Plastics Production Effluent Limitation Guidelines

Project:  Plastics Production Effluent Limitation Guidelines

Client:  Center for Biological Diversity

Location: United States

Services:  Wastewater/Sewer Systems; Environmental Advocacy

In light of recent expansions across the United States in petroleum production due to fracking and the resulting increased production of refined petroleum products, including plastics, the Center for Biological Diversity (CBD) planned to submit a petition to the United States Environmental Protection Agency (USEPA) to revise the Clean Water Act Effluent Limitation Guidelines (ELGs) for the petro-plastics industry.  CBD needed technical assistance on wastewater treatment and the Federal ELGs.  CEA Engineers was perfectly suited to assist CBD due to its expertise in wastewater treatment and water quality, and the fact that CEA Engineers has no conflicts of interest from previous work with petroleum producers, refiners, or any other industrial sector associated with petroleum production, refining, or processing.

In support of CBD’s petition, CEA Engineers assessed the adequacy of the current Federal ELGs for petroleum refining and conversion processes and resulting plastics production in terms of the pollutants produced and the wastewater technology standards in the ELGs.  CEA Engineers identified the primary pollutants produced by petroleum refining, conversion processes, and plastics production and compared them to current Federal ELGs.  The primary wastewater treatment technologies presently used in petroleum refining and plastics production facilities to meet the Federal Best Available Technology (BAT) standard were identified.

CEA Engineers then assessed the adequacy of the current ELGs to be protective of water quality and the technology standards to effectively treat the primary pollutants in wastewater produced by petroleum refining and plastics production, with special consideration on oil from fracking, which has a different pollutant profile than conventionally produced petroleum, and emerging pollutants, such as plastic pellets.

CEA Engineers developed a technical report for CBD that included the results of its analysis and recommendations for changes to current wastewater ELGs and technology standards.  Recommendations included treatment technologies to enhance pollutant removal from petroleum refining and plastics production wastewater to be more protective of water quality that current technology standards and practices, including advanced oxidation and membrane separation processes.

CBD’s used the analysis and recommendations in CEA Engineers’ technical report as support and basis for its petition to USEPA.  CBD successfully submitted its petition to the USEPA in conjunction with 280 environmental, public health, indigenous, and community non-governmental organizations in July 2019.