Lapeer County, Lapeer, Lapeer Plating & Plastics

Lapeer County, Lapeer, Lapeer Plating & Plastics

Updated: February 8, 2021

Background

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 webpage.  Access to: Wastewater Treatment Plants / Industrial Pretreatment Program.

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.

Recent Accomplishments

• LP&P continues to pretreat its process wastewater with a granular activated carbon system prior to discharge to the City of Lapeer WWTP sanitary sewer.  The City has issued an order requiring pretreatment for PFOS and ongoing monitoring.  LP&P has significantly reduced PFOS concentrations discharged.  The Lapeer WWTP process has been cleaned and over 90% of the contaminated sludge removed.  The Lapeer WWTP’s effluent quality has greatly improved in correlation with LP&P’s PFOS reductions and the cleaning at the Lapeer WWTP.
• On May 14, 2020, EGLE received LP&P’s Response Activity Plan (RAP). 
• On August 7, 2020, EGLE sent an audit response letter to LP&P’s RAP.  From EGLE’s review, the RAP did not contain sufficient information to conclude whether the RAP was approvable.  A list of lacking information was included in the response letter.  EGLE suggested to schedule a meeting between LP&P consultants, and owner, and EGLE staff to discuss appropriate actions needed to continue with the RAP.
• On January 11, 2021, the City extended its order, which requires ongoing monitoring for PFOS and compliance with local requirements, with LP&P through July 8, 2021.  

Next Steps

• 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.

Residential Well Testing/Alternate Water Information

• Not applicable; there are no known impacted water supplies at this time.

Upcoming Community Engagement

• None scheduled at this time.

Sampling: PFOS and PFOA Only

Type of Sample	Date Sampled	Number of Samples 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. 

Sampling notes

• On August 3, 2020, new Part 201 Criteria went into effect.  Historical sampling data compared to Part 201 Criteria >70 is captured in the historical timeline below.
• Other PFAS analytes were detected in samples.  There are no federal or state standards for these analytes.
• All four of the Type I community back-up wells for the City have been tested; results were non-detect for PFAS.  The City gets their drinking water from the Great Lakes Water Authority.
• There are no PFAS standards for biosolids.
• Soil, groundwater, and surface water samples were collected at four land application sites.

Lapeer WWTP – Lapeer Plating & Plastics PFAS Site Biosolids Land Application Investigation Workplan
April 16, 2019

Background

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.

Industrial Source of PFAS Identified - Lapeer Plating & Plastics

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. 

Screening of Biosolids Land Application Sites used by Lapeer WWTP

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. 

• Evaluation of Lapeer WWTP Biosolids Site 08n11e33-SK01 - December 21, 2018 - pdf
• Evaluation of City of Lapeer Wastewater Treatment Plant (WWTP) Site - December 21, 2018 - pdf
• Evaluation of Lapeer WWTP Biosolids Site 08n10e33-CL01 - September 27, 2018 - pdf
• Evaluation of Lapeer WWTP Biosolids Sites 08n11e16-Tg01 and 08n11e16-TG02 - September 27, 2018 - pdf

Additional Work to Further Characterize PFAS Concentrations in Biosolids

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:

• WWTP PFAS Sampling

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.

• Field Screening of Land Application Sites – “Industrially Impacted” Biosolids

In addition to the 41 WWTPs, by the summer of 2018, implementation of EGLE's Industrial Pretreatment Program 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. 

• Field Screening of Land Application Sites – “Low/Typical” Biosolids

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.

Lapeer Plating & Plastics Historical Timeline

As a part of routine monitoring around the state, EGLE identified elevated levels of PFOS in the Flint River. By collecting additional samples in the river, the Michigan Department of Environment, Great Lakes, and Energy (EGLE) identified the Lapeer WWTP as a significant source of the elevated PFOS levels. WWTPs treat waste from businesses and industries that discharge to them, so the Lapeer WWTP evaluated the contributors to their waste stream and discovered the source of PFOS was Lapeer Plating & Plastics. For more information about WWTPs and PFAS, visit the Wastewater Treatment webpage.

Lapeer Plating & Plastics is a decorative chrome plating facility that pre-treats and discharges process wastewater to the city of Lapeer’s sanitary sewer system for 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. Lapeer Plating & Plastics switched to a PFOS-free mist suppressant in 2013.

There is a fish consumption advisory for PFOS on the Flint River as a result of the discharge to surface waters.

• In June 2017, EGLE first suspected a source of PFOS coming from LP&P when effluent sampling results were received from the Lapeer WWTP. Results from the sampling showed 415 parts per trillion (ppt) PFOS being discharged from the Lapeer WWTP.
• In July 2017, EGLE conducted additional sampling at the facility, which confirmed levels of 19,000 ppt PFOS in LP&P’s process wastewater and 2,000 ppt PFOS in Lapeer WWTP’s final effluent. EGLE issued a Violation Notice to Lapeer Plating & Plastics to correct the discharge.
• On September 25, 2017, EGLE suspended the Lapeer WWTP’s approval to land apply biosolids generated at the WWTP based on levels of PFOS in the biosolids.  The Lapeer WWTP has been approved to land apply their biosolids since 2001.  The Lapeer WWTP  processed accumulated PFOS contaminated solids for disposal at a landfill. 
• On November 28, 2017, LP&P implemented corrective actions to eliminate the discharge of PFOS, including installation of a granular activated carbon treatment system. Process wastewater is now filtered through the treatment system prior to discharge to the sanitary sewer.  LP&P has continually made improvements to their pretreatment system.  Monitoring results indicate that PFOS levels are significantly reduced (ranging from <1.7– 430 ppt over the last few months) in discharges from the facility, although they are not eliminated.  PFOS concentrations in the treated wastewater discharge from the Lapeer WWTP has also decreased significantly (ranging from 8.2-17 ppt over the last several months) since LP&P installed treatment for PFOS. 
• In December 2017, EGLE screened a biosolids land-application site, owned and was frequently used by the City, for the presence of PFOS in the soils.  Results from that screening indicated that further investigation of potential impacts to groundwater and surface waters at the land application site was warranted.
• In May 2018, EGLE conducted additional soil, surface water, and groundwater monitoring at the initial biosolids application site, plus three additional fields.  Final reports of this sampling effort were completed in December 2018 and the results shared with the owners of the fields that were sampled, the City, EGLE, and DHHS.
• On October 9, 2018, LP&P identified and eliminated a potential source of PFOS from their lab.
• On October 10, 2018, the Notice of Termination from the City to LP&P was extended to January 29, 2019.  This action allows LP&P to continue discharging to the Lapeer WWTP if certain conditions are met.  The goal of the order is to reduce PFOS discharges to 12 ppt or less.
• In December 2018, the City conducted follow-up monitoring at the city-owned field.  Monitoring wells, soils, and the drainage swales were re-sampled as part of this effort.
• As of December 2018, biosolids field evaluation reports have been finalized and were sent out to property owners.
• On December 10, 2018, EGLE met with the City and LP&P to review progress on PFOS reductions and to discuss challenges and next steps.
• On January 11, 2018, the City reported that all four of their emergency back-up wells were non-detects for PFAS.  On January 25, 2019, the City, as a result of recent discharge violations, issued a Notice of Noncompliance and Opportunity to Show cause prior to termination of service on January 30, 2019 to LP&P.
• On January 29, 2019, LP&P submitted a written response to the January 25, 2019 Notice.
• On March 1, 2019, LP&P submitted a report of the first sampling event of their STSWCS.  Results showed elevated levels of PFOS and other parameters above criteria coming from roof drains (110 - 76,000 ppt PFOS) and in discharges to surface waters (1,100 ppt PFOS).
• On April 17, 2019, the City issued to LP&P Addendum #6 to the Notice of Termination, extending the potential date of termination due to noncompliance with PFOS concentrations of greater than 12 ppt to October 23, 2019.
• On May 13, 2019, added a section on the MPART webpage about the four biosolids reports.
• Based on information obtained from a consultant conducting storm water analysis at LP&P on May 29th, MDARD collected samples of distilled water sold at a local Lapeer gas station on June 4.  Samples were analyzed for PFAS as well as other potential contaminants and found to be non-detect for all parameters sampled.  The information from the consultant was likely due to cross-contamination during sampling conducted by LP&P’s consultant.
• There are two additional rounds of storm water sampling still to be completed.  Due to sampling issues LP&P requested an extension of the final STSWCS report which will now be submitted in August 2019.
• On August 30, 2019, LP&P submitted the second and third round of sampling results from the Short-Term Storm Water Characterization Study (STSWCS).  It is currently under review by EGLE.
• On September 9, 2019, EGLE staff met with City officials to review progress towards meeting water quality standards at the discharge from the Lapeer WWTP.  

Historical Sampling Chart: data is reflective of criteria prior to 8/3/2020:
PFOS + PFOA Only
This chart reflects data received prior to 8/3/2020.

Type of Sample	Date Sampled	Number of Samples Results	Number of Results Received	Number of Non-detects	Number of Non-detect and standard*	Number > 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.