Land Application Workgroup
The mission of the PFAS Land Application Work Group is to examine the presence and impacts of land application of residuals (biosolids, industrial residuals, and byproducts) containing PFAS compounds including:
- Continue to implement source control strategies where applicable.
- Mitigate public health and environmental risks of future land application of residuals.
- Investigate past land applications when concentrations of PFOS, PFOA and other compounds of concern may have been applied at higher rates prior to their phase out.
- Support EPA and other entities efforts to develop risk-based criteria for land application of residuals containing PFAS.
This workgroup, previously known as the MPART Biosolids Land Application Workgroup, is led by the Department of Environment, Great Lakes, and Energy (EGLE) and consists of representatives from Michigan Department of Agriculture and Rural Development (MDARD) and Michigan Department of Health and Human Services (MDHHS).
What is Land Application? | What are the Beneficial Use Provisions? | What are Biosolids?
Recent Accomplishments | Past Accomplishments and Background | Next Steps | Research/Studies and Reports | Timeline of Accomplishments
What is Land Application?
Land Application is the use and/or disposal of treated wastewater, industrial residuals/byproducts, biosolids, agricultural waste, and septage. Land application is completed by spreading, injecting, incorporating, or spraying the materials on or into agricultural fields. The land application of some materials is made possible by the Beneficial Use Provisions of Part 115, Solid Waste Management, of the Natural Resources and Environmental Protection Act of 1994 (Part 115).
What are the Beneficial Use Provsions?
The State of Michigan signed into law several amendments affecting the original beneficial reuse legislation contained in Part 115. Under these amendments, the land application of certain materials is overseen by MDARD as fertilizers or soil conditioners, while other materials continue to be land applied under Part 115.
What are Biosolids?
Biosolids are the nutrient-rich organic materials resulting from the treatment of domestic sewage in a wastewater treatment plant (WWTP) (visit our FAQ). Biosolids contain essential plant nutrients and organic matter. When treated and processed, biosolids can be recycled and applied to crops to improve and maintain productive soils and stimulate plant growth. For more information on biosolids, go to EGLE's Water Resources Division (WRD) Biosolids Program Web Page: Michigan.gov/Biosolids.
In Michigan, biosolids are beneficially used under requirements set forth in Michigan's Part 24 Administrative Rules, Land Application of Biosolids, promulgated under Part 31, Water Resources Protection, of the Natural Resources and Environmental Protection Act,
1994 PA 451, as amended; and the federal requirements contained in Title 40 of the Code of Federal Regulations, Part 503, Standards for the Use or Disposal of Sewage Sludge. Under these laws, biosolids must meet strict standards, including the amount of metals and pathogens they contain, and where and how they can be applied to land.
In contrast, sludge from WWTPs that does not need to meet these quality standards is typically disposed in a landfill or incinerated. Sludges from industrial processes and residential septic systems are not considered "biosolids" but under certain circumstances these wastes can be applied to land.
For more information on PFAS and biosolids see MPART's Frequently Asked Questions document.
- Interim Strategy - Land Application of Biosolids Containing PFAS (March 2021)
- EGLE announced the Interim Strategy - Land Application of Biosolids Containing PFAS at the Michigan Water Environment Association (MWEA) Annual Conference on March 30, 2021.
- The Interim Strategy includes requirements to guide WWTPs and landowners/farmers who make decisions on land applying biosolids with detectable concentrations of PFAS. The strategy requires WWTPs with a Residual Management Plan (RMP) planning to land apply biosolids on or after July 1, 2021 to sample for PFAS.
- The following documents describe the strategy and requirements in more detail:
- The Biosolids and Sludge PFAS Sampling Guidance can be found here: Biosolids and Sludge PFAS Sampling Guidance (michigan.gov).
- Developed tools for WWTPs and contractors for communicating with landowners and farmers on PFAS in biosolids and other beneficially used residuals. The following documents provide additional information for farmers and landowners:
- Completed the final detailed report covering the IPP PFAS Initiative and the Statewide Study of 42 municipal WWTPs, found here: Evaluation of PFAS in Influent, Effluent and Residuals of Wastewater Treatment Plants (WWTPs) in Michigan. For a summary of the study and the initial findings of the IPP PFAS Initiative, see the Summary Report: PFAS in Municipal Wastewater and Associated Residuals (Sludge/Biosolids).
- For a summary of the land application site screening results, see Statewide Wastewater Treatment Plant and Biosolids PFAS Study: Field Reports Summary.
- The Land Application Workgroup formed 2 subcommittees to continue obtaining and sharing new information. These subcommittees include the Land Application Legacy Site Review Subcommittee and the Land Application Frequently Asked Questions Subcommittee.
Past Accomplishments and Background:
After the Lapeer WWTP was found to be a significant source of PFAS contamination to the Flint River, tests revealed that Lapeer's sludge contained high levels of PFOS. In response, EGLE prohibited the sludge from being spread on land. MPART hired AECOM Technical Services Inc. to investigate PFAS issues related to Lapeer's Biosolids in late 2017/early 2018.
Reports from the Lapeer Biosolids PFAS Investigation were finalized and posted on the MPART website in late 2018. Following this investigation and the Michigan IPP PFAS Initiative, the Land Application Workgroup conducted a review of available research to better understand how common PFAS might be in biosolids.
The Land Application Workgroup expanded the Lapeer Biosolids PFAS Investigation to a Statewide Biosolids and WWTP PFAS Study. The study was completed to further our knowledge on the prevalence of PFAS in municipal WWTP effluents (the outflow of treated water) in Michigan and to evaluate what happens to PFAS in biosolids that are spread on land.
- The Statewide Biosolids and WWTP PFAS Study achieved the following:
- Developed a detailed sampling work plan to identify and prioritize facilities to be investigated, which included surveying each facility on treatment process and selecting sample locations.
- Collected samples of effluent, influent, and biosolids/sludge from the high priority WWTPs across Michigan and gathered detailed wastewater treatment process information from each WWTP based on the work plan.
- Developed the EGLE Biosolids Site Selection Procedure to prioritize sites and identify those most in need of further investigation.
- Collected samples of soil, surface water, tile drain water, and groundwater from agricultural fields that received biosolids from high priority WWTPs, which were WWTPs known to have industrially impacted biosolids with high concentrations of PFAS.
- Collected soil and surface water samples from agricultural fields that were expected to have a "typical" amount of PFAS in the biosolids. These fields served as a comparison group for the highly impacted biosolids at other fields.
- Collected crop samples from the Lapeer field that received biosolids impacted by PFAS.
- Re-sampled permanent monitoring wells installed at the Lapeer field the previous spring.
- Evaluated and selected a PFAS fate and transport model based on Michigan data and conditions. See Report - Review of Available Software for PFAS Modeling Within the Vadose Zone.
- Conducted the modeling to evaluate the potential for PFOS/PFOA migration from Michigan biosolids land application sites. Numerical Modeling of PFOS and PFOA Migration Through the Vadose Zone Following Land Application of Municipal Biosolids. Expected release in 2020.
- The Land Application Workgroup also completed the following activities:
- Refined procedures and processes developed under the Lapeer investigation and included lessons learned from planning the Statewide Biosolids and Municipal WWTP PFAS Study.
- Developed partnerships between EGLE, MDHHS, MDARD, and the agricultural community that allowed work on this issue to continue in a systematic and scientifically based way. Hosted stakeholder meetings attended by a cross section of the agricultural and wastewater treatment communities involved in biosolids land application.
- Integrated Land ApplicationWorkgroup efforts with those of the Wastewater, Surface Water, and Treatment Technology Workgroups while continuing involvement with groups such as the Michigan Water Environment Association - Biosolids and PFAS Committees, Michigan Rural Water Association, Michigan Waste and Recycling Association, Farm Bureau, and the North East Biosolids & Residuals Association.
- Conducted residential well sampling around biosolids land application sites in the Palo area in Ionia County and held public meetings on the situation.
- Participated in discussions with United States Environmental Protection Agency (USEPA) staff and various State of Michigan Departments and Divisions about investigating non-biosolid sludge applied to land.
- EGLE's Water Resources Division identified potential grant opportunities under the Surface Water Quality Initiatives Fund (SWQIF) - Substantial Public Health Risk Projects (SPHRP) Grant Program to assist WWTPs dealing with industrially impacted biosolids.
- The SWQIF-SPHRP Grant Program was amended to include eligibility criteria for grant funding for PFAS in biosolids projects.
- Participated in the investigation of elevated levels of PFOS in surface waters in and around Fort Gratiot Township and associated source tracking efforts. Investigated historical (1980-2000) biosolids land application. Conducted soils, surface water, and residential well sampling. The report is expected to be released in 2020.
- Collected plant tissue samples for PFAS analysis from several types of crops grown from a historic land application site suspected of having received multiple applications of industrially impacted biosolids from Wixom WWTP.
- The results of the investigations can be found in the Summary Report: PFAS Initiatives to Evaluate the Presence of PFAS in Municipal Wastewater and Associated Residuals (Sludge/Biosolids) in Michigan which details efforts of both the Wastewater Workgroup and the Land Application Workgroup.
- Overall, the MPART Land Application Workgroup has identified gaps in our data and knowledge about the impact of PFAS containing biosolids and we have worked to summarize and disseminate the results of our work on these topics to the public.
- Continue investigations in Fort Gratiot Township and Palo areas.
- Implement EPA multi-use grant which includes tasks to further evaluate PFAS in wastewater solids/sludge and associated biosolids.
- Continue to engage States in the upper mid-west to evaluate needs of the wastewater industry facing challenges finding suitable long-term sustainable options for disposal of WWTP solids. Establishing resiliency in disposal alternatives on a regional basis is critical to ensuring WWTPs continue providing the highest level of treatment for municipal wastewater.
- Continue work with WWTPs to manage industrially impacted biosolids/sludge, including SWQIF grant implementation.
- Continue communication efforts between WWTPs, landowners, and farmers on PFAS in biosolids and other beneficially used residuals. Develop tools for WWTPs and contractors for communicating with landowners and farmers on PFAS in biosolids and other beneficially used residuals.
- Continue to support USEPA in the development of a risk-based standard for PFAS in biosolids.
Research/Studies and Reports:
Timeline of Accomplishments:
- July 2017 - Point source monitoring for PFAS was conducted at three municipal WWTPs that discharge to the Flint River. This effort led to the identification of an industrial facility discharging to one of the WWTPs as a significant source of PFAS to the river.
- Lapeer - See the MPART Lapeer Plating & Plastics (LP&P) Web page.
- September 2017 - Sampling of Lapeer Biosolids led to designation as industrially impacted biosolids suspending land application. Worked with the City and LPP to find suitable disposal options.
- December 2017 - EGLE conducted first round of soil sampling from City of Lapeer land application site.
- April/May 2018 - Permanent monitoring wells (city owned site) installed. Soils/Surface Water/Groundwater samples collected. Monitoring wells surveyed, and groundwater samples collected (city owned site).
- May 2018 - Notification and meetings with farmers by MDARD and EGLE.
- May 16, 2018 - Finalized Lapeer WWTP - Lapeer Plating & Plastics PFAS Briefing and Communications Plan.
- July 13, 2018 - Formation of MPART Biosolids Workgroup
- July 23, 2018 - MDHHS conducted literature search and prepared draft background in PFAS document.
- December 20, 2018 and October 7, 2019 - Conducted Biosolids Stakeholders Meetings.
- November 2018 - Initiated statewide WWTP and Biosolids/Sludge Study.
- SWQIF-SPHRP Grants
- September/December 2019 - EGLE met with and advised representatives of the City of Bronson, City of Lapeer, City of Ionia, and the City of Wixom on submission of a SWQIF-SPHRP grant to assist in dealing with industrially impacted biosolids.
- October 2019 - City of Bronson was awarded a grant of $39,153.40.
- April 2020 - City of Lapeer submitted a revised application in April 2020. Revised grant application is currently being reviewed.
- January 2020 - City of Wixom submitted a grant application. As of May 2020, the grant agreement is being finalized to award the City of Wixom $350,000 under the program.
- October 2019 - Finalized Biosolids and Sludge PFAS Sampling Guidance Document.
- December 18, 2019 - Conducted Fort Gratiot Department of Attorney General site Investigation / Field Sampling.
- July 2019 - July 2020 - Conducted Palo Area sampling / residential well investigations.
- January 6, 2020 - Evaluate and select a PFAS fate and transport model and performed modeling based on Michigan data and conditions. Review of Available Software for PFAS Modeling Within the Vadose Zone
- March 2021 - EGLE announced the Interim Strategy - Land Application of Biosolids Containing PFAS at the Michigan Water Environment Association (MWEA) Annual Conference
- April 2021 - Final Summary Report: PFAS Initiatives to Evaluate the Presence of PFAS in Municipal Wastewater and Associated Residuals (Sludge/Biosolids) in Michigan.
- April 2021 - Residual Management Plan PFAS Modification Letters were sent to all WWTPs.
- April 2021 - MPART Land Application Workgroup Stakeholder Meeting held to discuss the newly implemented Biosolids Interim Strategy.
- May 2021 - Public Webinar held: Biosolids with PFAS - An Interim Strategy: What you need to Know About Sampling and Reporting.
- May 2021 - Completed surface water sampling investigation in Fort Gratiot.
- July 2021 - Interim Strategy - Land Application of Biosolids Containing PFAS in effect as of July 1, 2021.
Contact Information - Workgroup Leads
Jon Russell, Field Operations Manager-Lakes Erie and Huron
Water Resources Division
Stephanie Kammer, Emerging Pollutants Section Manager
Water Resources Division