NC0002305_Fact Sheet with Attachments_20241104_REVISED

Lear Fact Sheet NC0002305
Fact Sheet
NPDES Permit No. NC0002305
Permit Writer/Email Contact: Fenton Brown Jr., [e-mail]
Date: 16 January 2024 (Initial) / 4 November 2024 (revised)
Division/Branch: NC Department of Environmental Quality /NPDES Industrial Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
0 Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
• Chemical Addendum - (NC State specific, for specific large facilities using various chemicals)
• PFAS Questionnaire - (NC State specific, for specific large facilities using various chemicals)
• Permit Map(s): Applicants should develop maps that meet NCDEQ specifications: Maps to
include: (1) Aerial / Site location map; (2) Overall facility design map (e.g., SWMU, Treatment
lagoons, treatment facilities, operations, parking, closed facilities, known contaminated areas on
site, etc.) with total acreage by site feature. (3) Water Treatment / Quality Map: (a) location of
outfall(s) (latitude and longitude) with a key reflecting total flow by contributing source(s); (b)
sampling and monitoring location(s) (latitude and longitude); (c) Map scale (e.g. 1" = 500' or —);
(d) Distance in feet from outfall(s) (latitude and longitude) to sampling location(s); (e) Upstream
and downstream monitoring locations (latitude and longitude); (f) Groundwater monitoring well
location(s) (latitude and longitude). (g) Waterbody name, classification, TMDL status, etcetera;
(h) major roads; (i) etc. Include a stormwater outfall map with discharge and monitoring locations
so that the record has a comprehensive overview. Include a key of applicable ELG's by category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Lear Corporation (formerly Guilford Mills, Inc.)
Applicant Address:
1754 NC Hwy 903; Kenansville, NC 28349
Facility Address:
1754 NC Hwy 903; Kenansville, NC 28349
Permitted Flow:
1.5 MGD
Facility Type/Waste:
Biological Water Pollution Control System/94% Industrial/6% Water
Treatment Plant (WTP) and Domestic wastewater
Facility Class:
Class III
Treatment Units:
EQ basin, aeration basin, secondary clarification, flocculation, tertiary
clarification, chlorination, de -chlorination
Pretreatment Program (Y/N)
NA
County:
Duplin
Region
Wilmington
SIC Code(s)
2258 & 2262
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Lear Fact Sheet NC0002305
Briefly describe the proposed permitting action and facility background: Lear Corporation (formerly
Guilford Mills, LLC) submitted a NPDES permit renewal application November 28, 2022, for its
Kenansville plant. The Kenansville plant conducts operations for knitting, weaving, dying, fire retardant
lamination, and other finishing processes of synthetic fibers. The facility is permitted to discharge treated
industrial wastewater (collected in EQ Basin), non -contact cooling water, softened water, and domestic
water through Outfall 001. Outfall 001 (35'0l'00.4" N,-77°50'47.2" W) discharges to the NE Cape Fear
River Basin, a class C (Aquatic Life, Secondary Contact Recreation, Fresh Water) and Sw (Swamp
Waters) stream, outside the area of any drinking water supply watersheds.
The facility is classified under SIC code(s) 2258 and 2262/ NAICS Code 336360. Lear is subject to EPA
40 CFR 410 Textile Mills Subpart E Knit Fabric Finishing subcategory. 40 CFR 410.52 General
Processing Best Practicable Technology (BPT)- (a) limitations were applied to develop production based
effluent limits for LEAR's process. As a requirement, production based effluent limits were calculated
using the average of production over the last 5 years. Production numbers were tracked using yards; as a
result, LEAR measured and weighed various fabrics to create a legitimate density factor for converting
yards to pounds/day (Explained in Attachment #3). A Water Quality based model on the NE Cape Fear
River Basin, 18-74-1 stream segment, was completed in 1977, as a result Water Quality Based Effluent
Limits (WQBEL) were assigned to BOD, TSS, and DO. Additionally, a 2007 STREAM model study was
completed to refine the BOD loading criteria, sustaining instream WQBEL Dissolved Oxygen (DO).
Methylene Blue Substances (MBAS) monitoring was added then subsequently removed from the 2017
permit due to discontinued surfactants use.
Based upon the first public notice of this draft permit (16 January 2024), this permit has been revised with
consideration of comments from the following: permittee (Lear Corp.) comments, EPA Region 4
comments (5 May 2024), SELC comments and public comments. The revised version will be re -noticed.
Additional details can be found in Section 10.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 00 1 —Northeast (NE) Cape Fear River
Stream Segment:
18-74-(1)
Stream Classification:
C, SW
Drainage Area (mi2):
332
Summer 7Q10 (cfs)
5.90'
Winter 7Q10 (cfs):
21.70'
30Q2 (cfs):
35.90'
Average Flow (cfs):
402'
IWC (% effluent):
282
303(d) listed/parameter:
No
Subject to Total Maximum Daily Load
(TMDL)/parameter:
Yes- Statewide mercury TMDL, requires submittal of one
mercury measurement at low detection level (1631E)
Subbasin/HUC:
03-06-22/030300070206
USGS Topo Quad:
G27SE
'Low -Flow Stream data updated 27 August 2023. Also, Outfall 001 isn't located near a Drinking
Watershed supply downstream.
2The Instream Waste Concentration (IWC) has been updated from 26.35% to 28%, due to the USGS
low flow data update.
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Lear Fact Sheet NC0002305
3. Effluent Data Summary
Effluent data is summarized below for the period January 2019 through Oct 2023.
Table 1. Effluent Data Summary
Parameter
Units
Average
Max
Min
Permit Limit
Flow
MGD
0.58
1.15
0.002
MA 1.5
BOD
lbs./day
39.4
253
0.4
DM 258.9
MA 129.4
COD
lbs./day
627
4,085
6.2
DM 4,142
MA 2,071
TSS
lbs./day
72.01
1,245
1.06
DM 1,128.7MA
564.3
pH
SU
7.03
8.2
5.59
Not < 6.0 nor >
9.0
Fecal Coliform
#/100 ml
(GEOMEAN)
1,990
1
DM 400
3.58
MA 200
Total Residual Chlorine
µg/l
18.3
31
2.0
DM 28
TRC
Sulfide
lbs./day
0.3
4.6
0.02
DM 10.4
MA 5.2
Total Phenols
lbs./day
0.1
0.70
0.003
DM 5.2
MA 2.6
Total Chromium
lbs./day
0.084
0.89
0.02
DM 5.2
MA 2.6
Oil and Grease
mg/l
5.4
13.8
4.8
DM 45.0
MA 30.0
Total Cyanide
µg/l
6.6
53
0.01
DM 73
MA 19
DO
mg/1
7.4
11.1
4
DA not < 6
NH3-N
mg/l
0.34
5.1
0.02
Monitor & Report
Temperature
°C
21.8
33.4
5
Monitor & Report
Conductivity
umhos/cm
384
494
167
Monitor & Report
TN
mg/l
1.8
14.7
0.02
Monitor & Report
TP
mg/l
3.01
12.7
0.03
Monitor & Report
Chromium VI
µg/l
<10
<10
<10
Monitor & Report
Chronic Toxicity
Percentage
41.1
100
9.5
27%
THP3B
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA-Daily Average
Mg/L (Concentration) and lbs./day (Load) monitoring report will be applied to permit, to alleviate
further confusion when reporting on eDMR.
See Attachment 6 for details.
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Lear Fact Sheet
NC0002305
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit if coalition membership is maintained).
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): No
Name of Monitoring Coalition: N/A
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: The current permit requires stream monitoring for dissolved oxygen, temperature, and
conductivity, — 1 mile upstream (Goshen Swamp at Highway 11 Bridge) of discharge to NE Cape Fear
River and 2.7 miles downstream (Sarecta Road Bridge) of discharge to NE Cape Fear River. Upstream
and downstream samples are collected three times per week during June, July, August, and September
and once per week during the remainder of the year. Instream data from January 2019 through December
2023 have been summarized below in Table 2.
Table 2. Instream Monitoring Data Summary (eDMR Data)
Parameter
Units
(Upstream)
(Downstream)
Average
Max
Min
Average
Max
Min
Temperature
° C
22.34
30.2
5.4
22.14
29.8
6.30
Dissolved
Oxygen- DO
mg/1
4.82
9.8
0.89
5.47
10.3
1.90
Conductivity
µmhos/cm
181
429
21.3
200
493
71
Downstream temperature was not greater than 32 degrees Celsius [per 15A NCAC 02B .0211 (18)]
during the period reviewed. Downstream temperature was greater than upstream temperature by more
than 2.8 degrees Celsius on one occasion during the period reviewed.
It was concluded that no statistically significant difference exists between upstream and
downstream temperature. Monitoring has been maintained.
Average downstream DO was above 5 mg/L [per 15A NCAC 02B .0211 (6)] during the period reviewed.
Downstream DO was observed at levels less than 4.0 mg/L on 90 occasions during the period reviewed
while Upstream DO was observed at levels less than 4.0 mg/L on 167 occasions during the period
reviewed. It was concluded that a statistically significant difference exists between upstream and
downstream DO. Upstream DO was observed at levels less than 4.0 mg/L more frequently than
Downstream DO. Monitoring has been maintained.
It was concluded that no statistically significant difference exists between upstream and
downstream conductivity. Monitoring has been maintained.
In addition to the data collected by the Permittee, the Lower Cape Fear River Basin Association
(LCFRBA) collects data from monitoring stations B9191000 (Upstream), located approximately 0.85
miles upstream of the discharge, and B9191500 (Downstream) located approximately 2.7 miles
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Lear Fact Sheet NC0002305
downstream of the discharge. Coalition data from January 2019 - June 2023 have been summarized in
Table 3.
Table 3. Coalition Monitoring Data Summary
Parameter
Units
B9191000
(Upstream)
B9191500
(Downstream)
Average
Max
Min
Average
Max
Min
Ammonia
mg/l
0.06
0.45
0.02
0.08
0.88
0.02
TKN
mg/1
1.03
2.15
0.1
0.93
2.1
0.1
NO2+NO3
mg/1
0.22
2.02
0.02
0.38
1.77
0.02
TP
mg/1
0.22
0.9
0.03
0.22
0.88
0.02
pH
s.u.
6.73
7.5
5.7
6.77
7.4
6.1
Fecal Coliform
#/l00mL
(geomean)
58.3
1200
5
(geomean)
127.9
1100
14
The 2022 integrated report reported inconclusive data for fecal coliform, and the facility received 6
Notice of Violations (NOV's) for Fecal Coliform exceedances within the past five years of the permit
cycle. Therefore, further assessment of fecal coliform is needed. Per data reviewed from the Lower
Cape Fear monitoring coalition station, instream monitoring for fecal coliform has been added to the
permit at a variable frequency of three times per week in the summer (June- September), and once per
week for the Fall (October -December) winter (Jan through March), and spring (Apr -May).
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): Since the last permit renewal,
effective October 2018, the facility had a total of 49 violations. One violation for Exceeding the NPDES
narrative limit related to having more than trace amounts of observable foam from the Outfall; 18 limit
violations related to: Biochemical Oxygen Demand (BOD), Total Chlorine, Fecal Coliform, Total
Cyanide, Oil & Grease, Chemical Oxygen Demand (COD), Dissolved Oxygen (DO) and Total Suspended
Solids (TSS); 23 Monitoring Violations and Seven (7) Aquatic Toxicity Limit Violations.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 17 out of its last 24 quarterly chronic toxicity tests using Ceriodaphnia
dubia with a ChV limit of 27% (2016-2022 range). The facility failed 7 out of its 24 quarterly chronic
toxicity tests, Jan, Feb (2022 and 2023), April (2022), May (2022) and July (2023). As per the permit, the
facility passed the subsequent test required after said fails.
Summarize the results from the most recent compliance inspection: The compliance inspection,
conducted 25 May 2022, found minor signs of equipment maintenance issues that were in the process of
being addressed (i.e., Secondary Clarifier #2 short circuiting due to corrosion) and notations of the EQ
Basin solids accumulation. However, aside from the notated concerns, improvements were made, and all
Operations complied. The ORC had to review, recalculate, and update information for Sulfide,
Temperature, Conductivity, Cyanide, Sulfide, Total Phenols, and Total Chromium. Corrections were
subsequently reported to eDMR by the Operator Responsible in Charge (ORC) during the permit renewal
period.
In conjunction with the regional inspection, the DEQ central office staff conducted a Site visit on 1 June
2023. During their visit they discovered areas of concern resulting from lack of maintenance in the
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Lear Fact Sheet NC0002305
WWTP area, such as an unacceptable level of sludge in the aeration basin, chemicals stored without spill
containment, and other factors that may have contributed to the foaming issue. As a result of the visit,
monitoring and reporting for Zinc and Copper has been reinstated. Due to multiple toxicity test
compliance violations and complaints of foaming from Outfall 001, DEQ has decided to add the
monitoring of MBAS.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following stream flows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results):
N/A.
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): N/A
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD = 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: The current BOD
limits were calculated under 40 CFR 410.52(a) Effluent Limitation Guidelines (ELGs) based on
production for the previous permit cycle. The BOD limits have been evaluated based on the updated
production rate identified by the Permittee in their application. Calculations for the production value of
92,350 lbs./day, yielded limitations for BOD, Monthly Average (MA) 231 lbs./day and Daily Maximum
(DM) of 450 lbs./day. A STREAM model conducted in 2007 indicated WQBELs for BOD (DMA50.36
lbs./day MA: 300.24 lbs./day). Lastly, the 2007 STREAM model-BOD limitations were more restrictive
than the ELG, based on the reevaluated production rate.
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1(summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for non -municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1(acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal:
Limits for both Acute Ammonia (NH3) and Total Residual Chlorine (TRC) were reviewed in the
NH3/TRC Waste Load Allocation (WLA) Calculations Excel Spreadsheet (Attachment #5). No changes
are proposed for either NH3 or TRC. Therefore, TRC and Ammonia monitoring and reporting will remain
in the permit.
Reasonable Potential Analvsis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
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Lear Fact Sheet NC0002305
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/ 95% Probability; 2) assumption of zero
background; 3) use of detection limit for "less than" values; and 4) stream flows used for dilution
consideration based on 15A NCAC 213.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between January 2019
through June 2023. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: Cyanide, Total Chromium.
• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria,
but the maximum predicted concentration was >50% of the allowable concentration: Chromium
VI, conditional upon detection of Total Chromium > 39.0 µg/L.
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring since
they did not demonstrate reasonable potential to exceed applicable water quality
standards/criteria and the maximum predicted concentration was <50% of the allowable
concentration: None.
• Application Effluent Pollutant Scan Review: An effluent pollutant scan was evaluated for
additional pollutants of concern. Review based on assessment of detected analytes reported in
NPDES EPA permit application Form 2C Section 7. Table(s) B - D.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: None.
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: None.
For additional information regarding PFAS and 1,4-dioxane monitoring, see Monitoring Requirements
below.
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicitv Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: The facility remains classified as a Major Industry. The
USGS low flow data was reconfigured February 2024, due to updates in the United States Geological
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Lear Fact Sheet NC0002305
Survey (USGS) system. As a result, the low flow statistics have been recalculated, causing the Influent
Waste Concentration (IWC) to increase from 27% to 28%.
Due to historical issues and concerns raised involving toxicity test failures, the monitoring frequency
has been increased from quarterly to monthly, with the addition of a second species (Fat Head
Minnow). Additionally, the Permittee shall calculate and report the Lethal Concentration 50 (LCso)
value from the individual tests which will be reported in the monthly discharge reports; and the effluent
salinity analysis will be added to supplement this data. Lastly, should the Permittee consecutively fail
future toxicity tests, a Toxicity Identification Evaluation (TIE) or Toxicity Reduction Evaluation
(TRE) shall be conducted based on the permit conditions which will include a compliance schedule
and requirements ensuring the source of toxicity is eliminated.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
waste load allocation for point sources of 37 kg/year (81 lbs./year) and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending on if mercury
is a pollutant of concern. Effluent limits may also be added if annual average effluent concentrations
exceed the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a
TBEL value of 47 ng/l. (EPA 1631 E)
Describe proposed permit actions based on mercury evaluation: The facility sampled and tested for Total
Mercury, using an insufficiently sensitive test method. Compliance with the statewide Mercury TMDL
cannot be evaluated using the data available. As a result, the facility has agreed to perform a sampling and
monitoring event using EPA Method 1631E during the issuance of the Final Permit (XXX 2024) and
again 6 months prior to the end of the XXXX permit renewal.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: NA
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: As required by Session
Law 2018-5, Senate Bill 99, Section I LI r), every applicant shall submit documentation of any additional
pollutants for which there are certified methods with the permit application if their discharge is
anticipated via a Chemical Addendum to NPDES Application table. In their application, Lear Corp.
provided the Chemical Addendum and notated testing for Total Kjeldahl Nitrogen (TKN) and nitrate -
nitrite (NO2+NO3). Since Total Nitrogen is currently being monitored monthly and consists of TKN and
NO2+NO3. Monthly monitoring and reporting for TKN and NO2+NO3 has been added to the permit.
The current permit requires effluent monitoring for Chromium -VI conditional upon the facility reporting
a total chromium concentration exceeding 39 µg/L. The conditional Chromium -VI monitoring
requirement has been reevaluated with this renewal. The Reasonable Potential Analysis (RPA)
demonstrated no reasonable potential for excursions above the Chromium -VI surface water standard and
the maximum predicted concentration for Chromium -VI was less than 50% of the allowable discharge
concentration. However, due to the current production rate of 92,350 lbs/day, Total Chromium limits have
been reevaluated under EPA's Effluent Limitation Guideline (ELG) identified in 40 CFR
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Lear Fact Sheet NC0002305
410.52(a)(b)Best Practicable Technology (BPT) section based. The resultant total chromium monthly
average and daily maximum limitations have been found to be less stringent than the Chromium -VI
WQBELs, supporting the maintenance of the conditional Chromium -VI monitoring requirement. The
Permittee shall use sufficiently sensitive test methods to assess Chromium -VI concentrations below the
WQBEL, including when conducting Total Chromium monitoring. The comparison between Chromium -
VI WQBELs and Total Chromium ELGs has been summarized in Table 4. See Attachment(s) 2 &4 for
details.
Table 4: Comparison Chromium Parameters WQBEL to TBEL
Parameter 1
Daily Maximum
Limit
Monthly Average
Limit
Highest reported
concentration
Chromium III - WQBEL
5656.3 /L
843.0 /L
None Reported
Chromium VI - WQBEL
49.8 /L
38.9 /L
None Reported
Total Chromium — TBEL 1.5 MGD
464 /L
232 /L
106 /L
• Chromium III = Total Chromium — Chromium VI
There is an aesthetic water quality standard for Total Phenolic Compounds for class C streams.
Upon evaluation of the standard, considering the applicable 30-day minimum, 2 year return
period (30Q2) dilution impact, the WQBEL equivalent mass -based limit was less stringent than
the Effluent Limit Guidelines (ELG) limits. As such, the ELG-based limits have been applied.
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with to protect the designated waterbody: NA.
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H. 0 10 7(c) (2) (B), 40CFR 122.47, and EPA May 2007 Memo: N/A
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226 for this permit renewal: N/A.
7. Technology -Based Effluent Limitations (TBELs)
Industrials (if not applicable, delete and skip to next Section)
Describe what this facility produces: Warp knitting and weaving of synthetic fibers for the automotive
industry. Dyeing, finishing, flame lamination of knitted and woven synthetic fabrics.
List the federal effluent limitations guideline (ELG) for this facility: 40 CFR 410.50 Textile Mills Subpart
E Knit Fabric Finishing, Best Practicable Technology (BPT).
If the ELG is based on production or flow, document how the average production/flow value was
calculated: Lear Corporations EPA Effluent Limitation Guideline (ELG) is based on production, reported
in Pounds/Day (lbs./day). Initially, Lear Corp. reported the production of their product in Yards vs.
Pounds. To correct the issue, Lear Corp. performed measurements and calculations, acquiring the density
conversion factor of 0.586 lbs./yard (explained in Attachment 3). As a result, the average annual
production reported by the facility on the application is 92,350 lbs./day; this value includes an estimated
increase of 11.5%. (See Attachment 2)
For ELG limits, document the calculations used to develop TBEL limits: The limits in Table 5 are based
on the EPA's Effluent Limitation Guideline (ELG) standard 40 CFR 410.50 Knit Fabric Finishing, and
Lear Corps reported annual production rate of 92,350 lbs./day. (See Attachment 2)
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Lear Fact Sheet NC0002305
Table 5: TBEL Development per 40 CFR 410.52(a)(b)/BPT - 92,350 lbs./day
Pollutant
Daily Maximum
BPT
(1 b/1000 lb.)
Daily Maximum
Limit
(lb. /day)
DM
(mg/L)
Monthly Average
BPT
(lb./1000 lb.)
Monthly Average
Limit
(lb./day)
MA
(mg/L)
BOD5 (WQBEL)
5.0
461.8
36
2.5
230.9
18.5
COD (b)
20.0
1847.0
148
10.0
923.5
74
TSS
21.8
2013.2
161
10.9
1007
81
Sulfide
0.20
18.5
1.48
0.10
9.2
0.7
Phenol
0.10
9.2
0.74
0.05
4.6
0.37
Total Chromium
0.10
9.2
0.74
0.05
4.6
0.37
pH
Not less than 6.0 S.U. nor greater than 9.0 S.U.
If any limits are based on best professional judgement (BPJ), describe development: N/A
Document any TBELs that are more stringent than WQBELs: Based on a Division approved STREAM
model study submitted in June 2007 using the facility average flow of 1.5 MGD, and the Chemical
Biochemical Oxygen Demand (CBOD) and Nitrogenous Biochemical Oxygen Demand (NBOD) loading,
it was demonstrated that a monthly average BOD loading of 24 mg/L summer and 30 mg/L winter was
protective of the instream DO WQBEL of 5.0 mg/L. As a result, with the reported production of 92,350
lbs./day, the BOD TBEL equivalent monthly average limit concentration is 18.5 mg/L (230.9 lbs./day)
which is more stringent than the model demonstrated BOD protective levels of 24mg/L (300.2 lbs./day).
Lastly, the proposed TBEL TSS limits are more stringent under the reported production rate of 92,350
lbs./day in comparison to the 1977 model allocation of 2,071 lbs./day daily maximum and 1,033 lbs./day
monthly average. All the proposed TBEL Phenol limits are more stringent than the calculated RPA
WQBEL. See Attachment 2 and Attachment 4 for details.
Based on 40 CFR 410.52 (a) and (b), it is required to select the most stringent limit of the two applicable
limits given for COD, not a total of the two as was given in the last permit. As a result, the Best
Practicable Technology (BPT) limitations for COD given for the treatment is based on the requirements
from 40 CFR 410.52 (b).
Document any TBELs that are less stringent than previous permit: N/A
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: N/A.
Page 10 of 22

Lear Fact Sheet NC0002305
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: N/A
10. Emerging Contaminant Analysis: See Special Conditions A.(L), A.(6.) through A.(10.) of
the Permit for additional information.
As part of the permit development process NCDEQ personnel reviewed the following sources of
information and their applicability to this permit. This review addressed many of the concerns raised by
EPA Region 4's notes (Attachment 9) to NCDEQ of 5/6/24 and external comment letters. Below is a
chronology of EPA and NCDEQ efforts to regulate PFAS; for the latest updates, go to Per- and
Polyfluoroalkyl Substances (PFAS) I US EPA (www.epa.gov/pfas) and to: NCDEQ Understanding PFAS
at: https://www.deq.nc.gov/news/key-issues/emerging compounds/understanding-pfas.
• EPA published WAS Strategic Roadmap: EPA's Commitments to Action 2021-2024' in
October 2021 (document EPA- 100-K-21-002, available at PFAS Strategic Roadmap: EPA's
Commitments to Action 2021-2024).
• EPA expanded nationwide monitoring for 29 PFAS in drinking water under Revisions to the
Unregulated Contaminant Monitoring Rule (UCMR 5); the final rule was published in December
2021 (available at 2021-27858.pdf (govinfo.gov), 86 F.R. 73131 (Dec. 27, 2021)).
• EPA announced the following draft aquatic life water quality criteria for PFOA and PFOS in May
2022 (available at 2022-09441.pdf (govinfo.gov), 87 F.R. 26199 (May 3, 2022)): 49,000 ug/l
acute fish criteria and 94 ug/1 chronic fish criteria for PFOA; 3000 ug/l acute fish criteria and 8.4
ug/l chronic fish criteria for PFOS (expressed as mg/1 but converted to ug/l here for consistency
throughout the Fact Sheet).
o EPA published the following interim Health Advisory Levels (HALs) for PFOA and
PFOS on June 21, 2022 (available at 2022-13158.pdf (govinfo.gov), 87 Federal Register
36848 (June 21, 2022)):0.004 parts per trillion (ppt) for PFOA and 0.020 ppt for PFOS,
which are below currently achievable detection levels. Previously, the EPA's published
HALs had been 70 ppt for PFOA and PFOS.
• Also in the June 21, 2022, Federal Register, EPA published final HALs for hexafluoropropylene
oxide dimer acid (HFPO-DA) and its ammonium salt (together referred to as GenX chemicals) of
10 ppt and perfluorobutane sulfonic acid and potassium perfluorobutane sulfonate (together
referred to as PFBS) of 2000 ppt.
EPA circulated a memorandum to its regional offices and State regulatory authorities, including
NCDEQ, on December 5, 2022, with recommendations for addressing PFAS in NPDES permits,
including quarterly monitoring, Best Management Practices (BMPs), and using draft analytical
method 1633 as the preferred analytical method for 40 PFAS parameters in the absence of a final
40 C.F.R. Part 136 method. The memo also instructed NPDES permitting authorities, such as
NCDEQ, to provide notification to potentially affected downstream public water systems (PWS)
of draft permits with PFAS-specific monitoring, BMPs, or other conditions. (The memorandum is
available at hllps://www.epa.mov/pfas/ke-epa-actions-address-
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Lear Fact Sheet NC0002305
pfas#:-:text=On%20December%205°/o2C%202022%2C%20EPA,°/o2C%20or%20de%20minimis
%2C%20concentrations.
• EPA announced in January 2023 that it intends to revise the Landfills Point Source Category
Effluent Limitation Guidelines (ELGs) to address PFAS discharge from landfills (available at:
2023-01413.pdf (govinfo.gov), 88 F.R. 6258 (Jan. 31, 2023)).
• In March 2023, EPA proposed draft MCLs for PFOA, PFOS, and 4 other PFAS compounds
(available at: Federal Register, Volume 88 Issue 60 (Wednesday, March 29, 2023) (govinfo.gov),
88 F.R. 18638 (Mar. 29, 2023)):
• EPA has designated various PFAS Compounds as Hazardous substances in its "Final CERCLA
Hazardous Substances Designations for PFOA and PFOS" which can be found at:
https://www. epa. goy/pfas/key-epa-actions-address-
pfas#:-:text=On%20December%205%2C%202022%2C%20EPA,%2C%20or%20de%20minimis
%2C%20concentrations..
• EPA has provided its "Updated Interim Guidance on PFAS Destruction and Disposal" which can
be found at: https://www.epa.gov/pfas/key-epa-actions-address-
pfas#:-:text=On%20December%205%2C%202022%2C%20EPA,%2C%20or%20de%20minimis
%2C%20concentrationshttps://www. epa. goy/pfas/ke-epa-actions-address-
pfas#:—:text=On%20December%205°/o2C%202022%2C%20EPA,°/o2C%20or%20de%20minimis
%2C%20concentrations.
• EPA on 7/10/24 provided PFAS monitoring updates or Recommendations for Contaminants
(PFAS Compounds) to Monitor in Fish and Shellfish Advisory Programs:
o The Contaminants to Monitor for Advisories list contains contaminants for which EPA
or other federal agencies have released measures of oral toxicity in humans (e.g.,
reference dose, cancer slope factor).
• Five PFAS have been added to the Contaminants to Monitor for Fish and
Shellfish Advisories List. These are: Perfluorodecanoic acid (PFDA),
Perfluorohexane sulfonic acid (PFHxS), Perfluorononanoic acid (PFNA),
Perfluorooctanoic acid (PFOA), and Perfluorooctane sulfonic acid (PFOS).
• Other non-PFAS contaminants have been added to the Contaminants to
Monitor for Fish and Shellfish Advisories List. These are: Microcystins (a
cyanotoxin); BDE-47 (a flame retardant); Amphetamine (a pharmaceutical); and
Lead.
o EPA created a new Contaminants to Monitor to Watch list that contains nine
contaminants (seven PFAS compounds and two cyanotoxins). These compounds were
documented in studies as occurring in edible tissue of consumed fish or shellfish species
at a concentration that could be of concern for human health, based on EPA's analyses.
These compounds do not currently have measures of oral toxicity in humans (e.g.,
reference doses or cancer slope factors) issued by a federal agency. After relevant
toxicity values are developed for any of these contaminants, advisory programs should
evaluate the concentrations they have found in local fish and shellfish to determine if they
need to issue consumption advisories.
• The seven PFAS compounds that are on the new Contaminants to Monitor to
Watch list are: Perfluorodecanesulfonic acid (PFDS), Perfluorododecanoate
(PFDoA), Perfluoroheptanesulfonic acid (PFHpS), Perfluorooctanesulfonamide
(PFOSA), Perfluorotetradecanoic acid (PFTeDA), Perfluorotridecanoate (PFTrDA),
and Perfluoroundecanoate (PFUdA, PFUnA, PFUnDA).
o See the press release here: hllps://www.epa.gov/newsreleases/epa-releases-new-science-
based-recommendations-help-more-states-tribes-and-territories
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Lear Fact Sheet NC0002305
And the main landing page here: https://www.epa.gov/choose-fish-and-shellfish-
wisely/epa-guidance-developing-fish-advisories
NPDES permit limits are developed from federal ELGs, Federal and State regulatory standards,
promulgated water quality criteria, TBEL BPJs such as performance standards, and/or from site -specific
criteria after data collection, public notice, approval by EPA, and proposed rulemaking to apply the site -
specific criteria to a particular water body segment. To date, the federal ELGs have not been amended
to include PFAS although EPA has announced that ELGs are being re-evaluated. Any proposed
changes would have to be public noticed, have a comment period, have time to consider and respond to
comments, and possibly be re -drafted to incorporate changes because of the comments received before
they could be finalized and published with an effective date.
To date, no Federal or State surface water quality criteria have been promulgated.
As of the drafting of this permit, there is insufficient information to determine Technology -Based Effluent
Limitations (TBELs) on the facility based on Best Professional Judgement (BPJ) such as achievable
concentrations based on demonstrated treatment in conformance with 40 C.F.R. § 125.3 for deriving BPJ
TBELs. However, there are numerous potential treatment options that can be used to address PFAS in
discharges, but to develop treatment options the facility needs to have ample data with a full analysis to
address the types of PFAS in the discharge. To garner the necessary data to determine next steps the
revised permit includes the following requirements:
Monitoring and Sampling: The revised permit includes monitoring and sampling requirements
that will provide the data necessary to develop information about baseline PFAS levels if
reductions of such levels become required through State or Federal laws or regulations. Sampling
and analysis are required upstream, effluent, and downstream. Analysis will be conducted
adhering to Method 1633. Until there is an analytical method approved in 40 C.F.R. Part 136 for
PFAS monitoring, all PFAS monitoring to be reported on DMRs, including for PFOA and PFOS,
shall be conducted using EPA Draft Method 1633.
2. WET Testing: Because of the history of non-compliance at the site, WET testing shall be
increased from 6 x a year to 12 x a year. In addition, a second species has been added to the
Permit (See Special Condition A.(2)).
3. Groundwater Well Monitoring: Following the first public notice period, data became available
reflecting the presence of PFAS Compounds in one of the three wells on site, thus the new permit
includes monitoring and sampling of the groundwater wells for PFAS Compounds as follows:
• Well 1- Monitoring using the EPA 537.1 standard.
• Well(s) 2 and 3- Monitoring using EPA method 1633.
4. Schedule of Compliance PFAS Studies and Reports: Since PFAS has been detected on -site the
following schedule of compliance has been established in the permit. The information derived
during this compliance schedule shall be used later to determine next steps which may include the
establishment of limits.
a) PFAS Characterization Study: The Permittee shall submit a detailed study and analysis
(Analysis 1) to Division of all PFAS Compounds used at the site, processed at the site, and
released from the site per the permit. See Special Condition A (8). Of the permit for
additional details.
• This information will be critical in determining the next best steps, such as establishing
limits.
b) PFAS BAT Study: The Permittee shall develop and submit a detailed robust BPJ study /
analysis (Analysis 2) of the Best Available Technology (BAT) to reduce and/or eliminate
PFAS in the discharge to the Division per the Permit. See Special Condition A (8). Of the
permit for additional details.
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Lear Fact Sheet
NC0002305
• This information will be critical in determining the next best steps, such as establishing
limits.
c) PFAS BMP Study: The Permittee shall develop and submit a detailed BPJ study / analysis
(Analysis 3) of Best Management Practices (BMPs) for the site to the Division per the permit.
See Special Condition A (8). Of the permit for additional details.
• This information will be critical in determining the next best steps, such as establishing
limits.
d) Instream PFAS Characterization Study: As determined by the information provided in
steps 1, 2 and 3 above the Permittee may be required to develop and submit a comprehensive
plan to NCDEQ DWR per the Permit for evaluation of and determination of next steps. Upon
approval, Permittee shall submit results of the Characterization Study to NCDEQ DWR
which shall include an evaluation and assessment of all instream monitoring data: upstream,
effluent discharge and downstream gathered to date. See Special Condition A.(8.) of the
permit for additional details.
• This information will be critical in determining the next best steps, such as establishing
limits.
e) Permittee Options: In addition to permit imposed requirements the permittee has the option
to gather additional site -specific data to be used to determine next steps.
The data obtained by these studies and analysis will enable NCDEQ to inform upcoming risk
assessments and the need for future regulations and guidance pertaining to the management of
PFAS compounds associated with this site which may include the establishment of limits.
PFAS Re -Opener Clause: In addition, a re -opener clause has been included in the permit as
Condition A.(9.). If EPA publishes ELGs that include PFAS limits or if federal or state water
quality criteria are promulgated before the next renewal permit or if technology performance
standards based on best professional judgment become available during the renewal permit's
term, the NPDES permit can be re -opened and limits imposed for PFOA, PFOS, and possibly
other PFAS constituents. In that event, NCDEQ would follow regulatory procedures including
the issuance of a draft permit modification, public notice of the draft modification, a public
comment period, final permit issuance and notice of issuance, and opportunity for appeal.
If surface water quality criteria for PFOA, PFOS, or PFAS are promulgated during the permit
term or if technology- based performance standards for the treatment of PFOA, PFOS, or PFAS
become available, NCDEQ may modify or revoke and reissue the permit to impose limits
developed from the new promulgated criteria or in conformance with applicable technology -
based performance standards. Any such major permit modification shall be considered a formal
permitting action of NCDEQ subject to applicable permit modification procedures.
PFAS Fish Tissue Monitoring: Fish Tissue information provided has been reviewed, please see
Memorandum (Attachment 10) dated 4 November 2024.
1,4-Dioxane Re -Opener Clause: The permit requires monitoring and sampling for 1,4-Dioxane
which is commonly used at textile facilities of the nature of Lear Corporation. Also, for 1,4-Dixoane
is a re -opener clause Condition A.(10.).
Permittee Self -Imposed Measures: Although the permit includes specific monitoring and sampling
requirements for GenX, PFAS (Per- and polyfluoroalkyl substances) compounds, 1,4-Dioxane and
data gathering compliance strategies for PFAS compounds that are necessary to garner ample data to
determine next steps it is recommended that the Permittee take measures on its own during this permit
cycle to either reduce or eliminate the discharge of GenX, PFAS Compounds and 1,4-Dioxane from
the facilities discharges.
Such proactive measures may include all or a combination of the following:
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Lear Fact Sheet NC0002305
• Reduction or Elimination: It is recommended that the Permittee proactively reduce or
eliminate the discharge of GenX, PFAS compounds, and 1,4-Dioxane. This can be achieved
through various measures, including:
• Implementing Advanced Treatment Technologies: Using advanced filtration, adsorption,
or other treatment technologies to remove these contaminants from wastewater before
discharge.
• Process Modifications: Altering industrial processes to minimize the use or generation of
these harmful substances. Lear's current measures to address PFAS include the following:
1. Lear is planning to move away from the use of PFAS related chemicals.
2. As stated in the PFAS questionnaire submitted October 4, 2023, PFOA and
PFOS chemistries were removed from the facility in 2006-2008. The
transition for removal of the C6 fluorocarbon began at the beginning of 2024.
Specifically, in January and February 2024, Lear removed one of the final
two fluorinated chemicals from use in the process. In September of 2024, the
remaining fluorinated chemical use was reduced by half. By December 31,
2024, the fluorinated chemical will no longer be used in the process, thus
eliminating PFAS chemicals within the plant that could contribute to the
wastewater effluent.
3. Lear has a plan reflecting the transition away from the use of PFAS
chemicals. Presently, DWR does not have a copy of this plan due to the
proprietary nature of the plan.
o Source Control: Identifying and mitigating sources of these contaminants within the facility.
I (.Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 213.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
The last four and a half years of the facility's data for the Effluent Limitations Guidelines (ELG), 40 CFR
410.52 (a) (b), parameters have been reviewed in accordance with the criteria outlined in the guidance. As
a result, Lear Corp. will continue to monitor for the said pollutants (BOD, COD. TSS and DO) at a
frequency of three times per week based on the 15A NCAC 0213.0508 (d) Textile Processing standard.
PFAS Compounds
See detailed discussion previously in Section 10. The facility indicated the presence of PFAS compounds
in the 2023 PFAS questionnaire. Subsequently during the renewal process the facility provided lab data
reflecting PFAS in the effluent. Thus, to gain a better understanding, PFAS monitoring has been added to
the permit for Outfall 001 at a monthly frequency, sampling results using EPA Method 1633 (January 31,
2024). In addition, sampling and monitoring for PFAS compounds is required both upstream and
downstream monthly.
Page 15 of 22

Lear Fact Sheet NC0002305
Additional data revealed the detection of PFAS compounds in one of three production wells. Thus,
sampling requirements (Method 1633 and Method 537.1B Standard) for all three wells has also been
included in the permit. Sampling using the appropriate method shall take effect the first full calendar
quarter following 6 months after the effective date of the permit to provide the Permittee time to select a
laboratory, develop a contract, and begin collecting samples. Additional information pertaining to
monitoring requirements for existing groundwater wells is discussed previously in Section 10.
Information garnered from this work will enable the site operator and NCDEQ to determine next steps
based upon comprehensive science backed data. The need for this data is based upon numerous factors
noted elsewhere herein.
12.Endangered Species and Species of Concern
Staff also during the development of this permit assessed current and potential impacts to known
endangered species within waterbody. This is important because EPA Region 4's notes to the
NCDEQ of 5/6/24 raised concern about ensuring the protection of endangered species. This
evaluation included evaluating water quality for the endangered Atlantic sturgeon which involved
assessing various parameters that can affect their habitat and overall health. This evaluation included
the following parameters and/or review of the following documents:
1. Temperature: Sturgeons are sensitive to temperature changes. Monitoring water temperature
helps assess if it falls within the species' preferred range.
2. Dissolved Oxygen (DO): Sturgeon requires well -oxygenated water. Low DO levels can stress
or suffocate them. Continuous monitoring of DO levels is crucial, especially in areas prone to
hypoxia.
3. pH Levels: Sturgeon prefer neutral to slightly alkaline water. Extreme pH levels can be
harmful. Regular pH monitoring ensures water remains within suitable ranges.
4. Turbidity: Excessive sedimentation can impact sturgeon feeding and habitat. Monitoring
turbidity helps assess sediment levels, which can be caused by erosion, runoff, or dredging
activities.
Nutrient Levels: Excess nutrients from agricultural runoff or wastewater can lead to
eutrophication, harmful algal blooms, and degraded water quality. Monitoring nitrogen and
phosphorus levels is essential.
6. Toxic Substances: Assessing concentrations of heavy metals, pesticides, industrial chemicals,
and other pollutants is crucial. These substances can accumulate in sturgeon tissues,
impacting their health and reproductive success. This evaluation included an assessment of
Mercury as noted below.
7. Flow Rate and Hydrology: Sturgeon require specific flow regimes for spawning, migration,
and feeding. Alterations in flow patterns due to dams, diversions, or water withdrawals can
disrupt their life cycle.
8. Suspended Solids: Monitoring the concentration of suspended solids helps evaluate
sedimentation rates and overall water clarity, which can impact sturgeon behavior and habitat
suitability.
Microbial Contaminants: Monitoring for bacteria, viruses, and other pathogens is essential,
especially in areas impacted by sewage discharge or agricultural runoff.
Page 16 of 22

Lear Fact Sheet NC0002305
10. Habitat Quality: Assessing physical habitat features like substrate composition, depth, and
cover availability helps understand the suitability of an area for sturgeon spawning, feeding,
and shelter.
11. Biological Integrity: Monitoring fish populations, aquatic vegetation, and benthic
macroinvertebrates provides insights into overall ecosystem health, which indirectly affects
sturgeon populations.
12. Climate Factors: Considering long-term climate trends and their impacts on water
temperature, precipitation patterns, and sea level rise is crucial for understanding future
habitat suitability for sturgeon.
o Regular monitoring and analysis of these parameters provide valuable insights into water
quality trends and potential threats to Atlantic sturgeon populations. Implementing
conservation measures based on these evaluations can help mitigate risks and promote the
recovery of this endangered species.
o During this assessment the Permit Writer reviewed the following regulations to ensure
the protection of the Atlantic Sturgeon:
1. Federal Endangered Species Act (ESA):
• The ESA provides protection for endangered and threatened species and
their habitats across the United States, including the Atlantic Sturgeon.
• Under the ESA, federal agencies are required to ensure that their actions do
not jeopardize the continued existence of listed species or adversely modify
their critical habitat.
2. North Carolina Endangered Species Act:
• North Carolina has its own endangered species law, which complements
the federal ESA.
• This state law provides additional protections for species listed as
endangered or threatened within the state, including the Atlantic Sturgeon.
North Carolina Wildlife Resources Commission (NCWRC):
• The NCWRC is responsible for managing and conserving the state's
wildlife resources, including endangered species.
• The commission may enact regulations and management plans specific to
endangered species within North Carolina, which may include protections
for the Atlantic Sturgeon.
4. North Carolina Coastal Habitat Protection Plan:
• This plan addresses the conservation and management of coastal habitats
and species, including the Atlantic Sturgeon, along the North Carolina
coast.
• It may include measures to protect critical habitats, reduce habitat
degradation, and mitigate threats to endangered species.
5. North Carolina Division of Marine Fisheries (NCDMF):
• The NCDMF regulates fisheries and marine resources in North Carolina,
including species like the Atlantic Sturgeon.
• The division may enact regulations related to fishing practices, habitat
conservation, and species management to protect endangered species.
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Lear Fact Sheet NC0002305
6. Fisheries Management Plans (FMPs):
• The NCDMF may develop FMPs for certain species, including those listed
as endangered or threatened.
• These plans outline strategies for managing fisheries to ensure the
sustainability of fish populations and may include measures to protect
endangered species like the Atlantic Sturgeon.
7. Water Quality Regulations:
• Regulations related to water quality, including those enforced by the North
Carolina Department of Environmental Quality (NCDEQ), play a crucial role
in protecting aquatic habitats used by the Atlantic Sturgeon.
• These regulations aim to minimize pollution, preserve water quality, and
maintain suitable habitats for aquatic species.
13. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
14. Summary of Proposed Permitting Actions:
Table I: Current Permit Conditions and Proposed Changes-Outfal1 001
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 1.5 MGD
No change
15A NCAC 2B .0505
MA 230.9 lbs./day
MA- TBEL - 40 CFR 410.52(a)
BOD
MA 129.4 lbs./day
DM 450.4 lbs./day
Repo tigalue
DM-WQBEL. 2007 STREAM
DM 258.9 lbs./day
Concentration-Reporting
Model limit more stringent than the
added.
ELG at revised production rate.
MA 923.5 lbs./day
MA 2 071.0 lbs./day
DM 1847.0 lbs./day
COD
DM 4,142.0 lbs./day
-Reporting
TBEL - 40 CFR 410.52(b)
Concentration Value
added.
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Lear Fact Sheet
NC0002305
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
MA 161 bs/day
MA 564.3 lbs./day
DM 1006.6 lbs./day
TSS
DM 1,128.7 lbs./day
-Reporting
TBEL - 40 CFR 410.52(a)
Concentration Value
added.
H
6.0 - 9.0 SU
No change
TBEL - 40 CFR 410.52 a
Total Residual
DM 28 µg/L
No Change
WQBEL - State WQ standard, 15A
Chlorine TRC
NCAC 2B .0211
DO
Daily Average > 6.0
No change
WQBEL - State approved river
m /l
model.
NH3-N
Monitor Weekly
MA 3 mg/I
DM 15 mg/1
15A NCAC 02B .0400 et seq., 15A
NCAC 02B .0500 et seq.
Temperature
Monitor 3/Week
No change
15A NCAC 02B .0500
Conductivity
Monitor 3/week
No change
15A NCAC 02B .0500
Fecal coliform
MA 200 /100ml
No change
WQBEL - State WQ standard, 15A
DM 400 /100ml
NCAC 2B .0211
MA 9.2 lbs./day
MA 5.2 lbs./day
DM 18.5 lbs./day
Sulfide
DM 10.4 lbs./day
-Reporting
TBEL - 40 CFR 210.53(a)
Concentration Value
added.
MA 4.6 lbs./day
Total Phenolic
MA 2.61ess/day
DM 9.2 lbs./day-Reporting
Compounds
DM 5.21bs./day
TBEL - 40 CFR 210.53(a)
Concentration Value
added.
MA 4.6 lbs./day
MA 2.6 lbs./day
DM 9.2 lbs./day
Total Chromium
DM 5.2 lbs./day
-Reporting
TBEL - 40 CFR 210.53(a)
Concentration value
added
Monitoring/Reporting
MA 38.9 µg/L
WQBEL- State WQ Standard,
Chromium VI
DM 49.8 µg/L
15ANCAC 2B.0211. Pollutant of
concern.
MA 17.7 µg/L
WQBEL - State WQ standard, 15A
DM 68.5 µg/L
NCAC 2B .0211
MA 19.0 µg/1
No Change in
RPA Result showed 8 values
Total Cyanide
Weekly monitoring
monitoring
exceeding CW and a more stringent
limitation. Pollutant of concern BPJ
increase monitoring.
Oil & Grease
MA 30.0 mg/l
No change
BPJ - concern over industrial
DM 45.0 m /l
sources.
Surfactants,
No Requirement
Monitor Quarterly
BPJ - Visual Observation reveals
MBAS
limited maintenance observations.
BPJ-Visual Observation reveals
Total Copper
No Requirement
Annually
limited maintenance per industry
standards.
Total Zinc
No Requirement
Annually
BPJ- Visual Observation reveals
limited maintenance observations.
Page 19 of 22

Lear Fact Sheet
NC0002305
Parameter IF
Current Permit
Proposed Change
Basis for Condition/Change
Total Phosphorus
Monitor Monthly
No change
Discharge to NE Cape Fear River
Basin - 15A NCAC 213.0500
Total Kjeldahl
No Requirement
Monitor Monthly
For calculation of TN
Nitrogen, TKN
NO2+NO3
No Requirement
Monitor Monthly
For calculation of TN
Total Nitrogen
Monitor Monthly
No change
Discharge to NE Cape Fear River
Basin - 15A NCAC 213.0500
N/A
Monitor Monthly-
Onsite Wells
Applicable PFAS
Upstream, Effluent,
See Section 10. Method 1633
compounds
Downstream
NCDEQ monitoring method applied.
Re -opener Clause
Added
No Requirement
Monitor Monthly
15A NCAC 2H.0112(b) (1).
1,4 — Dioxane
NCGS 143-215.1 (b). Re -opener
clause added.
Report Quarterly
ort Monthly
15 A NCAC 0213.0200. After past
Chronic Toxicity
repeated violations of the limit and
EPA guidance the frequency has
been increased.
Acute Whole
No Requirement
Report Monthly
Effluent Toxicity-
Based on EPA guidance and BPJ.
LC50
Effluent Pollutant
Scan
Once every 3 years
No Change
40 CFR 122.21
Quarterly
15A NCAC 213.0505
Hardness -Total as
-Reporting in
Hardness -dependent dissolved
CaCO3
Once every 5 years
Concentration value
metals water quality standards
added.
approved in 2016.
40 CFR 410- This plant is a
Production Value
No Requirement
Report Monthly
Production based facility, ELG's are
based on production.
-Once at Permit
Low level
Issuance and there
Mercury
Once/Permit cycle
after
Method 1631E. BPJ.
6 Months prior to
permit expiration
Electronic
Electronic Reporting
No Change
EPA Electronic Reporting Rule
Reporting
Special Condition
2015.
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
LCOD limit from
2. Refer to Permit regarding increases to production value for details.
Page 20 of 22

Lear Fact Sheet NC0002305
15. Public Notice Schedule:
Permit to Public Notice: Revised Public Notice 5 November 2024 with public hearing 17 December
2024.
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
We received a total of 7,800 form emails from the public, regarding PFAS limits not being included into
the permit. Also. the EPA requested an extension for further review of the permit and their Public Notice
Period ended May 3, 2024. EPA submitted comments May 6, 2024 (with follow up material).
Tentative Issue Date for Final: X/XX/2024
16.Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
If yes, list changes and their basis below: TBD
PFAS monitoring increased at: Upstream, Effluent and Downstream and at on -site the
groundwater monitoring wells based on the data provided by the facility. See Sections 4, 10, 11
herein and Special Condition A.(L), and A.(6.) of the permit for details.
W.E.T monitoring increased from Quarterly to monthly, with an additional species (Fat Head
minnow). See Toxicity Testing Limitations Section 6, 10 and 11 herein and Special Conditions
A.(L), A.(2.), and A.(3.) of the permit for details.
• Compliance Schedule: See Sections 10-12 herein and Special Condition A.(8.) of the permit for
details. Key compliance elements include:
• PFAS Characterization Study,
• PFAS BAT Study,
• PFAS BMP Study,
• Instream PFAS Characterization Study, if required
• Permittee Options.
Additional Toxicity Test calculations, Acute TOX calculation, LC50. See Toxicity Test
Limitations section herein or Special Conditions A.(3.) for details.
PFAS Groundwater Well Quarterly Monitoring added to permit. See Section(s) 10-12 herein or
Special Condition A.(7.) of the Permit for details.
Production Value eDMR reporting added to table. See Section 6 herein or Special Condition
A.(4.) of the permit for details.
Page 21 of 22

Lear Fact Sheet
NC0002305
17. Fact Sheet Attachments (if applicable):
1. NPDES Implementation of Instream Dissolved Metals Standards — Freshwater Standards
(Attachment 1)
2. Production Value and EPA 40 CFR 410 Technology -Based Effluent Limitations (TBELs) and
Water Quality -Based Effluent Limitations (WQBELs) Calculations (Excel document)
(Attachment 2)
3. Production rate Density conversion description (PDF document) (Attachment 3)
4. Reasonable Potential Analysis (RPA) Spreadsheet Summary (Excel document) (Attachment 4)
5. Ammonia/Total Residual Chlorine Waste Load Allocation (NH3/TRC WLA) Calculations (Excel
document) (Attachment 5)
6. Electronic Reporting (eDMR) report and calculations. (Excel Document) (Attachment 6)
7. Production Forecast Explanation (Excel Document) (Attachment 7)
8. Additional information Requested. (PDF document) (Attachment 8)
9. Environmental Protection Agency (EPA) comments / NCDEQ Response Notes (4 November)
2024. (PDF document) (Attachment 9)
10. NCDEQ Environmental Toxicologist Fish Tissue Memorandum (4 November 2024). (PDF
document) (Attachment 10)
Date: XXX/XX/2024
Permit Writer: Fenton Brown Jr.
Page 22 of 22

ATTACHMENT 1
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016, must be calculated to protect the new standards - as
approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, µg/1
(Dissolved)
Acute SW, µg/1
(Dissolved)
Chronic SW, µg/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still necessary
to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC
213.0200 (e.g., arsenic at 10 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/1
Cadmium, Acute
WER*{1.136672- [ln hardness] (0.041838)) e^ {0.9789 [ln hardness]-3.443}
Cadmium, Acute Trout waters
WER*{1.136672- [ln hardness] (0.041838)) e^ {0.9789[ln hardness]-3.866)
Cadmium, Chronic
WER*{1.101672- [ln hardness] (0.041838)) e^ {0.7977[ln hardness]-3.909)
Chromium III, Acute
WER*0.316 e^ {0.8190[ln hardness] +3.7256)
Chromium III, Chronic
WER*0.860 e^ {0.8190[ln hardness] +0.68481
Copper, Acute
WER*0.960 e^ {0.9422[ln hardness]-1.700)
Copper, Chronic
WER*0.960 e^ {0.8545[ln hardness]-1.702)
Lead, Acute
WER*{1.46203- [In hardness] (0.145712)) • e^ {1.273[1n hardness]-1.460}
Lead, Chronic
WER*{1.46203- [ln hardness] (0.145712)) • e^ {1.273[ln hardness]-4.705)

Nickel, Acute
WER*0.998 e^ {0.8460[ln hardness] +2.2551
Nickel, Chronic
WER*0.997 e^ {0.8460[ln hardness] +0.05841
Silver, Acute
WER*0.85 • e^ 0.72[1n hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 e^ {0.8473[ln hardness] +0.884)
Zinc, Chronic
WER*0.986 e^ {0.8473[ln hardness] +0.884)
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness -dependent standards requires additional consideration to establish the numeric
standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge -specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present (i.e., consistently below
detection level), then the Division may remove the monitoring requirement in the reissued permit.
To perform an RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfs) 0.99'
• Effluent hardness and upstream hardness, site -specific data is preferred.
• Permitted flow.
• Receiving stream classification
2. To establish the numeric standard for each hardness -dependent metal of concern and for each
individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.

If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
_ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L)+s7Q10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q 10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
Caiss = 1
Ctotal 1 + {[Kpo] [ss(l+a)] [10 6]}
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (i.e., silver),
the dissolved numeric standard for each metal of concern is divided by the EPA conversion factor
to obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal
is dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q 10 + Qw) (Cwgs)(s7Q 10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)

Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q 10)
s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q 10 may be incorporated as applicable:
1 Q 10 = used in the equation to protect aquatic life from acute toxicity
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit (Total allowable
concentration) is included in the permit in accordance with the U.S. EPA Technical Support
Document for Water Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007, from James Hanlon to Alexis Strauss on
40 CFR 122.47 Compliance Schedule Requirements.
The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data
results may be used as a conservative surrogate in cases where there are no analytical results
based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for
total chromium will be compared against water quality standards for chromium III and
chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
48.8
DMR (Jan 2019-Dec 2023)
[Total as, CaCO3 or (Ca+Mg)]
Average Upstream Hardness (mg/L)
63.20
DMR (Jan 2019-Dec 2023)
[Total as, CaCO3 or (Ca+Mg)]
7Q10 summer (cfs)
6.50
Previous Fact Sheet
1 Q 10 (cfs)
4.91
RPA calculation
Permitted Flow (MGD)
1.50
Previous permit/Fact Sheet
Date: November/05/2024
Permit Writer: Fenton Brown Jr.

Production Value and EPA 40 CFR 410 TBELs and WOBELs Calculations
Production Values (pounds)
Lear Corporation Monthly Production Values in Yards
Maximum Yards nmduced for each year Max 2018 Max 2019
November
December
Monthly Avg
3,378,889 yds
Monthly Avg
3,281,533 yds
Yearly Total
40,546,672
Yearly Total
39,378,392
Density lbs./yd
0.586
Density lbs./yd
0.586
Total lbs./yr
23,760,350
Total lbs.
23,075,738
Total lbs/day'
69,071
Total lbs/day'
67,081
*estimate of 21 no -production
days for maintenance,
holidays, etc.
,erages of the Total ppd 2018 - 2C 73,824
Max ppd 2018-2023 90,346
Min ppd 2028-2023 64,265
Lear estimated an 11.5%
increase in production from
2022 as a future estimate 92,350
Max 2020
4,160,771
Max 2021
Max 2022
Monthly Avg
3,143,790 yds
Monthly Avg
3,392,874 yds
Monthly Avg
4,051,728 yds
Yearly Total
37,725,477
Yearly Total
40,714,485
Yearly Total
48,620,731
Density lbs./yd
0.586
Density lbs./yd
0.586
Density lbs./yd
0.586
Total lbs.
22,107,130
Total lbs.
23,858,688
Total lbs.
28,491,748
Total lbs/day-
64,265
Total lbs/day-
69,357
Total lbs/day-
82,825
MAXimum Yards produced
within a Syear period
yards
(Septmeber
5,580,058 2022)
Max Yards per month in a Year
based on MAX Averages
66,960,696 Yards for a Year
Density
0.586 Density(#/yd)
MAX produced in Pounds
39,238,967.86 Pounds
MAX Produced per year based
on a 344 day work week
114,066.77 #/day HIGH Production
ATTACHMENT
Max 2023
5,429,121
Monthly Avg
4,419,639
Yearly Total
53,035,665
Density lbs./yd
0.586
Total lbs.
31,078,900 2.12
Total lbs/day-
90,346
Estimated using November
and December 2022 production
Monthly Averages, Avg multiplied
by 12 months 43,894,950 Yards
Density 0.586 Density(#/yd)
Monthly Averages, Avg 25,722,440.70 Pounds
Monthly Averages, Avg Produced
perday 74,774.54 #/day

ATTACHMENT 2
Production Value and EPA 40 CFR 410 TBELs and WQBELs Calculations
Production Data 2018-2023
Months
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Average
(Yards)
2018 2019
2951722 2,984,749.00
3484577 3,235,961.00
4101528 3,847,741.00
3427960 2,840,707.00
3211968 3,091,058.00
4063935 4,142,214.00
2165083 2,394,238.00
3194436 3,262,984.00
3261802 3,860,273.00
4479727 2,962,331.00
3068023 2,995,080.00
3135911 3761056
Production years (4.5-5 years)
2020 2021
4,118,208.00 3,675,695.00
3,663,257.00 3,559,463.00
2,973,613.00 4,051,950.00
- 3,588,715.00
- 3,189,166.00
3,272,285.00 4,091,252.00
3,764,741.00 2,888,221.00
3,819,418.00 3,442,846.00
4,004,607.00 3,520,383.00
3,913,608.00 2,975,336.00
4,034,969.00 2,536,537.00
4160771 3194921
2022
3,197,357.00
3,758,489.00
4,408,827.00
3,401,323.00
3,399,864.00
4,594,584.00
3,884,958.00
4,051,016.00
5,580,058.00
4,479,579.00
3,832,579.00
4032097
2023
4,412,749.00
4,667,531.00
5,338,617.00
3,959,334.00
4,424,030.00
5,429,121.00
3,536,307.00
4,312,275.00
5,164,974.00
3,926,051.00
Average of
Averages
3378889.333 3,281,532.67 3,143,789.75 3,392,873.75 4,051,727.58 4,517,098.90 3,677,404.53
Production
Percentage rate
-11% -15% -8% 10% 23% per year
*Production data in Yards

Production Value and EPA 40 CFR 410 TBELs and WOBELs Calculations
Production by month (2019-2023)
ATTACHMENT
Amount of product
years
Months
Produced monthly
annual avg(Pounds/Month)
Syr annual
(Yards(
erage(Pounds/Month)
2U19 Jan
2,984,/49.W
1,922,9/6.14
Feb
3,235,961.00
1,922,978.14
Mar
3,847,741.00
1,922,978.14
Apr
2,940,707.00
1,922,978.14
May
3,091,058.00
1,922,978. 14
Jun
4,142,214.00
1,922,978.14
Jul
2,394,238.00
1,922,978.14
Aug
3,262,994.00
1,922,978.14
Sep
3,860,273.00
1,922,978.14
Oct
2,962,331.00
1,922,978.14
Nov
2,995,080.00
1,922,978'14
Dec
3,761,056.W
1,922,978.14
2020 Jan
4,118,208.00
1,842,260.79
Feb
3,663,257.00
1,12,260.79
Mar
2,973,613.00
J 842, 260079
Apr
-
1,942,260.79
May
-
1,842,260.79
Jun
3,272,285.00
1,942,260.79
Jul
3,764,741.00
1,942,260.79
Aug
3,819'418.00
1,842,260.79
Sep
4,004,607.00
1,842,260.79
Oct
3,913,608.00
1,842,260.79
Nov
4,034,969.00
1,842,260.79
Dec
4,160,771.W
1,942,260.79
2021 Jan
3,675,695.00
1,988,224.02
Feb
3,559,463.00
1,,988,2224.02
Mar
4,01,5
1,9882224.02
Apr
100
3,588,75.00
88,4020
May
3,189,166.00
1,988,224.02
Jun
4,091,252.00
1,988, 224 02
Jul
2,888,221.00
1,988,224.02
Aug
3,442,846.00
1,9as, 224.02
Sep
3,520,383.00
1,988,224.02
Oct
2,975,336.00
1,9as, 224.02
Nov
2,536,537.00
1,988,224.02
Dec
3,194,921.00
1,988,224.02
2022 Jan
3,197,357.00
2,374,312.36
Feb
3,758,489.00
2,374,312.36
Mar
4,408,827.00
2,374,312.36
Apr
3,401,323.00
2,374,312.36
May
3,399,864.00
2,31312.36
Jun
4,594,584.00
2,374,312.36
Jul
3,894,958.00
2,374'312.36
Aug
4,051,016.00
2,374,312.36
Sep
5,580,058.00
2,374,312.36
Oct
4,479,579.00
2,374,312.36
Nov
3,832,579.00
2,374,312.36
Dec
4,032,097.00
2,374,312.36
2023 Jan
4,412,749.00
2,589,908.31
Feb
4,667,531.00
2,589,908.31
Mar
5,338,617.00
2,589,908.31
Apr
3,959,334.00
2,589,908.31
May
4,424,030.00
2,589,908.31
Jun
5,429,121.00
2,589,,908.31
Jul
3,33700
2,58990-.31516205.0
432,7
2,8,0Aug 831
Sept
5,164,974.00
2,589,90-.31
Oct
3,926,051.00
2,589,908.31
Nov
3,832,579.00
2,589,908.31
Dec
4,032,097.00
2,589,908.31
Max Production rate for the last 5 years
Lowest Production rate for the last
Average of the Low and High
2,143,63b./3
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143'536.73
2,143,536.73
2,143,536.73
2,143,:36.73
21J43,536.73
2,143,:36.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143'536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,:36.73
2,143,536.73
2,143,:36.73
2,143,536.73
2,143,:36.73
2,143,536.73
2,143,:36.73
2,143,536.73
2,143,:36.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,:36.73
21J43,536.73
2,143,:36.73
21J43,536.73
2,143,:36.73
21J43,536.73
2,143,:36.73
21J43,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,:36.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2,143,536.73
2572244.07 1714829.38
2572244.07 1714829.38
2,589,908 Pounds/Month
7,528.80 Jf/day
1,842,261 Pounds/Month
5,355.41 Jf/day
2,216,094.55 p/Month
^77K/day
GUILFORD MILLS PRODUCTION
+Seriesl Series2
6,000,000 ---
5,000,000 ---
4,000,000 ---
E 3,000,000 - -
2,000,000 ---
1,000,o00 t---
2018 Jan
2951722
3378889.333
2301332.93
Feb
3484577
3378889.333
2301332.93
Mar
4101528
3378889.333
2301332.93
Apr
3427960
3378889.333
2301332.93
May
3211968
3378889.333
2301332.93
Jun
4063935
3378889.333
2301332.93
Jul
2165083
3378889.333
2301332.93
Aug
3194436
3378889.333
2301332.93
Sep
3261802
3378889.333
2301332.93
Oct
4479727
3378889.333
2301332.93
Nov
3068023
3378889.333
2301332.93
Dec
3135911
3378889.333
2301332.93
0i F{ I I I
zo f a'f a'� zo f a'f a'� zo f a'f a'.X o zo o zo
2018 2019 2020 2021 2022
28.7 = days/month (1720 days . 60 months) (1720 Work days in 5 years) 5 year-- 60 months
Current Permit(2017): 1,485,914 Ibs/month 51,774.0 Ibs/day
Renewal: 2,143,537 lbs/month IS year Avg) 74,687.7 lbs/day
Increase from current to renewal: 44.3%
F�
344 Actual Workdays (Reported from Lear)
1720 Total Working days in past 5 years for Lear
28.66667 Average working days/month
0.586 Vvd(Density Calculated from Lear)
48
54
25692565.6

Production Value and EPA 40 CFR 410 TBELS and WOBELs Calculations
TBEL & WQBEL Values
Qw= 1.5 MGD IWC 7Q10s= 28.27%
Requested Production, 92350 92.35 1000lbs/day IWC1Q10s= 32.14%
Ibs/day= IWC 30Cl2= 6.08%
ELG factors Ib/1000lb
Calculated Limits
WQS Limits
40 CFR
410
Parameter Subpart E
Daily Max
Monthly
Average
Daily Max
Limit (Ibs/day)
Monthly Avg
Limit (Ibs/day)
Acute or
Daily
(Ibs/day)
Chronic or
Monthly
(Ibs/day)
BOD 410.52(a)
5
2.50
461.8
230.9
450.4
300.2
TSS 410.52(a)
21.8
10.9
2013.2
1006.6
2071
1035
COD 410.52(a)
60
30
5541.0
2770.5
Sulfide 410.52(a)
0.2
0.1
18.5
9.2
Phenol 410.52(a)
0.1
0.05
9.2
4.6
123.4
61.7
Total chromium 410.52(a)
j 0.1
j 0.05
j 9.2
1 4.6
COD 430.52(b)
1 20
1 30
1847.0
1 923.5
pH 1 410.52(a)
1 Within 6.0 to 9.0 All times
Total mass -based limits
New Permit Limits (BOD & TSS) Based
on most stringent
Parameter
Daily Max
(Ibs/day)
Monthly Avg
(Ibs/day)
Daily Max
(mg/L)
Monthly
Avg(mg/L)
BOD
450.4
230.9
36
18.5
TSS
2013.2
1006.6
160.9
80.5
COD
1847.0
923.5
147.6
73.8
Sulfide
18.5
9.2
1.48
0.7
Total Phenols
1 9.2
4.6
0.74
0.37
Total chromium
1 9.2
4.6
0.74
0.37
1007 Model limits: Summer: 24 mg/L Winter: 30 mg/L
1G more stringent than allocation established 1977
No RPA for WQS, apply EG limits
No RPA for WQS, apply EG limits
Total COD Daily
Total COD Monthly
7388.0
3694.0
TBEL and WQBEL Limit
7n17 Permit I imit< t9177A H/Aav Prn,i,,&inn Ratal
Total Chromium
ELG
Chromium Hexavalent (IV) WQS, RPA Value
Chromium III WQS, RPA
Value
0.416746E
mg/1-DM
414 pg/I
53.2 pg/L CH VI
6191.4 pg/L CH III
0.20756833733
mg/I-MA
207 pg/I
41.8 pg/I CH VI
917.2 pg/L CH III
Chronic
(MA)
225.18
ATTACHMENT 2
mt%'Irlm
2023 Renewal Permit Limit (92350 #/day Production Rate)
Chromium
Hexavalent (IV) WQS Chromium III
Total Chromium (mg/1) ELG (RPA Value) WQS, RPA Valt
0.738209432 mg/I-DM 738 pg/L 49.8 pg/L CH VI 5656.3 pg/L CH III
0.36910471E ma/1-MA 369 ua/L 38.9 ua/1 CH VI 843.0 ua/L CH III
2023 Renewal Production Rqst
92350
Daily Max (Cr)
0.1
Monthly Avg, MA
0.05
Daily Max (Total Cr), DM
9.2
Monthly Avg (Ttl Chromium),MA
4.62
BOD ELG (TBELS) Converted (#/day to mg/L)
Current 51774 #/day Renewal 92350 #/day
20.7 1 mg/L DM 36.9 mg/L DM WQS Limits more stringent for Higher Production
30.3 mg/L MA 18.4E mg/L IMA ELG More Stringent
ELG Standards Implemented
Total Phenols ELG (TBELS) Converted (#/day to mg/L)
AR/A-,
DM
MA
ELG (pg/I)
WQS( RPA Value, Chronic)
5.2
2.9
pg/1
pg/I
0.416
mg/1-DM
416 pg/I
No WQS
0.232
mg/1-MA
232 pg/1
4932.3 pg/I
.•�I _ alRCa M/A�.•
DM
MA
ELG (pg/1)
WQS( RPA Value, Chronic)
9.2
4.6
pg/I
pg/I
mg/L
#/Day
0.74
mg/I-DM
738.2
9864.E
123.4061
0.37
mg/I-MA
369.1
4932.31
4.9323
161.70307
nLb Limns more stringent for nlgner ana lower proauction limns
0.6255

ATTACHMENT 3
Production Rate Density Conversion Description
From: Jr Brown, Fenton O
To: Cooley, Gianna
Subject: RE: [External] Lear Updated NPDES application
Date: Monday, December 11, 2023 4:42:00 PM
Attachments: imaae002.i)ng
mage003.pnng
Thank you.
Fenton Brown Jr.
Environmental Engineer II
NC Department of Environmental Quality
Division: Water Resources/ Permits
Office: Archdale Building
9th floor (Office-925 R)
512 North Salisbury Street
Raleigh, NC 27604
Mailing address: 1617 Mail Service Center
Raleigh, NC 27699-1617
Office #: [phone]
eMail: fenton.brown.ir(a deq.nc.gov
Q:>
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Cooley, Gianna <[e-mail]>
Sent: Monday, December 11, 2023 4:39 PM
To: Jr, Brown, Fenton 0 <[e-mail]>
Cc: Hagins, Juan <[e-mail]>; Cothran, Michael <[e-mail]>; Davis, John
<[e-mail]>; Cress, Lori <lori.cress @wsp.com>; Mcclintock, Kyle
<I<[e-mail]>
Subject: [External] Lear Updated NPDES application
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the
Report Message button located on your Outlook menu bar on the Home tab.
Good afternoon, Fenton,
Please find attached the updated NPDES application for Lear. The original signature pages and the
hard copy will be delivered to you this week. I've attached the updated production numbers and
have the following response to your 12/08/23 email in reference to how the density was calculated:
On October 30, 2023, Six one -yard samples of laminated cloth were cut and weighed. The samples
varied in thickness and width to account for the different types of product produced. The average
density was 0.586 lb/yd.

To check the above number, additional calculations were done from previous data. In 2022, the
different product foam densities were calculated and averaged as 0.369 lb/yd. The average cloth
densities were 0.446 Ib/yd. To get laminated product, the foam and cloth densities were added and
equal 0.81 lb/yard. The total pounds for laminated product for January - October 2023 was
16,068,411 yd*0.81 Ib/yd = 13,015,413 lb. The overall total pounds are face and lamination (already
measured in pounds, no calculation) added together: 13,015,413 lb + 12,543,391 lb = 25,560,554 lb
total product. The total product in yards for January - October 2023 was 44,196,529. Using the total
pounds and total product for the density, 25,560,554 Ib/44,196,529 yd = 0.578 Ib/yd, which is similar
to the weighed sample of finished product above.
Please let me know if you'd like to set up a call to go over these numbers further.
Thank you,
■ 4 S I ) Gianna Cooley, PE
Sr. Environmental Engineer
PE TX, VA, NC, SC
M+ 1 281-846-5751
NOTICE: This communication and any attachments ("this message") may contain information which is privileged, confidential, proprietary
or otherwise subject to restricted disclosure under applicable law. This message is for the sole use of the intended recipient(s). Any
unauthorized use, disclosure, viewing, copying, alteration, dissemination or distribution of, or reliance on, this message is strictly
prohibited. If you have received this message in error, or you are not an authorized or intended recipient, please notify the sender
immediately by replying to this message, delete this message and all copies from your e-mail system and destroy any printed copies.

Reasonable Potential Analysis (RPA) Spreadsheet Summary
input
ATTACHMENT
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
WWTP/WTP Class
NPDES Permit
C utfall
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
❑ Apply WS Hardness WQC
7Q1 Os (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
Effluent Hardness_
Upstream Hardness
Combined _Hardness _Chronic
_
Combined Hardness Acute
Data Source(s)
❑ CHECK TO APPLY MODEL
Lear Corporation
III
NC0002305
001
1.500
NE Cape Fear River
030300070206
C, Sw
5.90
21.70
35.90
402.00
4.91
48.8 mg/L (Avg)
--------------------
63.2 mg/L (Avg)
59.13 mg/L
--------------------
_ _ _ 58.57 mg/L
-BIMS eDMR data Jan 2019- May 2023. -USGS
Stream Stats data- 28 August 2023.
Par01
Par02
Par03
Par04
Par05
Par06E
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Table 2. Parameters of Concern
Name WQS Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
1.1306
FW
6.8098
ug/L
Chlorides
Aquatic Life
NC
230
FW
mg/L
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
238.2820
FW
1817.6745
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
pg/L
Copper
Aquatic Life
NC
16.4448
FW
23.3567
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
7.6890
FW
195.2590
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
77.1254
FW
688.8536
pg/L
Nickel
Water Supply
NC
25.0000
WS
N/A
pg/L
Selenium
Aquatic Life
INC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
1.2819
ug/L
Zinc
Aquatic Life
NC
262.8248
FW
258.6102
ug/L
1,4-dioxane
Human Health
NC
80
HH
ug/I
4_NC0002305 LEAR Corp_RPA Calculation_ ( 2024 Renewal), input
11 /13/2024

Reasonable Potential Analysis (RPA) Spreadsheet Summary ATTACHMENT 4
data
1-11 Use "PASTE SPECIAL- H2 Use "PASTE SPECIAL.
Effluent Hardness Values" then "COPY". Upstream Hardness Values" then "COPY".
Maximum data points Maximum data points
= 58 = 58
Date Data
BDL=1/2DL
Results
1 6/12/2023
50
50
Std Dev.
2 6/13/2023
42
42
Mean
3 6/14/2023
50
50
C.V. (default)
4 6/15/2023
48
48
n
5 6/20/2023
54
54
10th Per value
6
Average Value
7
Max. Value
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Date
Data
BDL=1/2DL
Results
1
6/12/2023
54
54
Std Dev.
7.9498
48.8000
2
6/13/2023
58
58
Mean
63.2000
0.6000
3
6/14/2023
62
62
C.V. (default)
0.6000
5
4
6/15/2023
68
68
n
5
44.40 mg/L
5
6/16/2023
74
74
10th Per value
55.60 mg/L
48.80 mg/L
6
Average Value
63.20 mg/L
54.00 mg/L
7
Max. Value
74.00 mg/L
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
4_NC0002305 LEAR Corp_RPA Calculation_ (2024 Renewal), data
-2- 11/13/2024

Reasonable Potential Analysis (RPA) Spreadsheet Summary ATTACHMENT 4
data
Par07
Par09
Use "PASTE SPECIAL-
Use "PASTE SPECIAL•
Total Phenolic
Compounds
Values" then "COPY".
Chromium
VI
Values" then "COPY".
Maximum data points
Maximum data points
= 58
= 58
Date
Data
BDL=1/2DL
Results
Date Data
BDL=1/2DL
Results
1
8/21/2019
9.94
9.9353749
Std Dev. 20.0910
1
4/21/2022
10
10
Std Dev. 0.6665
2
1/6/2022
9.99
9.994514
Mean 25.6189
2
4/28/2022
10
10
Mean 9.9138
3
2/2/2023
10.01
10.009409
C.V. 0.7842
3
5/5/2022
10
10
C.V. 0.0662
4
1/29/2020
10.04
10.038543
n 58
4
5/13/2022
10
10
n 58
5
1/5/2023
10.05
10.054361
5
5/19/2022
10
10
6
2/27/2019
10.06
10.055234
MultFactor= 1.00
6
5/26/2022
10
10
MultFactor= 1.00
7
11/27/2019
10.06
10.055456
Max. Value 100.1 ug/L
7
6/2/2022
10
10
Max. Value 10.0 pg/L
8
1/26/2022
10.06
10.058995
Max. Fred Cw 100.1 ug/L
8
6/9/2022
10
10
Max. Fred Cw 10.0 pg/L
9
5/13/2020
10.28
10.280072
9
6/16/2022
10
10
10
1/20/2022
11.02
11.017575
10
6/23/2022
10
10
11
8/9/2023
11.98
11.97606
11
6/30/2022
10
10
12
6/17/2020
12.67
12.674681
12
7/8/2022
10
10
13
12/11/2019
< 12.93
6.4650982
13
7/14/2022
10
10
14
10/19/2023
13.00
12.996981
14
7/21/2022
10
10
15
1/13/2022
13.07
13.067261
15
7/28/2022
10
10
16
1/8/2020
< 13.55
6.7759417
16
8/4/2022
10
10
17
9/11/2019
13.98
13.97729
17
8/11/2022
10
10
18
1/19/2023
14.01
14.005735
18
8/18/2022
10
10
19
12/2/2020
14.07
14.068107
19
8/25/2022
10
10
20
10/30/2019
14.94
14.941294
20
9/1/2022
10
10
21
5/20/2020
15.03
15.027896
21
9/8/2022
10
10
22
11/6/2019
15.09
15.086059
22
9/15/2022
10
10
23
7/31/2019
15.46
15.458754
23
9/22/2022
10
10
24
12/28/2022
15.64
15.643587
24
9/28/2022
10
10
25
6/15/2023
15.99
15.991222
25
10/6/2022
10
10
26
3/10/2022
16.09
16.094107
26
10/13/2022
10
10
27
3/25/2020
< 16.43
8.2146691
27
10/20/2022
10
10
28
12/16/2021
19.99
19.989028
28
10/27/2022
10
10
29
1/20/2021
20.06
20.062248
29
11/3/2022
10
10
30
3/3/2022
20.07
20.07337
30
11/10/2022
10
10
31
10/23/2019
20.82
20.816344
31
11/17/2022
10
10
32
8/24/2023
21.08
21.082955
32
11/22/2022
10
10
33
8/19/2020
21.97
21.971411
33
12/1/2022
10
10
34
8/26/2020
22.03
22.025213
34
12/8/2022
10
10
35
3/30/2023
22.08
22.075795
35
12/15/2022
10
10
36
2/17/2022
22.97
22.973815
36
12/20/2022
10
10
37
10/21/2020
23.09
23.088931
37
12/28/2022
10
10
38
4/17/2019
23.99
23.986834
38
1/5/2023
10
10
39
11/10/2022
25.03
25.025634
39
1/12/2023
10
10
40
4/6/2023
25.98
25.981362
40
1/19/2023
10
10
41
11/20/2019
26.96
26.959685
41
1/26/2023
10
10
42
10/14/2020
29.65
29.651621
42
2/2/2023 <
10
5
43
9/23/2020
30.08
30.075799
43
2/9/2023
10
10
44
2/9/2021
31.47
31.467193
44
2/16/2023
10
10
45
9/16/2020
34.08
34.084634
45
2/23/2023
10
10
46
12/9/2021
34.10
34.096987
46
3/2/2023
10
10
47
12/20/2022
35.95
35.951489
47
3/9/2023
10
10
48
4/1/2020
48.53
48.528276
48
3/16/2023
10
10
49
4/13/2023
49.06
49.063978
49
3/23/2023
10
10
50
9/9/2020
49.78
49.778124
50
3/30/2023
10
10
51
2/5/2020
< 50.03
25.014454
51
4/6/2023
10
10
52
4/15/2020
50.50
50.498597
52
4/13/2023
10
10
53
4/8/2020
52.91
52.912133
53
4/20/2023
10
10
54
9/2/2020
54.96
54.955907
54
4/27/2023
10
10
55
7/14/2022
57.98
57.976476
55
5/4/2023
10
10
56
2/10/2022
62.09
62.093576
56
5/11/2023
10
10
57
10/7/2020
99.58
99.584327
57
5/19/2023
10
10
58
11/18/2020
100.1
100.08792
58
5/25/2023
10
10
4_NC0002305 LEAR Corp_RPA Calculation_ (2024 Renewal), data
-3- 11/13/2024

Reasonable Potential Analysis (RPA) Spreadsheet Summary
ATTACHMENT 4
data
Par10
Use "PASTE SPECIAL-
Chromium, Total Values" then "COPY•.
Par12
Cyanide
Maximum data points
= 58
Date
Data
BDL=1/2DL
Results
Date Data
BDL=1/2DL
1
8/3/2023
<
9.98
4.99
Std Dev. 0.8144
1
4/10/2019 <
6
5
2
12/22/2021
<
9.98
4.99
Mean 5.2528
2
4/17/2019
6
5
3
9/15/2021
<
9.98
4.99
C.V. 0.1550
3
9/11/2019
6
5
4
8/26/2020
<
9.98
4.99
n 58
4
9/25/2019
6
5
5
2/9/2022
<
9.98
4.99
5
10/23/2019
6
5
6
10/12/2023
<
9.98
4.99
MultFactor= 1.00
6
11/13/2019
6
5
7
1/19/2023
<
9.98
4.99
Max. Value 8.4 pg/L
7
12/11/2019
6
5
8
6/17/2020
<
9.98
4.99
Max. Fred Cw 8.4 pg/L
8
7/8/2020
6
5
9
8/11/2022
<
9.98
4.99
9
7/15/2020
6
5
10
6/22/2023
<
9.98
4.99
10
5/12/2021
6
5
11
8/7/2019
<
9.98
4.99
11
11/3/2021
6
5
12
8/14/2019
<
9.98
4.99
12
11/10/2021
6.4
5
13
12/1/2022
<
9.98
4.99
13
4/15/2020
7
5
14
9/8/2022
<
9.98
4.99
14
6/10/2020
7
5
15
10/16/2019
<
9.98
4.99
15
7/29/2020
7
5
16
3/10/2021
<
9.99
4.99
16
9/1/2021
7
5
17
1/9/2019
<
9.99
5.00
17
6/9/2022
7
5
18
3/20/2019
<
9.99
5.00
18
3/2/2023
7
5
19
3/27/2019
<
9.99
5.00
19
3/30/2023
7
5
20
4/24/2019
<
9.99
5.00
20
9/8/2023
7
5
21
5/8/2019
<
9.99
5.00
21
3/24/2022
7.3
5
22
7/10/2019
<
9.99
5.00
22
9/18/2019
8
5
23
7/17/2019
<
9.99
5.00
23
1/22/2020
8
5
24
1/6/2021
<
9.99
5.00
24
3/11/2020
8
5
25
8/5/2021
<
9.99
5.00
25
6/17/2020
8
5
26
9/14/2023
<
9.99
5.00
26
6/24/2020
8
5
27
6/5/2019
<
9.99
5.00
27
12/15/2022
8
5
28
6/12/2019
<
9.99
5.00
28
6/29/2023
8
5
29
6/26/2019
<
9.99
5.00
29
3/25/2020
9
5
30
4/22/2020
<
9.99
5.00
30
4/1/2020
9
5
31
3/24/2021
<
9.99
5.00
31
4/8/2020
9
5
32
6/10/2021
<
9.99
5.00
32
2/23/2023
9
5
33
9/1/2021
<
9.99
5.00
33
12/29/2021
9.9
5
34
12/16/2021
<
9.99
5.00
34
11/20/2019
10
10
35
1/6/2022
<
9.99
5.00
35
2/12/2020
10
10
36
4/28/2022
<
9.99
5.00
36
5/25/2023
10
10
37
11/3/2022
<
9.99
5.00
37
12/1/2022
10.8
10.8
38
11/22/2022
<
9.99
5.00
38
10/16/2019
11
11
39
3/31/2022
<
9.99
5.00
39
3/4/2020
11
11
40
7/12/2023
<
10.00
5.00
40
7/6/2023
11
11
41
7/6/2023
<
10.00
5.00
41
7/12/2023
11
11
42
7/20/2023
<
10.00
5.00
42
8/3/2023
11
11
43
7/27/2023
<
10.01
5.00
43
2/26/2020
12
12
44
10/14/2020
<
10.03
5.02
44
11/11/2020
12
12
45
10/19/2023
<
10.04
5.02
45
2/17/2022
12
12
46
10/26/2023
<
10.04
5.02
46
6/22/2023
13
13
47
8/17/2023
<
10.05
5.02
47
5/6/2020
14
14
48
8/30/2023
<
10.05
5.03
48
11/17/2022
16
16
49
8/9/2023
<
10.07
5.03
49
12/8/2022
16
16
50
9/21/2023
<
10.08
5.04
50
9/8/2022
16.3
16.3
51
10/7/2020
<
10.10
5.05
51
10/26/2023
19
19
52
8/24/2023
<
10.34
5.17
52
11/6/2019
20
20
53
5/4/2023
<
10.51
5.26
53
6/23/2021
21.6
21.6
54
11/18/2020
<
14.28
7.14
54
2/19/2020
26
26
55
11/11/2020
<
15.30
7.65
55
3/16/2023
29
29
56
1/26/2022
<
15.48
7.74
56
8/5/2021
43
43
57
11/25/2020
<
16.63
8.32
57
2/5/2020
51
51
58
11/4/2020
<
16.73
8.36
58
12/18/2019
53
53
Use "PASTE
SPECIAL -Values"
then "COPY".
Maximum data points
Results
= 58
Std Dev.
10.6617
Mean
10.94
C.V.
0.9743
n
58
Mult Factor =
1.00
Max. Value
53.0 ug/L
Max. Fred Cw
53.0 ug/L
4_NC0002305 LEAR Corp_RPA Calculation_ (2024 Renewal), data
-4- 11 /13/2024

Reasonable Potential Analysis (RPA) Spreadsheet Summary
ATTACHMENT 4
Par14
Lead
Date
BDL=1/2DL Results
1 11/28/2022 <
10 5 Std Dev.
2 9/20/2019 <
3 1.5 Mean
3
C.V. (default)
4
n
5
6
Mult Factor =
7
Max. Value
8
Max. Fred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
data
Jse "PASTE SPECIAL- Par17 & Par18
✓alues"hen "COPY"
s
Maximum
m data points
= 58
3.2500
0.6000
2
3.79
5.000 ug/L
18.950 ug/L
Date Data
1 11 /28/2022 <
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Nickel
BDL=1/2DL
10 5
Use"PASTE
SPECIAL -Values"
then "COPY".
Maximum data
Result. points =58
Std De
Mean 5.0000
C.V. (d, 0.6000
n 1
Mult Fa 6.20
Max. VI 5.0 pg/L
Max. PI 31.0 pg/L
4_NC0002305 LEAR Corp_RPA Calculation_ (2024 Renewal), data
-5- 11/13/2024

Reasonable Potential Analysis (RPA) Spreadsheet Summary
ATTACHMENT 4
data
Par19
Use"PASTE
Par20
SPECIAL -Values"
Selenium then "COPY".
Maximum data
Date Data
Date Data BDL=1/2DL Result! points =58
1 11/28/2022 <
10 5 Std De
1 11/28/2022 <
2
Mean 5.0000
2
3
C.V. (di 0.6000
3
4
n 1
4
5
5
6
Mult Fa 6.20
6
7
Max. VI 5.0 ug/L
7
8
Max. PI 31.0 ug/L
8
9
9
10
10
11
11
12
12
13
13
14
14
15
15
16
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
Silver
BDL=1/2DL
10 5
Use"PASTE SPECIAL
Values" then "COPY"
Maximum data points
= 58
Results
Std Dev.
Mean
5.0000
C.V. (default)
0.6000
n
1
Mult Factor =
6.20
Max. Value
5.000 ug/L
Max. Fred Cw
31.000 ug/L
4_NC0002305 LEAR Corp_RPA Calculation_ (2024 Renewal), data
-6- 11/13/2024

Reasonable Potential Analysis (RPA) Spreadsheet Summary ATTACHMENT 4
data
Par21 Use "PASTE SPECIAL- Par22 Use "PASTE SPECIAL
Zinc Values" then "COPY". 1,4-dioxane Values" then "COPY"
Maximum data points Maximum data points
= 58 = 58
Date Data BDL=1/2DL
1 11 /28/2022 11 11
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Results
Date Data
BDL=1/2DL
Results
Std Dev.
1
10/23/2019
14.4 14.4
Std Dev.
9.2007
Mean
11.0000
2
11/13/2019
12 12
Mean
18.4667
C.V. (default)
0.6000
3
12/11/2019
29 29
C.V. (default)
0.6000
n
1
4
n
3
5
Mult Factor =
6.20
6
Mult Factor =
3.00
Max. Value
11.0 ug/L
7
Max. Value
29.000000 ug/I
Max. Pred Cw
68.2 ug/L
8
Max. Pred Cw
87.000000 ug/I
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
4_NC0002305 LEAR Corp_RPA Calculation_ (2024 Renewal), data
-7- 11/13/2024

Reasonable Potential Analysis (RPA) Spreadsheet Summary
ATTACHMENT 4
rpa
Lear Corporation
N00002305
Freshwater RPA -
95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Qw (MGD)
= 1.5000
WWTP/WTP Class: III
1Q10S (cfs)
= 4.91
IWC% @ 1Q10S = 32.13545266
7Q10S (cfs)
= 5.90
IWC% @ 7Q10S = 28.2674772
7Q10W (cfs)
= 21.70
IWC% @ 7Q10W = 9.677419355
30Q2 (cfs)
= 35.90
IWC% @ 30Q2 = 6.082406802
Avg. Stream Flow, QA (cfs)
= 402.00
IW%C @ QA = 0.575032462
Receiving Stream: NE Cape Fear River HUC 030300070206 Stream Class: C,Sw
Outfall 001
Qw=1.5MGD
COMBINED HARDNESS (ma/L)
Acute = 58.57 mg/L
Chronic = 59.13 mg/L
NC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS
PARAMETER
TYPE
Ci
a
~
j
RECOMMENDED ACTION
Chronic Applied Acute
n # Det. Max Pred Cw Allowable Cw
Standard
Acute: NO WQS
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
58 54
100.1
_ _ _ _ _ _
_ _ _ -di_ _ _ _ _ _ _ _ _ _
Chronic: 4,932-3
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: 5,656.3
Chromium III
NC
238.2820 FW(7Q10s) 1817.6745
µg/L
0 0
N/A
_ _ _
Chronic: ---843__.0--
---------------------------
Acute: 49.8
No detects
Chromium VI
NC
11 FW(7Q10s) 16
µg/L
58 57
10.0
Chronic: 38.9
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Chromium, Total
NC
µg/L
58 0
8.4
reported value = 8.3636100623
a: No monitoring required if all Total Chromium
samples are < 5 pg/L or Pred. max for Total Cr is <
allowable Cw for Cr VI.
NO DETECTS
Max MDL = 16.72722012462
A cute: 68.5
Apply limit with applied Chronic_
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
58 57
53.0
_ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 17.7
Weekly Monitoring will remian in effect
8 values > Allowable Cw
Acute: 607.612
No detects
Lead
NC
7.6890 FW(7Q10s) 195.2590
ug/L
2 0
18.950
Note: n 5 9
C.V. (default)
Chronic: 27.201
Limited data set
NO DETECTS
Max MDL = 10
No detects
Acute: NO WQS
Statewide TMDL not met therefore Quarterly
Mercury
NC
12 FW(7Q10s)
0.5
ng/L
1 0
620.0
monitoring will take effect.
Note: n 5 9
C.V. (default)
Chronic: 42.5
Limited data set
NO DETECTS
Max MDL = 200
Acute (FW): 2,143.6
Nickel
NC
77.1254 FW(7Q10s) 688.8536
µg L
No detects
1 0
31.0
Chronic (FW): 272.8
Note: n 5 9
C.V. (default)
Max MDL _=10
No detects
Nickel
NC
25.0000 WS(7Q10s)
µg/L
Limited data set
NO DETECTS
Chronic (WS): 88.4
Max MDL = 10
No detects
4_NC0002305 LEAR Corp_RPA Calculation_ ( 2024 Renewal), rpa
Page 8 of 9 11/13/2024

Reasonable Potential Analysis (RPA) Spreadsheet Summary
ATTACHMENT 4
rpa
Lear Corporation
Outfall 001
N00002305 Freshwater RPA - 95% Probability/95%
Confidence Using Metal Translators Qw = 1.5 MGD
Acute: 174.3
No detects
Selenium NC 5 FW(7Q10s) 56
ug/L
1 0 31.0
Note: n 5 9 C.V. (default) Chronic: 17.7
No detects
Limited data set NO DETECTS Max MDL = 10
Acute: 3.989
No detects
Silver
NC
0.06 FW(7Q10s) 1.2819
ug/L
1 0
31.000
Note: n 5 9
C.V. (default)
Chronic: 0.212
Limited data set
NO DETECTS
Max MDL = 10
No detects
Acute: 804.8
RP for Limited Dataset (n<8 samples) - apply
Zinc
NC
262.8248 FW(7Q10s) 258.6102
ug/L
1 1
68.2
Quarterly Monitoring
Note: n 5 9
C.V. (default)
Chronic: 929.8
RP for Limited Dataset (n<8 samples) - apply
Limited data set
No value > Allowable Cw
Quarterly Monitoring
Acute: NO WQS
1,4-dioxane
NC
80 HH(7Q10s)
ug/1
3 3
87.00000
Note: n 5 9
C.V. (default)
Chronic: 283.0
Apply Quarterly Monitoring - limited dataset from
Limited data set
No value > Allowable Cw
12019
4_NC0002305 LEAR Corp_RPA Calculation_ ( 2024 Renewal), rpa
Page 9 of 9 11/13/2024

ATTACH M ENT 5
Ammonia/Total Residual Chlorine Waste Load Allocation (NH3/TRC WLA) Calculations
W LA
NH3/TRC WLA Calculations
Facility: LEAR Corporation
PermitNo. NC0002305
Prepared By: Fenton Brown Jr.
Enter Design Flow (MGD): 1.5
Enter s7Q10 (cfs): 5.9
Enter w7Q10 cfs : 21.7
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS)
5.9
s7Q10 (CFS)
5.9
DESIGN FLOW (MGD)
1.5
DESIGN FLOW (MGD)
1.5
DESIGN FLOW (CFS)
2.325
DESIGN FLOW (CFS)
2.325
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
Upstream Bkgd (ug/1)
0
Upstream Bkgd (mg/1)
0.22
IWC (%)
28.27
IWC (%)
28.27
Allowable Conc. (ug/1)
60
Allowable Conc. (mg/1)
3.0
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform
w7Q10 (CFS)
21.7
Monthly Average Limit:
200/100mI DESIGN FLOW (MGD)
1.5
(If DF >331; Monitor)
DESIGN FLOW (CFS)
2.325
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
Dilution Factor (DF)
3.54 Upstream Bkgd (mg/1)
0.22
IWC (%)
9.68
Allowable Conc. (mg/1)
16.5
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Electronic Reporting (eDMR) report and calculations.
ATTACHMENT 6
Pivot Table
Parameter(s) Data
00010 - Temperature, Water Deg. Centigrade
i
Location UOM
Downstream I deg c
AverageParameter
30.12
30.12
MAX
1200
1200
min
6.3
6.3
Downstream Total
Effluent Ideg c
21.83 229.5
7.1
Effluent Total
21.83 229.5
7.1
Upstream Ideg c
24.82 1045
7
Upstream Total
24.82 1045
7
00010 - Temperature, Water Deg. Centigrade Total
24.85
1200
6.3
00094 - Conductivity
Downstream I umhos/cm
199.75
493
70.7
Downstream Total
199.75 493
70.7
Effluent umhos/cm
383.81 494
167
Effluent Total
383.81 494
167
Upstream umhos/cm
180.57 429
21.3
Upstream Total
180.57 429
21.3
00094 - Conductivity Total
280.92
494
21.3
00300 - Oxygen, Dissolved (DO)
Ik
Downstream I mg/I
5.47
10.3
1.9
Downstream Total
5.47 10.3
1.9
Effluent I mg/I
7.37 11.11
4
Effluent Total
7.37 11.11
4
Upstream mg/I
4.82 9.8
0.89
Upstream Total
4.82 9.8
0.89
00300 - Oxygen, Dissolved (DO) Total
6.18
11.11
0.89
00340 - Oxygen Demand, Chem. (High Level) (COD)
Effluent Ibs/day
627.23
4085
6.2
Effluent Total
627.23 4085
6.2
00340 - Oxygen Demand, Chem. (High Level) (COD) Total
627.23
4085
6.2
00400 - pH
IEffluent Isu
7.04
8.2
5.59
Effluent Total
7.04 8.2
5.59
00400 - pH Total
7.04
8.2
5.59
00556 - Oil & Grease
Effluent mg/l
5.39
13.8
4.76
Effluent Total
5.39 13.8
4.76
00556 - Oil & Grease Total
5.39
13.8
4.76
00720 - Cyanide, Total (as Cn)
Effluent
mg/I
5.00
5
5
ug/I
6.62 53
0.005
Effluent Total
6.59 53
0.005
00720 - Cyanide, Total (as Cn) Total
6.59
53
0.005
00745 - Sulfide, Total (as S)
Effluent Ibs/day
0.27
4.6
0.005
Effluent Total
0.27 4.6
0.005
00745 - Sulfide, Total (as S) Total
0.27
4.6
0.005
01032 - Chromium, Hexavalent (as Cr)
Effluent
mg/l
0.01
0.01
0.01
ug/l
0.01 0.01
0.001
Effluent Total
0.01 0.01
0.001
01032 -Chromium, Hexavalent (as Cr) Total
0.01
0.01
0.001
31616 - Coliform, Fecal MF, MFC Broth, 44.5 C
Effluent #/100ml
38.97
1990
1
Effluent Total
38.97 1990
1
31616 - Coliform, Fecal MF, MFC Broth, 44.5 C Total
38.97
1990
1
32730 - Phenolics, Total Recoverable
IEffluent Ibs/day
0.06
0.701
0.063
Effluent Total
0.06 0.701
0.003
32730 - Phenolics, Total Recoverable Total
0.06
0.701
0.003
50050 - Flow, in conduit or thru treatment plant
Effluent I mgd
0.57
1.153
0.002
Effluent Total
0.57 1.153
0.002
50050 - Flow, in conduit or thru treatment plant Total
0.57
1.153
0.002
50060 - Chlorine, Total Residual
50060 - Chlorine, Total Residual Total
IEffluent ug/1
Effluent Total
18.26
31
2
18.26 31
2
18.26 31
2
CO600 - Nitrogen, Total - Concentration
Effluent mg/1
1.80
14.7
0.02
Effluent Total
1.80 14.7
0.02
CO600 - Nitrogen, Total - Concentration Total
1.80
14.7
0.02
CO610 - Nitrogen, Ammonia Total (as N) - Concentration
Effluent mg/I
0.33
5.1
0.02
Effluent Total
0.33 5.1
0.02
CO610 - Nitrogen, Ammonia Total (as N) - Concentration Total
0.33
5.1
0.02
CO665 - Phosphorus, Total (as P) - Concentration
Effluent mg/l
3.01
12.7
0.03
Effluent Total
3.01 12.7
0.03
CO665 - Phosphorus, Total (as P) - Concentration Total
3.01
12.7
0.03
QD034 - Chromium, Total (as Cr) - Quantity Daily
IEffluent Ibs/day
0.06
0.1
0.004
Effluent Total
0.06 0.1
0.004
QD034 - Chromium, Total (as Cr) - Quantity Daily Total
0.06
0.1
0.004
QD310 - BOD, 5-Day (20 Deg. C) - Quantity Daily
I Effluent Ibs/day
39.44
253
0.4

Electronic Reporting (eDMR) report and calculations.
ATTACHMENT 6
Pivot Table
Parameter(s) Data
Parameter
Location UOM
Effluent Total
. -
39.44
MAX
253
min
0.4
QD310 - BOD, 5-Day (20 Deg. C) - Quantity Daily Total
39.44
253
0.4
QD530 - Solids, Total Suspended - Quantity Daily
QD530 - Solids, Total Suspended - Quantity Daily Total
IlEffluent Ibs/day
Effluent Total
72.07
1244.7
1.06
72.07 1244.7
1.06
72.07 1244.7
1.06
TGP3B - Pass/Fail Static Renewal May Chronic Ceriodaphnia
I Effluent pass/fail
31.81
100
1
Effluent Total
31.81 100
1
TGP3B - Pass/Fail Static Renewal May Chronic Ceriodaphnia Total
31.81
100
1
THP313 - CHV STATRE May Chronic Ceriodaphnia
Effluent percent
41.14
100
9.5
Effluent Total
41.14 100
9.5
THP313 - CHV STATRE May Chronic Ceriodaphnia Total
41.14
100
9.5
Grand Total
88.19
4085
0.001

ATTACHMENT 7
Production Forecast Explanation
Annual Data
2007
2008
2009
2010
2011
0.586
2007
2008
2009
2010
2011
Jan
3,031,803
2,928,232
674,215
1,714,464
1,887,835
0.586
1,776,637
1,715,944
674,215
1,714,464
1,887,835
Feb
2,322,061
2,701,115
849,960
1,876,725
1,766,535
0.586
1,360,728
1,582,853
849,960
1,876,725
1,766,535
Mar
2,386,793
2,676,602
955,144
2,039,238
2,236,526
0.586
1,398,661
1,568,489
955,144
1,194,993
1,310,604
Apr
3,033,471
2,946, 325
1,161, 273
1,876, 343
1,838, 225
0.586
1,777,614
1,726,546
1,161,273
1,876,343
1,838,225
May
2,738,362
1,925,294
925,029
1,879,307
1,879,307
0.586
1,604,680
1,925,294
925,029
1,879,307
1,879,307
Jun
2,950,549
2,525,453
1,086,276
2,078,146
2,078,146
0.586
1,729,022
1,479,915
1,086,276
1,217,794
1,217,794
Jul
2,275,512
1,643,409
1,102,452
1,618,126
1,618,126
0.586
1,333,450
1,643,409
1,102,452
1,618,126
1,618,126
Aug
2,510,007
2,161,526
1,498,391
2,187,525
1,887,331
0.586
1,470,864
1,266,654
1,498,391
1,281,890
1,887,331
Sep
3,091,370
2,140,010
1,869,340
2,182,335
1,958,280
0.586
1,811,543
1,254,046
1,869,340
1,278,848
1,958,280
Oct
3,189,290
2,261,568
2,069,110
2,058,381
2,183,486
0.586
1,868,924
1,325,279
1,212,498
1,206,211
1,279,523
Nov
2,957,248
1,371,205
1,698,562
1,916,314
1,941,865
0.586
1,732,947
1,371,205
1,698,562
1,916,314
1,941,865
Dec
2,501,508
1,003,865
1,522,139
1,835,041
1,426,018
0.586
1,465,884
1,003,865
1,522,139
1,835,041
1,426,018
2748997.833
2190383.667
1284324.25
1938495.417
1891806.667 2010801.567
-
-
AII values were reported and assumed to be pounds. However, based on
the high values reported, we
All numbers are assumed to be reported in pounds, however Production
felt the need to assume all data points were Yards and
not pounds, judging from historical data.
Numbers
in bold were converted to Pounds from Yards.
Monthly Average
2,748,998
2,190,384
1,284,324
1,938,495
1,891,807 #DIV/0!
1
1,610,913
1,488,625
1,212,940
1,574,671
1,667,620
Yearly Total
32,987,974
26,284,604
15,411,891
23,261,945
22,701,680
7
19,330,953
17,863,500
14,555,279
18,896,056
20,011,443
Density (#/yd)**
0.586
0.586
0.586
0.586
0.586
1
1
1
1
1
Total (#/yr)
19,330,953
15,402,778
9,031,368
13,631,500
13,303,184
19,330,953
17,863,500
14,555,279
18,896,056
20,011,443
Total (#/day) 56,194.63 44,775.52 26,253.98 39,626.45 38,672.05 - 56,194.63 51,928.78 42,311.86
(Averages of Total #/Day 20( 41,105 I 37,648
Max #/day (2007-2011) 56,194.63
Min #/day (2007-2011) 26,253.98
** After lengthy discussion with permitte, they were unable to
verify if this data was in Yards or pounds. Therefore we assumed the
production reported was in yards.
Production Increase (2017 renewal to 2023 renewal)
2007 2008 2009 2010 2011 2012I
Total (#/yr) 19,330,953 15,402,778 9,031,368 13,631,500 13,303,184
Total (#/day) 56,195 44,776 26,254 39,626 38,672
54,930.40 58,172.80

ATTACHMENT 7
Production Forecast Explanation
Annual Data
*2013
*2014
*2015
*2016 2017
2018
2019
2020
2021
2022
2023
1,521,283
1,521,283
1,537,304
1,353,296
2,951,722
2,984,749
4,118,208
3,675,695
3,197,357
4,412,749
1,505,061
1,505,061
1,385,915
1,454,793
3,484,577
3,235,961
3,663,257
3,559,463
3,758,489
4,667,531
1,482,821
1,482,821
1,310,131
1,465,571
4,101,528
3,847,741
2,973,613
4,051,950
4,408,827
5,338,617
1,821,113
1,821,113
1,674,872
1,297,340
3,427,960
2,840,707
-
3,588,715
3,401,323
3,959,334
1,387,845
1,387,845
1,279,888
1,456,494
3,211,968
3,091,058
-
3,189,166
3,399,864
4,424,030
1,617,749
1,617,749
1,503,470
1,427,592
4,063,935
4,142,214
3,272,285
4,091,252
4,594,584
5,429,121
1,141,171
1,446,577
1,433,325
2,165,083
2,394,238
3,764,741
2,888,221
3,884,958
3,536,307
1,506,290
1,513,147
1,331,166F1,784,167
3,194,436
3,262,984
3,819,418
3,442,846
4,051,016
4,312,275
1,982,471
1,502,117
1,388,226
3,261,802
3,860,273
4,004,607
3,520,383
5,580,058
5,164,974
1,499,959
1,869,524
1,784,167
4,479,727
2,962,331
3,913,608
2,975,336
4,479,579
3,926,051
1,518,194
1,244,130
1,133,637
3,068,023
2,995,080
4,034,969
2,536,537
3,832,579
3,832,579
1,458,253
1,058,488
1,412,355
1,412,355
3,135,911
3,761,056
4,160,771
3,194,921
4,032,097
4,032,097
Estimated
M.
Estimated
stimated
Production
Production
roduction using
using 2014
using 2015
2022 numbers.
1,536,851
1,497,488
1,431,205
1,411,497
3,378,889
3,281,533
3,143,790
3,392,874
4,051,728
4,419,639
18,442,210
17,969,855
17,174,456
16,937,962
40,546,672
39,378,392
37,725,477
40,714,485
48,620,731
53,035,665
*Production numbers were reported in POUNDS based on 2017
0.586
0.586
0.586
0.586
0.586
0.586
18,442,210
17,969,855
17,174,456
16,937,962
23,760,350
23,075,738
22,107,130
23,858,688
28,491,748
31,078,900
53,611.08
52,237.95
49,925.74
49,238.26
69,071
67,081
64,265
69,357
82,825
90,346
Avg of Ttl #/day 2013-
2016
51,253
Avg of Ttl #/day 2018-2023
73,824
Max #/day (2013-2016)
53,611.08
Max #/day (2018-2023)
90,346
Min #/day(2013-2016)
49,238.26
Min #/day(2018-2023)
64,265
24.69006255 Production Increase (2017 renewal to 2023 renewal)
I2013 2014 2015 2016
44.04
2017 20118 2019 2020 2021 2022 2023
23,760.350 23,075,738 22,107,130 23,858,688 28,491,748 31,078,900
69,071 67,081 64,265 69,357 82,825 90,346

ATTACHMENT
Production Forecast Explanation
Production by
month
5 yr annual
2007
annualavg
average
2007 Jan
3,031,803.00
2748997.833
2010801.567 2412961.88 1608641.25
Feb
2,322,061.00
2748997.833
2010801.567
Mar
2,386,793.00
2748997.833
2010801.567
Apr
3,033,471.00
2748997.833
2010801.567
May
2,738,362.00
2748997.833
2010801.567
Jun
2,950,549.00
2748997.833
2010801.567
Jul
2,275,512.00
2748997.833
2010801.567
Aug
2,510,007.00
2748997.833
2010801.567
Sep
3,091,370.00
2748997.833
2010801.567
Oct
3,189,290.00
2748997.833
2010801.567
Nov
2,957,248.00
2748997.833
2010801.567
Dec
2,501,508.00
2748997.833
2010801.567
2008 Jan
2,928,232.00
2190383.667
2010801.567
Feb
2,701,115.00
2190383.667
2010801.567
Mar
2,676,602.00
2190383.667
2010801.567
Apr
2,946,325.00
2190383.667
2010801.567
May
1,925,294.00
2190383.667
2010801.567
Jun
2,525,453.00
2190383.667
2010801.567
Jul
1,643,409.00
2190383.667
2010801.567
Aug
2,161,526.00
2190383.667
2010801.567
Sep
2,140,010.00
2190383.667
2010801.567
Oct
2,261,568.00
2190383.667
2010801.567
Nov
1,371,205.00
2190383.667
2010801.567
Dec
1,003,865.00
2190383.667
2010801.567
2009 Jan
674,215.00
1284324.25
2010801.567
Feb
949,960.00
1284324.25
2010801.567
Mar
955,144.00
1284324.25
2010801.567
Apr
1,161,273.00
1284324.25
2010801.567
May
925,029.00
1284324.25
2010801.567
Jun
1,086,276.00
1284324.25
2010801.567
Jul
1,102,452.00
1284324.25
2010801.567
Aug
1498,391.00
1284324.25
2010801.567
Sep
1:869340.00
1284324.25
2010801.567
Oct
2,069:110.00
1284324.25
2010801.567
Nov
1698,562.00
1284324.25
2010801.567
Dec
1:522,139.00
1284324.25
2010801.567
2010 Jan
1,714,464.00
1938495.417
2010801.567
Feb
1876,725.00
1938495.417
2010801.567
Mar
2:039,238.00
1938495.417
2010801.567
Apr
1,876,343.00
1938495.417
2010801.567
May
1,879,307.00
1938495.417
2010801.567
Jun
2,078,146.00
1938495.417
2010801.567
Jul
1,618,126.00
1938495.417
2010801.567
Aug
2,187,525.00
1938495.417
2010801.567
Sep
2,182,335.00
1938495.417
2010801.567
Oct
2,058,381.00
1938495.417
2010801.567
Nov
1,916,314.00
1938495.417
2010801.567
Dec
1,835,041.00
1938495.417
2010801.567
2011 Jan
1,887,835.00
1891806.667
2010801.567
Feb
1766,535.00
1891806.667
2010801.567
Mar
2:236,526.00
1891806.667
2010801.567
Apr
1,838,225.00
1891806.667
2010801.567
May
1,879,307.00
1891806.667
2010801.567
Jun
2,078,146.00
1891806.667
2010801.567
Jul
1,618,126.00
1891806.667
2010801.567
Aug
1,887,331.00
1891806.667
2010801.567
Sep
1,958,280.00
1891806.667
2010801.567
Oct
2,183486.00
1891806.667
2010801.567
Nov
1,941:865.00
1891806.667
2010801.567
Dec
1,426,018.00
1891806.667
2010801.567 2412961.88 1608641.25
Annual Average
1,178,329.72 Poundsperday
2008
2009
2010
2011
2928232
674215
1714464
1887835
2701115
849960
1876725
1766535
2676602
955144
2039238
2236526
2946325
1161273
1876343
1838225 2748997.833
1925294
925029
1879307
1879307 90328.51588
2525453
1086276
2078146
2078146
1643409
1102452
1618126
1618126
2161526
1498391
2187525
1887331
2140010
1869340
2182335
1958280
2261568
2069110
2058381
2183486
1371205
1698562
1916314
1941865
1003865
1522139
1835041
1426018
30.43333333 30.41666667
GUILFORD MILLS PRODUCTION
Monthly Production -Annual Average Production -5 yR Average Production
3,500,000 _______ ___________________________ ___________________________ _
3,000,000 ______ _________n
___ ___________________________ ___________________________ _
2,500,000 __ ______V
_______ _ _______ __ _______________ _
2,000,000
F
................................................................................................................................ ......................................................................... ................. .
1,500,000 ___________________________ ____ ______________ __
1,000,000 ___________________________ ________________________ _ ____
500,000 ___________________________ ___________________________ _
0
a �;;Q'�oz o LLgag;;< z o °LL'2a 2 < zo °LL'ia2 <v,ozo °LL'2<2- v,,oz
2007 2008 2009 2010 2011
30.43333333 = days/month (1,626 days. 60 months)
3100
Current: 2,554,270 Ibs/month
83,930.0 Ibs/day
Renewal: 2,010,802 lbs/month
66,072.3 lbs/day
Reduction from current to renewal:
-21.3%
5 330.3617
60 3964.34
21.8 1440.377
2554241.69
0.2 13.21447
0.1 6.607234
0.1 6.607234
5761.508

Additional Information Requested
ATTACHMENT 8
ROY COOPER
Governor
ELIZABETH S. B15ER
Secretary
RI CHARD E. ROGERS,IR.
Director
NORTH CAROLINA
B."WrOnorherrfal QUaWY
June 8, 2023
Mr. Steven Middlebrook, Plant Manager
Lear Corporation, Guilford Performance Textiles by Lear
1754 NC Highway 903
Kenansville, NC 28349
Dear Mr. Middlebrook:
Subject: Request for Additional Information
NPDES Renewal Application
NPDES Application NC0002305
Lear Corporation-Kenansville
Duplin County (WMO)
The Division has reviewed your application for renewal of NPDES permit NC0002305. To
complete our review in accordance with N.C.G.S. 143-215.1 and 15A NCAC 0211.0105, we
need the following additional or revised information:
I. Incomplete application: After reviewing the permit renewal application, the following items
were either incomplete, needed to be clarified, or are missing:
a. Form 1
i. Section 3.1: Wrong SIC code was entered. Verify that current SIC code is
accurate.
ii. Section 6.1: No boxes were checked for applicable environmental permits.
iii. Section 7: Map is missing additional information. Please review instructions
from FORM I Section 7. Map for further information.
iv. Section 9.2: Source of cooling needs to be updated.
b. Form 2C
i. Section 2.1: Water balance needs to be updated. (Should include influent flow,
cooling water sources, streams of all sources of wastewater leading to EQ basin).
Also, the GPD for operations contributing to flow needs to be reviewed and
updated.
ii. Section 3.1: Operations Contributing Flow -Operation section is incomplete.
Treatment Units- Description/Codes/Final disposal of solid section is incomplete.
iii. Section 7.1: Applicant checked NO for requesting waiver of Table A pollutants.
However, eDMR data shows multiple days of WAIVER placed for testing and
reporting. Explain justification of the selection of WAIVER for conventional
and non -conventional pollutants.
D E Q�� North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 1611 Mail Service Center Raleigh, North Carolina 27699-1611
NORTH CAROLMA -
oepanmentotenmmnmentaipual\ /� 919.707.9000

iv. Section 7.3(Table A): Temperature, Minimum and Maximum Daily Discharge
value section incomplete. pH Minimum and Maximum Daily Discharge value
section incomplete.
V. Section 7.8 (Table B-Section(s) 1-5): "Presence or Absence" section of Toxic
metals tests is incomplete. Please indicate if the required test result showed a
presence or absence in the effluent.
vi. Section 7.11 (Table B/Section 2.9): "Believed Absent" was selected with no
results to prove otherwise. Please provide results.
vii. Section 7 (Table B-Section 5.18-5.24): No testing data was provided. An effluent
sample of each is required.
viii. Section 7 (Table B- Section 5.5): Testing Required section not complete.
ix. Section 7.12-7.13 (Table C) Quantitative Data section incomplete. Provide data
indicating why pollutant is believed absent or believed present.
X. Section 7.14-7.15 (Table D): Pollutants 37, 63, 67, and 73, were selected as
"Believed Present". However, no testing data was provided for these pollutants.
An effluent sample of each is required.
xi. Section 9.2 Tests and purpose of test section incomplete.
xii. Section 12.2: Certification Statement incomplete.
xiii. Outfall number missing on Pollutant parameter pages Table B-Table E.
2. Upstream and effluent hardness data: The Division has adopted new dissolved metal
standards for the state, and the NPDES branch is required to implement the standards in
all permits advertised for public review after April 6, 2016. The new standards for seven
metals are hardness dependent. As a result, the NPDES branch requires site -specific
effluent hardness data and upstream hardness data for each facility monitoring these
metals to calculate permit limitations. Lear Corporation must collect five effluent
hardness samples and five upstream hardness samples (upstream of the discharge, as
CaCO3) simultaneously over a period of one week and submit this data along with its
application. Please determine an appropriate upstream sampling location by providing
the coordinates and mark them on an aerial map. Please discuss the proposed upstream
sampling location with the Division before taking upstream samples.
3. PFAS questionnaire: Due to the PFAS questionnaire being submitted (approximately
January 27, 2023) to LEAR corporation —30 days past. We are unable to provide an
extension for the duration of completeness. As a result, please submit the completed
questionnaire as soon as possible, but no later than 30 days, from the date of this letter.
4. Please provide a Stormwater Management Plan (SWMP) with applicable BMPs covering
all related operations and ancillary activities on site.
Please complete the standard Chemical Addendum to NPDES Application, included
herein, as Attachment 2A. An electronic copy in Excel is also included in the email
version sent to you
6. Please provide a detailed map showing all storm drain locations.
D E Q North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 1611 Mail Service Center Raleigh, North Carolina 27699-1611
NORTH CAROLINA
oapa"MM of
enmmn—Ul aualfty /� 919.707.9000

DWR appreciates Lear Corporation's cooperation in this matter. Please address the mentioned
items and resend a revised copy of the proposed application at your first convenience, but no later
than sixty (60) days from the date of this letter. We look forward to working with you.
If you have any questions, please contact Fenton Brown at: Fenton.brown.jrgdeq.nc.gov or Doug
Dowden at doug.dowden&deq.nc.gov.
Q
cc: Central Files; NPDES Files
Sincerely,
D 34&6,t,�
51-
Fenton Brown Jr.
Environmental Engineer II
NC DEQ / Division of Water Resources/
Permitting
cc: George Yankay Operator in Responsible Charge Lear Corp at: GYankay&fzfd.com
Steven Middlebrook, Plant Manager Lear Corp at: smiddlebrook(cr�,lear.com
Julie A. Grzyb, Deputy Director, Division of Water Resources at: julie.grz bgdeq.nc.gov
Michael Montebello, NPDES Program Branch Chief at: Michael.montebellogdeq.nc.gov
Doug Dowden, Environmental Program Supervisor at: doug.dowden(cr�,deq.nc.gov
Anjali Orlando, Environmental Specialist II at: Anjali.orlando(kdeq.nc.gov
Min Xiao, Engineer III NCDEQ Industrial Permitting Unit at: min.xiao(c�r�,deq.nc.gov
Tom Tharrington, Ass Regional Sup; Wilmington Regional Office at:
tom.tharrington(cr�,deq.nc. og_v
Morella Sanchez -King, Wilmington Office Regional Supervisor at: morella.sanchez-
kinggdeq.nc.gov
D EQ� North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 1611 Mail Service Center Raleigh, North Carolina 27699-1611
NORTH CAROLINA
oapanmam of enmmnmanui auai; /� 919.707.9000

ATTACHMENT 9
Environmental Protection Agency (EPA) comments / NCDEQ Response Notes
The U.S. Environmental Protection Agency (EPA) Region 4 has completed its review of the National Pollutant
Discharge Elimination System (NPDES) Permit for Lear Corporation (NC0002305) and is providing these
comments pursuant to the EPA/North Carolina NPDES Memorandum of Agreement (MOA) and the NPDES
implementing regulations at 40 Code of Federal Regulations (CFR) § 123.44. EPA extended the review of this
facility due to its high instream waste concentration, a significant noncompliance history, reported increased
production, the presence of endangered species habitat in the receiving water body and concerns about lack of
adequate protections for downstream drinking water wells, recreation use and subsistence fishing sources from
per- and polyfluoroalkyl substances (PFAS).
PFAS has been proven to be persistent and highly toxic to humans, wildlife, and the environment. These
chemicals are toxic to aquatic organisms which EPA has recognized by proposing a new aquatic life criterion for
PFOS and PFOA in 2022. These chemicals are also toxic to humans and that is why EPA has proposed new
drinking water Maximum Contaminant Levels (MCLs). On April 10, 2024, EPA announced the final National
Primary Drinking Water Regulation (NPDWR) for six PFAS chemicals. It proposes to establish legally enforceable
levels, called MCLs, for six PFAS chemicals in drinking water.
While the EPA Office of Waterworks 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, these
are permit requirements permit writers can implement under existing authorities to reduce the discharge of
PFAS.
The current draft permit does contain the quarterly monitoring suggested in the EPA's memo dated December
5, 2022 entitled Addressing PFAS Discharges in NPDES Permits and Through the Pretreatment Program and
Monitoring Programs as a first step starting to attempt to control PFAS, but EPA Region 4 has determined that
the draft permit does not adequately protect the health of the public or aquatic environment affected by these
discharges for the following reasons:
1. There is no Technology Based Effluent Limit Best Professional Judgement analysis for PFAS included in the
draft permit factsheet and the draft permit lacks TBELS, Best Management Practices (BMPs) and/or limits on
PFAS.
NC0002305 is an automotive interior textile plant that discharges significant amounts of PFAS to the Cape Fear
River Basin. The facility indicated the presence of PFAS compounds in the 2023 PFAS questionnaire attached to
their current application. Textile plants have been identified by EPA as a source of PFAS. The instream waste
concentration in the receiving water body for this facility is 28%. The facility indicates that production will be
increasing by 11.5% percent compared to 2022 production levels. The receiving water body, North East Cape
Fear, includes habitat for the endangered Atlantic sturgeon. The facility has been assessed 48 violations in the
last 5 year permit cycle. Downstream drinking water sources include numerous groundwater wells. The
waterbody use is designated by NCDEQ as class C secondary contact recreation and is widely used by the public
for that purpose. This discharge directly impacts surrounding environmental justice communities and
subsistence fishing that is prevalent in the Cape Fear River Basin. Given the totality of these facts, additional
controls beyond quarterly monitoring may be appropriate.
As specified in 40 CFR § 125.3, technology -based treatment requirements under Clean Water Act (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 addition to TBELs developed on a BPJ basis, if necessary to achieve water quality standards,
including state narrative criteria (CWA Section 301(b)(1)(C); 40 CFR § 122.44(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.
There are currently no applicable ELGs or numeric water quality standards for PFAS that apply to this facility. To
ensure protection of downstream communities and aquatic life, the factsheet must contain a robust BPJ analysis
of the best technology available to reduce PFAS in the discharge. Effective treatment technologies are available
for PFAS that are also cost effective including granular activated carbon, reverse osmosis and/or ion exchange.
Other facilities currently discharging in the state of North Carolina and in EPA Region 4 are using these
technologies to reduce PFAS in their discharges. A BPJ analysis must be performed, documented in the
factsheet, and any applicable TBELS added to the permit.
Given the maintenance issues documented in the factsheet at the facility, any BPJ analysis performed for this
facility must include a Best Management Practices (BMPs) analysis. The BPJ analysis should include any
applicable BMPs found at 40 CFR § 122.44(k)(4) including those identified in the December 5, 2022 Memo for
PFAS reduction referenced above and the July 2023 EPA Factsheet entitled Pollution Prevention Strategies for
Industrial PFAS Discharges. EPA recommends that NPDES permits for facilities incorporate BMPs when the
practices are "reasonably necessary to achieve effluent limitations and standards or to carry out the purposes
and intent of the CWA".
Additionally, the state should attempt to translate its narrative water quality criteria (40 CFR 122.44(d)(1)(ii)) by
incorporating the recently promulgated EPA drinking water MCLs as surrogate limits until applicable ELGs are
published. The state does not have to wait, and should not wait, for EPA to complete revision of the textile ELG if
there is reasonable potential to violate North Carolina's applicable narrative water quality standards pertaining
to toxic substances. North Carolina water quality standards state "the concentration of toxic substances, either
alone or in combination with other wastes, in surface waters shall not render waters injurious to aquatic life or
wildlife, recreational activities, or public health, nor shall it impair the waters for any designated uses" (15A
NCAC 02B .0208).
Other options to address PFAS in NPDES permits could include a requirement for the permittee to do a PFAS
Characterization Study. One facility in Region 4 has already proposed a permit that includes this requirement. All
options to address PFAS in the effluent that go beyond quarterly monitoring at this particular facility should be
considered by the state and documented in detail in the factsheet.
2. Quarterly monitoring frequency for Whole Effluent Toxicity (WET) Testing is inappropriate for this facility.
WET monitoring frequency should be increased to bimonthly.
NC0002305 has passed 17 out of its last 24 quarterly chronic toxicity tests. Failed toxicity tests for this facility
were dated January (2022), February (2002), April (2022), May (2022), January (2023), February (2023), and July
(2023).
Due to this facility's recent WET noncompliance history, EPA recommends increasing the WET Testing frequency
to bimonthly or twice a month testing to ensure the discharge is not causing chronic toxicity in the receiving

stream. Once the facility passes three years of WET testing without any failures, the option to decrease
frequency to monthly testing can be made available to the permittee.
3. The draft permit contains Chronic WET Testing only. The state should consider adding acute WET testing
limitations and/or monitoring.
While EPA recommends chronic testing for continuous discharges and persistent chemicals, acute testing could
provide additional data on the lethality of the discharge to aquatic organisms. To reduce complexity and prevent
the need for additional sampling, an LC50 can be calculated and reported from chronic test data.
4. The draft permit should include more detailed Toxicity Identification Evaluation (TIE)/Toxicity Reduction
Evaluation (TRE) language.
The current draft permit's TIE/TRE language is: "If the permittee fails multiple quarters, i.e., 2 quarters out of
four, then the permittee would need to send a "failed" sample to a NC Certified Laboratory for a TRE (Toxic
Reduction Evaluation)". More detail is needed in the permit regarding TIE/TRE procedures. A TRE Workplan
should include a schedule and reporting requirements to ensure the effluent toxicity is reduced or eliminated
and compliance with the permit is achieved in the required timeframe. The EPA WET method guidance that
addresses TIE/TRE procedures could be incorporated by reference in the permit.
5. This facility's reported increase in production needs to be clarified in the factsheet.
The facility reported a production increase of 11.5% in the factsheet. EPA Region 4 staff calculations show a
78.4% increase in production. Please clarify in the factsheet the calculations for anticipated increase in
production at this facility. Additionally, EPA requests a requirement be added to the permit that EPA Region 4
will be notified in a timely manner by the state of any letter or phone call the state receives alerting them to
increases in production at this facility.
Thank you for your consideration of these comments. EPA Region 4 looks forward to working with the North
Carolina Department of Environmental Quality (NCDEQ) to resolve the issues identified above and ensure
protection of the Cape Fear River Basin. Finally, EPA Region 4 requests an opportunity to review the Proposed
Final Permit for this facility based on 40 CFR § 123.44(j) and Section IV.B.6 of the MOA.

ATTACHMENT 10
NCDEQ Environmental Toxicologist Fish Tissue Memorandum
MEMORANDUM
To: Division of Water Resources, NCDEQ
From: Frannie Nilsen, PhD, Environmental Toxicologist, NCDEQ
Subject: Summary of PFAS Data for Lear's Kenansville Facility
Date: Nov 4, 2024
Summary of PFAS Data for Lear's Kenansville Facility
Discharge Data
SELC reports that PFOS and PFOA were detected in the facility's effluent in 2019 at 29.4 and 30.2 ng/L,
respectively (SELC Attachment 1). In 2022, CFRW reported PFOS and PFOA in the Cape Fear River
downstream from the facility at 13.6 and 9.9 ng/L, respectively (SELC Attachment 1). Other
measurements taken throughout the Cape Fear River Basin by DEQ and external entities from 2019 -
2024 elucidate that the concentration of PFOS consistently detected in the River ranges from 6 - 29 ng/L
and PFOA ranges from 2 - 86 ng/L (DEQ Ambient Lakes Study 2021 - 2023, Cape Fear Fish and Water
Study 2022, public utility monitoring data 2019-2024).
SELC reports that the company stated: "Lear's Kenansville facility produces solid waste, liquid waste,
and wastewater effluent which may contain C6 fluoropolymers that are used in the finishing process. "
And that the C6 fluoropolymer surface coating application in the finishing process at our facility may
result in PFAS chemicals being present in our waste streams. " (SELC Attachment 2). The C6 PFAS
compounds are PFHxA and PFHxS, not PFOS and PFOA which are C8 compounds (EPA). The C6 PFAS
were reported in the "Lear, 2021 PFAS Sampling Data" taken from the Enthalpy Analytical reports
provided by SELC in Attachment 2 (Perma I Lear, 2021 PFAS Sampling Data) and are summarized in
Table 1 below. The Lear PFAS data analyzed at Enthalpy Analytical Laboratory using the PFAS by
Isotope Dilution (non -potable water) method that provided analytical results for 21 PFAS compounds,
referred to in the reports as "Attachment B: DEQ Analyte List". It is unclear if these samples were run
using EPA Method 533, which is the isotope dilution method used in UCMR5, but has an analyte list of
25 PFAS.
The PFAS that appear to be related to the facility's discharge are the C4-C7 PFAS compounds. The C8
compounds (PFOS and PFOA) averages presented in Table 1 are consistent with multiple year averages
of waters across the state (PFOS 6 - 29 ng/L; PFOA 2 - 86 ng/L multiyear ranges).
Table 1: The Lear PFAS data analyzed at Enthalpy Analytical Laboratory using the PFAS by Isotope Dilution
Method (non -potable water).
Lear PFAS Data (ppt or ng/L)
#C
PFAS
Enthalpy
LOD; LOQ
Dec
2020
Jan
2021
Feb
2021
Mar
2021
Apr
2021
May
2021
Jun
2021
Average
C4
PFBA
0.15; 0.29
ND
21.1
41.6
ND
50.1
1 50.9
47
42.1
C5
PFPeA
0.09; 0.29
489
255
329
315
396
448
366
371.1
C6
PFHxA
0.16; 0.29
172
113
143
151
145
148
107
139.9
C6
PFHxS
0.08; 0.26
1.3
1.3
ND
2.3
1.2
1.6
2.1
1.6
C7
PFH A
0.07; 0.29
123
64.5
116
95
95.3
116
78
98.3
C8
PFOA
0.08; 0.29
27.4
18.9
13.9
15.6
10.2
16.4
16.8
17.0
C8
PFOS
1 0.05; 0.27
1 21.6
1 13.1
1 9.12
1 11.9
1 8.1
1 10.1
1 28.1
1 14.6

MEMORANDUM
Fish Data
Three fish samples collected downstream of the facility in July 2024 by Cape Fear River Watch (CFRW)
have PFOS concentrations of 182, 274, and 559 ng/g (SELC Attachment 3). The fish samples were run at
the GEL Laboratories and analyzed on an `as received' basis using the EPA 537.1 Modified analytical
method. There is no information as to how the samples were prepared prior to arrival at the analytical
laboratory or what the samples consisted of (i.e., fillet, whole fish). The comparison of the reported PFOS
concentrations to other fish data or consumption advisories is not possible until the preparation of the fish
and the tissues analyzed is provided.
All the PFAS reported in the Lear PFAS Data provided in Table 1 are presented in Table 2 corresponding
to the fish data. All PFAS in Table 2, except PFOS were reported at or below the Limit of Quantitation
(LOQ) at GEL Labs. The C6 PFAS implicated in the SELC Attachment 2 are all at or below the LOQ in
these fish samples. The only PFAS compound that was higher than the LOQ in these fish samples was
PFOS.
Table 2: The 3 individual fish data provided by the Cape fear River Watch (CFRW) in the SELC Attachment 3 file.
Samples were analvzed "as received" usine EPA Method 537.1 Modified at GEL laboratorv.
CFRW Fish PFAS Data n
/
#C
PFAS
GEL Labs
LOD; LOQ
Largemouth Bass
Bluegill Small
Bluegill Large
C4
PFBA
0.4; 1.0
1.0
1.0
1.0
C5
PFPeA
0.3; 1.0
1.0
1.0
1.0
C6
PFHxA
0.4; 1.0
1.0
1.0
1.0
C6
PFHxS
0.3; 0.9
0.9
0.9
ND
C7
PFH A
0.3; 1.0
1.0
1.0
1.0
C8
PFOA
0.4; 1.0
1.0
1.0
1.0
C8
PFOS
4.0; 10
559
274
182
Italic indicates that the reported value matches the LOQ.
Summary
The PFOA and PFOS effluent data that is presented in Table 1 above is similar in concentration
throughout the time that Lear sampled their effluent. The PFOS and PFOA concentrations observed in the
effluent samples is also like the PFOS and PFOA ranges observed in the Cape Fear River by monitoring
programs. The PFAS that appear to be related to the facility's discharge are the C4-C7 PFAS compounds,
all of which were reported at or below the Limit of Quantitation (LOQ) in the fish samples provide to
GEL Laboratories by CFRW (SELC Attachment 3).
The recommendation is for Lear to investigate where in their process the PFOA and PFOS may be
coming from, remove the contaminated infrastructure, develop best management practices, and continue
to monitor and report discharge concentrations.
2