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I/N Tek and I/N Kote <br />30755 Edison Road <br />New Carlisle, IN 46552 <br />IN °sec <br />IN Kol <br />February 4, 2011 <br />United States Environmental Protection Agency <br />Region 5, Water Division, WN -16J <br />NPDES Support and Technical Assistance Branch <br />77 West Jackson Boulevard <br />Chicago, Illinois 60604 <br />Attention. Ash Sajjad <br />Subject: Comments on the Public Notice for Modification <br />of Publicly Owned Treatment Works(POTW) <br />Pretreatment Program - City of South Bend, IN <br />Dear Mr. Sajjad, <br />Thank you for the opportunity to comment on the <br />proposed changes to the City's Municipal Ordinance <br />with regard to the Pretreatment Section. Our <br />comments are as follows: <br />1. Sec. 17 -8 (c)(14) - Page 21, AnY waters or <br />wastes having a P! lower than 6.0 will be <br />prohibited. This will require our permit to be <br />modified, since our current Permit # 161591_88966 <br />has a minimum pH limit of 5.0. A minimum pH limit <br />of 6.0 is typically applied as a crater quality <br />standard for the discharge into a water of the <br />state in order to protect wildlife, However, it is <br />not :necessary to specify such a limit on a pre- <br />treatment facility since the final treatment <br />facility (i.e., the POTW) has the capability to <br />adjust the pH prior to discharge to surface waters. <br />The waiver of a pH limit at internal treatment <br />facilities is recognized by the EPA as acceptable <br />as long as the final treatment system discharge has <br />a water quality based pH limit (see for example, 40 <br />CPR 420.07). <br />2. Sec. 17 -8 (d) (6) - Page 23, Any Industrial User <br />operating under a 12ermi.t....incorporatincf-ecfuivalent <br />mass or concentration limits Calculated from a <br />Production-based Standard shall notif the Director <br />within two (2)„ business days after the User has a <br />reasonable basis to know that the production level <br />will significantly chancre. within, the next calendar <br />month. An user not notifying the Director of such. <br />Partnerships between subsiftries of ArceforMiltal and Nippon Steel Corpor000n <br />