NC0002305_EPA Comment Response Letter_20241105

ROY COOPER
Governor
MARY PENNY KELLEY
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
November 08, 2024
Bridget Staples, M.P.H.
Environmental Scientist
US EPA Region 4, NPDES Water Division
61 Forsyth Street
Atlanta, GA 30303
Subject: Response to EPA Draft Permit
Comments dated 5/6/24
Permit NC0002305
Lear Corporation
Duplin County / Wilmington RO
Dear Ms. Staples,
We acknowledge and appreciate EPA's comments and supplemental information regarding this important
permit, dated 5/7/24. See the attached summary (Attachment 1) of items addressing issues raised. The
examples provided by the EPA included activities associated with PFAS WQBELs (Georgia), groundwater
remediation, landfill leachate, DoD operations and POTW information, but did not include examples of
PFAS TBELs standards associated with a wastewater for an operating textile manufacturer.
With that said, NCDEQ DWR believes that the attached revised draft permit and factsheet address concerns
raised related to PFAS compounds as well as other items on the attached. See the cover letter of the revised
NPDES Permit for the individual adjustments that have been made. Also, refer to the revised factsheet for
more information.
At present the revised permit will be issued for public notice with a scheduled hearing date of 12/17/24.
Also, attached is a copy of the public notice which contains details pertaining to the public hearing.
Please feel free to reach out to me at: 919-707-3612 or via email at: fenton.brown.jrndeq.nc. -og v or Doug
Dowden at: 919-707-3605 or email at doue.dowdengdeq.nc. -og_v at your earliest possible convenience.
Sincerely,
Fenton Brown Jr.
Engineer II
Division of Water Resources / Industrial
Permitting
ec: NCDEQ DWR Files, Wilmington RO, EPA Region 4
Attachments: Attachment 1, Cover Letter, NPDES Draft Permit, Factsheet, Public Notice and Public
Hearing
D North Carolina Department of Environmental Quality I Division of Water Resources
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512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA _
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ATTACHMENT 1
Sample Permits Provided by EPA 5/7/24
• SC0001368 Elevate Textiles Inc. / Carlisle Finishing Plant South Carolina: Draft
permit includes monitor and report only for PFAS, no TBELS were calculated. Permit
includes a re -opener clause if PFAS limits are promulgated.
• GA0003280 King America Finishing, Inc.: This permit does not establish PFAS limits,
but establishes a compliance schedule that includes a PFAS Characterization Study and
PFAS monitoring and sampling only. Permit includes a re -opener clause if PFAS limits
are promulgated.
• PA0046680 Republic Service of PA LLC: The permit does not include PFAS limits, no
TBELS were proposed. Permit includes a re -opener clause if PFAS limits are
promulgated.
• PA0245046 Horsham Air Guard Station — This Permit is a DOD facility that includes a
general (narrative) water quality criteria and RPA based on site detected combined
concentrations of PFOA and PFOS above the drinking water Health Advisory Level
(HAL) established by EPA in November 2016.
• WV0117986 The Chemours Company FC, LLC: This permit includes monitor and
report for 40 PFAS compounds using 1633 Method only.
• TN0005452 TVA - Kingston Fossil Plant: This permit was provided, but did not
include TBELS, but provided examples of various BMPs.
Unrelated to PFAS
• Toxicity — Refer to the following:
o Permit: Condition A.(2.)
o Factsheet: Section 6. Toxicity Testing Limitations, section
• Authorization to Apply New Production Limits, Refer to the following:
o Permit: Condition A.(4.)
o Factsheet: Section 7. Technology -Based Effluent Limitations (TBELs)
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center Raleigh, North Carolina 27699-1617
NORM CAROLINA
o.na�n.ntatEmi—m.ntaia-lity r 919.707.9000