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Pre production plastics and stormwater-h2 o-gtg
 

Pre production plastics and stormwater-h2 o-gtg

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    Pre production plastics and stormwater-h2 o-gtg Pre production plastics and stormwater-h2 o-gtg Presentation Transcript

    • 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 period Optimistic adoption early 2012
    • IGP Content Based On 2005 draft Covers more industrial facilities NAL’s and NEL’s Corrective action levels 1,2,3 Training requirements Electronic submittals Plastic receives no special treatment Removal 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 Cleanups Industrial 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 <5mm Seen as pellets, powders and flakes Found throughout the world’s oceans Found on California beaches Demonstrated 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 actions Beach Survey Self Audit Stakeholder Outreach Re-issue Industrial Stormwater General Permit Statewide 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 Format Estimated 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 waters Trash 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