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3 <br />PERMIT BRIEFING MEMO <br />1. Facility Description <br /> <br />Somaschini North America, LLC (Somaschini) machines steel gears. A small sample <br />of gears are tested for quality after grinding using a process called Nital Etch. The <br />Nital Etch process consists of acid etching of the steel gears to identify burning on <br />teeth of gears. Nital Etch is the application of acid to the metal gears which alters the <br />surface of the metal. This process constitutes as metal finishing. <br /> <br />2. Discharge Description <br /> <br />Somaschini currently chooses to have zero discharge. All wastewater, solvents, <br />coolants, and oils are contained and shipped off site. Average generation of <br />wastewater per month is 20 gallons, maximum generated is 30 gallons per month. <br /> <br />3. Sample Site Description <br /> <br />Somaschini does not currently have a designated sample site or control manhole <br />because there is no process discharge, wastewater, solvents, coolants, and oils are <br />contained and shipped off site. <br /> <br />4. Wastewater Treatment <br /> <br />There is no wastewater treatment due to all wastewater is shipped off site. <br /> <br />5. Classification <br /> <br />Somaschini is classified as a Categorical Industrial User (CIU) as defined in the <br />South Bend Municipal Code. Specifically, Somaschini is classified as a metal <br />finisher covered by 40 CFR 433.17 (PSNS) due to the quality control Nital Etch <br />process. <br /> <br />6. Calculation of Limits <br /> <br />Limits are applied without modification from 40 CFR 433.17 (PSNS) to the <br />process flow, which is categorical, unless local limitations are more astringent. <br /> <br />7. Monitoring Frequency <br /> <br />Monitoring frequencies are based on South Bend’s US EPA approved Industrial <br />Pretreatment Program monitoring plan. As long as there is zero industrial <br />wastewater discharge, Somaschini will submit monthly certification of zero <br />discharge. See this industrial wastewater discharge permit for details. <br /> <br /> <br /> <br />