Preproduction Plastic Debris Program:

Industrial Sources of Plastic Pellets in the Environment

California State Water Resources Control BoardDivision of Water QualityStormwater Section – Industrial Unit

• Preproduction plastic pellets are small (1-5mm) pellet shaped pieces of plastic that are melted or molded to create most common plastic goods such as food and beverage containers, bags, shrink wrap, and toys

• Preproduction plastic also comes in other shapes such as flake, powder and granule

• Preproduction plastic is produces in many common plastic resins such as HDPE, LDPE, PP, PVC, and PS

– On average, 1 pound of preproduction plastic contains approximately 22,000 pellets.

– A 1993 study by the EPA estimated 60 billion pounds of plastic resin is produced in the US per year

What are preproduction plastic pellets?

• Industrial Storm Water Permits

9,500 industrial facilities are enrolled in the Water Board’s Industrial Storm Water Permit which addresses pollutants in industrial storm water. Housekeeping measures are included to prevent trash and plastic debris from entering stormwater systems and waterways.

• Preproduction Plastic Debris Program

A new program (2008) formed by assembly bill to address storm water discharges of preproduction plastic pellets, the raw material used to produce most common plastic products.

Addressing Industrial Sources of Plastic Debris

Why focus on pellets?• Pellets are easily transported by wind and stormwater – and too small to be captured

by trash devices on storm drains • Plastic is a long lasting pollutant – it never “goes away.”

– Instead, it breaks into smaller pieces called microplastics• Wildlife mistake small pieces of plastic for food, resulting in negative biological

impacts • Plastic pellets can contain emerging pollutants of concern such as BPA• Plastic can absorb and concentrate persistent organic pollutants in the aquatic

environment like PCBs and DDT – problematic as pellets are consumed by wildlife• Plastic pellets in stormwater often end up in waterways and the ocean• Pellets, once in the environment, contribute to California’s litter problem

– Due to their size, pellets are a costly and complex type of litter to collect

Why focus on pellets?• Pellets are released from an identifiable source (plastic industrial sites) that

can be targeted through the Industrial General Storm Water Permit• Reasons for release are easily correctable

– Usually result from poor pellet handling or housekeeping practices

Inspecting an industrial site that handles plastics?

Follow the flow of materials

Here’s some examples…

Railcar Unloading

Railcar Unloading

Railcar Unloading

Railcar Unloading

Railcar Unloading

Railcar Unloading

Railcar Unloading: PVC Powders

Pneumatic Connections

Pneumatic Connections

Loading Docks

Loading Docks

Disposal

Disposal

Disposal

Disposal:Post-storm

Runoff

Outdoor Storage & Housekeeping

Outdoor Storage & Housekeeping

Outdoor Storage & Housekeeping

Outdoor Storage & Housekeeping

Leaking Equipment

Leaking Equipment

Silos &Storage Areas

Process Exposure: Cutting & Grinding

Process Exposure: Cutting & Grinding

Inadequate Containment

Inadequate Containment

Inadequate Containment

Containment

Plastic Bag Recycling: Outdoor Storage & Housekeeping

Plastic Bag Recycling: Post-storm Runoff

Plastic Bag Recycling: Equipment Track Out& Post-storm Runoff

Container Recycling

Storm drain with screen

Plastic Releases

Plastic Releases

Plastic Releases

Plastic Releases

Plastic Releases

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 houskeeping 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.

Preproduction Plastic Pellets Program • How can the Water Boards help local governments,

environmental organizations, and industry solve this problem?– Provide stakeholder meetings, educational materials and

presentations about pellet releases– Serve as a source of information and provide help for focusing

compliance efforts such as inspections and enforcement • How can the Water Boards regulate pellets?

– The next Industrial Storm Water Permit will include strict controls to prevent release of pellets in their manufacturing, handling, and transportation

– Inspections and enforcement for facilities failing to comply– Surveys and evaluations to understand characteristics of

California’s plastics industry• How many pellets are on California’s coast?

– A sampling program is underway to estimate how many pellets are on California’s beaches and where they are concentrated

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/

• Water Board Program Contacts:– Greg Gearheart

ggearheart@waterboards.ca.gov (916) 341-5892

– Chris Haynes chaynes@waterboards.ca.gov

(916) 341-6899 – Dylan Seidner

dseidner@waterboards.ca.gov (916) 341-5576