1. Preproduction Plastic Debris Program:
Industrial Sources of
Plastic Pellets in the Environment
California State Water Resources Control Board
Division of Water Quality
Stormwater Section – Industrial Unit
2. What are preproduction plastic pellets?
• 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
3. Addressing Industrial Sources of Plastic Debris
• 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.
4. 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
5. 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…
43. 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.
44. 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.
45. 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
46. 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/
47. • 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
