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Industrial Storm Water PFAS-related information and links
Industrial Storm Water PFAS-related information and links
About PFAS in Industrial Storm Water and Industrial Direct Discharges to Surface Waters
Per- and Polyfluoroalkyl Substances (PFAS) are a group of chemicals known for their water-, oil-, and fire-resistance. PFAS were used in various industrial processes for decades, and the properties that made them useful also make them persistent in the environment and difficult to destroy. Even if PFAS are no longer in use at a facility, they can still be present and continue to make their way into rivers, lakes, and wetlands, which can have harmful effects to human health and the environment. Visit the Michigan PFAS Action Response Team (MPART) website to learn more about PFAS.
Industrial Storm Water (ISW) Screening
Industrial storm water regulations apply to a wide range of industrial and municipal facilities. A phased approach to conduct screening at facilities regulated under the ISW program began in 2019. This approach focuses on prioritized facilities with known use of PFAS containing products (i.e. chrome platers and airports) and where elevated concentrations of PFAS in storm water are suspected due to known PFAS concentrations in groundwater, process industrial wastewater, soils, and/or surface waters associated with the facility. If PFAS storm water sampling results have the reasonable potential to exceed applicable surface water criteria, then the facility will be required to take actions to reduce PFAS concentrations in their discharge.
Industrial Direct Discharger and Industrial Storm Water Compliance Strategy
Facilities operating under NPDES Industrial Storm Water (ISW) and Industrial Direct (ID) permits are authorized to discharge storm water and process wastewater to surface waters of the state. Under the National Pollutant Discharge Elimination System (NPDES) permitting strategy, permittees are required to implement controls at their facilities to reduce pollutants in their discharges, including PFAS chemicals. Michigan has developed surface Water Quality Values (WQVs) for three PFAS: perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), and perfluorobutanesulfonic acid (PFBS). In 2020, the Water Resources Division (WRD) developed and implemented the Compliance Strategy for Addressing PFAS (PFOS/PFOA) from Industrial Direct Discharges and Industrial Storm Water Discharges, which addresses elevated concentrations of PFAS for which Michigan has WQVs from industrial direct and industrial storm water discharges. The compliance strategy establishes a compliance program and enforceable timeline to reduce or eliminate PFAS from discharges at industrial facilities authorized under NPDES and Groundwater Discharge permits to meet applicable criteria.
If a facility is identified as having a high potential for PFAS in their discharge, the WRD must determine whether the current permit coverage is adequate to protect waters of the state and ensure compliance with federal and state regulations. This is accomplished by requiring the facility to conduct a Short-Term Storm Water Characterization Study (STSWCS) and/or Short-Term Wastewater Characterization Study (STWCS) as appropriate. If after completion of the study, the facility’s discharges are found to contain concentrations above applicable criteria, the facility will be directed to address the unauthorized contaminants of concern in the discharge as expeditiously as possible. The WRD acknowledges that the identification of PFAS in these discharges may be new information and may require additional source investigation and development of site-specific corrective action plans to achieve compliance. As such, under the Industrial PFAS Compliance Strategy, most facilities will be offered the opportunity to enter an Administrative Consent Order (ACO) which will establish a compliance program and timeline for achieving compliance. Over the course of the ACO’s timeline, the facility will be required to create and conduct a Source Identification and Investigation Plan (SIIP), a Corrective Action Plan (CAP), and conduct discharge monitoring. Once implementation of the CAP is complete, and the facility is consistently meeting applicable criteria, the ACO may be terminated.
If a permittee chooses not to enter an ACO to address PFAS in discharges, EGLE may modify the permit, deny reissuance of a renewal application, or move to revoke the permit after due process. If revoked, any discharge by the permittee would be an unauthorized discharge. EGLE would then pursue enforcement of the unauthorized discharge violations in accordance with Part 31 of the NREPA.
The United States Environmental Protection Agency (USEPA) issued a memo on December 6, 2022 providing recommendations to states to address PFAS in NPDES regulated discharges. The USEPA delegated Michigan the authority to administer the NPDES program in October of 1973. Starting in 2017, EGLE’s Water Resources Division (WRD) has developed compliance and permitting strategies to address PFAS discharges from NPDES permitted facilities in Michigan. EGLE WRD reviewed the USEPA memo and developed the following document comparing EGLE WRD’s compliance and permitting strategies with the USEPA’s guidance.
- Addressing PFAS in NDPES Regulated Discharges: A Comparison of Michigan’s Compliance and Permitting Strategies and the USEPA Guidance
EGLE has developed many guidance documents to assist facilities in addressing PFAS.
PFAS Sampling Guidance
The following documents provide guidance for surface water or wastewater sampling:
Sampling guidance for additional media such as drinking water and groundwater can be found on MPART’s PFAS Sampling Guidance webpage.
PFAS Short-Term Storm Water Characterization Study (STSWCS) Plan Template
The PFAS STSWCS Plan Template outlines the requirements and methods for planning a Short-Term Storm Water Characterization Study at an industrial facility that the WRD has determined to have a high potential to be discharging storm water contaminated with PFAS above applicable criteria to surface waters of the state.
PFAS Minimum Recommended Analyte List for Industrial Direct and Industrial Storm Water Dischargers (August 2022)
The PFAS Minimum Recommended Analyte List for ID and ISW Dischargers is a list of the PFAS chemicals that the WRD recommends including in PFAS sampling and analysis for water samples.
PFAS Source Investigation and Identification Plan (SIIP) – General
The PFAS General SIIP is a guidance document that outlines a methodical approach for determining potential sources of PFAS across various locations at an industrial facility.
PFAS Source Investigation and Identification Plan for Airports
The PFAS Airport SIIP is a guidance document that outlines a methodical approach for determining potential sources of PFAS across various locations at an airport.
PFAS Substantially Identical Discharge Guidance
The PFAS Substantially Identical Discharge Guidance document explains how a facility may be eligible for reduced monitoring if discharge points are determined by EGLE to be substantially identical.
2022 Summary of Industrial Storm Water and Industrial Direct PFAS Facilities
The WRD is working to address surface water discharges that are contaminated with PFAS at facilities that are known to have PFAS in their discharge or that are determined to have a high potential for PFAS in their discharge. Prioritization of high potential PFAS facilities is determined by industrial sector type, current or historical use of PFAS chemicals as part of their industrial process, training or historical use of Aqueous Film Forming Foam (AFFF) onsite, and existing samples that identify PFAS at the facility (e.g., PFAS impacted groundwater). The sector types that have a high potential for PFAS presence in their discharge are metal plating and finishing, airports and military bases, chemical manufacturing and petroleum refining, landfills, sites with legacy contamination, bulk fuel transfer sites, paper or pulp facilities, groundwater clean-up (GWCU) sites, and sites identified through WRD watershed investigations. The adjacent figure shows the number of facilities in each sector type for current PFAS investigations.
The Michigan PFAS Action Response Team (MPART) is a unique, multi-agency proactive approach for coordinating state resources to address PFAS contamination. Agencies responsible for environmental protection, public health, natural resources, agriculture, military installations, commercial airports, and fire departments work together to ensure the most efficient and effective response.
The MPART Wastewater Workgroup consists of staff from multiple programs within the WRD and develops other strategies to investigate and address PFAS in municipal and industrial wastewater, biosolids, storm water, and groundwater through existing regulatory programs.
MPART Investigations and Sites – for more information about ongoing remediation at specific sites.
MPART PFAS Foam on Lakes and Streams – for more information about foam on surface water, and what you should do if you see any.
Other EGLE Wastewater PFAS Resources
PFAS Information Related to Biosolids
PFAS Information Related to NPDES