Michigan Steps Up Fight Against PFAS Contamination

Michigan has increased efforts to protect its residents from the emerging threat of per- and polyfluoroalkyl substances (PFAS) with a pair of regulatory actions aimed at reducing the presence of these chemicals in the state’s water supply:

• In January the state adopted the Environmental Protection Agency’s threshold for perfluorooctanoate (PFOA) and perfluorooctane sulfonate (PFOS) as the state standard for the acceptable combined concentration in groundwater.
• In late February the Michigan Department of Environmental Quality rolled out the Industrial Pretreatment Program (IPP) PFAS Initiative for wastewater treatment plants to reduce the presence of PFAS in Michigan surface waters due to the discharge of treated wastewater effluent.

PFAS History

PFAS – synthetic organic chemicals manufactured for more than 70 years for their unique inert nature as non-stick coatings, stain and water proofing agents, demisting agents in metal plating operations and as fire-fighting foam – are now recognized as an emerging contaminant with the potential to cause significant human health risks. Because of their inert nature, they resist photolytic, biological and chemical degradation, and therefore are found ubiquitously in the environment.

Following the EPA’s Lead

In 2016 the EPA issued a Lifetime Health Advisory (LHA) for two of the most widely detected PFAS – perfluorooctanoate and perfluorooctane sulfonate – and established an acceptable threshold for these compounds in drinking water at 70 ng/L (nanograms/liter, or parts per trillion).

In the wake of that advisory, the State of Michigan created the Michigan PFAS Action Response Team to research, identify and establish PFAS response actions relative to the discovery, communication and mitigation of PFAS.

By adopting the EPA’s LHA for these contaminants, Michigan may now take regulatory enforcement actions against any responsible party that violates the state’s cleanup rules for these contaminants.  These enforcement actions will require a responsible party to conduct activities to address the contamination in Michigan to reduce risk to human health and the environment.

The Industrial Pretreatment Program

The state’s Industrial Pretreatment Program is designed to assess whether wastewater treatment plants may be violating Michigan’s Rule 57 Water Quality Standards for PFOS and PFOA.

• The standards for PFOS are 12 ng/L for lakes and streams not used as a drinking water source and 11 ng/L for lakes and streams used as a drinking water source.
• The standards for PFOA are 12,000 ng/L for lakes and streams not used as a drinking water source, and 420 ng/L for lakes and streams used as a drinking water source.

The program requires the following actions be taken by treatment plant operators:

1. Conduct an initial screening of all industrial users in the system that may be significant dischargers of PFOS or PFOA.
2. Develop a plan to monitor all identified potential PFAS dischargers no later than June 29 or submit for approval by May 1 an alternate monitoring strategy and/or request for deadline extension.
3. Perform potential source monitoring in accordance with the developed plan.
4. If sources of PFOS and PFOA are identified, the sources of the PFAS concentrations in the effluent should be addressed through product substitution, operational controls, pretreatment or cleanup of historical contamination. Plant operators must also sample their effluent to assess their discharge relative to PFOS and PFOA.
5. Submit by June 29 an interim report of source identification and initial corrective actions proposed or performed.
6. After submitting the interim report, continue to address sources and perform additional monitoring as necessary and then submit a summary report by October 26 describing any additional proposed actions.

Because current drinking water standards are higher than the imposed discharge standards, some plant operators may show evidence of high PFOS or PFOA in the effluent simply because the community’s water supply in which it serves contains elevated concentrations of PFOS and PFOA.

What This Means

IPP dischargers should review their operation records for evidence of the use of any product containing PFAS or their use in firefighting operations. They should also work with the local treatment plant personnel so they can gather appropriate samples for PFAS analysis.

If you are a significant discharger of PFAS to your wastewater treatment plant, TRC can help you set up a subsequent confirmation sampling program to verify or refute treatment plant sampling results. If verified, TRC can assist with mitigation plans and remedial measures to address PFAS discharges from your facility.

Next Steps

• Interested in learning more? Contact TRC’s Dave McKenzie at DMcKenzie@trcsolutions.com for more information.
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