thereafter, revise, if appropriate, such regulations."11 Historically,
EPA has combined rulemakings for effluent limitations and guidelines into a single rulemaking and
referred to the resulting rule as an "ELG." Similarly, EPA consolidates its review of effluent limitations
required under Section 301(d) and its review of effluent limitations guidelines under Section 304(b) into
an annual review of the 59 promulgated ELGs.12
8 See CWA Sections 301(a), 301(b), and 402; 33 U.S.C. 1311(a), 131l(b), and 1342.
9 See CWA Sections 307(b) and 307(c); 33 U.S.C. 1317(b) and 1317(c).
10 See CWA Section 301(d); 33 U.S.C. 1311(d).
ii See CWA Section 304(b); 33 U.S.C. 1314(b). See also Our Children's Earth v. EPA, 527 F.3d 842, 848-49 (9" Cir. 2008)
("Sections 304(b) and (m) require an annual review of "guidelines for effluent limitations" applicable to direct dischargers
and revision "if appropriate").
12 See Our Children's Earth v. EPA, 527 F.3d 842, 849 (9" Cir. 2008) (discussing EPA's processes of combining the reviews
required under Sections 301(d) and 304(b)).
2-3

2-Background
For indirect dischargers, i.e., those that discharge to POTWs, the CWA requires EPA "from time to
time" to publish proposed regulations establishing pretreatment standards.13 The CWA also requires
EPA to "review at least annually ... and, if appropriate, revise guidelines for pretreatment." 14
For new sources, both direct and indirect, the CWA requires EPA to "publish (and from time to time
thereafter, revise) a list of categories of sources, which shall, at the minimum, include ..." and "propose
and publish regulations establishing Federal standards of performance for new sources within such
category."15 The CWA further provides that, "[t]he Administrator shall, from time to time, as
technology and alternatives change, revise such standards following the procedure required by this
subsection for promulgation of such standards."16
In the 1987 Amendments to the CWA, Congress added a provision that requires EPA to biennially
publish in the Federal Register a "plan" that "establish[es] a schedule for the annual review and revision
of promulgated effluent guidelines," identifies certain categories of sources for which ELGs have not
previously been published, and establishes a schedule for promulgating ELGs for certain categories of
sources for which such guidelines have not previously been published.17 The biennial planning
requirement was enacted after the CWA provisions regarding review and revision of effluent limitations
and ELGs and informs EPA's obligations under those provisions. When read together, these provisions
require EPA to annually review ELGs and revise those guidelines, if appropriate, and to biennially
publish a plan as described above.
While the CWA requires EPA to annually "review" effluent limitations guidelines and pretreatment
standards,18 it does not require EPA to make a "yes" or "no" determination every year on whether to
revise the guidelines and standards. See Effluent Guidelines Program Plan 14 (Plan 14, U.S. EPA,
2021a) Section 2.3 for further discussion of EPA's annual obligations. Further, where EPA initiates
rulemaking revising ELGs, the CWA confers discretion on EPA as to the timing for that rulemaking
(U.S. EPA, 2022o).
To increase transparency and stakeholder awareness, EPA's biennial plans include information on its
review of existing ELGs and pretreatment standards, as well as industries reviewed for potential
development of new ELGs or pretreatment standards.
Plan 15 describes ongoing planning activities, including projects EPA initiated as part of its 2021 annual
review and details EPA's effluent guidelines planning efforts, including preliminary category reviews,
category studies, and ELG rulemakings. For additional details, see EPA's 2021 Annual Review of
Industrial Wastewater Discharges (U.S., EPA, 2022a) and 2021 Preliminary Review of Industrial Point
Source Categories (U.S. EPA, 2022b).
13 See CWA Section 307(b); 33 U.S.C. 1317(b).
14 See CWA Section 304(g); 33 U.S.C. 1314(g).
15 See CWA Section 306(b)(1); 33 U.S.C. 1316(b)(1).
16 See CWA Section 306(b)(1)(B); 33 U.S.C. 1316(b)(1)(B).
17 See CWA Section 304(m); 33 U.S.C. 1314(m).
18 See CWA Sections 304(b), 304(m)(1)(A), and 304(g); 33 U.S.C. 1314(b), 1314(m)(1)(A), 1314(g).
2-4

3—Summary of Preliminary Plan 15 Public Comments
3. SUMMARY OF PUBLIC COMMENTS RECEIVED ON PRELIMINARY EFFLUENT GUIDELINES
PROGRAM PLAN 15
On September 14, 2021, EPA published Preliminary Plan 15 for a 30-day public comment period (86 FR
51155). EPA received over 34,000 public comment letters on Preliminary Plan 15, the majority of which
were submitted as part of four different mass -mail campaigns that supported the agency's review of and
actions on PFAS and the meat and poultry industry. Apart from the mass -mail campaigns, EPA received
67 public comments.
EPA received comments on most of the topics presented in Preliminary Plan 15. Table 3-1 includes a
summary of the major comments discussed in the public submissions and is generally organized by
topic. See EPA's Response to Comments for the Effluent Guidelines Program Plan 15 for all comment
responses (U.S. EPA, 2022c).
3-1

3—Summary of Preliminary Plan 15 Public Comments
Table 3-1. Summary of Public Comments Received on Preliminary Plan 15
Topic
Summary
Commenter Types
(Count by Type)
ELG Planning
• EPA should prioritize the ELG program and reconsider its approach for reviewing and revising ELGs.
Env. Organization (6)
• EPA needs to annually review industrial discharges and revise ELGs to meet the goals of the CWA. Despite progress
Federal Agency (1)
made by the agency, less than half of waterways assessed for impairments have been determined to be safe and clean.
Industry Trade Assoc. (5)
• Over two thirds of the industrial regulations are 30 years old. EPA has not applied upgrades in treatment technologies to
State Govt. (1)
lower limits for the categories after many were originally established in the 1970s and 1980s. EPA should streamline its
approaches by applying data and knowledge collected about current technologies when considering wastewater
treatment upgrades (or issues) common among multiple industries (e.g., nutrients).
• EPA should manage pollutants at the source, reducing burdens on POTWs that receive industrial discharges.
• EPA ELG planning tools should be more transparent. In its analyses, EPA should consider toxicity of contaminants in
its rankings analyses in addition to reviewing EPA's Contaminant Candidate List (CCL).
• ELG planning should consider innovative approaches for complying with NPDES requirements and further advancing
the goals of the CWA.
• EPA should establish the strongest possible standards to protect waters, which are essential to communities (e.g.,
drinking water and business development).
• Commenters generally agree with the limitations outlined by EPA on the 2020 cross -category concentration analysis,
though one commenter noted that evaluating loads is also flawed because it does not consider permit limits or water
quality at the industry level.
• EPA should annually review and publish summaries of industry technology updates, characterization data, and
clarifications on applicability to help with implementation of ELGs, specifically older regulations.
• Commenters support the use of membrane technologies, both economical and versatile, in combination with
chemical/physical treatment and/or biological treatment.
Environmental
• EPA should consider multiple environmental justice indicators in its annual reviews and look beyond EJScreen, as that
Env. Organization (8)
Justice
tool does not provide a risk analysis and does not consider multiple environmental indicators at one time. EPA should
Federal Agency (1)
consider the following in its proposed analyses: expanding the geographic proximity from wastewater discharge point,
Industry Trade Assoc. (2)
considering cumulative impacts (both environmental and from multiple dischargers in an area), measuring impaired
Private Citizen (2)
water bodies, evaluating compliance within a geographic location, evaluating water bodies for downstream impacts,
State Govt. (1)
assessing impacts of fish consumption advisories on tribal and low-income communities, and considering impacts on
Indigenous communities and sacred lands and waters.
• EPA's proposed environmental justice methodology may not capture all environmental justice and inequity
considerations.
• EPA should consider environmental justice in the planning process and in regulation development.
• Commenters stated specific environmental justice concerns with refineries, facilities discharging PFAS, fertilizer
manufacturing facilities, slaughterhouses, and CAFOs.
• EPA should consider prioritizing industries that are not currently regulated and are located in communities with
environmental justice concerns.
3-2

3—Summary of Preliminary Plan 15 Public Comments
Table 3-1. Summary of Public Comments Received on Preliminary Plan 15
Topic
Summary
Commenter Types
(Count by Type)
PFAS —
• Commenters stated PFAS are extremely persistent in the environment and the human body, and many have been
Env. Organization (7)
General
linked at very low doses to serious health harms.
Federal Agency (3)
• Recent action by EPA falls short of what is needed to sufficiently address industrial discharges of PFAS both in terms
Industry (4)
of scope and urgency. Commenters urged EPA to curb industrial releases of the toxic "forever chemicals" known as
Industry Trade Assoc. (4)
PFAS.
Private Citizen (6)
• EPA should promulgate PFAS ELGs and pretreatment standards for multiple industry sectors at once and include all
State Govt. (1)
those that contribute to PFAS discharges.
• EPA should set deadlines for the development of new standards to address industrial discharges of PFAS.
• Commenters support the U.S. House of Representative's bipartisan legislation that requires EPA to set PFAS standards
for nine industry categories within four years.
• EPA should finalize a PFAS Road Map that shifts responsibility for PFAS discharges to polluters. EPA is encouraged
to: require the disclosure of PFAS and use of technology to control discharges, set a PFAS drinking water standard,
quickly set nationwide standards to restrict industrial releases of PFAS, designate PFAS as hazardous substances, end
needless uses of PFAS, and ensure that PFAS wastes are properly disposed.
• Commenters support EPA actions in issuing a regulatory determination under the Safe Drinking Water Act for
perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), proposing to expand monitoring of PFAS in
drinking water, developing new analytical methods, providing more funding for local communities, restoring scientific
integrity to EPA's review of PFAS, taking steps to close PFAS loopholes, and demanding more data from polluters.
• Commenters varied in their opinion on the classification of PFAS. Some stated that PFAS are too broad of a class to
promulgate regulations collectively, while others stated that PFAS must be addressed as a class, not as one chemical at
a time. Some commenters encouraged EPA to delineate exact which chemical is being regulated and transition to using
CAS Registry numbers when referring to compounds in the PFAS family.
• Some commenters noted that PFAS burdens environmental justice communities.
• EPA should conduct PFAS-specific screening across all industrial categories and incorporate Toxics Release Inventory
(TRI) data into the analysis to reduce data gaps due to the lack of a part 136 PFAS surface water analytical method.
• EPA should develop PFAS discharge prioritization guidance for states.
• EPA must push state agencies to incorporate technology -based limits into state issued permits through case -by -case
analyses, as required by the CWA, and provide guidance to states for conducting these analyses.
• Some commenters stated that legacy and current use of PFAS should be addressed in analyses and in the development
of regulations.
• EPA should clarify whether stormwater practices and PFAS concentrations in stormwater were limiting factors in the
agency's analysis.
• EPA should include reverse osmosis and granulated activated carbon in technology -based regulations for PFAS.
3-3

3—Summary of Preliminary Plan 15 Public Comments
Table 3-1. Summary of Public Comments Received on Preliminary Plan 15
Topic
Summary
Commenter Types
(Count by Type)
PFAS —
• EPA should validate and finalize Draft Method 1633 and develop methods to detect total organic precursors (TOP) and
Env. Organization (2)
Analytical
total organic fluorine (TOF).
Industry (1)
Methods
0 In addition to Draft Method 1633, EPA should develop recommended sampling techniques/guidance.
Industry Trade Assoc. (2)
• PFAS data analyzed by EPA for Preliminary Plan 15 predates a draft method; one commenter was unaware of any
Private Citizen (1)
other ELG that has been developed based on sampling data absent a single reference analytical method.
• Once an analytical method is developed, it will take time to build laboratory capacity. Commenters are unaware of
other ELGs that have faced this capacity issue.
• Commenters noted that EPA should consider whether or not analytical methods are available for the specific chemical
being regulated, as EPA's Draft Method 1633 is only applicable to 40 PFAS.
PFAS —
• Some commenters support the revision of the OCPSF ELG and agree that it is warranted.
Env. Organization (2)
Organic
• EPA's announced rulemaking should consider the wide variety of facilities and operations captured in the category and
Industry (1)
Chemicals,
specifically define impacted facilities.
Industry Trade Assoc. (2)
Plastics and
. Some commenters stated that PFAS formulators, including those not currently regulated, should be considered when
State Govt. (1)
Synthetic
developing ELG.
Fibers
. One state commented that their sampling program has not identified OCPSF facilities as sources of discharges to
(OCPSF)
POTWs or surface waters. However, there are data that suggest that some facilities may have PFAS discharges
associated with the storage of aqueous film -forming foam (AFFF). This state also stated that there are 29 chemical
manufacturers in the state that are not categorically covered under OCPPF; some are sources of PFAS, and these
manufacturers should be considered as part of the rulemaking.
• One commenter stated that EPA should review the wastewater characterization data and identify any pretreatment in
order to effectively characterize treatment. EPA should also consider collecting paired influent -effluent data across
treatment technologies.
• One commenter stated that EPA should further study PFAS formulators and agreed that these facilities should not be
regulated at this time.
PFAS — Metal
• Commenters supported the proposed rulemaking for the Metal Finishing Category and stated that EPA should consider
Env. Organization (3)
Finishing and
specific regulatory language (e.g., a subcategory or paragraph) for chromium electroplating and chromium anodizing.
Industry (1)
Electroplating
• EPA should also consider expanding the scope to identify the presence of PFAS at all metal finishers, including
State Govt. (1)
electroplaters.
• One commenter stated that the EPA PFAS report should be updated to include perfluorononanoic acid (PFNA) data
from the Region 5 PFAS Electroplater Study for chromium electroplating and chromium anodizing operations.
3-4

3 Summary of Preliminary Plan 15 Public Comments
Table 3-1. Summary of Public Comments Received on Preliminary Plan 15
Topic
Summary
Commenter Types
(Count by Type)
PFAS — Textile
• One commenter stated that textile mills are known dischargers of PFAS.
Env. Organization (1)
Mills
0 EPA should issue Section 308 letters to require data collection for PFAS in discharges.
Industry (1)
• EPA should make data collected in the study publicly available on EPA's website and publish a separate detailed study
Industry Trade Assoc. (1)
report on its findings.
PFAS —
The Landfill ELG should include pretreatment standards, as leachate is a significant source of PFAS and other
Env. Organization (2)
Landfills
compounds released to POTWs.
Industry (3)
• EPA's study should cover active and closed landfills.
Industry Trade Assoc. (1)
• The current methods EPA is evaluating for the treatment of PFAS from leachate have not been proven to be viable for
State Govt. (1)
full-scale implementation (or economically feasible).
• Landfills are not the users of PFAS; they are the receivers. As such, industry believes that there are opportunities for
them to minimize discharges of PFAS. However, industry maintains that the most effective approach to controlling
PFAS would be to eliminate it at the source. Minimization techniques should be evaluated as part of the detailed study.
• EPA's review of landfills should account for different landfill profiles and, therefore, different wastewater
characterization.
• Two commenters stated that they welcome the opportunity to share information on the data requested as part of
Preliminary Plan 15.
• One commenter expressed interest in collaborating with EPA to conduct further research and study leaching
characteristics and evaluate applicable treatment technologies.
PFAS — Other
Pulp, Paper, and Paperboard
Env. Organization (2)
Industries
• A commenter stated that EPA should continue its study on the use and discharge of PFAS at pulp and paper mills.
Industry (2)
• States expressed concern about indirect discharges of PFAS from legacy PFAS (e.g., in recycled fibers) even though
Industry Trade Assoc. (2)
the industry will phase out direct application of PFAS in new products in 2024.
State Govt. (2)
• Pulp and paper sites have contaminated ground water and soils that contribute to impacted ground and surface water
(via old paper sludge land application sites).
• EPA should consider working with the U.S. Food and Drug Administration to evaluate PFAS in the food packaging
industry.
• EPA should consider monitoring PFAS in paper mill intake water to determine if it is a relevant source of PFAS.
• One commenter stated that the pulp and paper industry phased out the use of long -chain PFOA and PFOS
approximately 10 years ago and has almost completed its transition of intentional short -chain PFAS in its
manufacturing process.
3-5

3 Summary of Preliminary Plan 15 Public Comments
Table 3-1. Summary of Public Comments Received on Preliminary Plan 15
Topic
Summary
Commenter Types
(Count by Type)
Leather Tanning and Finishing
• EPA should consider PFAS limitations for this category due to data indicating contaminated ground water and
stormwater associated with these sites.
Plastics Molding and Forming
• EPA should prioritize this industry sector in its ongoing PFAS research, collect data from the industry, and determine
if updated ELG are necessary to address PFAS.
Paint Formulating
• EPA should collect data from the industry to determine if updated ELG are necessary to address PFAS.
• A commenter also noted that because paints are flammable, sites may be outfitted with AFFF.
E&EC
• The use of PFAS in electronics is well documented. EPA should complete its detailed study and should update the
public in Plan 15.
Airports/AFFF
• EPA should continue studying the use of AFFF at airports and consider expanding the scope of facilities identified as
having a stockpile of AFFF.
• EPA should include more firefighting solutions other than PFAS-free firefighting foam.
• One state commented that no new ELG for airports were required at this time because it found no current impairments
resulting from PFAS storage, loading, or use at airports in Wyoming.
Petroleum
• A commenter stated that EPA should complete a thorough review of the petroleum refining ELG, including an
Env. Organization (1)
Refining
assessment of BAT and limits for other pollutants discharged by the industry.
• Over the course of a multi -year review, EPA failed to consider or answer the questions needed to determine if revision
to the existing ELG is warranted.
• Current ammonia discharge monitoring report (DMR) data suggest that the ammonia limits (established in 1974) no
longer represent BAT.
• EPA should promulgate concentration- or mass -based limitations so that larger refineries are held to similar standards
as smaller refineries.
• EPA should consider nitrates, selenium, mercury, nickel, and PFAS (including legacy contamination from the use of
AFFF).
Oil and Gas/
• EPA should continue to study Oil and Gas Extraction/Centralized Waste Treatment ELG, specifically for HAS as
Env. Organization (2)
Centralized
there is evidence that PFAS are used in oil and gas production and potentially oil recovery operations and that
State Govt. (1)
centralized waste treatment facilities are a source of PFAS to POTWs.
3-6

3 Summary of Preliminary Plan 15 Public Comments
Table 3-1. Summary of Public Comments Received on Preliminary Plan 15
Topic
Summary
Commenter Types
(Count by Type)
Waste
• EPA should set national standards for produced water in order to help states set appropriate standards and ensure water
Treatment
quality.
• One commenter expressed support for EPA's decision not to make changes to Section 437 (to allow for more
flexibility for increased discharge of produced water to centralized waste treatment facilities).
• EPA should engage with stakeholders on a more robust study of produced water discharges to determine if revised
ELGs are needed.
• EPA should review the Fertilizer Manufacturing ELG. EPA has overlooked details about discharges that impact
communities with environmental justice concerns and pollute climate, air, and surface water in its decision not to
continue review of the category as announced in the Preliminary Plan 15.
• EPA should develop ELGs for three categories of fertilizer manufacturing plants: manufacture of nitrogen fertilizer
ingredients, manufacture of phosphorus fertilizer ingredients, and plants that mix nitrogen and phosphorus ingredients
Fertilizer Mfg.
with others for finished fertilizer products.
Env. Organization (1)
• One commenter stated that EPA's most recent review was insufficient to determine whether the existing ELG and
pretreatment standards are appropriate.
• EPA's cross -category concentration analysis was not grounded in CWA requirements; EPA should have compared
fertilizer manufacturing concentrations to actual permit limits required by the ELG.
• One commenter stated that pollutants from fertilizer manufacturing and the application of fertilizer products impact
human health and the environment.
• EPA should consider limitations, or mitigation strategies, for bromides to help protect sources of drinking water.
• EPA must set zero discharge requirements for bottom ash transport water and flue gas desulfurization wastewater.
• EPA should target the discharges associated with legacy wastewater.
Env. Organization (3)
Steam Electric
One commenter stated that EPA should propose revised standards sooner than the announced Fall 2022 timeline.
Industry Trade Assoc. (2)
• One commenter agreed with EPA's 2020 rulemaking decision not to establish membrane technology as BAT and
State Govt. (2)
supports the 2020 Rule.
• One state commented that it does not show any impairments from steam electric power plants; therefore, they do not
support a revised rulemaking and welcome the opportunity to meet with EPA to discuss.
3-7

3 Summary of Preliminary Plan 15 Public Comments
Table 3-1. Summary of Public Comments Received on Preliminary Plan 15
Topic
Summary
Commenter Types
(Count by Type)
• One commenter stated that it is collaborating with EPA to update and clearly define the list of facilities that are
captured under the applicability of the ELG as part of the detailed study effort referenced in Plan 14 (86 FR 1960).
Env. Organization (3)
Meat and
• EPA should strengthen the ELG for MPP as soon as possible, as available technology for these wastewaters has
Industry Trade Assoc. (3)
Poultry
improved.
Private Citizen (1)
Products (MPP)
• One commenter indicated that the MPP industry has caused interference and pass through at POTWs.
State Govt. (2)
• EPA can use existing DMR data, information on BAT nutrient removal technologies from industry (or best
performers), and information on nutrient removal technologies from POTWs to revise MPP ELG.
Concentrated
Animal
0 One commenter urged EPA to review the ELG for the CAFOs industry based on assertions that: EPA has factual
Feeding
evidence that demonstrates the inadequacy of the current ELG, current wastewater management practices are no longer
Env. Organization (1)
Operations
BAT, and EPA's current rankings methodology (based solely on DMR data) does not accurately characterize pollutant
(CAFOs)
impacts.

4—Summary of Annual Review Activities
4. SUMMARY OF ANNUAL REVIEw ACTIVITIES
This section presents EPA's 2021 annual review activities. These review activities include review of
discharge monitoring report (DMR) data and ranking of pollutant load discharged across all existing
ELGs, comprised of industries with existing ELGs and some industries that are not currently regulated
by ELGs. EPA has taken the following actions as part of its 2021 annual review:
• Conducted a rankings analysis (as a follow-on of the cross -category concentration analysis
conducted for the 2020 annual review and described in Preliminary Plan 15) of point source
categories based on pollutant load data reported on 2019 DMRs (see Section 5.1). EPA used
2019 DMR data for the 2021 annual review because they were the most recent and complete
set of industrial wastewater discharge data available when the rankings analysis began.
• Conducted preliminary category reviews of three point source categories to assess discharges
of PFAS and other regulated and unregulated pollutants to determine whether the categories
warrant further review and study: Leather Tanning and Finishing (40 CFR part 425), Paint
Formulating (40 CFR part 446), and Plastics Molding and Forming (40 CFR part 463) (see
Sections 5.2 through 5.4). EPA used 2020 DMR and Toxics Release Inventory (TRI) data for
these preliminary category reviews because they were the most recent and complete set of
industrial wastewater discharge data available when the category reviews began.
• Continued to screen, prioritize, and further review specific industrial wastewater treatment
technologies that may be more broadly evaluated as technology options in future studies and
rulemakings (see Section 5.5).
• Continued to compile wastewater treatment technology information in the Industrial
Wastewater Treatment Technology (IWTT) Database and populate the information into the
IWTT web application for public use (see Section 5.6.1).
In Preliminary Plan 15, EPA announced that it was initiating a detailed study for one point source
category: Landfills (40 CFR part 445). See Section 6.3.3 for information on EPA's next steps regarding
this category.
EPA also explained in Preliminary Plan 15 that it was considering how best to incorporate equity and
environmental justice considerations into the ELG planning process. As a component of the preliminary
reviews for the Leather Tanning and Finishing, Paint Formulating, and Plastics Molding and Forming
Categories, EPA compiled publicly available socioeconomic data for census block groups where
facilities discharging to surface water or POTWs are located to evaluate the impact of potential
discharges and help further prioritize the categories for review and study. Specifically, EPA evaluated
the following indicators: the percentile of people of color, low income, life expectancy at birth,
unemployment rate, less than high school education, and linguistically isolated relative to the U.S.
median value (50th percentile). For an entire category, EPA calculated the percentage of facilities
located in census block groups that had one or more socioeconomic indicators greater than the national
80th percentile, consistent with the EJScreen methodology for highlighting communities that may require
closer attention. See EPA's 2021 Preliminary Review of Industrial Point Source Categories for more
details on the specific analyses performed as part of the preliminary category reviews (U.S. EPA,
2022b). Section 5.7 describes this methodology in more detail.
4-1

4—Summary of Annual Review Activities
As required by the CWA, EPA reviewed all point source categories as part of its annual review. Given
EPA's current priorities and available resources, the agency will continue to focus on the categories
identified in EPA's PFAS Strategic Roadmap that are likely discharging PFAS, in addition to the other
point source categories discussed in this Plan. Categories not discussed in detail in Plan 15 are not
priorities for further study or rulemaking at this time. EPA will continue to review all point source
categories while preparing the next plan.
The 2021 annual review and the information presented here in Plan 15 build on EPA's previous annual
reviews, including the 2020 annual review and ELG planning process described in Preliminary Plan 15
(U.S. EPA, 2021b). EPA will present its 2022 annual review as part of Preliminary Plan 16 and expects
to expand its rankings analyses to include additional metrics such as size of the industry, average
volume of wastewater discharged, age of regulations, current ELG requirements and technology basis,
presence of PFAS in industrial wastewater discharges, discharges to impaired waters, and demographics
data associated with the location of industrial dischargers.
EPA also received petitions for rulemaking that in part request changes to the ELG for CAFOs and
Plastic Manufacturers and is carefully reviewing those petitions.19,20
" Food & Water Watch, et al. "Petition to Revise the Clean Water Act Regulations for Concentrated Animal Feeding
Operations." Submitted 8 March 2017. Food & Water Watch filed a mandamus action in the U.S. Court of Appeals for the
Ninth Circuit asking the court to order EPA to respond to the petition. As of the time of signature of Plan 15, EPA and Food
& Water Watch have entered into the Court's mediation program to address the mandamus action.
20 Center for Biological Diversity, et al. "Petition to Revise the Clean Water Act Effluent Limitations Guidelines and
Standards for the Petro -Plastics Industry Under the 40 CFR part 419 Petroleum Refining Industrial Category (Cracking and
Petrochemicals Subparts) and part 414 Organic Chemicals, Plastics, and Synthetic Fibers Industrial Category." Submitted 23
July 2019.
4-2

5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
5. REVIEWS OF INDUSTRIAL WASTEWATER DISCHARGES AND TREATMENT TECHNOLOGIES
This section describes EPA's ongoing ELG program planning activities and analyses to identify
industrial categories for potential new or revised ELGs and summarizes the sources and limitations of
the data used to complete the reviews. This section also presents findings and next steps for the
associated planning activities.
5.1 DMR Pollutant Load Rankings Analysis
As part of its 2021 annual review of the ELGs, EPA used DMR data to rank categories by total annual
pollutant load discharged. This rankings analysis provides a mechanism for prioritizing specific point
source categories for further review. The following subsections discuss the data sources and
methodology of the DMR pollutant load rankings analysis, describe factors that EPA considered in its
review, and summarize the results of the review. For additional details on the DMR pollutant load
rankings analysis, see EPA's 2021 Annual Review of Industrial Wastewater Discharges (U.S. EPA,
2022a).
5.1.1 Data, Methodology, and Analysis Considerations
For this analysis, EPA evaluated available industrial wastewater discharge data reported on facilities'
2019 DMRs, which was the most current DMR data set available at the time the rankings analysis was
conducted. Facilities that discharge wastewater to "waters of the United States" pursuant to a National
Pollutant Discharge Elimination System (NPDES) permit are required to report monitoring data via
DMRs for pollutants listed in their NPDES permits. Facilities send DMRs electronically to their
respective NPDES permitting authorities (state or EPA). The DMR data are stored in EPA's centralized
program database, Integrated Compliance Information System National Pollutant Discharge Elimination
System (ICIS-NPDES). ICIS-NPDES captures pollutant -specific permit limits, monitoring
requirements, and DMR data, including, but not limited to, facility, outfall, and monitoring -period -
specific pollutant discharge concentrations, quantities, and wastewater flows. EPA's Water Pollutant
Loading Tool compiles the ICIS-NPDES data into a web -based platform that calculates and presents
facility pollutant discharges in pounds per year or by monitoring period, as described in Section 3 of the
Technical Users Background Document for the Discharge Monitoring Report (DMR) Pollutant Loading
Tool (U.S. EPA, 2012) and summarized in EPA's 2021 Annual Review oflndustrial Wastewater
Discharges (U.S. EPA, 2022a).
As a first step, EPA downloaded data from the Water Pollutant Loading T00121 and established a
crosswalk to relate individual facility and subsequent parameter -level data to the most appropriate point
source category or potential point source category, primarily based on the facility's reported Standard
Industrial Classification (SIC) or North American Industry Classification System (NAICS) code and the
reported parameter. These links enabled EPA to analyze discharges within and across point source
categories.
21 Water Pollutant Loading Tool Resources: https://echo.epa.gov/trends/loading-tool/resources (see "Effluent Guidelines
(ELG) Crosswalks (used only for Top Industrial Dischargers of Toxic Pollutants)"). EPA uses the "NPDES ID and Parameter
Code to Point Source Category" crosswalk for its annual review analyses.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
EPA then downloaded the following 2019 DMR data for each facility from the Water Pollutant Loading
Tool into a static database to preserve the integrity of the data and facilitate subsequent analyses (ERG,
2021 a):
• NPDES permit number.
• Parameter name and code.
• Pollutant name and code.
• Average concentration in milligrams per liter (mg/L).
• Maximum concentration (mg/L).
• Total load discharged for 2019 in pounds per year (lb/year).
• Wastewater flow for 2019 (million gallons per day).
EPA used 2019 data for this review because they comprised the most recent and complete set of
industrial wastewater discharge data available when EPA began the review.
Using the point source category crosswalk, EPA linked all records to a point source category using the
NPDES permit number and the parameter and then summed the annual load across pollutants to the
facility level and, subsequently, to the point source category level. EPA then ranked point source
categories from highest to lowest pounds of discharge in 2019. Section 5.1.3 of this report presents the
results of the 2021 rankings analysis (based on the 2019 DMR data).
5.1.2 Data Quality Review and Corrections
For this analysis, EPA evaluated completeness, accuracy, and reasonableness of the downloaded 2019
data as follows.
Completeness. EPA assessed completeness of the data sets by comparing the volume of the 2019
downloaded ICIS-NPDES data to data from a similar analysis conducted in 2017 to ensure that there
was no discrepancy that would indicate an incomplete download of the data. EPA identified a 1 percent
increase in the total count of facilities reporting data, as new facilities or pollutants are typically added
each year as permits are developed or revised.
Accuracy and reasonableness. For the top ten point source categories in the pollutant load rankings,22
EPA identified outliers (where a few facilities form most of the point source category load) and
determined if any of the data were a result of data entry errors (e.g., unit errors, such as data entered as
"2.7 grams" instead of "2.7 milligrams").
For identified facility outliers, EPA used the Enforcement and Compliance History Online (ECHO)
effluent charts23 to investigate and determine if the outlier data resulted from reporting errors. These
effluent charts graph facilities' submitted monitoring data from all years, allowing EPA to identify
whether the data are consistent over time. EPA identified potential data errors where the facility effluent
22 Note that EPA did not review data from facilities in categories where ELGs were promulgated or revised in the past seven
years.
23 ECHO: https://echo.epa.gov.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
data were unexpectedly different from year to year and/or month to month (higher or lower) by an order
of magnitude or more and reported these potential errors through its Integrated Error Correction Process
(IECP), via the error report feature built into ECHO's website. In instances where the IECP confirmed
the error, EPA recalculated the annual pollutant loads and reran the rankings. For additional details on
the identified outliers and data corrections, see EPA's 2021 Annual Review of Industrial Point Source
Categories (U.S. EPA, 2022a).
5.1.3 Results of the DMR Pollutant Load Rankings Analysis
Table 5-1 presents the 2021 annual review discharge rankings using 2019 DMR data. The rankings
include the 2019 aggregated annual loads for each point source category (ranked from highest to
lowest), the percentage of the total load the point source category comprises, and the number of facilities
in each point source category that reported data greater than zero in 2019.
The rankings analysis provides a mechanism for EPA to review discharges from industrial categories
and potentially prioritize specific point source categories for further review. EPA's recommendation to
further prioritize categories also considers other aspects such as stakeholder input and Administration
priorities. As described in this Plan, EPA continues to focus on and evaluate the extent and nature of
PFAS discharges and assess opportunities for limiting those discharges from multiple industrial
categories, as outlined in EPA's PFAS Strategic Roadmap. Specifically, as identified in the agency's
PFAS Strategic Roadmap, EPA conducted a preliminary review of three point source categories to
assess discharges of PFAS and other regulated and unregulated pollutants to determine whether the
categories warrant further review and study: Leather Tanning and Finishing (40 CFR part 425), Paint
Formulating (40 CFR part 446), and Plastics Molding and Forming (40 CFR part 463) (see Sections 5.2
through 5.4). For the three preliminary category reviews, EPA used 2020 DMR and TRI data, as these
data were publicly available during the agency's review (see Section 1 of EPA's 2021 Preliminary
Review of Industrial Point Source Categories for a description of the data sources, uses, and limitations
(U.S. EPA, 2022b)).
The results of the pollutant load rankings analysis, presented in Table 5-1, did not present any findings
that altered EPA's decision on prioritization for industrial category reviews targeting PFAS at this time.
EPA may choose to prioritize reviews of these categories differently in the future.
Table 5-4. 2021 Annual Review Discharge Ranking Results
2019 DMR
Cumulative
Facilities
40 CFR
Point Source Category Name
Annual Loads
Percentage of
Percentage of
Reporting
Part
(lb/year)
Total Load
Total Load
Discharges
Greater than Zero
414
Organic Chemicals, Plastics, and
120 000 000 000'
72%
°
72/0
609
Synthetic Fibers'
423
Steam Electric Power Generating'
14,600,000,000
9%
81%
808
N/A
Drinking Water Treatment
5,830,000,000
3%
84%
2,022
435
Oil and Gas Extraction
3,130,000,000'
2%
86%
489
419
Petroleum Refining
3,040,000,000
2%
88%
642
433
Metal Finishing'
1 2,510,000,000'
2%
1 90%
638
5-3

5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
Table 5-1. 2021 Annual Review Discharge Ranking Results
40 CFR
Part
Point Source Category Name
2019 DMR
Annual Loads
(lb/year)
Percentage of
Total Load
Cumulative
Percentage of
Total Load
Facilities
Reporting
Discharges
Greater than Zero
434
Coal Mining
2,380,000,000
1%
91%
1,674
415
Inorganic Chemicals Manufacturing
2,310,000,000
1%
92%
229
436
Mineral Mining and Processing
2,020,000,000
1%
94%
1,324
430
Pulp, Paper, and Paperboard'
1,640,000,000
1%
95%
233
420
Iron and Steel Manufacturing
1,320,000,000
1%
95%
145
432
Meat and Poultry Products'
1,030,000,OOO'
1%
96%
296
445
Landfills'
690,000,000
<1%
96%
247
438
Metal Products and Machinery
674,000,000
<1%
97%
836
405
Dairy Products Processing
590,000,000
<1%
97%
118
440
Ore Mining and Dressing
537,000,000
<1%
97%
91
449
Airport Deicing
496,000,000
<1%
98%
79
N/A
Miscellaneous Foods and Beverages
463,000,000
<1%
98%
159
444
Waste Combustors
379,000,000
<1%
98%
25
460
Hospital
360,000,000
<1%
98%
237
463
Plastics Molding and Forming'
345,000,000
<1%
99%
120
451
Concentrated Aquatic Animal
Production
278,000,000
<1%
99/0 °
306
454
Gum and Wood Chemicals
Manufacturing
247,000,000
<1%
99/0 °
12
408
Canned and Preserved Seafood
Processing
225,000,000
<1%
99%
99
407
Canned and Preserved Fruits and
Vegetables Processing
145,000,000
<1%
99%
81
N/A
Unassigned Waste Facility
131,000,000
<1%
99%
178
N/A
Food Service Establishments
121,000,000
<1%
99%
172
429
Timber Products Processing
117,000,000
<1%
99%
271
455
Pesticide Chemicals
109,000,000
<1%
99%
31
437
Centralized Waste Treatment
103,000,000
<1%
100%
15
421
Nonferrous Metals Manufacturing
101,000,000
<1%
100%
56
418
Fertilizer Manufacturing
89,400,000
<1%
100%
59
422
Phosphate Manufacturing
85,900,000
<1%
100%
18
409
Sugar Processing
84,600,000
<1%
100%
34
411
Cement Manufacturing
80,000,000
<1%
100%
507
442
Transportation Equipment Cleaning
75,900,000
<1%
100%
127
N/A
Independent and Stand-alone Labs
51,600,000
<1%
100%
37
439
Pharmaceutical Manufacturing
43,400,000
<1%
100%
56
464
Metal Molding and Casting
(Foundries)
35,200,000
<1%
100%
48
406
Grain Mills
33,000,000
<1%
100%
32
410
Textile Mills'
27,600,000
<1%
100%
58
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
Table 5-1. 2021 Annual Review Discharge Ranking Results
40 CFR
Part
Point Source Category Name
2019 DMR
Annual Loads
(lb/year)
Percentage of
Total Load
Cumulative
Percentage of
Total Load
Facilities
Reporting
Discharges
Greater than Zero
443
Paving and Roofing Materials (Tars
and Asphalt)
20,800,000
<1%
100%
91
457
Explosives Manufacturing
14,600,000
<1%
100%
15
428
Rubber Manufacturing
14,100,000
<1%
100%
82
N/A
Printing & Publishing
8,640,000
<1%
100%
12
426
Glass Manufacturing
7,050,000
<1%
100%
42
469
Electrical and Electronic
Components
6,020,000
<1%
100%
9
471
Nonferrous Metals Forming and
Metal Powders
5,970,000
<1%
100%
56
450
Construction and Development
5,170,000
<1%
100%
182
424
Ferroalloy Manufacturing
4,380,000
<1%
100%
11
467
Aluminum Forming
3,350,000
<1%
100%
21
425
Leather Tanning and Finishing'
2,520,000
<1%
100%
3
417
Soap and Detergent Manufacturing
1,710,000
<1%
100%
14
468
Copper Forming
759,000
<1%
100%
18
458
Carbon Black Manufacturing
639,000
<1%
100%
8
412
Concentrated Animal Feeding
Operations'
325,000
<1%
100%
18
N/A
Industrial Laundries
177,000
<1%
100%
3
446
Paint Formulating'
131,000
<1%
100%
20
427
Asbestos Manufacturing
53,300
<1%
100%
1
461
Battery Manufacturing
47,100
<1%
100%
7
447
Ink Formulating
33,900
<1%
100%
5
N/A
Tobacco Products
19,200
<1%
100%
2
465
Coil Coating
1,250
<1%
100%
3
459
Photographic
6.90
<1%
100%
1
Total
167,000,000,000
-
-
-
a — EPA is currently monitoring, reviewing, or studying this category or conducting a rulemaking for this category.
b — 2019 DMR Annual Load may be overestimated due to outliers in the underlying data. EPA submitted the outliers via the
error report feature built into ECHO'S website but has not identified a correction at this time.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
5.2 Leather Tanning and Finishing Point Source Cateiory (40 CFR part 425)
EPA announced the Leather Tanning and Finishing Category (40 CFR part 425) for preliminary review
in EPA's PFAS Strategic Roadmap. EPA initiated a preliminary review of this category to gather
additional information on discharges associated with PFAS, among other pollutants.
Leather tanning and finishing refers to processes that convert animal hides or skins into leather. In 1982,
EPA promulgated ELG for this industry, which cover wastewater generated from beamhouse, tanyard,
and retan and wet -finish process steps. EPA established production -based limitations for direct
dischargers and concentration -based limitations for indirect discharges for nine subcategories (U.S.
EPA, 1982). The ELG include limitations for BODs, oil and grease, total suspended solids (TSS), total
chromium, pH, and sulfide. As part of this preliminary category review, EPA evaluated U.S. census data
and 2020 DMR and TRI data to assess the size of the industry and corresponding pollutant loads. The
census data showed that the number of leather tanning and finishing facilities has been decreasing
steadily since 2000 and that most tanneries are small operations with fewer than 20 employees.
PFAS are used in leather manufacturing to improve the efficiency of the tanning process. PFAS can also
be applied to leather to provide water and oil repellence, stain resistance, and oil release (Gliige et al.,
2020). PFAS discharges were not reported from this industry in either 2020 DMR or TRI data because
the category is not currently required to report discharges in NPDES permits or based on current TRI
reporting criteria. Therefore, EPA evaluated the available PFAS data from the Michigan Department of
Environment, Great Lakes, and Energy (MI EGLE),24 which collected PFAS data as part of a state
sampling effort separate from NPDES permit (i.e., DMR) and TRI reporting requirements. The MI
EGLE data set captured four leather tanning facilities in the sampling effort. Three out of four leather
tanning facilities in Michigan had detectable quantities of PFAS in their effluent. The highest
concentration detected was 83 ppt of PFOS. MI EGLE did not identify leather tanneries as a high
priority source of PFAS or PFOA compared to other industries identified during their ongoing study;
however, they did identify some inactive tanneries that used PFAS in the past as contaminated sites (MI
EGLE, 2020a; U.S. EPA, 2022d).
Three leather tanning facilities reported DMR data in 2020; one facility accounted for over 90 percent of
the DMR discharges. Because EPA determined that one facility contributed to the majority of the loads,
EPA did not prioritize DMR data for further pollutant -specific reviews. Over 99 percent of the total
2020 TRI loads were reported as indirect releases to POTWs. The top pollutant contributing to over 90
percent of the indirect load was ammonia.
Ammonia accounts for 93 percent of the 2020 TRI indirect loads. Research indicates that ammonia is
generated during two steps in the leather tanning process: (1) the soaking and unhairing step (during
which the proteins removed can convert to ammonia) and (2) the deliming step (where ammonia comes
from the addition of ammonia salts, ammonium chloride, and ammonium sulfate). Because facilities
report total estimated releases to TRI (i.e., total pounds per year) and there are no corresponding
concentration data available in TRI, EPA reviewed the ammonia concentrations collected as part of the
24 See the MI EGLE Industrial Pretreatment Program OPP) PFAS Initiative website for more information.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
1982 rulemaking. In 1982, EPA collected effluent samples from 31 tanneries across all nine subparts;
ammonia concentrations ranged from 1 mg/L to 680 mg/L.
The regulation of ammonia was considered during the 1982 rulemaking, specifically the potential
substitution of Epsom salts for ammonia during the deliming process. EPA did not promulgate
pretreatment standards in 1982 because this substitution was determined to be cost prohibitive. As part
of this review, EPA compared the 1982 ammonia concentrations to inhibition thresholds for ammonia at
POTWs. An inhibition threshold is a concentration range at which a pollutant in a POTW's wastewater
or sludge causes operational problems for biological treatment processes. Based on the available
documentation, ammonia concentrations observed during the 1982 rulemaking were generally lower
than 2004 inhibition thresholds for ammonia based on activated sludge (480 mg/L) and anaerobic
digestion (1,500 mg/L to 8,000 mg/L), suggesting that ammonia discharges are not causing impacts to
POTW operations (U.S. EPA, 2022b).
EPA evaluated facilities for environmental justice concerns including whether they are located in census
block groups (i.e., communities) that have higher demographic metrics than the national average (50th
percentile). The 2-factor demographic index considers the average of people of color and low-income
populations, and the 5-factor index considers low income, education less than a high school degree,
linguistic isolation, unemployment, and life expectancy. The communities surrounding leather tanning
and finishing facilities are on average at the 53rd percentile for the 2-factor demographic index and at the
70th percentile for the 5-factor index. Four facilities are in census block groups in the 80th percentile or
higher for one or both indices, and overall, these facilities are in communities with higher -than -average
demographic indicators.
EPA is not prioritizing the Leather Tanning and Finishing Category for further review or ELG revision
at this time. EPA recommends that state and local permitting authorities consider applying water -
quality -based effluent limitations, as appropriate, to address any potential issues with direct discharging
facilities within this category. During this review, EPA has not identified any data that suggest
discharges from leather tanning facilities to POTWs are impacting POTW operations at this time. The
PFAS data EPA reviewed are limited; however, EPA expects to review additional data in the coming
years as a result of the POTW Influent Study (Section 6.3.5), updated TRI reporting requirements for
PFAS, and NPDES permit monitoring requirements for federally -issued permits.25 These data will help
EPA identify any significant sources of these chemicals in future reviews.
5.3 Paint Formulating Point Source Cate2ory (40 CFR part 446)
EPA announced the Paint Formulating Category (40 CFR part 446) for preliminary review in EPA's
PFAS Strategic Roadmap. The PFAS Strategic Roadmap identifies the ELG program as a potential
method for restricting PFAS discharges from industrial wastewater sources as a key action (U.S. EPA,
2021d). EPA initiated a preliminary review of the Paint Formulating Point Source Category to gather
additional information on discharges associated with PFAS, among other pollutants.
21 See EPA's April 2022 memorandum and December 2022 memorandum, detailing the agency's intention to address PFAS
discharges in NPDES permits and through the pretreatment program and monitoring programs. In addition to reducing PFAS
discharges, this will also provide data to inform ELG planning and actions.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
In 1975, EPA promulgated ELG for this industry, which captured the discharges resulting from the
production of paint and coatings. EPA organized the ELG into three subcategories based on the base and
the technique used for equipment washing (U.S. EPA, 1975):
• Subcategory A. Oil -Base Solvent Wash Paint Manufacture.
• Subcategory B. Oil -Base Caustic Wash Paint Manufacture.
• Subcategory C. Water -Base Paint Manufacture.
EPA established zero discharge regulations for BPT, BAT, NSPS, and PSNS for Subcategory A and
reserved26 PSES for Subcategory A. EPA reserved the Subcategory B regulation and planned to
reevaluate Subcategory C for promulgation at a later date. Resin manufacture is covered under 40 CFR
part 414: Organic Chemicals, Plastics, and Synthetic Fibers.
As part of this preliminary category review, EPA evaluated 2019 U.S. Census data and 2020 DMR and
TRI data to learn more about the size of the industry, discharge practices, and corresponding pollutant
loads. The count of facilities from the 2019 U.S. Census and 2020 DMR and TRI data suggests that the
proportion of direct and indirect discharges within the industry remains similar to 1975 and that most
discharges of process wastewater are indirect discharges (U.S. EPA, 2022b). Census data suggest that
much of the industry is comprised of small establishments (i.e., less than 20 employees).
EPA's limited literature search identified that PFAS are used in paint, coating, and varnish
manufacturing. A 2022 Organization for Economic Cooperation and Development (OECD) report, Per -
and Polyfluoroalkyl Substances and Alternatives in Coatings, Paints and Varnishes (CPVs), Report on
the Commercial Availability and Current Uses, identified that the majority of PFAS in coatings, paints,
and varnishes are fluoropolymers and, to a lesser degree, short -chain PFAS used in household paints.
The PFAS function as levelling, wetting, and anti -blocking agents and provide protective properties for
increased durability and weatherability, as well as repellency for anti -stick and anticorrosive
applications (OECD, 2022; GHige et al., 2020). These properties allow paints to apply smoothly and
evenly and prevent damage to the surfaces they cover and the paints themselves. Several resources
indicated that there are viable PFAS alternatives for paint including polyurethane, polyethylene, and
polyvinylchloride (OECD, 2022). EPA did not identify any PFAS discharge data from this industry in
either 2020 DMR or TRI because these facilities are not currently required to report discharges in
NPDES permits or based on current TRI reporting criteria. Therefore, EPA evaluated the available
PFAS data from MI EGLE,27 which collected PFAS data as part of a state sampling effort separate from
NPDES permit (i.e., DMR) and TRI reporting requirements (U.S. EPA, 2022d). Based on state -provided
data, EPA found six facilities with available PFAS discharge data, four of which had detectable
quantities of PFAS in their effluent. PFOS and PFOA had the highest average concentrations at 6.05 ppt
and 0.15 ppt, respectively. EPA expects that the POTW Influent Study (Section 6.3.5) which EPA
intends to initiate will provide further information on any PFAS discharges from indirect dischargers in
this industry.
26 "Reserved" refers to a placeholder within the Code of Federal Regulations. The agency may "reserve" certain ELGs to
indicate that it may develop ELGs at a later date.
27 See the MI EGLE Industrial Pretreatment Program (IPP) PFAS Initiative website for more information.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
To understand current discharges of non-PFAS pollutants, EPA reviewed 2020 DMR and TRI data for
the Paint Formulating Category. From the 2020 DMR data, EPA identified 18 facilities with NPDES
permits. EPA found that all effluent limits in the 18 discharge permits were associated with stormwater
or other noncontact process wastewater outfalls, which is to be expected as the regulations for
Subcategory A (Oil -Base Solvent Wash Paint Manufacture) require zero discharge of pollutants from
process wastewater. EPA reviewed pollutants reported to 2020 TRI, which provides available data on
indirect discharges. EPA focused the review on solvents and metals, which make up the majority of the
indirect discharges reported to TRI. Solvents are used as a volatile vehicle that film -forming binders and
pigments are dissolved into, and they provide different properties to paints. Metals in the paint industry
are used as biological inhibitors, driers, and pigments. From the review of TRI data, EPA found:
• Solvents such as glycols, and others, have been used historically and are currently used in the
paint formulating industry.
• Zinc is a prominent metal discharged from the paint industry, as it was during the 1975
review.
• Lead have been phased out of the industry since the 1975 review (U.S. EPA, 1975).
EPA evaluated facilities for environmental justice concerns including whether they are located in census
block groups (i.e., communities) that have higher demographic metrics than the national average (50th
percentile). The 2-factor demographic index considers the average of people of color and low-income
populations, and the 5-factor index considers low income, education less than a high school degree,
linguistic isolation, unemployment, and life expectancy. Paint formulating facilities are located in
communities that are on average at the 51 st percentile for the 2-factor demographic index and at the 59th
percentile for the 5-factor demographic index. These facilities have similar demographic indicators to
the national average.
EPA is not prioritizing the Paint Formulating Category for further review or ELG revision at this time.
Based on the available data, revisions to the ELG are unlikely to result in significant pollutant discharge
reductions relative to the other point source categories discussed in this Plan. EPA recommends that
state and local permitting authorities consider applying water -quality -based effluent limits, as
appropriate, to address any potential issues with solvents, or other pollutants in discharges from this
category. EPA intends to continue to monitor the use, discharge, and treatment of PFAS from paint
formulating facilities as part of the POTW Influent PFAS Study (Section 6.3.5), updated TRI reporting
requirements for PFAS, and NPDES permit monitoring requirements for federally -issued permits and
state -issued permits as more states include monitoring for PFAS in permits.28 These data will help EPA
identify any significant sources of these chemicals in future reviews and understand the
subcategorization of current facility discharges, in particular indirect discharges.
28 See EPA's April 2022 memorandum and December 2022 memorandum, detailing EPA's intention to address HAS
discharges in NPDES permits and through the pretreatment program and monitoring programs. In addition to reducing
PFAS discharges, this will also provide data to inform ELG planning and actions.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
5.4 Plastics Molding and Forming Point Source Category (40 CFR part 463)
EPA announced the Plastics Molding and Forming Category (40 CFR part 463) for preliminary review
in EPA's PFAS Strategic Roadmap. EPA initiated a preliminary review of the Plastics Molding and
Forming Category to gather additional information on discharges associated with PFAS, among other
pollutants.
In 1984, EPA promulgated ELG for this industry, which capture processes that blend, mold, form, or
otherwise process plastic materials into intermediate or final plastic products. Specifically, the ELG
cover process water that contacts plastic material, product, or the surfaces of shaping equipment used to
mold or form plastic materials. EPA organized the ELG into three subcategories based on the pollutant
characteristics of the process water (U.S. EPA, 1984):
• Subcategory A. Contact Cooling and Heating Water. This includes process water that comes
into contact with plastic materials or plastic products during heat transferring processes.
• Subcategory B. Cleaning Water. This includes process water used to clean the surface of an
intermediate or final plastic product, including water used in the detergent wash cycle or
rinse cycles. It also includes water that comes into contact with shaping equipment surfaces
(i.e., molds and mandrels) that have been in contact with plastic material for the purpose of
cleaning equipment surfaces.
• Subcategory C. Finishing Water. This includes process water used to finish plastic products
such as carry -away waste plastic materials or product lubrication. It includes water used to
machine or assemble intermediate or final plastic products.
EPA established BPT, BAT, and NSPS for BODs, oil and grease, TSS, and pH and reserved29 PSES and
PSNS regulations for phthalates (U.S. EPA, 1984). The applicability of the Plastics Molding and
Forming Point Source Category (40 CFR part 463.1) overlaps with others, including the Metal Finishing
(40 CFR part 433), Electroplating (40 CFR part 413), and Organic Chemicals, Plastics, and Synthetic
Fibers (40 CFR part 414).
As part of this preliminary category review, EPA evaluated U.S. census data and 2020 DMR and TRI
data to learn more about the size of the industry and corresponding pollutant loads. EPA did not identify
any PFAS discharge data in DMR or TRI because the category is not currently required to report
discharges in NPDES permits or based on current TRI reporting criteria. Therefore, EPA evaluated
available PFAS data from MI EGLE30 and Wisconsin Department of Natural Resources31, which
collected PFAS data as part of a state sampling effort separate from NPDES permit (i.e., DMR) and TRI
reporting requirements (U.S. EPA, 2022d; U.S. EPA, 2022e). EPA also met with one manufacturer to
further understand PFAS discharges associated with the industry (U.S. EPA, 2022f).
PFAS are used in the plastics molding and forming industry for their hydrophobic and oleophobic
properties and low surface tension, which are desirable in plastics (Ghige et al., 2020). These properties
29 "Reserved" refers to a placeholder within the Code of Federal Regulations. The agency may "reserve" certain ELGs to
indicate that it may develop ELGs at a later date.
30 See the MI EGLE Industrial Pretreatment Program (IPP) PFAS Initiative website for more information.
31 See the Wisconsin DNR PFAS initiatives website for more information.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
may help with improving polymer extrusion and reducing imperfections on the mold. Based on the state -
provided data, EPA found five facilities with available PFAS discharge data, three of which had
detectable quantities of PFAS in their effluent. PFOS, PFOA, and perfluorohexanoic acid (PFHxA) had
the highest average concentrations at 13 ppt, 4 ppt, and 1 ppt, respectively.
EPA reviewed the top-ranking DMR and TRI pollutants in the 2020 data. Based on an initial review of
the 2020 DMR data, EPA found that 98 percent of the annual loads were associated with stormwater
(which is covered under general permits for stormwater associated with industrial activity) and not
captured in the applicability of this ELG. Excluding stormwater discharges, EPA identified the
following pollutants for review:
• Regulated pollutants: TSS, oil and grease, BOD5, bis(2-ethylhexyl) phthalate, di-n-butyl
phthalate, and dimethyl phthalate.
• Unregulated pollutants: chemical oxygen demand (COD), total organic carbon (TOC),
nitrogen compounds, and N,N-Dimethylformamide.
As part of its review, EPA found:
• Reported average concentrations of TSS, oil and grease, and BOD5 were an order of
magnitude below the current ELG.
• Bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and dimethyl phthalate regulations are
reserved under the current ELG; bis(2-ethylhexyl) phthalate discharges are similar to those
reported in 1984, and phthalate discharges reported on 2020 DMRs are lower than the
existing regulations for other categories.
• COD, TOC, and ammonia concentrations were found to be generally lower than 1984
observations.
• The extent of the use of N,N-Dimethylformamide is not currently known, but the data
suggest that only a small subset of facilities release this pollutant. For these reasons, EPA did
not review discharges of this pollutants further.
EPA evaluated facilities for environmental justice concerns including whether they are located in census
block groups (i.e., communities) that have higher demographic metrics than the national average (50th
percentile). The 2-factor demographic index considers the average of people of color and low-income
populations, and the 5-factor index considers low income, education less than a high school degree,
linguistic isolation, unemployment, and life expectancy. Communities surrounding plastics molding and
forming facilities are on average at the 43rd percentile for the 2-factor demographic index and at the 55th
percentile for the 5-factor demographic index. Plastics molding and forming facilities overall have
demographic indicators similar to the national average.
EPA is not prioritizing the Plastics Molding and Forming Category for further review or ELG revision at
this time. Based on the available data, revisions to the ELG are unlikely to result in significant pollutant
discharge reductions relative to the other point source categories discussed in this Plan. EPA
recommends that state and local permitting authorities consider applying water -quality -based effluent
limits, as appropriate, to address any potential issues with phthalates or other pollutants in discharges
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
from this category. EPA intends to continue to monitor discharges from this category, specifically for
PFAS. The PFAS data EPA reviewed are limited; however, EPA expects to review additional data in the
coming years as a result of the POTW Influent Study (Section 6.3.5), updated TRI reporting
requirements for PFAS, and NPDES permit monitoring requirements for federally -issued permits and
state permits as more states include monitoring for PFAS in permits.32 These data will help EPA identify
any significant sources of these chemicals in future reviews.
5.5 Industrial Wastewater Treatment Technologies Reviews
EPA continued its industrial wastewater treatment technology review, initially described in Preliminary
Effluent Guidelines Program Plan 14 (Preliminary Plan 14) (see Section 3.6 of Preliminary Plan 14,
U.S. EPA, 2019a). As described in Preliminary Plan 15, EPA summarized its key findings to date for
four treatment technologies in the memorandum "Key Findings for EPA's Industrial Wastewater
Treatment Technology Reviews" (ERG, 2021b) and in the preliminary review for suspended growth
systems (activated sludge) and membranes (ERG, 2021 c; ERG, 2021 d). As part of ongoing treatment
technology reviews, EPA is currently reviewing ion exchange and granular activated carbon and the
corresponding applications for industrial wastewater discharges.
5.6 ELG Planning Tools
EPA continued to maintain the IWTT Database and the ELG Database. These databases, described in
more detail below, are used to supplement EPA's ongoing category reviews by:
• Identifying pollutants with ELGs for specific point source categories.
• Comparing current discharge concentrations to effluent data in IWTT and long-term average
data, limitation data, and technology bases in the ELG Database.
See EPA's 2021 Preliminary Review of Industrial Point Source Categories for a description of the
specific analyses performed as part of the preliminary category reviews (U.S. EPA, 2022b).
5.6.1 Industrial Wastewater Treatment Technology Database
IWTT is an online database that contains wastewater treatment technology performance data from 34
industrial point source categories and removal performance data for 205 individual pollutant parameters.
As part of maintaining the IWTT database, EPA continually collects industrial wastewater treatment
performance information to populate the database and makes the information available to the public
through the IWTT web application.33 As described in Preliminary Plan 15, EPA identified and screened
additional references across a broad range of industries from key technical conferences on wastewater
treatment, including the 2019 and 2020 Water Environment Federation's Technical Exhibit and
Conference (WEFTEC). EPA also screened references identified through the Multi -Industry Per- and
Polyfluoroalkyl (PFAS) Study — 2021 Preliminary Report (U.S. EPA, 2021c). During the 2022 annual
reviews, EPA intends to populate IWTT with these references. EPA also intends to continue to review
32 See EPA's April 2022 memorandum and December 2022 memorandum, detailing EPA's intention to address HAS
discharges in NPDES permits and through the pretreatment program and monitoring programs. In addition to reducing HAS
discharges, this will also provide data to inform ELG planning and actions.
" See https://www.epa.gov/eg/industrial-wastewater-treatment-technology-database-iwtt.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
and identify references from conferences, including 2021 and 2022 WEFTEC and the 2022 International
Water Conference. IWTT currently contains performance data for 58 different treatment technologies,
some of which may be components of a larger treatment system.
5.6.2 Effluent Limitations Guidelines and Standards Database
As discussed in Plan 14, EPA has compiled information on its ELGs for the 59 different point source
categories34 into a consolidated ELG Database in order to reference and query ELGs, long-term average
data, and technology bases as part of ongoing category reviews. EPA has now made the information
publicly available through the ELG Database web application. Users of this tool can search for
information within and across ELGs. The database captures information from the CFR35 as well as from
the technical development documents supporting promulgated rules. The ELG Database includes the
following information:
• Regulations promulgated (e.g., BPT, BAT, BCT, NSPS, PSES, PSNS).
• Applicability of the ELGs, including definitions of any regulated subcategories.
• Wastestreams or process operations associated with each regulation.
• Pollutant limitations.
• CFR references to best management practices, monitoring requirements, and narrative
limitations.
• Rule history, including promulgation and revision dates.
• Technology bases for the underlying regulations.
5.7 Environmental Justice
As part of Preliminary Plan 15, EPA solicited public comment on how best to incorporate equity and
environmental justice considerations into the ELG planning process. Specifically, EPA proposed using
EJScreen, the agency's mapping and screening tool that combines demographic and environmental
indicator information, to assess the proximity and potential impact of industrial discharges on
underserved and underrepresented populations.
As part of the preliminary category reviews completed and discussed in this Plan (see Sections 5.2
through 5.4), EPA developed a methodology that evaluates demographic data within census block
groups, corresponding to the geographic locations of facilities within point source categories. The
methodology maps facilities within a category and indicates which categories are at the 80th percentile or
greater for a selected demographic metric:
• Standard two -metric (people of color and low income).
• Five -metric (low income, education, linguistic isolation, unemployment, and life
expectancy).
34 See EPA's Industrial Effluent Guidelines webpage for a list of the 59 point source categories.
35 See the eCFR.
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5-Reviews oflndustrial Wastewater Discharges and Treatment Technologies
EPA may explore using additional metrics to evaluate environmental justice concerns in future category
reviews, including impairment status (and impairment cause(s)) under Assessment, Total Maximum
Daily Load (TMDL) Tracking and Implementation System (ATTAINS); facility contacts, Resource
Conservation and Recovery Act (RCRA) permit status, greenhouse gas releases, and demographic
percentiles. EPA may also consider whether a facility is located in a disadvantaged community based on
the Climate and Economic Justice Screening Tool (CEJST) methodology and the count of disadvantaged
categories for each facility (e.g., climate change, clean energy/energy efficiency, clean transit). The
results for each preliminary category review are presented in EPA's 2021 Preliminary Review of
Industrial Point Source Categories (U.S. EPA, 2022b).
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6 Ongoing ELG Studies
6. ONGOING ELG STUDIES
This section summarizes the status of EPA's ongoing ELG studies.
6.1 Electrical and Electronic Components Point Source Cate2ory (40 CFR part 469)
The purpose of this detailed study was to determine if the Electrical and Electronic Components
(E&EC) ELG (40 CFR part 469) warrant further review or possible revision. As part of the 2015 annual
review, EPA initiated a preliminary review of the E&EC Category in response to stakeholder comments
received during a 2014 National Association of Clean Water Agencies (NACWA) conference regarding
the applicability of the ELG to the manufacture of sapphire crystals. Additional information collected
during the 2016 annual review focused on 40 CFR 469 Subpart A (Semiconductors). Following this
review, EPA determined that further review of the category was appropriate and began a detailed study
related to Subparts A, B (Electronic Crystals), C (Cathode Ray Tubes), and D (Luminescent Materials)
to further characterize the industry profile.
As part of this study, 34 different permitting authorities (EPA regions, state, and local) from 19 states
provided information. The study identified 104 facilities permitted according to requirements in CFR
part 469. As when the rule was originally issued, the general distribution of facilities subject to each
subpart remained the same, with most being permitted under Subpart A, followed by Subpart B, and
only a few for Subparts C and D. While manufacturing activities have remained similar, manufacturing
technologies have evolved to produce ever smaller and more complex devices that are faster and more
energy efficient. This has required a corresponding evolution in the equipment, chemicals, and
components used in the manufacturing process.
Over 95 percent of the permitted facilities are indirect dischargers sending their wastewater to a local or
regional wastewater treatment facility. For the most part, the discharges from these indirect facilities are
a small fraction of the total received by the wastewater treatment facility, although for a few of the
larger facilities the discharge can account for 10 to 20 percent of the incoming flow. While most
facilities are indirect dischargers, many also have a solvent management plan to collect and ship their
organic solvents off site for processing to keep them from being discharged in their wastewater.
The composition of the wastestream has changed through the years as technologies have changed. In
1983, when the current ELG rule was written, chlorinated solvents and strong acids for the etching
process were used in this industry. Over the years the chlorinated solvents have been replaced, and the
industry is no longer using the original regulated solvents. At present, over 70 different elements (some
added an atom at a time) from the periodic table are used by the industry as a whole, but the specific
number and composition varies from facility to facility. Strong acids remain, but etching is achieved
through the use of cold plasmas generated from a variety of gases. PFAS have been used for some time,
with PFOA and PFOS being recently phased out and other PFAS replacing them. PFAS as a class of
chemicals is difficult to eliminate from the production process as their chemical and physical properties
are difficult to replicate with non-PFAS compounds.
The wastewater treatment systems being utilized are similar to those available in 1983—pH adjustment,
chemical precipitation, filtration, and activated carbon finishing. Each facility also employs
ultrapurification processes to produce high -quality water to meet their exacting requirements. A growing
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6 Ongoing ELG Studies
number of E&EC facilities also utilize this equipment to conserve water, reclaiming water used in their
production process that originally would have been discharged after a single use. This wastewater is
considerably cleaner than that supplied by the local drinking water provider and easier to purify.
The ELG regulation (40 CFR part 469), in conjunction with locally employed discharge limits, has for
the most part been effective in limiting the discharge of pollutants from these facilities. While the
regulation could be modified to remove subsections that are no longer relevant and clarify certain
sections that can be confusing for permit writers, the review of monitoring data from these facilities
(U.S. EPA, 2022p) does not demonstrate a need to revise the existing regulation at this time. EPA
intends to continue to monitor discharges of PFAS from this category. The PFAS data EPA reviewed are
limited; however, EPA expects to review additional data in the coming years as a result of the POTW
Influent Study (Section 6.3.5), updated TRI reporting requirements for PFAS, and NPDES permit
monitoring requirements for federally -issued permits and state permits as more states include monitoring
for PFAS in permits.36 These data will help EPA identify any significant sources of these chemicals in
future reviews.
6.2 Concentrated Animal Feeding Operations Point Source Cate2ory (40 CFR part 412)
CAFOs are facilities that confine and maintain large numbers of animals for specified periods of time
(40 CFR 122.23 defines CAFOs in precise terms). The CAFOs ELG regulate two parts of CAFOs: the
"production area" and the "land application area." The production area is the area that includes the
animal confinement area, manure storage areas, raw materials storage area, and waste containment areas
(40 CFR 122.23(b)(8)). The land application area is the land under the control of a CAFO owner or
operator to which manure, litter, and process wastewater from the production area is or may be applied
(40 CFR 122.23(b)(3)).
The existing CAFOs ELG impose substantial and detailed requirements on both the production area and
land application area. The ELG requirements for the production area prohibit the discharge of manure,
litter, and process wastewater from the production area to waters of the United States, with only one
exception (40 CFR 412.31(a)). Under this exception, the ELG allow discharges from the production area
where those discharges are caused by precipitation and where the production area is designed to contain
all manure, litter, and process wastewater from a 25-year, 24-hour rainfall event (40 CFR 412.3l(a)(1)
defines this exemption in precise terms).37
The ELG requirements for the land application area prohibit discharges unless those discharges qualify
as "agricultural stormwater," which the CWA expressly excludes from regulation (33 USC 502(14)).
EPA interprets "agricultural stormwater" to include any precipitation -related discharges of manure,
litter, and process wastewater from the land application areas if the manure, litter, and process
wastewater has been applied to the land application area in accordance with a site -specific "nutrient
management plan" that ensures appropriate agricultural utilization of the nutrients in the manure, litter,
36 See EPA's April 2022 memorandum and December 2022 memorandum, detailing EPA's intention to address PFAS
discharges in NPDES permits and through the pretreatment program and monitoring programs. In addition to reducing PFAS
discharges, this will also provide data to inform ELG planning and actions.
31 The ELG allow CAFOs to request site -specific alternatives to the containment requirements if those alternatives result in
discharge amounts that are equal to or less than the containment requirements (40 CFR 412.31(a)(2) defines these alternative
requirements in precise terms).
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6—Ongoing ELG Studies
or process wastewater (40 CFR 122.23(e)). A nutrient management plan addresses the form, source,
amount, timing, and method of application of nutrients on each field to achieve crop production goals
while minimizing the transport of nutrients to surface waters (40 CFR 412.4(c)(1)). The application rates
for manure, litter, and process wastewater must be established in accordance with technical standards
established by each state (see 40 CFR 123.36; 412.4(c)(2)). The ELG also require CAFOs to comply
with certain recordkeeping and reporting requirements related to both the production area and the land
application area (40 CFR 412.4(b), (c)).
EPA has concluded that it needs to gather additional information to inform a decision as to whether
rulemaking to revise the ELG is warranted. See Appendix A for discussion of the agency's rationale for
this decision and the information EPA plans to gather as part of its detailed study.
6.3 PFAS Industrial Sources and Discharge Studies
As part of the statutorily required ELG planning process, EPA's Office of Water examined readily
available public information about PFAS discharges. The Preliminary Plan 14 and a supporting report,
The EPA's Review of Per- and Polyfluoroalkyl Substances (PFAS) in Industrial Wastewater Discharge,
both published in October 2019, describe the review activities and findings of the initial examination
and identify several industries with facilities that are likely to be discharging PFAS in their wastewater
(U.S. EPA, 2019a; U.S. EPA, 2019b). In 2019, EPA determined that further data collection and study
were necessary to inform decisions about how best to address industrial PFAS discharges and initiated
the Multi -Industry PFAS Study. The Multi -Industry PFAS Study focused on data collection and review
of PFAS manufacture, use, control, and discharge by specific point source categories that EPA
determined were likely to be discharging PFAS in their wastewater. The objectives of the Multi -Industry
PFAS Study were to: 1) examine specific industrial categories and facilities manufacturing, using, or
discharging PFAS; 2) collect, compile, and review information and data on PFAS in industrial
discharges; 3) use compiled data to characterize PFAS types and concentrations discharged in industrial
wastewater; and 4) assess availability and feasibility of control practices and treatment technologies
capable of reducing or eliminating PFAS in wastewater discharges.
In September 2021, EPA published the Multi -Industry PFAS Study — Preliminary 2021 Report which
discussed information and data EPA collected on PFAS manufacture, use, control, and discharge by five
point source categories: OCPSF; Metal Finishing; Pulp, Paper, and Paperboard; Textile Mills; and
airports (U.S. EPA, 2021c). In Preliminary Plan 15, also published in September 2021, EPA announced
the following actions based on the information and data collected during the Multi -Industry PFAS Study
(U.S. EPA, 2021b):
• Initiate rulemaking to revise limitations for the OCPSF Point Source Category to address
PFAS discharges from PFAS manufacturers.
• Initiate rulemaking to revise limitations for the Metal Finishing and Electroplating Point
Source Categories to address PFAS discharges from chromium finishing operations.
• Initiate detailed studies of PFAS discharges from the Textile Mills and Landfills Point
Source Categories.
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6 Ongoing ELG Studies
• Continue to monitor the anticipated reduction of PFAS use and discharge by pulp and paper
mills and airports through the ELGs annual review process.
Sections 6.3.1 to 6.3.4 discuss information and data EPA has collected and reviewed since September
2021 on PFAS use, control, and discharge from textile mills, landfills, pulp and paper mills, and airports,
respectively. Section 6.3.5 discusses a new study EPA intends to initiate to continue studying PFAS
discharges to POTWs. See Section 7 for additional information on ongoing rulemakings to address
PFAS discharges from the OCPSF and Metal Finishing and Electroplating Categories.
6.3.1 Airports
Based on information and data EPA collected as part of the Multi -Industry PFAS Study, EPA
documented that aqueous film forming foam (AFFF) has been, and continues to be, used by airports in
the United States to prevent, extinguish, and control flammable liquid -based fires. There are different
types of firefighting foams, not all of which contain PFAS, but all historically and currently
manufactured AFFF products contain PFAS as an active ingredient. EPA determined that 14 CFR part
139 airports38 are currently required by the Federal Aviation Administration (FAA) to use only
firefighting foams that conform to military specification (MILSPEC) MIL-PRF-24385: "Fire
Extinguishing Agent, Aqueous Film -Forming Foam" and that no fluorine -free foams currently meet this
standard. Therefore, the 500+ FAA -certified airports in the United States will continue to use PFAS-
containing firefighting foam formulations until a fluorine -free foam is approved for use. EPA
determined these airports may have historically generated and discharged PFAS-containing wastewater
(i.e., water contaminated with AFFF) from live -fire firefighting training, firefighting equipment testing,
and emergency response activities. EPA announced in Preliminary Plan 15 that it would continue to
review airports to further understand the potential for discharge of PFAS-containing wastewater from
facilities that use AFFF and to monitor the industry's anticipated phase out of AFFF.
While developing ELG Plan 15, EPA collected additional data on AFFF use and wastewater
management from 14 CFR part 139 airports from the FAA. EPA met with the FAA in March 2022 to
discuss updates related to the FAA's efforts to reduce, and eventually eliminate, use and release of
PFAS-containing AFFF (U.S. EPA, 2022g). In recent years, both the FAA and the United States
Department of Defense (DOD) have taken voluntary actions to curb the release of AFFF during
nonemergency exercises (i.e., training and testing), replace legacy AFFF firefighting foams which
contain long -chain PFAS, and fund development of fluorine -free foams.
As part of the FAA's guidance on minimizing potential environmental impact from AFFF during testing
and firefighting training, the FAA recommends 14 CFR part 139 airports install testing devices for
firefighting equipment that eliminate release of AFFF during mandatory periodic testing of firefighting
foam system performance, and the FAA is no longer requiring these airports to use AFFF during live
firefighting testing. As of March 2022, the FAA has approved and is funding four different types of
testing devices for firefighting equipment that do not require dispensing AFFF when airports conduct
periodic equipment testing and training: Eco-Logic System from E-One, NoFoam System, Oshkosh Eco
38 Regulation at 14 CFR part 139 requires the FAA to issue airport operating certifications to airports that: 1) serve scheduled
and unscheduled air carrier aircraft with more than 30 seats; 2) serve scheduled air carrier operations in aircraft with more
than nine seats but less than 31 seats; or 3) the FAA Administrator requires to have a certificate. Most commercial service
airports are 14 CFR part 139 certified.

6 Ongoing ELG Studies
EFP (Electronic Foam Proportioning) System, and Rosenbauer FIXMIX 2.0E Input -Based
Proportioning Test System (FAA, 2021 a). The FAA extended the program funding the testing devices
for firefighting equipment at 14 CFR part 139 airports until November 2023, an additional two years
beyond the original program end date (FAA, 2021b). As of March 2022, the FAA has stated that more
than half of the 518 certified airports have adopted these procedures and equipment, eliminating the
release of AFFF except for during actual emergency response (U.S. EPA, 2022g). See Table 6-1 for a
breakdown of system type and airport count.
Table 6-1. System Type and Airport Count
System Type
14 CFR part 139
Airport Count
Eco-Logic System from E-One
156
NoFoam System
92
Oshkosh ECO EFP System & Oshkosh ECO EFP vehicles retrofitted
91
Rosenbauer FIXMIX 2.0E Input -Based Proportioning Test System
33
Total 14 CFR part 139 Airports (as of May 2022)
518
In April 2020, the DOD amended MILSPEC MIL-PRF-24385 to specify that AFFF with the lowest
demonstratable concentrations of PFOS and PFOA should be used in the interim before a suitable
PFAS-free foam is available for use. As of June 2022, all firefighting foam formulations that meet
MILSPEC MIL-PRF-24385 contain less than 800 parts -per -billion of PFAS. The DOD has issued
guidance and best management practices to control and capture AFFF releases in the event of an actual
emergency response. The DOD is developing guidance to address cleanup and disposal of existing
AFFF stockpiles and residuals in firefighting equipment (U.S. EPA, 2022g).
The FAA, the DOD, and firefighting foam manufacturers are collaboratively researching PFAS-free
foam alternatives to identify formulations that are more environmentally friendly and that provide an
equivalent level of performance as the current MILSPEC MIL-PRF-24385. As of July 2022, the FAA
has studied 36 fluorine -free foams (I I commercially available, 25 manufacturer prototypes) and
conducted more than 500 fire suppression tests at the FAA Technical Center as part of their MILSPEC
development and firefighting foam research program (U.S. EPA, 2022g). On July 2022, the FAA
released its report on evaluating commercially available fluorine -free foams, which do not contain
PFAS, to determine if any fluorine -free foam can be considered a suitable replacement for AFFF for use
on aviation fuel fires. The FAA's full findings can be found in the Fluorine free Foam Testing report
which concludes that none of the fluorine -free foam candidates consistently had an equivalent
extinguishing performance to AFFF (FAA, 2022).
Only the DOD is authorized to update MILSPECs. On June 2, 2022, the DOD published draft
MILSPEC MIL-PRF-XX727 ("Fire Extinguishing Agent, Fluorine -Free Foam (173) Liquid Concentrate,
For Land -Based, Fresh Water Applications") for PFAS-free firefighting foam, a significant step in the
process for meeting the deadline of publishing a new fluorine -free foam MILSPEC by January 31, 2023,
MKI

6 Ongoing ELG Studies
as required by the 2020 National Defense Authorization Act (NDAA).39 The FAA plans to adopt and
require use of PFAS-free firefighting foams compliant with the new MILSPEC once it is published. The
FAA expects that it will take 14 CFR part 139 airports approximately two to five years to transition from
procurement and use of AFFF to the new PFAS-free firefighting foams. The FAA is targeting
completion of this transition by January 2025, or as soon as possible thereafter. The FAA notes that
there will be a lot of competition between military sites, airports, and industrial facilities for the limited
initial supply of PFAS-free firefighting foam product. Figure 6-1, provided to EPA by the FAA,
illustrates the DOD and FAA schedule to replace AFFF with PFAS-free foams along with relevant
NDAA deadlines.
NDAADeadlines
Publish
MILSPEC
Stop Buying
Stop Using
Extension#1 Etension 42
1/31/23
10/1/23
10/1/24
10/1/25 10/1/26
Fire Tests
C
qualify Al�ents
Environment
PFAS Content
buy New Agents
Standards
0 Human Health
Replace
Agent
Additional Fielding Activil' !as ash Research
Q
reQuired Transition
Q
MILSPEC
E PAt Actio nl
Jan ' lan
Jan
Jan
lan
r lan
2021 2022
20231
IV 24
2325
2026
Transition Planning
CParticipation in MILSPECI)evelopment i
Ex + ute AFFF to FFF Transition PI}n
�
Additional
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and
'
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rn 0evelo ment
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Q
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1.Issue advance notice ofproposed rulamaking on
us PFAS under CERCLA(Spring 22)
LL
Chem cal Analysis'"'
2. Proposeto des grate ortain PFAS as CERCLA
ha —dons substances (Spri ng22—Summer 23)
New Product oevelopmett
3. Issue updated guidance on destroying and
disposing PFAS(NI 2023)
AFFF=Aqueouefilrn forming foam
CERCLA=Comprah ensive Environmental Response,
Compensation, Liability An
FAA Adopt
MILSPEC
" FAA w11continue toevofuote ne w FFF as they become a 6bEle
"Perormedb AirForceMh hintery t
f y g gency ogreemen
FFF=Fluorine -free foam
oeree
N oAA= Na ti on sl Oefen se Auth on zst Ion Act
1/31(23
t EPA off—
f LondondEmergency Management
Figure 6-1. DOD and FAA Schedule for Replacing AFFF
At this time, the FAA has not determined whether to require exclusive use of fluorine -free firefighting
foams or to permit 14 CFR part 139 airports to use existing AFFF stockpiles once a final fluorine -free
firefighting foam MILSPEC is published and adopted. The FAA states that this will be heavily
dependent on how many foams meet the new MILSPEC, and there could be supply issues if there is
only one qualifying foam. Similarly, the FAA does not plan on issuing guidance to address cleanup and
disposal of existing AFFF stockpiles and residuals in firefighting equipment (U.S. EPA, 2022g).
Based on this information, EPA is not prioritizing a rulemaking on this category at this time. EPA will
continue to review airports to further understand the potential for discharge of PFAS-containing
wastewater from facilities that use AFFF and to monitor the industry's transition to fluorine -free foam.
EPA intends to provide updates on these activities in subsequent ELG program plans.
" The 2020 NDAA requires the Secretary of the Navy to publish new specifications for PFAS-free firefighting foams by
January 2023, the DOD to cease procurement of PFAS-containing products by October 2023, and the DOD to cease use of
AFFF at all military installations by October 2024, with limited exceptions.

6 Ongoing ELG Studies
6.3.2 Textile Mills Point Source Category (40 CFR part 410)
Based on information and data EPA collected as part of the Multi -Industry PFAS Study, EPA -
documented PFAS have been, and continue to be, used by textile mills in the United States to impart
outdoor gear, clothing, household fabrics, carpets, and other textile products with water, oil, soil, and
heat resistance; to improve cleanability of oil- and water -based stains; as a wetting or antifoaming agent
when dyeing and bleaching; and as a breathable moisture barrier to wind and rain. EPA determined that
most textile mills are not monitoring PFAS; however, limited discharge sampling data available
indicated that PFAS may be present (U.S. EPA, 2021c). EPA announced in Preliminary Plan 15 that it
would initiate a detailed study of wastewater discharges from the Textile Mills Point Source Category to
continue collecting and reviewing information and data on wastewater discharges of PFAS from textile
mills that historically or currently use PFAS.
Since September 2021, EPA has collected additional data on PFAS use and discharge from textile mills
from technical literature, textile manufacturing companies, EPA regions, and state and local wastewater
regulatory authorities. New information and data collected and reviewed by EPA since publication of
Preliminary Plan 15 is summarized below.
EPA conducted outreach to six state agencies or local wastewater treatment coordinators to discuss
available data on use, control, discharge of PFAS from textile mills to state waters and POTWs, and to
obtain state -level lists of permitted textile mills (U.S. EPA, 2022d; U.S. EPA, 2022e; U.S. EPA, 2022h;
U.S. EPA, 2022i; U.S. EPA, 2022j; U.S. EPA, 2022k). EPA met with W.L. Gore & Associates in
December 2021 to discuss PFAS use and discharges associated with performance textile manufacturing.
EPA determined that the company's textile mills use PFAS chemistry in the manufacture of textile
products, but all wastewater generated from these processes is captured and transferred offsite for
incineration (i.e., zero discharge of these process wastewaters) (U.S. EPA, 2022f). EPA attempted to
meet with representatives of two industry trade associations — the National Council of Textile
Organization (NCTO) and the Carpet and Rug Institute (CRI) — and their member companies to collect,
on a voluntary basis, information on the use and discharge of PFAS by textile mills; however, EPA has
been unsuccessful in arranging such a meeting.
EPA assessed the number and location of textile mills, characterized their manufacturing and discharge
practices, and identified pollutant control practices and technologies currently in place using national
EPA data sets (e.g., ECHO, DMR, TRI), state -submitted lists of permitted textile mills, and Davison's
2022 Textile Blue Book (an industry directory for textile mills, dyers, finishers, and suppliers)
(Davison's Publishing, 2022). Based on these data sources, EPA estimates the national population of
textile mills, dyers, and finishers in the United States is over 2,100 facilities.
To supplement limited available data, in November 2021 EPA used the authority granted in CWA
Section 308 to require nine textile manufacturing companies complete a survey to obtain information
related to PFAS use and import, PFAS in industrial wastewater discharges, wastewater treatment of
PFAS-containing industrial wastewater, and other information necessary for EPA's study of the
category. EPA sent the request to Brookwood Companies, Elevate Textiles, Milliken & Co., Mohawk
Industries, Mount Vernon Mills, Sage Automotive Interiors, Shaw Industries Group, Tex Tech
Industries, and W.L. Gore & Associates on November 30, 2021. EPA received timely responses from
6-7

6 Ongoing ELG Studies
these nine companies by February 2022, providing information on 92 of their facilities. An anonymized
summary of the responses is below:40
• 19 of 92 textile mills (21 percent) reported that they used PFAS in textile manufacturing in
2020, and responses led EPA to conclude that two additional facilities likely used PFAS in
their textile manufacturing. Responses indicated that side -chain fluorinated polymers and/or
fluoropolymer coatings are used for oil, water, and stain resistance.
• 18 of the 19 textile mills (95 percent) that reported PFAS use also reported either permanent
closure by 2026 or the intention to reduce or eliminate PFAS use by the end of 2026, through
product replacement or using alternative surface treatment technologies.
• Most textile mills that reported using PFAS generate and discharge wastewater from the
associated operations. Only two of these textile mills treat their effluent wastewater and
operate wastewater treatment systems demonstrated to be effective at removing or
eliminating PFAS in wastewater (e.g., granulated activated carbon).
• More than half of the textile mills that responded to the data request discharge their process
wastewater to a POTW. The existing ELG for the Textile Mills Point Source Category do not
establish pretreatment standards for any pollutant.
EPA continued to evaluate the available data on types and concentrations of PFAS in wastewater
discharged from textile mills. As described in Preliminary Plan 15, EPA previously identified a state
permitting authority data source containing PFAS monitoring data for textile mill effluent (MI EGLE,
2020b). EPA has since collected analytical data from four additional data sources that meet EPA's
acceptance criteria for inclusion in analyses for characterizing PFAS discharges in industrial wastewater
discharges:41
• Michigan EGLE 2022 PFAS monitoring results for direct and indirect discharging facilities
(U.S. EPA, 2022d).
• North Carolina Department of Environmental Quality 2019 PFAS monitoring order for one
textile mill (NC DEQ, 2022).
• Merrimack, New Hampshire, Wastewater Treatment Facility PFAS monitoring results for
one textile mill (U.S. EPA, 2022k).
• PFAS monitoring results submitted by five textile mills as part of the response to EPA's
November 2021 PFAS data request.
EPA included 358 PFAS sample results representing 10 facilities from the combined five data sources in
its analysis characterizing PFAS in textile mill effluent. Table 6-2 presents the average, minimum, and
maximum concentrations for each PFAS observed in effluent from the 10 textile mills. As illustrated in
the table, EPA estimated the average concentrations for short -chain perfluoroalkyl carboxylic acids
4' The sampled population is not statistically representative of the industry. EPA selected companies likely to be using PFAS
and discharging process wastewater to complete the PFAS data request.
4i EPA's acceptance criteria are presented in the memorandum "Development of the PFAS Wastewater Characterization
Analytical Database" (ERG, 2022a).

6—Ongoing ELG Studies
(PFCAs) and short -chain fluorotelomers were generally higher relative to perfluoroalkane sulfonic acids
(PFCAs) and long -chain PFCAs. Average PFAS concentrations in textile mill wastewater are lower than
average PFAS concentrations observed in effluent from PFAS manufacturers, chromium finishing
facilities, and landfills.
M

ELG Studies
Table 6-2. Textile Mills Effluent PFAS Concentrations
PFAS Subgroup
Analytee^b
Facilities
with Data
Quantified
Detections/Total
Sample Results
Concentration
Range (ppt)`
Average
Concentration
(ppt)`
Perfluorobutanoic acid (PFBA)
7
8/14
ND 343
32.7
Perfluoropentanoic acid (PFPeA)
7
9/14
ND — 1360
176
Perfluorohexanoic acid (PFHxA)
7
10/14
ND — 2340
227
Perfluoroheptanoic acid (PFHpA)
7
10/14
ND — 383
66.1
Perfluorooctanoic acid (PFOA)
10
17/29
ND — 1400
80.5
Perfluoroalkyl
Perfluorononanoic acid (PFNA)
7
10/14
ND — 65.9
6.27
carboxylic acids
Perfluorodecanoic acid (PFDA)
7
10/14
ND — 96.1
6.10
(PFCAs)
Perfluoroundecanoic acid (PFUnA)
7
5/14
ND — 22.6
1.36
Perfluorododecanoic acid (PFDoA)
7
4/14
ND — 19.4
0.757
Perfluorotridecanoic acid (PFTrA)
7
1/14
ND — 0.307
0.0439
Perfluorotetradecanoic acid (PFTeA)
7
0/14
ND
ND
Perfluorohexadecanoic acid (PFHxDA)
4
0/4
ND
ND
Perfluorooctadecanoic acid (PFODA)
4
0/4
ND
ND
Perfluorobutane sulfonic acid (PFBS)
7
3/14
ND-3
0.362
Perfluoropentane sulfonic acid (PFPeS)
7
1/14
ND — 1.2
0.171
Perfluorohexane sulfonic acid (PFHxS)
7
5/14
ND — 386
11.5
Perfluoroalkane sulfonic
acids (PFSAs)
Perfluoroheptane sulfonic acid (PFHpS)
7
3/14
ND — 7.32
0.383
Perfluorooctane sulfonic acid (PFOS)
10
17/29
ND — 600
39.4
Perfluorononane sulfonic acid (PFNS)
7
0/14
ND
ND
Perfluorodecane sulfonic acid (PFDS)
7
0/14
ND
ND
Perfluoroalkane
sulfonamides (FASAs)
Perfluorooctane sulfonamide (PFOSA)
3
5110
ND — 10.3
1.21
4:2 fluorotelomer sulfonic acid (4:2 FTSA)
2
0/7
ND
ND
Fluorotelomer sulfonic
acids (FTSAs)
6:2 fluorotelomer sulfonic acid (6:2 FTSA)
2
7/7
84 — 264
188
8:2 fluorotelomer sulfonic acid (8:2 FTSA)
2
3/7
ND — 5.48
0.643
N-Alkyl perfluoroalkane
N-methyl perfluorooctane sulfonamido acetic acid
(NMeFOSAA)
3
3/ 10
ND — 20.7
7.61
sulfonamido acetic acids
(FASAAs)
N-ethyl perfluorooctane sulfonamido acetic acid
(NEtFOSAA)
3
8/10
ND — 98.8
19.0
6-10

ELG Studies
Table 6-2. Textile Mills Effluent PFAS Concentrations
PFAS Subgroup
Analytee^b
Facilities
Quantified
Detections/Total
Concentration
Average
Concentration
with Data
Sample Results
Range (ppt)`
(ppt)`
Per- and polyfluoroalkyl
ether carboxylic acids
Hexafluoropropylene oxide dimer acid (HFPO-DA)
1
0/1
ND
ND
(PFECAs)
Sources: ERG, 2022b.
Abbreviations: ND — nondetection; ppt — parts -per -trillion (equivalent to nanograms per liter).
a — This table presents data for all HAS listed in the draft EPA Method 1633 analyte list for which sample results are available and meet EPA's acceptance criteria.
EPA also collected data for perfluorododecane sulfonic acid (PFDoS).
b —The table identifies short -chain PFCAs (57 carbons) and short -chain PFSAs (<5 carbons) in blue text, while long -chain PFCAs (>8 carbons) and long -chain PFSAs
(>6 carbons) are designated in red text.
c — In this analysis, EPA treated all nondetection results as zero for the purpose of estimating concentrations. All concentration values were rounded to three significant
figures.
6-11

6—Ongoing ELG Studies
EPA intends to expand this detailed study, pending resource availability, to allow for additional data
collection and outreach for this industry through the use of a mandatory, nationally representative
questionnaire.
6.3.3 Landfills Point Source Category (40 CFR part 445)
As described in Preliminary Plan 15, EPA initiated a detailed study of wastewater discharges from the
Landfills Point Source Category (40 CFR part 445), focusing on PFAS discharges in landfill leachates.
This was a result of the Landfills preliminary category review based on public comments received on
Preliminary ELG Plan 14 identifying landfill leachate effluent as a source of PFAS discharges to surface
waters and POTWs. The goals of this study were to understand the total number and location of landfills
discharging leachate across the United States, characterize PFAS in leachate effluent from regulated
landfills, and identify current wastewater treatment technologies and management practices at regulated
landfills. EPA used information collected from the study to evaluate whether the ELG for the Landfills
Point Source Category should be revised.
Since September 2021, EPA has collected publicly available information to construct a picture of the
industry's facilities, discharge practices, and control practices/technologies currently in place, including
their effectiveness for PFAS removal. EPA also collected information to begin determining whether
pollutants in landfill leachate pass through, interfere with, or are otherwise incompatible with POTW
operations; to identify documented environmental or human health impacts associated with landfill
discharges and exposure to PFAS, and to determine the proximity of landfill leachate discharges to
CWA Section 303(d) impaired waters and communities with environmental and demographic
characteristics of concern. EPA evaluated information from the following EPA data sources:
• ECHO database.
• RCRAInfo database.
• ICIS-NPDES Permit database.
• DMR data available via EPA's Water Pollutant Loading Tool.
• Landfill Methane Outreach Program (LMOP).
• TRI database.
EPA Office of Water conducted outreach and engagement with other EPA offices, EPA regional offices,
states, trade associations representing public and privately held landfills, and the Environmental
Research and Education Foundation (EREF). EPA conducted outreach to six state agencies to discuss
impacts of landfill leachate discharges on PFAS management in state waters and POTWs, and to obtain
state level lists of permitted landfills (U.S. EPA, 2022d; U.S. EPA, 2022e; U.S. EPA, 2022h; U.S. EPA,
2022i; U.S. EPA, 2022j; U.S. EPA, 20221).
EPA also engaged with industry stakeholders including the National Waste and Recycling Association
(NWRA), the Solid Waste Association of North America (SWANA), and the Association of State and
Territorial Solid Waste Management Officials (ASTSWMO) to understand their perspectives and
provide them with an opportunity to share insights on the industry. EPA additionally met with two
privately -owned landfill operating companies in the United States, Waste Management and Republic
Services, to further understand their operations and PFAS management practices.
6-12

6 Ongoing ELG Studies
EPA also collected analytical data from over 200 RCRA Subtitle D Non -Hazardous Waste Landfills to
characterize PFAS concentrations and species distributions in landfill leachate and gathered information
from published literature, including journal articles and federal and state reports.
The following summarizes the study findings to date:
• In the 2000 Landfills ELG technical development document, EPA estimated there were 1,662
landfills that collect landfill -generated wastewater, comprising approximately 16 percent of
landfills nationwide. A majority of the landfills subject to ELG (81 percent) are RCRA
Subtitle D Non -Hazardous Waste Landfills (EPA, 2000).
• In 2000, EPA established BPT, BAT, BCT, and NSPS limitations for landfills that directly
discharge wastewater to surface waters; EPA did not establish pretreatment standards (PSES
and PSNS) for landfills that indirectly discharge via POTWs (see 65 FR 3048, January 19,
2000).
• Landfills are essential utilities and the ultimate destination of many discarded consumer and
industrial products containing PFAS. PFAS presence in landfill leachate is caused by the use
and disposal of products manufactured with PFAS.
• EPA evaluated discharge data from over 200 landfills from across the country and found
PFAS present in the leachate at over 95 percent of the landfills. PFAS detections included 63
different PFAS with average concentrations for an individual compound as high as 14,000
parts -per -trillion (ppt) (ERG, 2022c).
• Landfill leachate, while a challenging matrix, is likely able to be treated by typical PFAS
treatment technologies such as granular activated carbon, ion exchange, and reverse osmosis.
• EPA estimates that approximately 13,200,000 individuals live within one mile of a landfill.
In these communities, the average median income is $48,100 and on average 31 percent of
the population belongs to a minority group. EPA calculated the state percentiles of all
landfill -proximal census block groups for demographic and environmental indicators
available through EJScreen. The median percentile for all indicators exceeded the state
average except for the percentage of the population under five years old and for ozone levels.
At least two environmental indicators exceed the 80th percentile in 45 percent of these
communities.
Based on information and data collected through the Landfill Leachate Detailed Study, the development
of effluent guidelines and pretreatment standards for landfills that discharge their leachate is warranted.
Therefore, EPA intends to revise the existing Landfills Point Source Category (40 CFR part 445) ELG
to address PFAS discharge from these landfills pending resource availability. Once EPA develops the
schedule for this rulemaking, it will be published in EPA's Regulatory Agenda.
6.3.4 Pulp, Paper and Paperboard Point Source Category (40 CFR part 430)
As described in EPA's Multi -Industry PFAS Study, PFAS have been, and continue to be, used by pulp,
paper, and paperboard facilities in the United States as a coating or additive to provide water, oil, and
grease resistance to food contact papers and other specialty paper products. EPA collected data from one
trade association and eight major companies from this category. Based on these data, EPA determined
6-13

6 Ongoing ELG Studies
that only a small subset of facilities were actively applying PFAS, the production of paper products
containing PFAS at these facilities was less than 0.1 percent of the industry's overall production, and the
industry is planning to eliminate use of PFAS by end of 2023.
EPA announced in Preliminary Plan 15 that it would continue to review the Pulp, Paper, and Paperboard
Point Source Category to further understand the potential for wastewater discharges of PFAS from
facilities that historically or currently use PFAS and to monitor the industry's anticipated phase -out of
PFAS. While developing ELG Plan 15, EPA has collected additional data on PFAS use and discharge
from pulp, paper, and paperboard facilities from the United States Food and Drug Administration
(FDA), a trade association, paper manufacturing companies, and state regulatory authorities. New
information and data collected by EPA since publication of Preliminary Plan 15 are summarized below.
In April 2022, EPA met with the FDA to discuss use of PFAS as food contact substances. All food
contact substances must be authorized by the FDA prior to marketing and typically come through the
Food Contact Substance Notification Program, under which the FDA reviews available migration,
exposure, and human health risk data to ensure a food contact substance is safe for its intended use prior
to approving it for use on the market. Manufacturers of chemicals authorized as a food contact
substances are permitted to market and sell these chemicals to food contact paper and packaging
producers, who use them in products with food contact applications. Since the 1960s, the FDA has
authorized several PFAS for use as food contact substances including certain long -chain PFAS (PFOA
and PFOS have never been authorized) and more recently short -chain fluorotelomer PFAS and
polyfluorinated polymers. FDA provided EPA with a list of all effective Food Contact Notifications
containing PFAS that the FDA had authorized, as of July 2022, as grease -proofing agents used in food
contact paper and paperboard. EPA determined that, as of July 2022, FDA had authorized 35 effective
Food Contact Notifications containing PFAS submitted by ten manufacturing companies; however, the
manufacturers had voluntarily ceased nearly half of these Food Contact Notifications for introduction
into interstate commerce and delivery (FDA, 2022). FDA states that three manufacturers have agreed to
a complete market phase -out of PFAS containing or degrading to 6:2 FTOH by December 31, 2023. The
market phase -out is a response to FDA research that raised questions about human health risks for 6:2
FTOH.42 While companies are permitted to use other authorized PFAS-based food contact substances,
the FDA expects that most manufacturers will seek to replace PFAS with authorized nonfluorinated
replacements in response to public pressure and consumer demand for PFAS-free chemistries in food
contact paper and packaging (U.S. EPA, 2022m). These expectations are consistent with EPA's findings
that pulp, paper, and paperboard companies plan to eliminate PFAS use by end of 2023 and transition to
non-PFAS chemistries for oil and grease resistance in food contact paper and packaging.
EPA continued to conduct outreach and collect data on PFAS use and phase -out from this industry. In
March 2022, the American Forest and Paper Association (AF&PA), a national trade association for the
forest, pulp, and paper industry whose 39 member companies represent about 87 percent of pulp, paper,
and paper -based packaging and tissue production capacity in the United States, inquired to its member
companies regarding ongoing PFAS use in pulp, paper, and paperboard manufacture and transition to
PFAS-free chemicals. These data indicated that most AF&PA member companies that previously
42 Additional information on authorized uses of PFAS in food contact applications and this voluntary phase -out is available
on the FDA's website at https://www.fda.gov/food/chemical-contaminants-food/authorized-uses-pfas-food-contact-
applications
6-14

6 Ongoing ELG Studies
reported PFAS use in calendar year 2020 have since ceased all PFAS use at their pulp, paper, and
paperboard facilities. As of July 2022, EPA is aware of five pulp and paper mills in the United States, all
operated by Ahlstrom-Munksj6, that continue to use PFAS. All five of these facilities are expected to
complete phase -out of all PFAS-based production by the end of 2023. PFAS use by AF&PA member
companies remains limited to food contact substances authorized by the FDA. EPA determined that all
companies that have joined AF&PA since September 2021 do not intentionally add PFOA, PFOS, or
any other PFAS in pulp, paper, or paperboard products (U.S. EPA, 2022n).
To respond to public comments on Preliminary Plan 15, EPA gathered information regarding whether
the recycle of PFAS-treated paper products may result in the transfer, and ultimately discharge, of PFAS
in wastewater. Based on AF&PA data, EPA estimates that 78 percent of the approximately 340 pulp and
paper mills operating in the United States use recovered fiber in the manufacture of pulp, paper, and
paperboard products. However, the service life of PFAS-treated food contact paper and packaging is
brief and the recycle rates for these products is low. EPA determined less than 15 percent of the United
States population had access to recycling for direct contact foodservice paper and packaging in 2021
and, therefore, most food contact paper and packaging is thrown in the trash at the point of use (U.S.
EPA, 2022n). Further, most member companies are targeting paper products that are as close as possible
to virgin material for recycle (i.e., not products previously treated with PFAS). Some recovered fiber
mills have zero tolerance for food contamination and will not accept any food contact papers and
packaging for recycle. Because the production of PFAS-treated paper products is low (and continues to
decrease) and most recovered fiber is not generated from PFAS-treated paper products, it is unlikely that
recovered fiber facilities would be a significant source of PFAS discharges. Based on pulp and paper
mill effluent data collected by the National Council for Air and Stream Improvement (NCASI), EPA
determined that PFAS concentrations in effluent from mills using virgin pulp and mills using recovered
fiber are low and that these data also show no significant difference in type or quantity of PFAS between
the two types of facilities (U.S. EPA, 2022n; ERG, 2022b).
EPA continued to evaluate the available data on types and concentrations of PFAS in wastewater
discharged from pulp, paper, and paperboard facilities. As described in Preliminary Plan 15, EPA
previously identified three state permitting authority data sources containing PFAS monitoring data for
pulp and paper mill effluent (MI EGLE, 2020b; MI EGLE, 2020c; VT DEC, 2020; U.S. EPA, 2021e).
EPA has since collected analytical data from four additional data sources that meet EPA's acceptance
criteria for inclusion in analyses for characterizing PFAS in industrial wastewater discharges:43
• Michigan EGLE 2022 PFAS monitoring results for direct and indirect discharging facilities
(U.S. EPA, 2022d).
• Wisconsin Department of Natural Resources 2020 investigative order PFAS monitoring data
for 40 industrial facilities and 78 POTWs (U.S. EPA, 2022e).
• New Hampshire Department of Environmental Services submission of PFAS sample results
from the state's Environmental Monitoring Database (U.S. EPA, 20221).
43 EPA's acceptance criteria are presented in the memorandum "Development of the PFAS Wastewater Characterization
Analytical Database" (ERG, 2022a).
6-15

6 Ongoing ELG Studies
• AF&PA data submission of NCASI-collected effluent samples for six unidentified pulp and
paper mills (U.S. EPA, 2022n).
EPA included 4,664 PFAS sample results representing 52 facilities from the combined seven data
sources in its analysis characterizing PFAS in pulp, paper, and paperboard facility effluent. Table 6-3
presents the average, minimum, and maximum concentrations for each PFAS observed in effluent from
the 52 pulp, paper, and paperboard facilities. As illustrated in the table, EPA estimated the average
concentrations for short -chain PFCAs were generally higher relative to PFSAs and long -chain PFCAs.
Despite the phase -out of long -chain PFAAs, some pulp, paper, and paperboard facilities still report
detectable levels of PFOA and PFOS in their wastewater.
6-16

ELG Studies
Table 6-3. Pulp, Paper, and Paperboard Effluent PFAS Concentrations
PFAS Subgroup
Analytee°b
Facilities with Data
Quantified
Detections/ Total
Sample Results
Concentration
Range (ppt)`
Average
Concentration (ppt)`
Perfluorobutanoic acid (PFBA)
26
32/43
ND — 638
38.5
Perfluoropentanoic acid (PFPeA)
26
33/43
ND — 246
22.7
Perfluorohexanoic acid (PFHxA)
26
41/43
ND — 640
33.1
Perfluoroheptanoic acid (PFHpA)
26
39/43
ND — 206
15.2
Perfluorooctanoic acid (PFOA)
52
168/229
ND — 680
22.2
Perfluoroalkyl
Perfluorononanoic acid (PFNA)
38
34/57
ND — 52.6
4.08
carboxylic acids
Perfluorodecanoic acid (PFDA)
26
15/43
ND — 19.7
0.969
(PFCAs)
Perfluoroundecanoic acid (PFUnA)
26
9/43
ND — 15.3
0.423
Perfluorododecanoic acid (PFDoA)
26
6/43
ND — 20.3
0.469
Perfluorotridecanoic acid (PFTrA)
26
5/43
ND — 24.9
0.503
Perfluorotetradecanoic acid (PFTeA)
26
6/43
ND — 23
0.465
Perfluorohexadecanoic acid (PFHxDA)
3
0/7
ND
ND
Perfluorooctadecanoic acid (PFODA)
3
2/7
ND — 14.6
2.91
Perfluorobutane sulfonic acid (PFBS)
38
36/57
ND — 254
4.84
Perfluoropentane sulfonic acid (PFPeS)
25
4/42
ND — 1.43
0.122
Perfluorohexane sulfonic acid (PFHxS)
38
32/57
ND — 59
1.98
Perfluoroalkane sulfonic
acids (PFSAs)
Perfluoroheptane sulfonic acid (PFHpS)
23
4/40
ND — 0.28
0.03
Perfluorooctane sulfonic acid (PFOS)
52
161/231
ND — 810
16.1
Perfluorononane sulfonic acid (PFNS)
25
1/42
ND — 2.17
0.022
Perfluorodecane sulfonic acid (PFDS)
26
3/43
ND — 5.17
0.117
Perfluoroalkane
sulfonamides (FASAs)
Perfluorooctane sulfonamide (PFOSA)
25
1/42
ND — 17.5
0.7
4:2 fluorotelomer sulfonic acid (4:2 FTSA)
23
0/33
ND
ND
Fluorotelomer sulfonic
acids (FTSAs)
6:2 fluorotelomer sulfonic acid (6:2 FTSA)
24
19/36
ND — 284
8.7
8:2 fluorotelomer sulfonic acid (8:2 FTSA)
24
6/36
ND — 0.821
0.119
Perfluoroalkane
sulfonamido ethanols
N-methyl perfluorooctane sulfonamide
(NMePFOSA)
18
0/22
ND
ND
(FASEs),
perfluoroalkane
N-ethyl perfluorooctane sulfonamide
(NEWFOSA)
18
0/22
ND
ND
6-17

ELG Studies
Table 6-3. Pulp, Paper, and Paperboard Effluent PFAS Concentrations
PFAS Subgroup
Analytee°b
Facilities with Data
Quantified
Detections/ Total
Concentration
Average
Sample Results
Range (ppt)`
Concentration (ppt)`
sulfonamido acetic acids
N-methyl perfluorooctane sulfonamido
18
2/22
ND — 6.62
0.459
(FASAAs), and N-Alkyl
ethanol (NMeFOSE)
FASAAs
N-ethyl perfluorooctane sulfonamido
18
0/22
ND
ND
ethanol (NEtFOSE)
N-methyl perfluorooctane sulfonamido
26
12/43
ND — 12
1.56
acetic acid (NMeFOSAA)
N-ethyl perfluorooctane sulfonamido
26
20/44
ND — 46
4.31
acetic acid (NEtFOSAA)
Hexafluoropropylene oxide dimer acid
20
10/25
ND — 3.14
0.392
(HFPO-DA)
Per- and polyfluoroalkyl
4 8-dioxa-3H-perfluorononanoic acid
ether carboxylic acids
(DONA)
17
0/17
ND
ND
(PFECAs)
Sodium dodecafluoro-3H-4, 8-
2
0/6
ND
ND
dioxanonanoate (NaDONA)
9-chlorohexadecafluoro-3-oxanone-l-
16
0/16
ND
ND
Per- and polyfluoroalkyl
sulfonic acid (90-1`173ONS/17-5313 Major)
ether sulfonic acids
11-chloroeicosafluoro-3-oxaundecane-l-
(PFESAs)
sulfonic acid (11C1-PF3OudS/F-53B
16
0/16
ND
ND
Minor)
Sources: ERG, 2022b.
Abbreviations: ND — nondetection; ppt — parts -per -trillion (equivalent to nanograms per liter).
A — This table presents data for all PFAS listed in draft EPA Method 1633 analyte list for which sample results are available and meet EPA's acceptance criteria. EPA
also collected data for 10:2 fluorotelomer sulfonic acid (10:2 FTSA) and perfluorododecane sulfonic acid (PFDoS).
B —The table identifies short -chain PFCAs (<7 carbons) and short -chain PFSAs (<5 carbons) in blue text, while long -chain PFCAs (>8 carbons) and long -chain PFSAs
(>6 carbons) are designated in red text.
C — In this analysis, EPA treated all nondetection results as zero for the purpose of estimating concentrations. All concentration values are rounded to three significant
figures.

6 Ongoing ELG Studies
Based on this information, EPA is not prioritizing a rulemaking on the Pulp, Paper and Paperboard Point
Source Category at this time. EPA will continue to review this category with particular attention to
understanding the potential for legacy discharges from these facilities after the industry's transition to
PFAS-free additives. EPA intends to provide updates on these activities in subsequent ELG program
plans.
6.3.5 POTW Influent PFAS Study
EPA's PFAS Strategic Roadmap identifies the unique challenges posed by PFAS contamination and
states its approach includes a "deeper focus to preventing PFAS from entering the environment in the
first place —a foundational step to reducing the exposure and potential risks of future PFAS
contamination." EPA's PFAS Strategic Roadmap and Preliminary Plan 15 further discuss the ubiquitous
nature of PFAS and the paucity of PFAS monitoring data from industrial sources. EPA has reviewed the
readily available PFAS monitoring data to date and continues to look for additional sources of PFAS.
For many industries, PFAS monitoring of effluent discharges has not yet been conducted. These
characterization data would fill a crucial data gap in the agency's efforts to establish technology -based
limits for PFAS. Pending resource availability, EPA intends to initiate a POTW Influent PFAS Study,
which will focus on collecting nationwide data on industrial discharges of PFAS to POTWs. This
includes indirect discharges from categories recently reviewed and categories identified but for which
insufficient PFAS monitoring data exists.
EPA's intent is to partner with wastewater treatment facilities to conduct this national sampling effort.
Recent improvements to analytical methods; including Draft EPA Method 1633, which measures 40
PFAS in a number of environmental matrices, and Draft EPA Method 1621, which measures Adsorbable
Organic Fluorine (AOF) (a surrogate for the presence of PFAS), in wastewater. EPA plans to collect
samples of PFAS and AOF from industrial sources upstream of POTWs, before mixing and dilution
from other wastestreams make it difficult to identify the source of the PFAS. As part of initiating this
effort, EPA intends to develop an Information Collection Request (ICR) and a sampling strategy
providing more details about the POTW Influent PFAS Study.
6-19

7 Ongoing ELG Rulemaking
7. ONGOING ELG RULEMAKINGS
This section summarizes the status of EPA's ongoing ELG rulemaking efforts.
7.1 Steam Electric Power Generating Point Source Category (40 CFR part 423)
EPA promulgated new ELG for the Steam Electric Power Generating Point Source Category in 2015
and revised them in 2020. The rules are subject to legal challenge in the U.S. Court of Appeals for the
Fifth and Fourth Circuits. The legal challenges to the 2015 ELG for flue gas desulfurization (FGD)
wastewater and bottom ash (BA) transport water have been held in abeyance since EPA commenced its
reconsideration rulemaking, which EPA completed in August 2020. The 2020 Rule established revised
effluent limitations for FGD wastewater and BA transport water. Meanwhile, the Court proceeded to
hear claims on aspects of the 2015 rule that were not the subject of EPA's reconsideration rulemaking.
On April 12, 2019, the U.S. Court of Appeals for the Fifth Circuit struck down as unlawful aspects of
the 2015 ELG pertaining to effluent limitations for "legacy" wastewater and combustion residual
leachate. The Court vacated those portions of the 2015 ELG rule and remanded them to the agency.
Subsequent to the 2020 Rule, on July 26, 2021, EPA announced it was initiating a new supplementary
rulemaking to strengthen certain wastewater pollution discharge limitations for coal power plants that
use steam to generate electricity. EPA undertook a science -based review of the 2020 Rule under
Executive Order 13990, finding that there are opportunities to strengthen certain wastewater pollution
discharge limitations. For example, treatment systems using membranes have advanced since the 2020
Rule's issuance and continue to rapidly advance as an effective option for treating a wide variety of
industrial pollution, including from steam electric power plants. EPA expects this technology to
continue advancing and the agency will evaluate its availability (as defined in the CWA) as part of the
new rulemaking. While the agency pursues this new supplementary rulemaking, the current regulations
are being implemented and enforced. These requirements provide significant environmental protections
relative to a 1982 rule that was previously in effect. The 2015 and 2020 rules are leading to better
control of water pollution from power plants while reducing the cost of controls such as biological
treatment systems and membrane treatment systems. The agency's approach is securing progress made
by the 2015 and 2020 rules while the agency considers more stringent requirements.
EPA continues to work on the new supplementary rulemaking announced in July 2021, including
continuing to analyze information and data, such as performance data and costs related to various
pollution control technologies for treating and controlling steam electric wastewaters. EPA anticipates
signing a notice of proposed rulemaking by early 2023.
7.2 Meat and Poultry Products Point Source Cateiory (40 CFR part 432)
EPA initially promulgated the MPP ELG in 1974 and amended the regulations in 2004. The current
regulation covers wastewater directly discharged by meat and poultry slaughterhouses and further
processors as well as independent renderers. The technology basis for existing non -small direct
dischargers includes biological treatment with partial denitrification. The current MPP ELG does not
include pretreatment standards for any facilities indirectly discharging process wastewater. In the
Effluent Guidelines Program Plan 14 (January 2021), EPA announced a detailed study of the MPP
Category. The MPP Category ranked among the top two industrial categories in EPA's cross -industry
review of nutrients in industrial wastewater. During the study, EPA evaluated publicly available data for
7-1

7 Ongoing ELG Rulemaking
direct discharging facilities, which make up a small portion of the industry, and data from POTWs. The
record indicated that in addition to having high nutrient discharges, indirect discharging MPP facilities
may be causing problems for POTWs. In addition, the data showed that some MPP facilities are already
removing nutrients and achieving effluent concentrations below the current ELG requirements. In
Preliminary Program Plan 15, EPA summarized the detailed study, indicated that a revision to the ELG
may be appropriate, and stated that EPA would be initiating a rulemaking to revise the MPP ELG.
A survey of the current MPP industry is critical for the rulemaking process and necessary for EPA to
determine what revisions may be appropriate. Data collection activities will provide a robust data set
that characterizes wastewater generation, treatment, and discharge from MPP facilities. As part of the
rulemaking process, EPA processed and received Office of Management and Budget approval in June
2022 for an ICR to collect financial and engineering data from MPP facilities. With input from
stakeholders, EPA's Office of Water has developed a short, census questionnaire and a more detailed
questionnaire that was sent to facilities in fall 2022. EPA is currently administering both of these
questionnaires to facilities engaging in meat and poultry processing, including those currently regulated
under 40 CFR part 432 and facilities that discharge wastewater directly to waters of the United States,
indirectly discharge wastewater, or do not discharge wastewater. EPA is administering both
questionnaires via a web -based platform, Qualtrics Survey Software (Qualtrics). Based on data primarily
from the U.S. Department of Agriculture Food Safety and Inspection Service and ICIS-NPDES, EPA
estimates the MPP industry has between 7,000 and 8,000 facilities. Because no one data source collects
information from all MPP facilities, the exact number is unknown, and the survey questionnaires will
help determine the number of facilities. In addition, EPA has conducted site visits of facilities that
represent meat and poultry processors across current effluent guidelines subcategories, including those
that treat process wastewater with high-level treatment technologies.
EPA intends to select up to 10 facilities for multiday sampling to fill any data gaps remaining from the
questionnaire data collection. The purpose of the multiday sampling is to characterize pollutants in raw
wastewaters prior to treatment, as well as to document wastewater treatment plant performance.
Selection of facilities for multiday sampling will be based on an analysis of information collected during
the site visits, as well as the following criteria:
• The facility performs meat and/or poultry slaughtering and/or further processing operations
representative of MPP facilities.
• The facility uses in -process treatment and/or end -of -pipe treatment technologies that EPA
may consider for technology option selection.
• Compliance monitoring data for the facility indicates that it is among the better performing
treatment systems or that it employs a wastewater treatment process for which EPA sought
data for option selection.
EPA intends to propose this regulation in December 2023.
7-2

7 Ongoing ELG Rulemaking
7.3 Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category: PFAS
Manufacturers and Formulators (40 CFR part 414)
EPA announced in Preliminary Plan 15 and in the PFAS Strategic Roadmap that it will revise the ELG
for the OCPSF Point Source Category (40 CFR part 414) to address wastewater discharges of PFAS
from PFAS manufacturing facilities. Based on information and data collected, EPA determined that
PFAS have been, and continue to be, manufactured and used by PFAS manufacturing facilities in the
United States.
In December 2021, EPA delivered a data request under Section 308 of the CWA to obtain information
and data from the industry that will provide a robust data set that characterizes wastewater generation,
treatment, and discharge from PFAS manufacturing facilities. In addition, EPA has conducted virtual
site visits of facilities that manufacture PFAS and treat the process wastewater with advanced
wastewater treatment technologies.
Based on data collected from outreach and the Section 308 questionnaire, EPA sampled wastewater at a
number of facilities in 2022. The purpose of the sampling was to characterize pollutants in raw
wastewaters prior to treatment, as well as to document wastewater treatment performance. Selection of
facilities for sampling is based on an analysis of information collected during the site visits and the
responses to the data request. Pending resource availability, EPA intends to publish a proposed rule in
the spring of 2024 and intends to continue to evaluate the need to develop regulations to address PFAS
discharges from PFAS formulators/processors.
7.4 Metal Finishing (40 CFR part 433) and Electroplating (40 CFR part 413) Point Source
Categories
EPA announced in Preliminary Plan 15 and in the PFAS Strategic Roadmap that it will revise the ELG
for the Metal Finishing and Electroplating Point Source Categories (40 CFR part 433 and part 413,
respectively) to address wastewater discharges of PFAS. Based on data collected to date, EPA has
identified facilities conducting operations that use or may have used hexavalent chromium, including
chromium electroplating, chromium anodizing, chromate conversion coating, and chromic acid etching
(referred to as chrome finishing facilities), as the most significant source of PFAS in the Metal Finishing
and Electroplating Point Source Categories. Existing data demonstrate that these facilities have
concentrations of PFOS in their effluent that is, on average, several orders of magnitude higher than
metal finishing and electroplating facilities that do not conduct chrome finishing.
PFAS are present in wastewater from chrome finishing facilities primarily due to the use of PFAS
containing chemical fume suppressants to mitigate emissions and inhalation exposure of hexavalent
chromium. A revision to the National Emission Standards for Hazardous Air Pollutants (NESHAP)
phased out the use of PFOS in 2015; however, PFOS is still detected in wastewater from facilities that
have used PFOS-based chemical fume suppressants in the past. As a result of the phase -out, many
facilities switched to a chemical fume suppressant containing a different PFAS: 6:2 fluorotelomer
sulfonic acid (6:2-FTSA). This has been detected at high levels in the wastewater from chrome finishing
facilities that use it.
EPA has learned that: (1) it is possible to successfully mitigate hexavalent chromium emissions using
commercially available chemical fume suppressants that do not contain any PFAS; (2) many facilities
7-3

7 Ongoing ELG Rulemaking
could switch their operations to using trivalent chromium, which does not require the use of chemical
fume suppressants; (3) a number of facilities are successfully using granular activated carbon to treat
PFOS in wastewater to meet water quality limitations and granular activated carbon may be effective for
other PFAS in metal finishing and electroplating wastewater; and (4) other technologies exist or are in
development that may be able to treat PFAS in wastewater from chrome finishing facilities, including
membranes, ion exchange, and PFAS destruction techniques.
Pending available resources, EPA intends to collect the data necessary to revise these ELGs, which will
include conducting a survey of the industry and analysis of wastewater samples in the coming year. EPA
intends to publish a proposed rule by the end of 2024.
7-4

8 References for Plan 15
8. REFERENCES FOR PLAN 15
Davison's Publishing. Davison's Publishing Co. LLC. 2022. List of Textile Mills, Dyers, &
Finishers - Davison's 2022 Textiles Blue Book. DCN PFAS00868.
2. ERG. 2021a. Eastern Research Group, Inc. 2019 DMR Database. (September). EPA-HQ-
OW-2021-0547-0271.
3. ERG. 2021b. Eastern Research Group, Inc. Key Findings from Preliminary Treatment
Reviews: Nutrient Removal. EPA-HQ-OW-2021-0547. DCN 11105.
4. ERG. 2021 c. Eastern Research Group, Inc. Preliminary Technology Review: Suspended
Growth Wastewater Treatment Systems. (September). EPA-HQ-OW-2021-0547. DCN
11023.
5. ERG. 2021 d. Eastern Research Group, Inc. Preliminary Technology Review: Membrane
Wastewater Treatment Systems. (September). EPA-HQ-OW-2021-0547. DCN 11024.
6. ERG. 2022a. Eastern Research Group, Inc. Memorandum: Development of the PFAS
Wastewater Characterization Analytical Database (October 2022). DCN PFAS00844.
7. ERG. 2022b. Eastern Research Group, Inc. PFAS Wastewater Characterization Analytical
Database (October 2022). DCN PFAS00843.
8. ERG. 2022c. Eastern Research Group, Inc. Landfill Leachate PFAS Data and Results
Summary from the PFAS Wastewater Characterization Analytical Database (October
2022). DCN PFAS00845.
9. FAA. 2021a. United States Federal Aviation Administration. National Part 139 CertAlert
No 21-01: Aqueous Film Forming Foam (AFFF) Testing at Certificated Part 139 Airports.
(June 1). EPA-HQ-OW-2021-0547-0216. DCN PFAS00045.
10. FAA. 2021b. United States Federal Aviation Administration. Program Guidance Letter 21-
01: Extension of Eligibility for Stand -Alone Acquisition of Input -based Testing Equipment
and Truck Modification. (October 5). DCN PFAS0093IA5.
11. FAA. 2022. United States Federal Aviation Administration. Fluorine -Free Foam Testing
Report. (July 28). DCN PFAS00874. Available online at
https://www.airporttech.tc.faa. gov/Products/Airport-Safety-Papers-Publications/Airport-
Safety-Detail/fluorine-free-foam-testing
12. FDA. 2022. United States Food and Drug Administration. Inventory of Effective Food
Contact Substance (FCS) Notifications. Available online at
https://www.fda. gov/food/packaging-food-contact-substances-fcs/inventory-effective-food-
contact-sub stance-fc s-notifications
13. GHige et al. 2020. GHige, J., Scheringer, M., Cousins, I., DeWitt, J., Goldenman, G.,
Herzke, D., Lohmann, R., Ng, C., Trier, X., Wang, Z. An overview of the uses of per- and
polyfluoroalkyl substances (PFAS). (30 October 2020). Environmental Sciences: Processes
& Impacts, 22, 2345-2373. EPA-HQ-OW-2021-0547-0297. DCN PFAS00104. Available
online at https://doi.org/l0.1039/DOEM00291G
:

8 References for Plan 15
14. MI EGLE. 2020a. Michigan Department of Environment, Great Lakes, and Energy.
Michigan Industrial Pretreatment Program (IPP) PFAS Initiative: Identified Industrial
Sources of PFOS to Municipal Wastewater Treatment Plants. (August 2020). EPA-HQ-
OW-2021-0547-0403. DCN PFAS00161.
15. MI EGLE. 2020b. Michigan Department of Environment, Great Lakes, and Energy. PFAS
Effluent Sample Results for Indirect Discharge Facilities. (January 24). EPA-HQ-OW-
2021-0547-0402. DCN PFAS00160.
16. MI EGLE. 2020c. Michigan Department of Environment, Great Lakes, and Energy. PFAS
Effluent Sample Results for Direct Discharge Facilities. (January 24). EPA-HQ-OW-2021-
0547-0401. DCN PFAS00159.
17. NC DEQ. 2022. 2019 PFAS Investigation Order Results for Lear Corporation Textile Mill
in Wilmington, North Carolina (NPDES No. NC0002305). (February 25). DCN
PFAS00879.
18. OECD, 2022. Per- and Polyfluoroalkyl Substances and Alternatives in Coatings, Paints
and Varnishes (CPVs): Report on the Commercial Availability and Current Uses.
(January). DCN 11133.
19. U.S. EPA. 1975. United States Environmental Protection Agency. Development Document
for Effluent Limitations Guidelines and New Source Performance Standards for the Oil
Base Solvent Wash Subcategories of the Paint Formulating and the Ink Formulating Point
Source Category. (July). DCN 11134.
20. U.S. EPA. 1982. United States Environmental Protection Agency. Development Document
for Effluent Limitations Guidelines and Standards for the Leather Tanning and Finishing
Point Source Category (EPA 440/1-82/016). (November). DCN 11183.
21. U.S. EPA. 1984. United States Environmental Protection Agency. Development Document
for Effluent Limitations Guidelines and Standards for the Plastics Molding and Forming
Point Source Category (December). DCN 11136.
22. U.S. EPA. 2000. United States Environmental Protection Agency. Development Document
for Final Effluent Limitations Guidelines and Standards for the Landfills Point Source
Category. (January). EPA-821-R-99-019. EPA-HQ-OW-2021-0547. PFAS00183.
23. U.S. EPA. 2012. United States Environmental Protection Agency. Technical Users
Background Document for the Discharge Monitoring Report (DMR) Pollutant Loading
Tool. (January). EPA-HQ-OW-2014-0170-0058. Available online at:
https: Hecho.0a. gov/trends/loading-tool/water-pollution-
search/results/? s=546008 a2bc 3 d6f6e2fdOce45 cb78 9d7d3 5 c77c40.
24. U.S. EPA 2019a. United States Environmental Protection Agency. Preliminary Effluent
Guidelines Program Plan 14. (October). EPA-821-R-19-005. EPA-HQ-OW-2018-0618-
0572. Available online at https://www.epa.gov/eg/effluent-guidelines-plan-14-documents.
25. U.S. EPA. 2019b. United States Environmental Protection Agency. The EPA's Review of
Per- and Polyfluoroalkyl Substances (PFAS) in Industrial Wastewater Discharge. (October
1). EPA-821-R-19-006. EPA-HQ-OW-2021-0547-0359. DCN PFAS00129.

8 References for Plan 15
26. U.S. EPA. 2021 a. United States Environmental Protection Agency. Effluent Guidelines
Program Plan 14. (January). EPA-HQ-OW-2018-0618-0658.
27. U.S. EPA. 2021b. United States Environmental Protection Agency. Preliminary Effluent
Guidelines Program Plan 15. (September). EPA-821-R-21-003. EPA-HQ-OW-2021-0547-
0367. Available online at https://www.epa.gov/system/files/documents/2021-09/ow-prelim-
elg-plan-15_508.pdf
28. U.S. EPA. 2021c. United States Environmental Protection Agency. Multi -Industry Per- and
Polyfluoroalkyl Substances (PFAS) Study - 2021 Preliminary Report. (September). EPA-
82 1 -R-21-004. EPA-HQ-OW-2021-0547-0361. DCN PFAS00001. Available online at
https://www.epa.gov/system/files/documents/2021-09/multi-industry-pfas-
study preliminary-2021-report _508_2021.09.08.pdf
29. U.S. EPA. 2021d. United States Environmental Protection Agency. PFAS Strategic
Roadmap: EPA's Commitments to Action 2021-2024. (October 18). DCN PFAS00866.
Available online at h!tps://www.epa.gov/pfas/pfas-strategic-roadmap-epas-commitments-
action-2021-2024.
30. U.S. EPA. 2021e. United States Environmental Protection Agency. Notes from Meeting
with Georgia-Pacific, LLC and American Forest and Paper Association. (July 9). EPA-HQ-
OW-2021-0547-0283. DCN PFAS00080.
31. U.S. EPA. 2022a. United States Environmental Protection Agency. EPA's 2021 Annual
Review of Industrial Wastewater Discharges (November). EPA-HQ-OW-2021-0547. DCN
11139.
32. U.S. EPA. 2022b. United States Environmental Protection Agency. 2021 Preliminary
Review of Industrial Point Source Categories. (November). EPA-HQ-OW-2021-0547.
DCN 11137.
33. U.S. EPA. 2022c. United States Environmental Protection Agency. Response to Comments
for the Preliminary Effluent Guidelines Program Plan 15. (November). EPA-HQ-OW-
2021-0547. DCN 11138.
34. U.S. EPA. 2022d. United States Environmental Protection Agency. Notes from January 11,
2022 Meeting with Michigan Department of Environment, Great Lakes, & Energy. (April
25). DCN PFAS00924.
35. U.S. EPA. 2022e. United States Environmental Protection Agency. Notes from January 10,
2022 Meeting with Wisconsin Department of Natural Resources (WI DNR). (April 6).
DCN PFAS00915.
36. U.S. EPA. 2022f. United States Environmental Protection Agency. Notes from December
8, 2021 Meeting with W.L. Gore & Associates, Inc (Gore). (January 13). DCN
PFAS00853.
37. U.S. EPA. 2022g. United States Environmental Protection Agency. Notes from March 15,
2022 Meeting with the Federal Aviation Administration (FAA). (July 19) DCN
PFAS00931.

8 References for Plan 15
38. U.S. EPA. 2022h. United States Environmental Protection Agency. Notes from November
19, 2021 Meeting with Alabama Department of Environmental Management (ADEM).
(March 17). DCN PFAS00847.
39. U.S. EPA. 2022i. United States Environmental Protection Agency. Notes from March 4,
2022 Meeting with Georgia Department of Natural Resources (GA DNR). (May 6). DCN
PFAS00905.
40. U.S. EPA. 2022j. United States Environmental Protection Agency. Notes from January 21,
2022 Meeting with Minnesota Pollution Control Agency (MPCA). (April 6). DCN
PFAS00890.
41. U.S. EPA. 2022k. United States Environmental Protection Agency. May 2022 Email
Correspondence with Merrimack Wastewater Treatment Facility. (May 26). DCN
PFAS00881.
42. U.S. EPA. 20221. United States Environmental Protection Agency. Notes from January 5
2022 Meeting with New Hampshire Department of Environmental Services (NHDES).
(February 22). DCN PFAS00854.
43. U.S. EPA. 2022m. United States Environmental Protection Agency. Notes from April 25,
2022 Meeting with the Food & Drug Administration (FDA). (July 7). DCN PFAS00911.
44. U.S. EPA. 2022n. United States Environmental Protection Agency. Notes from April 28,
2022 and May 23 Meetings with American Forest and Paper Association (AF&PA).
(August 10). DCN PFAS00938.
45. U.S. EPA. 2022o. United States Environmental Protection Agency. 2022 The U.S.
Environmental Protection Agency's Obligations Under Clean Water Act Section 304(m).
(November). EPA-HQ-OW-2021-0547. DCN 11196.
46. U.S. EPA. 2022p. United States Environmental Protection Agency. Electrical & Electronic
Components (40 CFR Part 469) Detailed Study Report. (November). EPA-HQ-OW-2021-
0547. DCN 11197.
47. VT DEC. 2020. Vermont Department of Environmental Conservation. Poly- and
Perfluoroalkyl Substances at Wastewater Treatment Facilities and Landfill Leachate: 2019
Summary Report. (January 30). EPA-HQ-OW-2021-0547-0313. DCN PFAS00120.
Available online at
hgps:Hdec.vermont. gov/sites/dec/files/wmp/SolidWaste/Documents/02.03.20_PFAS%20in
%20LF%20and%20W WTF%20Final%20Report.pdf
O.

Appendix A Response to Remand of ELG Plan 14 in Food and Water Watch V. EPA (No. 21-71084 9th Cir.)
Appendix A —Response to Remand of ELG Plan 14 in Food and Water Watch V.
EPA (No. 21-71084 9th Cir.)

Appendix A Response to Remand of ELG Plan 14 in Food and Water Watch V. EPA (No. 21-71084 9th Cir.)
A.1 Background
CAFOs are facilities that confine and maintain large numbers of animals for a specified period of time.
40 CFR 122.23 (defining CAFOs in precise terms). The CAFOs ELG regulates two parts of CAFOs:
the "production area" and the "land application area." The production area is the area that includes the
animal confinement area, manure storage areas, raw materials storage area, and waste containment
areas. 40 CFR 122.23(b)(8). The land application area is the land under the control of a CAFO owner
or operator to which manure, litter, and process wastewater from the production area is or may be
applied. 40 CFR 122.23(b)(3).
In Effluent Guidelines Program Plan 14, EPA stated that it was not appropriate at that time to revise the
effluent guidelines for the CAFOs industrial point source category. This determination with respect to
CAFOs was challenged in the U.S. Court of Appeals for the Ninth Circuit. Food and Water Watch v.
U.S. EPA, (9th Cir. No. 21-71084). On February 25, 2022, the court granted EPA's motion for remand
of that decision. This Plan responds to that remand.
A.2 Existing CAFOs ELG
The existing CAFOs ELG imposes substantial and detailed requirements on both the production area
and land application area. The ELG requirements for the production area prohibit the discharge of
manure, litter, and process wastewater from the production area to waters of the United States, with only
one exception. 40 CFR 412.3l(a). Under this exception, the ELG allows discharges from the
production area where those discharges are caused by precipitation and where the production area is
designed to contain all manure, litter, and process wastewater from a 25-year, 24-hour rainfall event. 40
CFR 412.31(a)(1) (defining this exemption in precise terms).
The ELG requirements for the land application area prohibit discharges unless those discharges qualify
as "agricultural stormwater," which the Clean Water Act expressly excludes from regulation. 33 USC
502(14). EPA interprets "agricultural stormwater" to include any precipitation -related discharges of
manure, litter, and process wastewater from the land application areas if the manure, litter, and process
wastewater has been applied to the land application area in accordance with a site -specific "nutrient
management plan" that ensures appropriate agricultural utilization of the nutrients in the manure, litter,
or process wastewater. 40 CFR 122.23(e). A nutrient management plan addresses the form, source,
amount, timing, and method of application of nutrients on each field to achieve crop production goals
while minimizing the transport of nutrients to surface waters. 40 CFR 412.4(c)(1). The application
rates for manure, litter, and process wastewater must be established in accordance with technical
standards established by each state. See 40 CFR 123.36; 412.4(c)(2).
The ELG also requires CAFOs to comply with certain recordkeeping and reporting requirements related
to both the production area and the land application area. 40 CFR 412.4(b), (c).
A.3 Information to Determine Whether to Undertake Rulemaking to Revise the CAFOs ELG
A decision whether to undertake rulemaking to revise the CAFOs ELG is informed by understanding the
extent to which the current ELG is controlling pollutant discharges from CAFOs, and, if not, the extent
to which revisions to the ELG could result in improved water quality protection. Understanding the
potential effectiveness of ELG revisions requires up-to-date information about the extent to which
A-1

Appendix A Response to Remand of ELG Plan 14 in Food and Water Watch V. EPA (No. 21-71084 9th Cir.)
CAFOs are discharging to "waters of the United States," technologies that are available and
economically achievable for controlling CAFOs discharges, and implementation issues associated with
currently applicable standards. EPA has decided to gather additional information and conduct a detailed
study on these issues in order to be able to make an informed decision as to whether to undertake
rulemaking.
A.4 Information Gathering and Study
EPA intends to gather information about many aspects of implementation of the existing CAFOs ELG
and discharges from the production area and land application area. This information will help shed light
on the appropriateness of ELG revision in light of the statutory standards for effluent guidelines,
including that they reflect the best available technology economically achievable, after consideration of
factors specified in the Act.
First, EPA intends to identify the extent to which CAFOs discharge into "waters of the United States."
As commenters on Preliminary Plan 15 noted, EPA's data about discharges of pollutants from CAFOs is
sparse; indeed, its preliminary analysis was only able to analyze monitoring data from sixteen reporting
CAFOs. EPA intends to gather information about discharges from the production area to appropriate
characterize whether manure, litter, and process wastewater flows off land application areas. EPA has
reviewed many studies addressing impacts of CAFOs on surrounding communities and the environment,
but little data is available demonstrating the impacts of CAFOs specifically on "waters of the United
States," particularly considering the agricultural stormwater exemption. EPA also intends to assess
whether any discharges from CAFOs are concentrated in particular regions or states, or whether they are
widespread nationally. Understanding the nature and frequency of discharges is critical to understanding
the extent to which potential revision of the ELG could yield significant pollutant reductions.
In addition, EPA plans to gather information about new technologies and practices for reducing
discharges from the production area and land application area. EPA will consider whether these
technologies may be technologically available and economically achievable for the CAFOs point source
category. See 33 U.S.C. § 1311(b)(2). EPA lacks a sufficient understanding of technologies and
practices that may have developed since its 2003 and 2008 rules, including their effectiveness at
reducing discharges of pollutants beyond what is already required in the CAFOs ELG, the applicability
of these technologies in a variety of situations, any secondary impacts they may have on farm
production, and their cost to CAFOs owners and operators. EPA also intends to study the financial
health of the agriculture industry as a whole and by sector, to the extent possible. Given the statute's
requirement that any ELG revision be technologically available and economically achievable, EPA
believes it should have a greater understanding of the availability, effectiveness, and economic
achievability of new technologies.
This information is important for EPA to be able to make an informed, reasoned decision regarding the
effectiveness of the existing ELG and whether emerging alternatives to existing requirements may be
technologically available and economically achievable and may better protect water quality. EPA will
evaluate other issues related to the CAFOs ELG in addition to the issues highlighted above, and the
focus of the detailed study will evolve as EPA gathers information.
A-2

Appendix A Response to Remand of ELG Plan 14 in Food and Water Watch V. EPA (No. 21-71084 9th Cir.)
A.5 Conclusion
For the reasons provided above, EPA has determined that gathering additional information and
conducting a detailed study of the CAFOs ELG is a necessary next step for evaluating whether revisions
to the ELG are warranted. Completing this study before determining whether to revise the ELG also
reflects EPA's careful evaluation of the Agency resources that would need to be committed to a
rulemaking, due to the large number of environmental priorities that EPA has concluded need to be
addressed through rulemaking. Typical ELG rulemakings take several years, 3 full-time employees,
and a million dollars per year in contractor support. As noted above, EPA promulgated the CAFOs
ELG in 2003 and revisions in 2008 — these rulemakings and associated litigation spanned approximately
11 years. Thus, a decision to undertake rulemaking has significant implications for the Agency's
allocation of its resources. EPA has concluded that the information that will be collected is the
appropriate course of action to make an informed, reasoned determination whether the potential
environmental benefits of undertaking rulemaking justify devoting the significant resources that are
required for such a rulemaking.
In deciding to gather information and conducting a detailed study prior to making a decision whether to
undertake such a rulemaking, the Agency has also considered the substantial resources that it has
committed to revising ELG for other industrial sectors and that undertaking rulemaking for CAFOs at
this time could divert resources from these efforts. For example, EPA has undertaken rulemaking to
control, for the first time, discharges of per -and polyfluoroalkyl substances (PFAS) from certain
manufacturers and processors. See Section 7.3 and the Multi -Industry PFAS Study — 2021 Preliminary
Report. EPA has also recently determined that it will undertake rulemaking to improve control of
discharges from meat and poultry slaughterhouses. See Section 7.2. EPA is also now engaged in
rulemaking for part of the power industry sector. See Section 7.1. EPA is undertaking those
rulemakings because it had sufficient information to determine that revising those ELG would advance
protection of quality of the nation's waters and, in the absence of such information with regard to
CAFOs, has determined not to divert resources from those efforts.
For the reasons described above, EPA has determined that collecting further information and conducting
a detailed study will enable the Agency to make an informed, reasoned decision whether to undertake
rulemaking to revise the ELG for CAFOs.
A-3

ATTACHMENT 5

To: Kemp Burdette
cyclopure
Water Test Kit Pro Results Report
Date: September 20, 2022
Thanks for testing your water with us! This report is for Kit No. #1371 sampled with
unfiltered water from Near Sarecta NC. You can view results in raw data format below.
PFAS detects are highlighted in yellow.
Kit# 1371 (Near Sarecta - Unfiltered). We found 10 PFAS in water sample #1371, with
a total concentration of 71.7 ppt. The other 45 PFAS tested for measured non -detect.
WTK ID
WTK PFAS 1371
Name
Kemp Burdette
Sampling Location
Near Sarecta, NC 29349
Coordinates
Lat: 34.9799 Long: -77.8626
Filtered/Unfiltered
Unfiltered
Sampling Date
912122
Order ID
P-119087180
PFBA
1.3
PFPeA
17.9
PFHxA
13.3
PFH A
6
PFOA
9.9
PFNA
2.4
PFDA
2.2
HFPO-DA GenX
< 2 n IL
PFBS
< 1 n IL
PFHxS
< 1 n IL
PFOS
13.6
Total PFAS 11 Compounds)
66.6
Additional PFAS
N-McFOSAA
3.4
PFOSA
1.7
Total PFAS All Detected
71.7
Values are in part per trillion (ppt). Limit of quantification is 1.0 ppt for all
PFAS, other than GenX which is 2.0 ppt.
Our Lab Method
_ When the WTK is received by the lab, Cyclopure analytical chemists perform
•
standard solid -phase extraction (SPE) to recover PFAS compounds collected in
the DEXSORB extraction disc. The eluted PFAS sample is subsequently analyzed
on a HPLC-MS/MS.
Cyclopure analytical chemists use isotope dilution methods to measure a total of
55 PFAS on HPLC-HRMS/MS, including all PFAS listed under EPA Methods 533,537
and 1633 draft.
North Carolina PFAS
Regulations
EPA has set Health
Advisory Levels for PFOA
(0.004 ppt); PFOS (0.02);
GenX (10 ppt) and PFBS
(2,000 ppt). The North
Carolina Department of
Health has established a
provisional health goal of
140 ppt for GenX for
drinking water.
Cyclopure Inc 8045 Lamon Ave, Suite 140 Skokie, IL 60077 Makers of Purefast Filters

IH CYCLOPURE
Appendix.
PFAS detected by Cyclopure analytical methods.
Compound
Abbreviation
CAS#
EPA 1633
Perfluorobutanoic Acid
PFBA
375-22-4
Y
Perfluoropentanoic Acid
PFPeA
2706-90-3
Y
Perfluorohexanoic Acid
PFHxA
307-24-4
Y
Perfluoroheptanoic Acid
PFHpA
375-85-9
Y
Perfluorooctanoic Acid
PFOA
335-67-1
Y
Perfluorononanoic Acid
PFNA
375-95-1
Y
Perfluorodecanoic Acid
PFDA
335-76-2
Y
Perfluoroundecanoic Acid
PFUnA
2058-94-8
Y
Perfluorododecanoic Acid
PFDoA
307-55-1
Y
Perfluorotridecanoic Acid
PFTrDA
72629-94-8
Y
Perfluorotetradecanoic Acid
PFTeA
376-06-7
Y
Perfluoropropane Sulfonic Acid
PFPrS
423-41-6
Perfluorobutane Sulfonic Acid
PFBS
375-73-5
Y
Perfluoropentane Sulfonic Acid
PFPeS
2706-91-4
Y
Perfluorohexane Sulfonic Acid
PFHxS
355-46-4
Y
Perfluoroheptane Sulfonic Acid
PFHpS
375-92-8
Y
Perfluorooctane Sulfonic Acid
PFOS
1763-23-1
Y
Perfluorononane Sulfonic Acid
PFNS
474511-07-4
Y
Perfluorodecane Sulfonic Acid
PFDS
335-77-3
Y
Perfluorododecane Sulfonic Acid
PFDoS
79780-39-5
Y
4:2 Fluorotelomer Sulfonate
4:2 FTS
414911-30-1
Y
6:2 Fluorotelomer Sulfonate
6:2 FTS
425670-75-3
Y
8:2 FluorotelomerSulfonate
8:2 FTS
481071-78-7
Y
10:2 Fluorotelomer Sulfonate
10:2 FTS
120226-60-0
Perfluorobutane Sulfonamide
FBSA
30334-69-1
N-Methylperfluorobutanesulfonamide
McFBSA
68298-12-4
Perfluorohexane Sulfonamide
FHxSA
41997-13-1
Perfluorooctane Sulfonamide
PFOSA
754-91-6
Y
Perfluorodecane Sulfonamide
FDSA
N/A
N-Ethylperfluorooctane-l-Sulfonamide
NEtFOSA
4151-50-2
Y
N-Methylperfluorooctane-l-Sulfonamide
NMeFOSA
31506-32-8
Y
Perfluorooctane Sulfonamido Acetic Acid
FOSAA
2806-24-8
N-Ethyl Perfluorooctane SulfonamidoAcetic Acid
NEtFOSAA
2991-50-6
Y
N-Methyl Perfluorooctane Sulfonamido Acetic Acid
NMeFOSAA
2355-31-9
Y
N-methyl perfluorooctanesulfonamidoethanol
NMeFOSE
24448-09-7
Y
N-ethyl perfluorooctanesulfonamidoethanol
NEtFOSE
1691-99-2
Y
Hexafluoropropylene Oxide Dimer Acid
HFPO-DA
13252-13-6
Y
4,8-Dioxa-3H-Perfluorononanoate
ADONA
919005-14-4
Y
Perfluoro-3-MethoxypropanoicAcid
PFMPA
377-73-1
Y
Perfluoro-4-MethoxybutanoicAcid
PFMBA
863090-89-5
Y
Perfluoro-3,6-DioxaheptanoicAcid
NFDHA
151772-58-6
Y
9-Chlorohexadecafluoro-3-Oxanone-1-Sulfonic Acid
9CI-PF30NS
756426-58-1
Y
11-Chloroeicosafluoro-3-Oxanonane-1-Sulfonic Acid
11CL-PF30UdS
763051-92-9
Y
Perfluoro(2-ethoxyethane) Sulfonic acid
PFEESA
113507-82-7
Y
Perfluoro-4-ethylcyclohexane Sulfonic Acid
PFECHS
646-83-3
8-Chloroperfluoro-l-OctanesulfonicAcid
8CI-PFOS
777011-38-8
3-Perfluoropropyl Propanoic Acid
3:3FTCA
356-02-5
Y
2h,2h,3h,3h-Perfluorooctanoic Acid
5:3FTCA
914637-49-3
Y
3-Perfluoroheptyl propanoic acid
7:3FTCA
812-70-4
Y
2H-Perfluoro-2-dodecenoic acid
FDUEA
70887-94-4
2H-perfluoro-2-decenoic acid
FOUEA
70887-84-2
Bis(perfluorohexyl)phosphinicacid
6:6PFPi
40143-77-9
(Heptadecafluorooctyl) (tridecafluorohexyl) Phosphinic Acid
6:8PFPi
610800-34-5
Bis(perfluorooctyl)phosphinicacid
8:8PFPi
40143-79-1
N-(3-dimethylaminopropan-1-yl) perfluoro-l-hexanesulfonamide
N-AP-FHxSA
50598-28-2

ATTACHMENT 6

DocuSign Envelope ID: 2CECEAE6-310B-4211-9465-74BB8D100E84
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Steven Middlebrook
Plant Manager
1754 NC Highway 903/11 North
Kenansville, NC 28349
Dear Sir:
NORTH CAROLINA
Environmental Quality
January 27, 2023
Subject: Permit Renewal
Additional Information Request
NC0002305 — Lear Corp
1754 NC-903, Kenansville
Duplin County / WRO
NCDEQ Division of Water Quality Permitting's Industrial Permitting Unit (Division) has conducted an
initial review of the renewal application for Lear Corp's NPDES permit. To enable the Division to
complete the review in accordance with N.C.G.S. 143-215.1 and 15A NCAC 2H.0105 please provide all
information requested herein to this office during this renewal review period.
Additional Information (ADS sought is necessary to proceed with a thorough and complete review of the
application. Per 15A NCAC 2H.0107 (b) the applicant shall be given up to sixty (60) days to provide the
information to make the application complete. Please provide all ADI requested to the following in the
time limits noted:
NCDEQ/ DWR
NPDES Industrial Permitting Unit
Attn: Douglas Dowden
1617 Mail Service Center
Raleigh, NC 27699-1617
and by email to: doug.dowden�a�ncdenr.gov
ADDITIONAL INFORMATION REQUEST
1. PFAS Data and Analysis: As an Organic Chemicals, Plastics and Synthetic Fibers (OCPSF) facility, and with
guidance provided by Environmental Protection Agency (EPA) there are potential sources of PFAS related
compounds that may be in the wastewater, solid waste or sludge. Please complete the PFAS questionnaire
as Attachment 1 herein and submit with the additional information. Based on the response(s) provided, we
may request additional information on the application.
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
NCRTHCARCUNAPI ^� 919.707.9000

DocuSign Envelope ID: 2CECEAE6-310B-4211-9465-74BB8D100E84
2. Solids Disposal Practices: What is your solids treatment system? And what is your current solids
management plan from your wastewater treatment system and are there any planned changes during this
upcoming permit cycle?
3. Groundwater Monitoring Wells: Does the facility include any monitoring wells within the vicinity of on -
site wastewater treatment systems? If so, please provide all monitoring data from the last Permit cycle (5-
years) in excel format for all constituents monitored and analyzed and a map of all monitoring well
locations. Include in the table all established limits by parameter. Please provide related Permit numbers
and copies of Permits.
4. Daily Production Levels: The application submitted did not include daily production levels during the
past five (5) years. This data is necessary to calculate appropriate limits based on OCPSF technology
guidelines. Please provide daily production levels for the past five (5) years in an Excel spreadsheet. If the
facility is anticipating different production levels for the next five (5) years, please provide predicated
production levels for the next five (5) years and relevant data to support the prediction.
We appreciate your attention to these matters and look forward to continuing to work with you and your team
on this Permit renewal. Pending review and evaluation of provided information, further action or additional
information may be required.
I thank you in advance to your attention to the above reference matter. If you have any questions about the
NPDES permit process, please contact me at the following e-mail address: doug.dowden e,ncdenr.gov, or
telephone number: 919-707-3605.
Sincerely,
DocuSigned by:
E
6U9�.A.S � 06(Al tAA,
Doug�as'owden
Environmental Program Supervisor II
Industrial NPDES Permitting Unit
cc: Central Files; NPDES Files
ec: Anjali Orlando, Environmental Specialist II at: Anjali.orlando(cr�,ncdenr.gov
Min Xiao, Engineer III NCDEQ Industrial Permitting Unit at: min.xiao(kncdenr.gov
George Yankay Operator in Responsible Charge Lear Corp at: GYankay(kgfd.com
Steven Middlebrook, Plant Manager Lear Corp at: smiddlebrook(klear.com
Julie A. Grzyb, Deputy Director, Division of Water Resources at: julie.grzyb(kncdenr.gov
Michael Montebello, NPDES Program Branch Chief at: Michael.montebello(kncdenr.gov
Tom Tharrington, Ass Regional Sup; Wilmington Regional Office at: tom.tharrington(kncderingov
Morella Sanchez -King, Wilmington Office Regional Supervisor at: morella.sanchez-king(kncderingov
D � � North Carolina Department of Environmental Quality 1 Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CARGHWA
nwo mme�mro���wq�si\ 919.707.9000

DocuSign Envelope ID: 2CECEAE6-310B-4211-9465-74BB8D100E84
ATTACHMENT 1
PERMIT APPLICATION SUPPLEMENT- PFAS SCREENING QUESTIONS:
1. Do you use any material or products (directly or indirectly) in your operations that contain
fluorinated chemicals? If so, please identify what materials or products contain fluorinated
chemicals.
2. Will your facility formulate or create products (directly or indirectly) which contain fluorinated
chemicals? If so, please identify the specific fluorinated chemicals that may be formulated or
created.
3. Will your facility produce solid waste, liquid waste, wastewater effluent, or other waste containing
fluorinated chemicals? Please be as specific as possible to describe what fluorinated chemicals may
result in the facility's wastewater, solid waste, or sludge.
4. Are there processes or operations that use equipment, material, or components that contain PFAS
chemicals (e.g., surface coating, clean room applications, solvents, lubricants, fittings, tubing,
processing tools, packaging, facility infrastructure)? Could these activities result in fluorinated
chemicals being discharged as products, or by-products (i.e., through leaching, chemical process,
heat treatment, pressurization, etc.)?
5. List CAS numbers of all known or believed present fluorinated compounds from the questions
above. Please provide descriptions, quantities, and whether there are any unknowns related to the
above questions.
6. Are there other facilities or operations in the U.S. or internationally that are identical to or may use
processes similar to the facility in North Carolina? If so, please provide facility identification
information and wastewater characterization including all PFAS compounds?
7. Additionally, have any PFAS analytical results been collected with any analytical test method
similar to the following EPA Test Methods. Are any of the fluorinated compounds listed in one of
the following methods and can you provide us with data resulting from these test methods?
• Methods 533 & 537.1 (drinking water)
• SW-846: Method 8327 (water)
• Draft Method 1633 (water, solids, tissue)
• "Total PFAS" Draft Method 1621 (wastewater)
D � � North Carolina Department of Environmental Quality 1 Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CARGHWA
nwo mme�mro���Wq�si\ 919.707.9000