Opportunity to Comment: Special Requirements Proposed for Plastics Facilities Subject to California Storm Water Regulations

August 31, 2012

Interested parties have until October 22 to submit comments on California's 2012 Draft National Pollutant Discharge Elimination System (NPDES) General Permit for the Discharge of Storm Water associated with Industrial Activities (2012 Draft NPDES Industrial General Permit).

The draft contains elements specific to plastics facilities:

• "Plastic Materials" would include "plastic resin pellets, powders, flakes, additives, regrind, scrap, dust, and industrial process waste or recycling with the potential to discharge or migrate off-site"
• Affected entities would be required to implement best management practices (BMPs), though the draft provides a "no exposure" exemption. There is also an exemption if certain BMPs are met; however, discharge or off-site migration of Plastic Materials would constitute an illicit discharge in violation of the permit
• Covered facilities that manufacture, transport, store or consume plastics materials would have to report information about the plastics and the BMPs employed
• Minimum requirements for storm water pollution prevention plans (SWPPPs)

New requirements may raise questions and concerns. California's State Water Resources Control Board has scheduled additional workshops, on September 5 and 24. Resources include California's Preproduction Plastic Debris Program.

Operation Clean Sweep®, an environmental program of BMPs designed to reduce accidental pellet loss, is an industry-led initiative. An informational webinar on the program will be held on October 16, 2012.

Founded in 1937, SPI: The Plastics Industry Trade Association promotes growth in the $380 billion U.S. plastics industry. Representing nearly 900,000 American workers in the third largest U.S. manufacturing industry, SPI delivers advocacy, market research, industry promotion, and the fostering of business relationships and zero waste strategies. SPI also owns and produces the international NPE trade show. All profits from NPE are reinvested into SPI’s industry services. Find SPI online at www.plasticsindustry.org and www.inthehopper.org.

"From resin suppliers and equipment makers to processors and brand owners, SPI is proud to represent all facets of the U.S. plastics industry," said William R. Carteaux, president and CEO, SPI. Our most recent economic reports show that the plastics industry as a whole is resilient, and has come through the recession significantly better than other U.S. manufacturing sectors."