05-09-11 Council Agenda & Packet

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with limitations in the permit would be significant. Note that this would only apply to limitations that were developed from production based categorical standards, and only in the case that those limitations were more stringent than local limitations. In the I/N Tek — I/N Kote discharge permit, the only limitations developed from production based standards are Iead and zinc. If the production rate were to increase significantly enough that the discharge limitation might change, the user would be required to notify the Director within (2) days of having a reasonable basis to know. Failure to submit this notification would result only in the user having to comply with the existing limitations in the permit. Note: the discharge limitations for lead and zinc in I/N Teks — IIN Kote's permit were adjusted using the combined wastestream formula to account for both dilution waters and wastewater regulated by two different categories, and therefore only the pollutant load allocated for the production based standard would be modified in the formula, resulting in only an indirect modification of the final limitations. 3. Sec 17 -10 (a) (1) — Page 29, Users shall provide wastewater treatment as necessarta comply with this Division and shall achieve compliance with all categorical Pretreatment Standards, ,Local Limits, and the prohibitions set out in Section 17-8(c) of this Division within the time limitations specified by EPA the State or the Director, whichever is more stringent. An facilities necessar for compliance shall be provided, operated, and maintained at the User's ex ense. Detailed plans describing such facilities and operating rocedures shall be submitted to the Board or its designee for review, and no construction shall be commenced until approval in writing is granted. The review of such plans and operating procedures shall in no way relieve the user from the responsibility of Cit y under the provisions of this Division. All facilities necess for compliance shall be sub'ect to eriodic inspection by the City to determine that such facilities are being operated in conformity with applicable Federal, State and local law. The owner shall maintain operational ,records of the influent and effluent to show the performance of the treatment facilities and for comparison against City monitoring records. Does this mean written approval is required to mods or improve facilities? The above language seems to require approval before treatment facilities can be modified or constructed and yet hold the discharger accountable to insure that the discharge is acceptable. The City should not be in the position of approving treatment systems unless hey are willing to accept the consequences of the failure of the approved system to meet discharge limitations. The City appreciates your comments on Section 17 -10 (a)(1), and shares concern regarding the "approval" of pretreatment equipment. The purpose for the this provision is to allow the City of South Bend (City) to review proposed modifications to industrial facility to determine if those modifications comply with the conditions of the existing permit. The City's intent is not to approve the design or anticipate performance. The following change had been made: