1. Pre-Production Plastics and
Storm Water with IGP Update
Headwaters to Ocean (H2O) 2011
Chris Haynes, PE
CA State Water Board

2. 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

3. 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

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

5. 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

6. 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

7. Water Quality/Storm Water Response
Trash TMDLs
 LA
 SF
 Others
Beach Cleanups
Industrial and Construction General Permits

8. 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.

9. 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

11. 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.

16. 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)

17. 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

18. Self Audit Discussion
 500 Permitted Facilities Surveyed
 3000 Facilities Statewide

19. 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%

20. 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%

21. 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.

22. You don’t want to see this:

23. How it should look:

24. How it should look:

25. How it should look:

26. Loading Docks

27. Disposal

28. Silos &
Storage Areas

29. Inadequate Containment

30. 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.

31. 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.

32. 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/

33. 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.

34. Questions?

35. 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