Page 154 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

outlines five mandatory BMPs that are required for all facilities that handle
preproduction plastic. These mandatory BMPs are included in this General Permit.

The State Water Board has received comments regarding the Water Code requirements
for Plastics Facilities to install a containment system for on-site storm drain locations
that meet 1mm capture and 1-year 1-hour storm flow requirement standards. As a
result, this General Permit includes the option under Water Code section 13367 that
allows a plastics facility to propose an alternative BMP or suite of BMPs that can meet
the same performance and flow requirements as a 1mm capture and 1-year 1-hour
storm flow containment system standards. These alternative BMPs are to be submitted
to the Regional Water Board for approval. This alternative is intended to allow the
facility to develop BMPs that focus on pollution prevention measures that can perform
as well as, or better than, the containment system otherwise required by the statute.

The State Water Board also includes two additional containment system alternatives in
this General Permit that are considered to be equivalent to, or better than, the 1mm
capture and 1-year 1-hour storm flow requirements:

 An alternative allowing plastic facilities to implement a suite of eight BMPs
addressing the majority of potential sources of plastic discharges. This suite of
BMPs is based on industry and U.S. EPA recommendations and Water Board
experience with storm water inspections, violations, and enforcement cases
throughout California.

 An alternative allowing a facility to operate in a manner such that all preproduction
plastic materials are used indoors and pose no potential threat for discharge off-site.
The facility is required to notify the Regional Water Board of the intent to seek this
exemption and of any changes to the facility or operations that may disqualify the
facility for the exemption. The exemption may be revoked by the Regional Water
Board at any time.

Plastics facilities may use preproduction plastic materials that are less than 1mm in
size, or produce materials, byproducts, or waste that is smaller than 1mm in size.
These small size materials will pass through the 1mm capture containment system
required by Water Code section 13367. Plastics facilities with sub-1mm materials must
design a containment system to capture the smallest size material onsite with a 1-year
1-hour storm flow requirement, or propose alternative BMPs for Regional Water Board
approval that meet the same requirements.

The remaining BMPs required by Water Code section 13367 are consistent with
recommendations for handling and clean-up of preproduction plastics in the American
Chemistry Council publication, Operation Clean Sweep and U.S. EPA’s publication
Plastic Pellets in the Aquatic Environment: Sources and Recommendations. The State
Water Board believes that the entire approach in this General Permit for plastic
materials is consistent with Water Code section 13367.

R. Regional Water Board Authorities

The Regional Water Boards retain discretionary authority over many issues that may
arise from industrial discharges within their respective regions. This General Permit

Order 2014-0057-DWQ 70