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As a part of routine monitoring around the state, the Michigan Department of Environment, Great Lakes, and Energy (EGLE) identified elevated levels of PFOS in the Flint River. By collecting additional samples in the river, EGLE identified the Lapeer Wastewater Treatment Plant (WWTP) as a significant source of the elevated PFOS levels. WWTPs do not use PFOS but do treat waste from industries that may use PFOS-containing chemicals. The Lapeer WWTP evaluated potential sources of PFOS to its collection system and discovered the source of PFOS was LP&P.
For more information about WWTPs and PFAS, visit the Wastewater Treatment Plants / Industrial Pretreatment Program page.
LP&P is a decorative chrome plating facility that pre-treats and discharges process wastewater to the City of Lapeer's (City) sanitary sewer system for further treatment at the Lapeer WWTP. Plating facilities historically used PFOS containing mist-suppressants in their industrial processes to comply with hexavalent chromium air emission requirements and protect worker health and safety. LP&P switched to a PFOS-free mist suppressant in 2013, but residual PFOS remains in the facility.
There is a fish consumption advisory for PFOS on the Flint River as a result of this discharge to surface waters.
Content posted February 2021.
Not applicable; there are no known impacted water supplies at this time.
EGLE staff reached out to LP&P for a response to EGLE's RAP audit. LP&P, nor its consultants, have responded. Further communications are planned soon.
The Department of Environment, Great Lakes and Energy (EGLE) identified elevated levels of PFOS in fish tissue and surface water samples in the Flint River. Based on these results, the Department of Health and Human Services (DHHS) issued a fish consumption advisory for PFOS in the Flint River in 2015, updated in 2018. Several rounds of follow-up sampling conducted by the EGLE Water Resources Division of the Flint River and its tributaries resulted in the identification of the City of Lapeer Wastewater Treatment Plant (WWTP) as a significant source of PFOS to the river in May of 2017. Subsequent testing of biosolids generated at the Lapeer WWTP also found elevated concentrations of PFOS in the solids.
PFAS is not generated at the Lapeer WWTP. The Lapeer WWTP receives industrial wastewater from Lapeer Plating & Plastics (LP & P) located at 395 DeMille Road, in the City of Lapeer. The discharge from LP & P makes up approximately 4.4 percent of the total flow into the WWTP. LP & P is an automotive supplier that does decorative chrome plating on plastic. Historically, a PFOS containing product was used as a mist suppressant in their plating process as a means of complying with national regulations to control air emission of chromium from chromium electroplating and anodizing tanks. EPA regulations eventually banned PFOS-containing chemicals from chrome electroplating tanks starting in September 2015. LP & P has indicated that they switched to a “PFOS-free” mist suppressant in all tanks in 2013. Current concentrations of PFOS in the industrial wastewater at LP & P appear to be from the past use of PFOS containing products as part of the industrial process. This is consistent with findings of other metal finishers (both active and historic) in the state.
The Lapeer WWTP uses conventional WWTP treatment processes that are very effective in treating typical contaminates found in sanitary wastewater. However, these conventional processes do not effectively treat and remove PFOS. PFOS instead is passed through the treatment process at the WWTP and is discharged in the effluent to the South Branch of the Flint River. In addition, PFOS accumulates in solids generated at the WWTP. These solids are referred to as sludge or as biosolids when they undergo treatment that meets state and federal standards for beneficial reuse.
The City of Lapeer was authorized to land-apply biosolids from the Lapeer Wastewater Treatment Plant (WWTP) under their National Pollutant Discharge Elimination System (NPDES) Permit No. MI0020460 in accordance with a Residuals Management Program (RMP) approved by EGLE on October 17, 2000.
In 2017, PFOS levels in the biosolids generated at the Lapeer WWTP was found to be 2,100 nanograms per gram (ng/g). Although there is no federally established concentration limit for PFOS in biosolids, after review of existing PFAS related biosolid studies in other states, this level is highly elevated and the EGLE determined the biosolids were “industrially impacted”. As such, the EGLE suspended the City of Lapeer’s authorization to land apply biosolids on September 29, 2017. The Lapeer WWTP is currently managing accumulated PFOS-contaminated biosolids at their facility for disposal at a landfill. It should be noted that since installation of treatment at LP & P, concentrations of PFOS in biosolids generated at the Lapeer WWTP have been significantly reduced.
There is limited data on the fate of PFAS at land application sites where biosolids with elevated concentrations were applied. In order to further our knowledge of the potential use, the EGLE conducted screening of four fields (three locations) that received biosolids from the Lapeer WWTP. The fields were selected through a prioritization process which factored in years of use, application rates, and consistency of acres used. Other factors also considered included, soil type, geology, down gradient receptors, and proximity to recreational surface waters.
As part of the study, soil, groundwater, drain tile (where present) and surface water samples were collected from all four fields. Samples of effluent and sludge were also collected at the Lapeer WWTP.
Findings from the study are detailed in four technical reports and are provided as links below. In summary, the study found that there was no indication that residential wells located near the fields sampled were at risk for PFAS contamination. This was further supported by results of groundwater samples collected from community water supplies and public schools near the biosolids application sites which were non-detect for PFAS.
In addition, the study found that fields that received a higher ratio of total tonnage of biosolids applied to acres used, had higher levels of PFAS in the soils, groundwaters, and surface waters. Elevated levels in adjacent surface waters found at two of the fields are thought to be the result of a combination of surface runoff, and the discharge of shallow, perched groundwater via tile drains or surface swales. The potential for ingestion of PFAS-impacted fish near two of the fields was identified and PFAS related fish consumption advisories have been issued by the Department of Health and Human Services for the South Branch of the Flint River and Lake Pleasant based on tissue analysis of fish collected within those waterbodies.
In their December 7, 2018 report, the Michigan PFAS Science Advisory Panel recommended that “Michigan gather information to understand the extent of PFAS contamination in biosolids and encourage research to assess the fate and transport of PFAS from contaminated biosolids into crop plants and groundwater.”
In step with this recommendation, in 2018 – 2019, the EGLE conducted additional studies to look at PFAS concentrations in sludge/biosolids generated at WWTPs and at PFAS levels at biosolid land application sites associated with other WWTPs. The studies are summarized below:
Influent, effluent, and sludge/biosolid samples were collected at 41 WWTPs in October and November of 2018. The WWTPs were selected based on size (20 largest plus a subset of mid-to large systems treatment processes, geographical representation across the state.
In addition to the 41 WWTPs, by the summer of 2018, implementation of EGLE's IPP PFAS Initiative identified other WWTPs that had industrial impacted biosolids due to high PFOS concentrations. These WWTPs had PFOS concentrations and industrial sources similar to those that were found in Lapeer. Field screening (soil, tiles, and surface water samples) was conducted at a sub-set of land application sites that received biosolids from these WWTPs.
It is expected that low levels of PFAS, including PFOS, will be found in solids generated at most WWTPs. This is due in large part to the common use of PFAS in many commercial, residential, and industrial applications and products for many decades. With this in mind, and in lieu of having federally established criteria for PFAS concentrations in biosolids, the EGLE also selected land application sites for screening (soil, tile, surface water sampling) from fields that received biosolids with much lower, and what might be considered more “typical” concentrations of PFOS.
It is expected that these studies will help the state develop guidance for informed management of biosolids in regard to PFAS in the future. As of May 2019, reports from the 2018/2019 studies were still under development and will be shared once complete.
This chart reflects data received prior to August 3, 2020.
|
Type of Sample |
Date Sampled (or Range) |
Number of Samples |
Number of Results Received |
Number of Non-Detects | Number Between Non-detect and Standard* | Number Greater Than or Equal to Standard |
|---|---|---|---|---|---|---|
|
Surface Water |
2013 - June 2019 | 46 | 46 | 1 | 5 | 40 |
| Effluent (WWTP) | August 2020 - December 2020 | ~41 | ~41 | 1 | 2 | ~38 |
| Effluent (LP&P) | August 2020 | ~372 | ~372 | 1 | 20 | ~351 |
| Cumulative | ~459 | ~459 | 3 | 27 | ~429 |
*Surface water and effluent results are compared to Rule 57 surface water quality values of
12 ppt for PFOS and 12,000 ppt for PFOA.
|
Type of Sample |
Date Sampled (or Range) |
Numberof Sample Results |
Number of Results Received |
Number of Non-detects |
|---|---|---|---|---|
|
Effluent (WWTP) |
August 2020 - December 2020 | 5 | 2 | 0 |
| Effluent (LP&P) | August 2020 | 12 | 6 | 0 |
* Residential well and groundwater monitoring well results are compared to EGLE Part 201 criteria for 7 PFAS compounds: PFOS (16 ppt), PFOA (8 ppt), PFNA (6 ppt), PFHxS (51 ppt), PFHxA (400,000 ppt), PFBS (420 ppt), and HFPO-DA (370 ppt).
* Surface water and effluent sample results are compared to Rule 57 non-drinking water values of 12 ppt for PFOS and 12,000 ppt for PFOA.
