Preproduction Plastics Control Options Under California 2012 IGP

The revised California draft Industrial General Permit (IGP) includes controls required for pre-production plastic. Preproduction plastics used by the plastic manufacturing industry are small in size and have the potential to mobilize in storm water. Water Code section 13367 requires the State Water Board to implement measures that control discharges of preproduction plastic. Water Code section 13367 outlines five mandatory BMPs that are required for all facilities that handle preproduction plastic. These mandatory BMPs are included in the 2012 draft IGP.

The State Water Board had received comments regarding the Water Code requirements that plastic 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, the 2012 IGP 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 included two additional containment system alternatives 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.
• 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.

Plastic 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 materials will bypass the 1mm capture containment system required by Water Code section 13367. Plastic 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 these same requirements.


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting and Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website