NC0002305_NOV-2023-PC-0006_20230215

CORPORATION
0
LEAR®
February 15, 2023
NC Department of Environmental Quality
Division of Water Resources
127 Cardinal Drive Extension
Wilmington, NC
28405
To Whom It May Concern,
Lear Corporation
Kenansville, NC
1754 NC Hwy 903
Kenansville, NC 28349
USA
Phone [phone]
Fax [phone]
This is in response to our Notice of Violation (Tracking Number NOV-2023-PC-0006) for permit no. NC0002305.
Upon receipt of your notice regarding "Effluent/Receiving Waters — More than a trace amount of foam observed in the
receiving waters at the outfall". We would like to have the following put on file as it outlines our investigation and
conclusion as to what might have happened with this incident.
1) The production department conducted an exhaustive review of chemicals used and production practices that
resulted in the following list of "Foam Issues Action Items".
The traditional process review for increased levels of foaming in our wastewater facility include the following:
a) Review Water Hardness/pH for the in -coming process water
o Daily hardness levels should be verified
b) Review any process changes relative to the Dye House and Finishing processes
o Increased volume in the "Washer — Frame 6" — validation of the chemical concentration being utilized.
o Confirm any changes in the Dye House relative to Dispersing Agents (Leveling Agents, Oligomer
Dispersants, etc.) and manufacturing procedures
c) Confirm no changes in yarn or greige suppliers
o Did we change our yarn mix based on demand?
o Did we utilize more greige from the UK (yarn vendors are different)?
d) Determine if there are any chemical leaks or spills for process chemistries that would leak directly into the system.
o CIR Leaks
o Drum or Tote Spills
2) The wastewater operators:
a) By the COB (09/02/2022) we started "drip feeding" an anti -foam product procured from our chemical
supplier.
b) Increased number of visits to "point of discharge" to confirm "no foam discharge"
c) On 09/07/2022 installed a new, more permanent chemical feed pump and tote system to feed FoamNix8
antifoam.
d) On 09/14/2022 installed trail cam at "point of discharge" to aid in monitoring effluent/stream interface.
Sincerely,
George Yankay
Wastewater Technical Advisor / ORC
[e-mail] [phone]