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i/N Tek and 11N Kate <br />30755 Edison Road <br />New Carlisle, IN 46552 <br />IN Tek <br />Nkod <br />N Kote <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 60504 <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 _pHlower 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 water 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 />CFR 420.07). <br />2. Sec. 17--8 (d) (6) - Page 23, Any Industrial User <br />operatinq under a 12ermit incor oratin e ivalent <br />mass or concentration limits calculated from a <br />p__roduction -based Standard shall notify -the Director <br />within, two 2� }_ business days after the User.hasa <br />reasonable basis to know that the production level <br />Partnerships between subs €diodes &ArtelorMfMo! and Nippon Steel CorporoHon <br />