Are Preproduction Plastic Pellets Part of Your Process? What You Need to Know About Regulatory Compliance
For facilities handling preproduction plastic materials, extra measures must be taken to ensure regulatory compliance. Preproduction plastic resin pellets, powders, dust, or flakes usually less than five millimeters in size, otherwise known as “nurdles”, are melted together to produce bags, containers, toys, and other plastic products we use daily. Nurdles are easily mobilized by storm water, adding to the pollution issue within California waters. There are many environmental issues that arise due to the small size and chemical durability of these materials. Nurdles can scatter easily throughout waterways and become trapped in vegetation and sediment, making remediation efforts difficult and costly. Nurdles have been shown to never fully break down into organic compounds and assimilate into the environment, and instead degrade into smaller and smaller pieces. Animals, including fish, birds, turtles, marine mammals, invertebrates, and plankton have all been shown to mistakenly eat nurdles, leading to death. Nurdles have been shown to attract and accumulate potentially hazardous compounds that can achieve toxic levels when in the environment.
What’s Your Status…Under the Industrial General Permit? Make Sure You are Meeting All Reporting Guidelines
Do you have an Industrial General Permit or are you required to get one?
Does your facility require coverage under California’s National Pollutant Discharge Elimination System (NPDES) Permit for the Discharge of Storm Water Associated with Industrial Activities, also known as the Industrial General Permit (Permit)? Many industrial manufacturing facilities may not be aware that the Permit has been renewed or that their facility is even required to obtain permit coverage. While the State Water Resources Control Board and Regional Boards have been trying to get the word out for the past three years, facilities are still falling through the cracks and are deemed out of compliance if found. The local city and county agencies are also required to identify these facilities and report them to the SWRCB if found. Facilities that fail to respond to SWRCB notices may face the mandatory minimum penalty of $5,000 under Section 13399.33(a)(1) of the California Water Code if the Regional Water Quality Board decides to take early action. Furthermore, continued violations of the General Permit may result in the imposition of administrative civil liability in an amount of up to $10,000 for each day of violation under Section 13385 of the California Water Code.
The 2016-2017 wet season brought much needed rainfall to California. According to the National Centers for Environmental Information, the State received an average of 27.81 inches of precipitation during the 2017 rain season, which runs from October 1 to September 30. Reservoirs are full, vegetation is lush and the drought is officially over in most parts of the state. As summer approaches, the warmer weather combined with increased moisture creates the perfect environment for life to flourish. This can prove to be a hazardous environment for field personnel and environmental inspectors who work outdoors.
As we enter the summer months, the wet conditions created this past year provides excellent breeding grounds for mosquitos and other insects. Increases in algae provides food for mosquito larvae. An increase in vegetation provides cover and food for mice and other rodents. An increase in rodents provides food for snakes and other carnivores. The result of this ecological event is an increase in all species of life which has been evident in most parts of California this spring.
The Hidden Cost of Compliance: Permit Termination
Your construction project has reached its completion from a construction stand point, your subs have finally completed their tasks and moved on to the next project, and your project owner is ready to occupy. You may think everything is ready to move on to the next project, right?
Not so fast!!
You still may be on the hook for weekly storm water inspections under the Construction General Permit as your project has not reached regulatory requirements for completing and receiving approval of Notice of Termination of the Permit.
California State Superior Court Reduces Allowable Concentration Levels for Hexavalent Chromium in Groundwater
As part of its regulations, the California State Water Resources Control Board (State Water Board) has developed Maximum Contaminant Levels (MCLs) for various chemicals that threaten groundwater supplies. These are health protective drinking water standards which are required to be met by public water systems. They take into account not only chemicals' health risks but also factors such as their detectability and treatability, as well as costs of treatment.
In April, Lisa Kay participated in the first of a three part workshop on Stormwater Capture and Treatment. This project aims to educate the business community, civic leaders and policy makers of the potential for stormwater capture and reuse as a sustainable source of water supply within the San Diego Region. Our second workshop will focus on discussing the regulatory hurdles to stormwater capture and reuse and will be held on May 15th at The San Diego Foundation. If you would like to register to attend, please send an email request to firstname.lastname@example.org and we will get you on the list! The video below discusses the project.
New rulemaking to create new water use efficiency standards for commercial, industrial, and institutional water use will be developed this year and adopted no later than 2021, but perhaps sooner. On Friday, April 7, 2017 Governor Brown announced the drought officially over and finalized his plan for “Making Water Conservation a California Way of Life”. This plan has implications for businesses and agencies with regards to water conservation standards and possible mandatory measures as well as enforcement. The Department of Water Resources, together with the State Water Resources Control Board, will be developing the regulations to meet the objectives set forth in this conservation plan. There will be opportunity for stakeholder comments and Alta experts will keep you informed as the rulemaking moves forward.
If you have questions on water, call us at (800) 777-0605 or email@example.com .
The AAAEA-CA is excited to announce the annual Technical Exchange & Networking Luncheon titled "Industrial and Municipal Stormwater Compliance from Challenges to Opportunities" and presented by industry leaders:
On March 16, 2017 Alta hosted a workshop to provide in depth information regarding the California Industrial General Permit and its implementation requirements. The workshop was held in Long Beach at the Grand Event Center and provided attendees information and tips for compliance in the implementation of SWPPPs, training, ERA Level 1, ERA Level 2, and impending TMDLs. The event focused on key compliance concerns, best practices for avoiding Notice of Violations or third party lawsuits, and common best management practice (BMP) devices to control and reduce pollutants in stormwater runoff. Attendees included both private industrial and municipal sector personnel.