Ohio EPA has released proposed pretreatment and indirect discharge permit (IDP) rules (OAC 3745-3 and 3745-36, respectively). The existing 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 applicable requirements are explicitly stated within that chapter (OAC 3745-36). The majority of the changes are, therefore, more in the spirit of re-organization than 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 POTW operating its own pretreatment program (per OAC Chapter 3745-3) will now need to obtain an indirect discharge permit pursuant to OAC Chapter 3745-36. Ohio EPA forecasts this to affect a handful of dischargers. These changes are currently at the interested party review stage, and Ohio EPA is seeking comment on the rules and the draft Common Sense Initiative Business Impact Analysis. Comments are due August 10, 2018.

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