To investigate sources of Per- and Polyfluoroalkyl Substances (PFAS) in wastewater that discharge to surface water (e.g., lakes, rivers, streams, etc.) or groundwater and implement source control through existing regulatory programs.
The Wastewater Workgroup includes staff from the Michigan Department of Environment, Great Lakes, and Energy (EGLE), Water Resources Division (WRD), Emerging Pollutants Section, Field Operations Section, Industrial Pretreatment Program (IPP), Point Source Monitoring Program, Permit Section, Surface Water Assessment Section, and Biosolids Program.
- The Wastewater Workgroup has worked diligently to identify and control sources of PFAS, primarily perfluorooctanesulfonic acid (PFOS), being discharged to groundwater and surface waters of the State of Michigan.
- Source Tracking: The Wastewater Workgroup conducted sampling of municipal and industrial discharges to rivers, lakes, streams, and groundwater as part of PFOS source tracking efforts. These efforts led to identification and implementation of source control measures at permitted discharges that were determined to be significant sources in several watersheds. These activities occurred/are occurring in the following areas:
- Municipal Wastewater: The Wastewater Workgroup identified municipal Wastewater Treatment Plants (WWTPs) that receive wastewater from industrial facilities as a potential significant source of PFAS to surface waters. As a result, the Wastewater Workgroup developed and implemented the IPP PFAS Initiative in 2018. This initiative required 95 municipal WWTPs with IPPs to identify and control significant sources of PFOS to their system. To date, implementation of the Initiative has resulted in significant decreases of pollutants passing through WWTPs and entering the environment. Learn more about the IPP initiative.
A person collecting a water sample from a pipe using a dipper.
- Municipal NPDES Permitting Strategy: The Wastewater Workgroup developed a Municipal National Pollutant Discharge Elimination System (NPDES) permitting strategy for PFOS and perfluorooctanoic acid (PFOA). The goal of the strategy is to continue to identify, reduce, and remove PFOS and PFOA at WWTPs. See the Municipal NPDES Permitting Strategy for PFOS and PFOA for more information.
- Point Source Monitoring: Since 2017, the Wastewater Workgroup has collected over 186 samples for PFAS analysis from permitted (and unpermitted) discharges from both municipal and industrial facilities. Sampling occurs at permitted facilities in response to source tracking efforts or in response to specific concerns/knowledge about PFAS use at the facility. In addition, PFAS analysis has been added to routine compliance sampling inspections for permitted facilities that have been determined to be a potential source of PFAS. Moving forward, non-municipal wastewater NPDES dischargers that are found to be discharging PFOS and/or PFOA above water quality values will be initially regulated through Administrative Consent Orders (ACOs) and then through NPDES permits as they are reissued. The first such ACO became effective March 16, 2020. These efforts, in combination with other effluent sampling conducted as part of a study by the Land Application Workgroup, have helped narrow the focus on sources of PFAS to surface waters and understand the prevalence of PFAS (specifically, PFOS) in WWTP discharges.
The above images depict EGLE staff getting ready to and sampling a roadside manhole as part of an inspection.
- 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 (mainly chrome platers and airports) and where elevated concentrations of PFOS 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 initial sampling shows results over water quality values, then the facility will be required to take appropriate actions to reduce their discharge.
Two people conducting an industrial storm water inspection; looking at an outdoor pumping system.
- Industrial Direct Discharger and Industrial Storm Water Compliance Strategy: The Wastewater Workgroup developed a compliance strategy for addressing PFOS and PFOA discharges from industrial direct and industrial storm water discharges. The goal of the strategy is to reduce or eliminate PFOS and PFOA from industrial facilities holding NPDES and Groundwater Discharge permits to meet applicable criteria. See the Compliance Strategy for Addressing PFOS and PFOA from Industrial Direct and Industrial Storm Water Discharges for more information.
As we move forward, more time will be devoted to both direct dischargers and permit development efforts, while the core IPP and point source monitoring efforts continue. This workgroup will:
- Continue implementation of the IPP PFAS Initiative to identify and control sources in municipal WWTPs.
- Assist WWTPs to institute pollution minimization/treatment strategies (PMPs) and sewer use ordinances (SUO) for PFOS and PFOA. The SUO provides the legal authority for the PMPs.
- Evaluate other NPDES and Groundwater permittees that were not included in the IPP PFAS Initiative to identify and control discharges of PFAS to surface waters and groundwater. These include industrial direct dischargers and other WWTPs that do not have IPP requirements, as well as industrial storm water dischargers.
- Incorporate monitoring in NPDES permits and ultimately (towards the end of the five ‑year span) institute PFAS effluent limits for those that need to install treatment or other controls.
Research/Studies and Reports:
- Michigan Chrome Plater Fume Suppressant Study: The Wastewater Workgroup partnered with the United States Environmental Protection Agency (EPA), Office of Research and Development (ORD), National Exposure Research Laboratory to answer the question of whether current PFOS "replacement" products being used at chrome plating facilities were contributing to elevated PFOS in discharges from those facilities. As part of this effort, EGLE sampled 11 chrome platers (effluent and fume suppressants) in July 2019. The Wastewater Workgroup will share results to assist industry with decisions on product use, clean up, and treatment. Read the report, "Targeted and Nontargeted Analysis of PFAS in Fume Suppressant Products at Chrome Plating Facilities".
- Municipal Wastewater and Biosolids/Sludge Study: The Wastewater Workgroup along with the Land Application Workgroup contracted with consulting firm, AECOM Technical Services, Inc. (AECOM), to conduct a study in the fall of 2018 of 42 municipal WWTPs to evaluate the presence of PFAS in influents, effluents, and associated residuals (sludge/biosolids) generated at the facilities. As part of this initiative, screening of 29 land application sites was conducted to further understanding of the potential impacts to the environment from land-applied biosolids. Samples were analyzed for up to 28 PFAS compounds. For a summary of the study and initial findings of the IPP PFAS Initiative, see the Summary Report: PFAS in Municipal and Associated Residuals (Sludge/Biosolids). For the complete detailed report covering the IPP PFAS Initiative and the Statewide Study of 42 municipal WWTPs, see Evaluation of PFAS in Influent, Effluent, and Residuals of Wastewater Treatment Plants (WWTPs in Michigan.
- Industrial Sources of PFOS to Municipal Wastewater Treatment Plants: The Wastewater Workgroup reviewed the data collected from the IPP PFAS Initiative and found that the majority of significant PFOS sources to WWTPs were landfills that accepted industrial wastes containing PFOS, metal finishers with a history of fume suppressant use, and contaminated sites associated with industries or activities with PFOS usage. Other sources found included centralized waste treaters (CWT), paper manufacturing/packaging, commercial industrial laundries, chemical manufacturers, and sewers contaminated with aqueous film forming foam (AFFF). To read the full report, see the Source Report: Identified Industrial Sources of PFOS to Municipal Wastewater Treatment Plants (Report).
There is still a lot of work to be done on all fronts to control and identify sources and identify treatment/reduction strategies for all types of wastewater, including leachate from landfills. A better understanding of mass loading and potential breakdown of PFAS through various treatment processes at municipal WWTPs is important to aide municipalities and industries as they develop PFAS reduction strategies.
Timeline of Accomplishments:
- May 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. See the Lapeer Plating & Plastics Site Page.
- November 21, 2017: Met with the EPA and the National Association of Surface Finishing (NASF), an important stakeholder group, as part of outreach efforts to discuss PFAS issues with the metal finishing industry.
- January 8, 2018: Met with the EPA and NASF as part of outreach efforts to discuss PFAS issues with the metal finishing industry.
- February 1, 2018: Presented to the Michigan Municipal Executives on the upcoming launch of the IPP PFAS Initiative.
- February 20, 2018: IPP PFAS Initiative was launched:
- February 2018 - present: Workgroup members attend regularly scheduled meetings with various stakeholder groups, such as the Michigan Manufacturers Association (MMA) and the Michigan Water Environment Association (MWEA), to update them on our PFAS in wastewater efforts.
- March 23, 2018: Met with the EPA and NASF as part of outreach efforts to discuss PFAS issues with the metal finishing industry.
- September 14, 2018: Presented at the Michigan Chapter of NASF conference on the IPP PFAS Initiative.
- October 10, 2018: Presented to the Association of Clean Water Administrators (ACWA) Pretreatment Workgroup on the IPP PFAS Initiative.
- October 11, 2018: Developed Wastewater PFAS Sampling Guidance.
- October - November 2018: Materials Management Division/Michigan Waste & Recycling Association (MWRA) Landfill Leachate Study.
- October 29 - November 20, 2018: Conducted statewide WWTP and Biosolids/Sludge Study.
- March 5, 2019: EGLE met with MWRA to discuss results of the Landfill Leachate Study.
- July 22 and 23, 2019: EGLE sampling for Fume Suppressant Study with the EPA, ORD.
- September 2019: Developed the Municipal NPDES Permitting Strategy for PFOS and PFOA.
- October 17, 2019: Launch of the Michigan IPP WWTP PFAS Status interactive map on the Michigan PFAS Action Response Team Wastewater Treatment Plants/Industrial Pretreatment Program website.
- March 16, 2020: First ACO regulating PFOS/PFOA from a point source became effective.
- May 13, 2020: Presented to the National Association of Clean Water Agencies (NACWA) National Pretreatment Virtual Event on the IPP PFAS Initiative.
- June 2020: Release of the Summary Report, "PFAS Initiatives to Evaluate the Presence of PFAS in Municipal Wastewater and Associated Residuals (Sludge/Biosolids) in Michigan."
- June 2020: Release of the Michigan Chrome Plater Fume Suppressant Study report, "Targeted and Nontargeted Analysis of PFAS in Fume Suppressant Products at Chrome Plating Facilities."
- August 2020: Release of Source Report: "Identified Industrial Sources of PFOS to Municipal Wastewater Treatment Plants."
- April 2021: Release of the detailed report, "Evaluation of PFAS in Influent, Effluent, Residuals of Wastewater Treatment Plants (WWTPs) in Michigan."
- October - November 2021: Conducted a statewide study of 44 WWTPs to evaluate the presence of PFAS in influents, effluents, and associated residuals (sludge/biosolids) generated at the facilities. This study was an expansion of the 2018 Statewide WWTP and Biosolids/Sludge Study. The 2021 study included:
- Resampling of 23 municipal WWTPs for PFAS from the 2018 study to fill data gaps and evaluate the effectiveness of industrial source control.
- Sampling of 9 municipal non-IPP WWTPs for PFAS to expand Michigan's dataset and compare against the IPP WWTPs data.
- Sampling of 5 municipal WWTPs and 7 industrial facilities (i.e., laundromats, vehicle washwater sites, school) with regulated groundwater discharges for PFAS to increase understanding of the presence of PFAS from these discharges and assist with prioritizing and planning future efforts to address discharges that may exceed criteria.
Wastewater Workgroup Lead Name and Email:
Emerging Pollutants Section Manager, WRD
Webpage updated: November 29, 2021