Pre-Production Plastics and Storm Water with IGP Update

Headwaters to Ocean (H2O) 2011

Chris Haynes, PE

CA State Water Board

Current Industrial General Permit Reissuance Process

Draft released 2/11 comments received 5/11

~250 comment letters plus significant legislator interest

Follow-up draft Summer 2011 Another comprehensive public comment

periodOptimistic adoption early 2012

IGP Content

Based On 2005 draft Covers more industrial facilitiesNAL’s and NEL’sCorrective action levels 1,2,3Training requirementsElectronic submittals Plastic receives no special treatmentRemoval of group monitoring incentive

“One Word Plastics”

In the 1967 Classic “The Graduate” Ben receives this prophetic word of advice from Mr. McGuire. Plastics were the future.

Plastic’s Benefits

Over the last 40 years plastics have become ubiquitous in our lives Improving health in medicine Preserving food Saving energy Changing the way we work and play

Plastic’s Costs

Over the last 40 years plastics have also become ubiquitous in the environment Plastic has become trash in our oceans, rivers,

lakes and streams Plastic bags blow across our landscape Plastics contain new chemicals of concern such

as Bisphenol A

Water Quality/Storm Water Response

Trash TMDLs LA SF Others

Beach CleanupsIndustrial and Construction General Permits

AB 258 - CA Water Code 13367

Applies to facilities in California that manufacture, handle, or transport preproduction plastics.

Discharge of preproduction plastics is determined by the California Legislature to be a threat to the state’s marine environment.

Potential sources of preproduction plastics in the environment are manufacturers, transporters, warehousers, processors, and recyclers.

Migration of preproduction plastics from international waters may also be a potential source.

Preproduction Plastic (PPP)

The raw material input for nearly all plastic products

PPP is small <5mmSeen as pellets, powders and flakesFound throughout the world’s oceansFound on California beachesDemonstrated environmental harm

PPP Issues

Spilled PPP can be transported by stormwater PPP is a problematic type of litter to remove due

to its small size and resistance to environmental degradation.

PPP can be mistaken for food by marine life. PPP consumed by marine life can cause

feelings of satiation which lead to starvation. PPP absorbs persistent organic pollutants

(POPs) and marine life consumption of PPP may intensify bioaccumulation these pollutants.

Water Board Activities

Conduct compliance inspections Conduct targeted enforcement actionsBeach SurveySelf AuditStakeholder OutreachRe-issue Industrial Stormwater General

PermitStatewide Trash Policy (conceptual stage)

Beach Survey Summary

RWQCB Total Density/m2 % of Total

Santa Ana (8) 15.2 63

Los Angeles (4) 7.9 33

San Diego (9) 0.7 3

San Francisco (2) 0.3 1

North Coast (1) 0.2 <1

Total 1.3 100

Self Audit Discussion

500 Permitted Facilities Surveyed 3000 Facilities Statewide

Resins Used

Average single facility consumption: 10.2 million pounds per year

Resin Type Estimated Pounds/Year Percentage

PVC 719,308,669 29.9%

PS 435,879,614 18.1%

HDPE 379,941,636 15.8%

PET 281,860,794 11.7%

Other 260,669,104 10.8%

LDPE/LLDPE 175,466,183 7.3%

PP 75,696,991 3.1%

ABS 58,402,367 2.4%

PC 16,625,756 0.7%

Total 2,403,851,114 100%

Format of Resin

FormatEstimated Pounds/Year Percent

Pellets 987,720,556 41.1%

Powders 417,103,021 17.4%

Unspecified 999,027,537 41.6%

Total 2,403,851,114 100%

The Ask – What Can MS4s Do to Help?

Local agencies are more likely to see and correct this problem – please keep an eye out for PPPs and related facilities.

Recognize PPP as a pollutant of concern If you see outdoor exposure of PPP, and

think it is appropriate, require IGP coverage. If you aren’t sure, call for help.

Address PPP in SWPPPs using “state of the art” resources – call us for help.

You don’t want to see this:

How it should look:

How it should look:

How it should look:

Loading Docks

Disposal

Silos &Storage Areas

Inadequate Containment

U.S. EPA Release Pathway Findings:

Poor communications between industry management, company management and related industries (e.g., trucking and railcar)

Lack of employee awareness and inadequate training Inadequate containment facilities and apparatuses Careless routine operations Inadequate housekeeping practices Easily damaged or leaky packaging Improper shipping practices Lack of recycling

Source: U.S. EPA. Plastic Pellets in the Aquatic Environment: Source and Recommendations. 1993.

U.S. EPA Recommendations:

Implement Operation Clean Sweep’s Zero Pellet Loss program Educate employees and train them to minimize pellet spillage and

loss Install pellet containment systems or use portable apparatuses Institute pellet containment activities during routine plan operations Recycle spilled pellets Improve the quality and frequency of pellet clean-up procedures Use puncture-resistant packaging Inspect shipping vehicles and containers before and after loading

pellets

Source: U.S. EPA. Plastic Pellets in the Aquatic Environment: Source and Recommendations. 1993.

Further Reading State Water Resource Control Board

http://www.waterboards.ca.gov/ Preproduction Plastic Debris Program

http://www.waterboards.ca.gov/water_issues/programs/stormwater/plasticdebris.shtml

U.S. EPA – Plastic Pellets in the Aquatic Environment http://www.epa.gov/owow/oceans/debris/plasticpellets/index.html

Plastic Debris: Rivers to Sea Proceedings from 2005 Water Board sponsored conference on plastic debris and

trash http://plasticdebris.org/

NOAA: Plastic Marine Debris http://marinedebris.noaa.gov/info/plastic.html

Operation Clean Sweep Industry education program that aims for zero pellet loss http://www.opcleansweep.org/

Where is the Plastics Program headed?

More work with PPP facilities and transporters

Bigger picture – all plastics in watersTrash policy, TMDLs and advocacy for

“reduce/reuse”More studies on sources, distribution, fate

and transport in CA waters, etc.

Questions?

For More Information

Water Board Program Contacts: Chris Haynes - chaynes@waterboards.ca.gov

(916) 341-6899 Dylan Seidner - dseidner@waterboards.ca.gov

(916) 341-5576 Greg Gearheart - ggearheart@waterboards.ca.gov

(916) 341-5892