PFAS

Per- and polyfluoroalkyl substances (PFAS) are a large group of synthetic chemicals that are resistant to heat, water, and oil. PFAS have been classified by the U.S. Environmental Protection Agency (EPA) as an emerging contaminant on the national landscape.

For decades, they have been used in many industrial applications and consumer products such as carpeting, waterproof clothing, upholstery, food paper wrappings, personal care products, fire-fighting foams, and metal plating. They are still used today. PFAS have been found at low levels both in the environment and in blood samples of the general U.S. population.

These chemicals are persistent, which means they do not break down in the environment. They also bioaccumulate, meaning the amount builds up over time in the blood and organs.

Studies in animals who were exposed to PFAS found links between the chemicals and increased cholesterol, changes in the body's hormones and immune system, decreased fertility, and increased risk of certain cancers. Studies in which animals were given high levels of PFAS showed effects including low birth weight, delayed puberty onset, elevated cholesterol levels, and reduced immunologic responses to vaccination. Animal studies help scientists understand what could happen in people.

PFOS or perfluorooctane sulfonate is a specific chemical associated with aqueous film forming foam (AFFF) fire-fighting foam, and demisters/defoamers/surfactants used by the plating industry to control air emissions of hexavalent chromium and as a wetting agent. It is persistent and bioaccumulative. It is a human health threat when ingested (in food or drinking water) and is of special concern for discharges to surface water because it bioaccumulates readily in some species of fish. The water quality value is very low at 12 ng/l for lakes and streams not used as drinking water sources and 11 ng/l for those used as drinking water sources.

PFOA or perfluorooctanoic acid (also called “C8”) is a specific chemical associated with non-stick coatings for cookware and fabric treatments for stain- and water-repellency. It is a human health threat when ingested (in food or drinking water) and is of concern especially when contaminating sources of drinking water. It does not bioaccumulate as readily in fish as PFOS, so the water quality value for lakes and streams not used as drinking water sources is relatively high (170 ng/l). If a lake or stream is used as a drinking water source, the water quality standard is much lower (66 ng/l).

On February 4, 2019, Governor Gretchen Whitmer signed Executive Order 2019-3, establishing the Michigan PFAS Action Response Team (MPART) as an enduring body to address the threat of PFAS contamination in Michigan, protect public health, and ensure the safety of Michigan's land, air, and water, while facilitating inter-agency coordination, increasing transparency, and requiring clear standards to ensure accountability. MPART is comprised of seven state departments, including: Michigan Department of Military and Veterans Affairs (MDMVA), Michigan Department of Environment, Great Lakes, and Energy (EGLE), Michigan Department of Health and Human Services (MDHHS), Michigan Department of Natural Resources (DNR), Michigan Department of Agriculture and Rural Development (MDARD), Michigan Department of Transportation (MDOT), Michigan Department of Licensing and Regulatory Affairs.

These agencies are working with federal and local partners to conduct investigations to identify areas and sources of PFAS contamination throughout the state and ensure appropriate public health responses.

Refer to the MPART website for additional information.

Yes, there has been ambient monitoring in selected areas around the state since 2001. Follow up monitoring is continuing in targeted areas. The 2015 report Michigan Department of Community Health Final Report, USEPA-Great Lakes Restoration Initiative Project, May 28, 2015, provides information on a project to measure perfluorinated compounds in Michigan surface waters and fish from September 1, 2012 to February 28, 2015. In addition, the public can view PFAS surface water sample results on the MPART PFAS Geographic Information System app which features several datasets as part of MPART’s efforts.

Yes, the public can see which POTWs have PFAS data associated with their permitted discharge at the MPART PFAS Geographic Information System app and clicking on the Publicly Owned Treatment Works with PFAS Data layer. The public can click on a specific facility and be directed to the MiEnviro Portal Site Map Explorer page for that facility in order to view PFAS laboratory reports. Instructions for searching in Site Map Explorer can be found in the Publicly Owned Treatment Works with PFAS Data layer.

A summary of the activities of the U.S. EPA and other states can be found on the U.S. EPA’s web site at www.epa.gov/pfas. Also, the Agency for Toxic Substances and Disease Registry has a link to site-related activities around the country at Map of PFAS Sites | PFAS and Your Health.

The United States Environmental Protection Agency (U.S. EPA) released a document called the “Fact Sheet – PFOA & PFOS Drinking Water Health Advisories.” The fact sheet is available at on their Drinking Water Health Advisories for PFOA and PFOS page. In addition, the public can visit the MPART Drinking Water and Wells webpage for further information and resources.

The Interstate Technology Regulatory Council (ITRC) has provided information on PFAS treatment technologies for various environmental media on their website. In addition, the Michigan PFAS Action Response Team (MPART) Treatment Technologies Workgroup website has ????

The data we have seen indicate that very little (if any) removal of PFAS chemicals occurs as a result of conventional wastewater treatment.

The Michigan Rule 57 Values are developed to protect humans, wildlife, and aquatic life. The Rule 57 Water Quality Values for Select PFAS (listed in nanograms per liter which is equivalent to parts per trillion) are as follows:

*Human Noncancer Value (HNV), Final Chronic Value (FCV), Aquatic Maximum Value (AMV), Final Acute Value (FAV)
** New Water Quality Values 
(-) Aquatic Life Values for PFHxS and PFNA are currently under development

In August 2020, the Michigan Department of Environment, Great Lakes, and Energy (EGLE) promulgated rules establishing maximum contaminant levels (MCLs) for seven PFAS compounds under the authority of the Safe Drinking Water Act.

For NPDES permittees, Part I.C.1.f. requires permittees to prohibit discharges that cause their POTWs to pass through pollutants greater than water quality values to surface water. Water quality values have been established for five PFOS and PFOA as described in the question "What criteria has Michigan established to regulate PFAS in drinking water?" above. Part I.C.1.g. further prohibits NPDES permittees from accepting discharges that restrict, in whole or part, with their management of biosolids. These are current permit requirements. State Groundwater Discharge Permits have similar requirements. EGLE WRD is asking NPDES and Groundwater permittees to comply with these provisions for PFAS. These are new pollutants to consider but the same requirements that POTWs have been complying with for many years.

In addition, EGLE WRD also has authority under the Part 23 Rules to require review of new pollutants: R323.2303 (4)(a)(ii) Each POTW that has an approved pretreatment program shall review and update the local limits… when new pollutants that are previously unevaluated are identified.

Please contact the IPP PFAS Specialist assigned to your area.

If sources of PFAS are found through source monitoring at values greater than the Water Quality Values, you are required to sample your WWTP effluent for PFAS.

You are required to work with the industry to reduce and/or eliminate PFAS from their effluent. In addition, you are required to monitor your WWTP effluent for PFAS. We understand you would prioritize each source based on their contribution of PFAS to the POTW.

These instances will be evaluated on a case-by-case basis. The first step would be to work with identified sources of PFAS to reduce and/or eliminate those discharges. Additional monitoring, including biosolids may be required. EGLE will send a letter to the POTW outlining the next steps the POTW will need to take.

The effort may be funded either by charging back costs to industrial sources, sewer fees, or local general funds.

This issue will likely require coordinated effort among various programs and government officials. Please document your findings and contact your Regional IPP PFAS Specialist.

If the POTW is conducting a PFAS collection system evaluation as part of an approved Pollutant Minimization and Source Evaluation Program or approved Alternative Monitoring Plan with the results being non-detect, and the POTW is in compliance with the PFAS Water Quality Values and the Land Application of Biosolids Containing PFAS Interim Strategy requirements are being met, then no further sampling is needed. However, if the POTW is experiencing problems with meeting established Water Quality Values for PFAS or biosolids requirements, then additional sampling is necessary.

The goal of the Municipal NPDES Permitting Strategy for PFAS is to reduce and/or eliminate PFAS at the source before PFAS can be discharged to the POTW. The WWTPs with an IPP, confirmed industrial sources, and the reasonable potential to discharge PFAS greater than the Water Quality Values may see PFAS effluent limits in their upcoming NPDES Permit.

Timelines will vary depending on the PFAS reduction/elimination approach(s) available to the Non-Domestic Users and the extent of the existing contamination. In some cases, replacing the PFAS containing chemical with a non-fluorinated substitute may be feasible and sufficient. Others may require more proactive measures after eliminating PFAS-containing chemicals including cleaning or replacing plating tanks, sumps and conveyances that contain residual PFAS. In some instances, the installation of treatment such as an ion exchange resin system or activated carbon filtration may be necessary. EGLE will accept reasonable timeframes for these types of activities provided there is an ongoing active effort to address the PFAS contamination that was found onsite.

This will be evaluated on a case-by-case basis, but in general we anticipate follow-up monitoring will occur at a frequency appropriate to demonstrate the discharger’s progress in the PFAS reduction and elimination effort.

U.S. manufacturers committed to voluntarily phasing out the manufacturing of PFOA and PFOS completely by 2015. However, concerns remain regarding alternative/replacement chemicals, especially those that may contain precursors to PFOS and PFOA. EGLE is working with a number of interested parties regarding PFAS issues and has had a number of discussions with manufacturers regarding PFAS issues.

Our expectation is that you will conduct a desk evaluation of your non-domestic users that may discharge PFAS such as metal finishers, landfills, centralized waste treaters, tanneries, fabric treaters, chemical companies, contaminated sites, car washes, schools, medical entities, or any other industries that you suspect may discharge PFAS. These nondomestic users would be considered your potential sources. All should be screened for whether they have used or produced PFAS, particularly PFOS and PFOA. Sampling the respective discharge of the nondomestic user is the best way to determine if it is a probable source. 

Those nondomestic users found to be discharging PFAS in exceedance of any of the Water Quality Values would be considered a probable source. Due to the persistent nature of PFAS, especially the longer chain chemicals such as PFOS, residual PFAS may be found many years after they have been used. Please see the report, Michigan Industrial Pretreatment Program (IPP) PFAS Initiative: Identified Industrial Sources of PFOS to Municipal Wastewater Treatment Plants, for an overview of the nondomestic sources of PFOS to POTWs.

Yes, POTWs are required to investigate any potential sources of PFAS that may be contributing to their PFAS loading, including known sources other than those types specifically identified. This required investigate process should be ongoing to identify any potential sources. If you have questions concerning a potential source, please contact your IPP PFAS Regional Specialist.

PFAS may show up on Safety Data Sheets (SDS) or Material Safety Data Sheets (MSDS). Sometimes we have seen it listed as “fluorinated surfactants” or “organic fluorosulfonate.” Since small concentrations of these pollutants are important, any amount listed would make the industry a probable source and an immediate concern. However, some SDS will not list the chemical because they are proprietary chemicals. The POTW should require the industrial user to contact the supplier to find out if a product contains PFAS. The POTW may choose to perform effluent sampling if deemed necessary and use the results as a basis for their inquiry.

Non-Domestic Users should be considered sources if their discharge contains PFAS greater than the water quality values for their receiving stream. See the "What criteria has Michigan established to regulate PFAS in surface water?" question.

Yes. Since PFOS is bioaccumulative and sources may be obscured by dilution, it is still important to evaluate PFAS sources and eliminate them as much as possible. The loading to our lakes and streams is ultimately what will result in bioaccumulation in our fisheries. Effluent results may vary over time. Having less than the water quality standard in your effluent will, however, provide your WWTP with much more flexibility in responding to any sources of PFAS found. See also the question "What is EGLE’s legal authority to enforce the requirements of the Municipal NPDES Permitting Strategy for PFAS?" for legal authority.

You are required to submit your evaluation along with documentation in the Interim Report. If EGLE agrees with your assessment, you will be notified in writing that no further action will be needed.

No. However, if you suspect a potential source is a probable source due to past or current use of PFAS containing chemicals please notify your IPP PFAS Specialist.

If you have reason to believe these sources used chemicals containing PFAS and the PFAS containing chemicals may be discharged to the sanitary sewer, then they should be added to the list of probable sources to be sampled. POTWs need to be aware of possible inflow or infiltration into their collection system as well as the potential for environmental contamination such as groundwater. Abandoned sites may need to be brought to the attention of EGLE staff.

Yes, PFAS contaminated sites should be identified as potential sources if inflow or infiltration in nearby sanitary sewers has the potential to transport these pollutants to WWTP. It is recommended that you contact EGLE staff with knowledge of these sites to determine if PFAS have been associated with site contamination. Monitoring well data may be useful in making such determinations. If PFAS have been identified as site contaminants AND if inflow or infiltration into the nearby sewers occurs a representative downstream location in the collection system should be sampled. An alternative monitoring plan should be proposed for the site.

In this case study, the local fire department was contacted and was able to identify the foam that was used. They had a MSDS on file along with the quantity used. When documented records are unavailable, but there is a past knowledge of AFFF usage related to a fire or a verbal account regarding a suspected site, it may be necessary to determine possible contamination by sampling the area for PFAS. Inflow and infiltration into the sanitary sewers from known firefighting sites where AFFF was used should be factored into the probable source determination.

Yes. Please see the Commercial Industrial Laundries section of the report, Michigan Industrial Pretreatment Program (IPP) PFAS Initiative: Identified Industrial Sources of PFOS to Municipal Wastewater Treatment Plants.

Yes. A closed or open Type II Municipal Solid Waste Landfill will likely have some PFAS due to disposal of consumer/household products. The impact of the landfill discharge of PFAS on the WWTP will depend on amount of leachate being discharged and the concentrations of PFAS in the leachate.

In our experience, PFAS chemicals tend to persist in plating tanks, treatment tanks, sumps, air pollution control equipment and piping conveyances for some time after their use has been discontinued.

Yes, the state is beginning the process of reviewing and sampling contaminated sites that may contain PFAS. If you have questions about a specific site, please contact your District IPP staff who can identify the appropriate project manager.

On December 6, 2024, the USEPA issued a prepublication version of 40 Code of Federal Regulations (CFR) Part 136 – Guidelines Establishing Test Procedures for the Analysis of Pollutants that includes methods for the analysis of 40 PFAS analytes in wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and fish tissue. The prepublication version includes two test methods, with USEPA Method 1633A for wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and fish tissue and ASTM D8421-24 for aqueous samples only.

Until methods for the analysis of PFAS are promulgated, PFAS samples may be analyzed for 28 PFAS using, USEPA Method 1633A, ASTM D7979, ASTM D8421-24, or an isotope dilution method (sometimes referred to as Method 537 modified) until one or more analytical methods are promulgated at which time only promulgated methods may be used. Regardless of the method used, the Permittee should choose a laboratory with sufficient quality assurance/quality control practices, quantification/reporting levels, and detection levels.  The required minimum quantification level is 2 ng/L.

The holding time will depend on the analytical method and/or laboratory chosen. Always request and follow the instructions provided by your laboratory and confirm the holding time and any other special sample handling procedures they require.

You should use a laboratory that you believe implements a good Quality Assurance/Quality Control program for PFAS analysis of wastewater. Please see the PFAS Minimum Laboratory Analyte list from the PFAS Action Response Team website, to find a laboratory. Scroll down the analytes list, and on the last page you'll see a link to United States Department of Defense (DOD), Environmental Laboratory Accreditation Program which maintains a list of laboratories for the determination of PFAS in various environmental media.

Most labs that can test wastewater samples for PFAS will likely be able to analyze biosolids for PFAS, but you will need to check with individual laboratories.

EGLE’s laboratory can analyze wastewater samples for PFAS, but cannot be used by non-EGLE entities.

Please consult with your chosen laboratory regarding their capabilities for the specific wastewater you are sampling. We understand that some wastewater may pose challenges to laboratories. You may wish to consult more than one laboratory and consider which method is best for the particular environmental matrix.

It is required to sample for the 28 PFAS listed on the EGLE PFAS Minimum Analyte List. More PFAS analytes, including some from the list, may emerge as precursors to PFOS and/or PFOA or contaminants of concern in the future. Until methods for the analysis of PFAS are promulgated, PFAS samples may be analyzed for 28 PFAS using, USEPA Method 1633A, ASTM D7979, ASTM D8421-24, or an isotope dilution method (sometimes referred to as Method 537 modified) until one or more analytical methods are promulgated at which time only promulgated methods may be used.

We recommend the POTW conduct the sampling of the nondomestic user so that the quality of the sampling process is known. However, we understand that many communities will charge back the cost of sampling to their users. If POTWs request sampling by the nondomestic user, they must require them to use sampling techniques that will not cause cross contamination.

No. On December 6, 2024, the USEPA issued a prepublication version of 40 Code of Federal Regulations (CFR) Part 136 – Guidelines Establishing Test Procedures for the Analysis of Pollutants that includes methods for the analysis of 40 PFAS analytes in wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and fish tissue. The prepublication version includes two test methods, with USEPA Method 1633A for wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and fish tissue and ASTM D8421-24 for aqueous samples only.

Until methods for the analysis of PFAS are promulgated, PFAS samples may be analyzed for 28 PFAS using, USEPA Method 1633A, ASTM D7979, ASTM D8421-24, or an isotope dilution method (sometimes referred to as Method 537 modified) until one or more analytical methods are promulgated at which time only promulgated methods may be used. Regardless of the method used, the Permittee should choose a laboratory with sufficient quality assurance/quality control practices, quantification/reporting levels, and detection levels.  The required minimum quantification level is 2 ng/L.

The following types of clothing are considered best to wear while sampling for PFAS:

• Cotton or synthetic clothing without stain- or water-resistant coatings
• PVC or wax-coated clothing, neoprene
• Old, well-laundered clothing
• Powderless nitrile gloves
• Polyurethane or PVC boots or PFAS-free overboots

However, use common sense. What matters most is what may come into contact with the sample. Safety first. For more information regarding PFAS sampling, please visit the Michigan PFAS Action Response Network (MPART) Sampling Guidance webpage.

Beginning in 2021, EGLE rolled out the Land Application of Biosolids Containing PFAS Interim Strategy that required facilities to test for PFOS prior to land application. With an update in 2024, all facility’s must test their biosolids at least once per calendar year for PFOS and PFOA. Depending on the PFOS and PFOA concentrations, there may be restrictions on land application. For more information, please see EGLE’s Biosolids PFAS webpage.

Many methods currently being implemented by laboratories are able to test both wastewater and biosolids samples. Isotope dilution methods 537 modified and ASTM D7979 are commonly used by laboratories for both wastewater and biosolids PFAS analysis. The EPA has finalized method 1633A, Analysis of Per- and Polyfluoroalkyl Substances in Aqueous, Solids, Biosolids, and Tissue Samples by Liquid Chromatography-Tandem Mass Spectrometry (LC-MS/MS), and has proposed for promulgation within Method Update Rule (MUR) 22. The EPA also included method ASTM D8421, Standard Test Method for Determination of Per- and Polyfluoroalkyl Substances in Aqueous Matrices by Co-solvation followed by LC/MS/MS, in MUR22 for aqueous matrices. Once a method has been promulgated in Title 40 Part 136 of the Code of Federal Regulations, Guidelines Establishing Test Procedures for the Analysis of Pollutants, only promulgated methods may be used for PFAS compliance sampling. Of the three (3) methods proposed for promulgation in MUR22, only one (1), EPA Method 1633A, is approved for biosolids. For more information, please contact your regional IPP PFAS specialist.

There is certainly the potential for cross media contamination and we cannot predict how various stakeholders will respond to this challenge. However, EGLE’s WRD does not expect WWTPs that identify sources of PFAS to force certain users out of their systems. Instead, we encourage WWTPs to take a systematic approach, working with EGLE and other partners to evaluate options for reducing or treating sources of PFAS and to use the IPP process to ensure that water quality and public health are protected.