Ohio EPA Division of Surface Water issued a Notice of Interested Party Review for Pretreatment and Indirect Discharge Permit (IDP) Program rules in Ohio Administrative Code (OAC Chapters 3745-3 and 3745-36).
Currently, the Pretreatment and IDP rules overlap with one another quite significantly, and the IDP rules frequently cross-reference the Pretreatment rules. The proposed revisions expand the IDP rules so that all the applicable requirements are explicitly stated within that chapter (OAC 3745-36).
The bulk of the changes are more in the spirit of re-organization than they are imposing entirely new terms. There is one substantive change to note: Under the reorganized rules, non-significant categorical industrial users that do not fall under the jurisdiction of a publicly owned treatment works (POTW) operating their own pretreatment program (per OAC Chapter 3745-3) will now need to obtain an indirect discharge permit pursuant to OAC Chapter 3745-36.
Please see this comparison from OMA environmental counsel, Bricker & Eckler, which details the current versus proposed rules and this Ohio EPA document that helps illustrate the difference between the two rule chapters.
Comments to the rules are due August 10. Please contact OMA’s Rob Brundrett with questions or if you would like to comment. 8/2/2018