Nurdles Result in Industrial Compliance Hurdles

8/15/2017

Image Credit to SCCWRP

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.

It is estimated that around 60 billion pounds of these nurdles are produced in the United States each year and are transported to multiple types of facilities by use of rail, ship, and truck (SCCWRP). Throughout California, nurdles can be discharged to the environment by manufacturing, transportation, storage, processing, and recycling facilities that handle these materials. To comply with the Industrial General Permit (Permit), industrial facilities that handle nurdles must implement additional BMPs along with those required in the Permit to eliminate potential discharges of these materials to storm water discharge locations. These additional BMPs include:

Installation of a containment system designed to capture all particles down to 1mm in size with a treatment capacity no less than peak flow rate from a one year, one-hour storm event at every discharge location downflow of plastic handling and storage areas.
Plastic materials must be transferred and stored using durable sealed containers designed for loading and unloading activities to prevent rupture and spills.
Secondary containment capture devices shall be used during transfer and movement of plastic materials.
Employees shall use readily available vacuum or similar cleanup systems to contain potential spills
Facilities that handle plastic materials smaller than 1mm shall implement a containment system designed to capture the smallest particles used at the facility with a treatment capacity no less than peak flow rate from a one year, one-hour storm event at every discharge location downflow of plastic handling and storage areas.

The experienced professionals at Alta can help with all your storm water compliance needs, whether you handle plastic materials or not. Our team of QISPs, CPSWQs, QSDs and QSPs help to keep your facility in compliance with the Permit from Notice of Intent to Notice of Termination. For more information, call Alta at (800)-777-0605 or email info@altaenviron.com.

Blog post by Austin Kay, Water Resources Specialist.

References:

“Project: Plastic Pellets on Beaches.” Plastic Pellets on Beaches, Southern California Coastal Water Research Project, www.sccwrp.org/ResearchAreas/MarineDebris/PlasticPelletsOnBeaches.aspx.