Wastewater Treatment Plants / Industrial Pretreatment Program

The Michigan Department of Environment, Great Lakes, and Energy (EGLE) is responsible for protecting the public health and the environment by regulating discharges of wastewater to Michigan’s surface waters. Anyone discharging wastewater into the surface waters of the state is required by law to obtain a National Pollutant Discharge Elimination System (NPDES) permit. The NPDES program regulates municipalities and industries that discharge directly into lakes and streams by limiting pollutants and requiring other protections. 

EGLE is undertaking several efforts to address PFAS in surface waters, including monitoring municipal and industrial discharges, launching the IPP PFAS Initiative, and monitoring lakes and streams.  As a special effort under the NPDES program, the MDEQ launched the Industrial Pretreatment Program (IPP) Per- and Polyfluoroalkyl Substances (PFAS) Initiative in February 2018.  This initiative aims to reduce and eliminate certain PFAS from industrial sources that may pass through municipal wastewater treatment plants (WWTP) and enter our lakes and streams, potentially causing fish consumption advisories or polluting public drinking water supplies. 

Learn more information about EGLE's PFAS sampling of lakes and streams.

Wastewater Discharged Directly into Lakes and Streams

Updated: October 16, 2019

EGLE’s Water Resources Division (WRD) has added PFAS sampling into routine NPDES permit compliance sampling inspections to further understand the prevalence of PFAS in wastewaters of Michigan.  EGLE has sampled 43 municipal WWTPs and 26 industrial dischargers (industrial sites including airports, landfills, paper plants, and groundwater clean-up sites for other contaminants) since 2017.

Industrial Discharges to Wastewater Treatment Plants

Many industries discharge to municipal WWTPs rather than discharge directly to surface waters.  Municipal WWTPs often regulate their industrial users through an IPP required by their NPDES permit. The IPPs provide the basis for WWTPs to regulate industries so industrial pollutants do not interfere with treatment processes or pass through to our lakes and streams. IPPs may require industries to pretreat wastewater or otherwise reduce or eliminate harmful pollutants. The IPP is a federally-mandated program and a core part of the federal Clean Water Act. For more information about IPP, see Michigan's Industrial Pretreatment Program web page.

For municipal WWTPs, major sources of PFOS and PFOA so far include metal finishers, paper manufacturers, and fabric/leather treaters that have used PFAS-containing chemicals as well as those industrial users (such as landfills and centralized waste treaters) that may have accepted wastes from these sources.  Although chemical manufacturers in the United States voluntarily stopped making PFOS and PFOA years ago, these chemicals may still be manufactured in other countries and imported.  These persistent chemicals may also be found in factories years after they were used.  Sites contaminated by firefighting foams or PFAS-contaminated industrial wastes may also be sources for WWTPs if they discharge to the sanitary sewer.

Unfortunately, conventional WWTP treatment does not effectively remove PFAS if it is discharged to the sewer system by industries or contaminated sites.  Instead, PFAS may be passed through treatment to lakes, streams, and groundwater as well as interfere with management of solids from the treatment process referred to as sludge or biosolids.

Michigan’s Industrial Pretreatment Program (IPP) PFAS Initiative

In order to address the potential that municipal WWTPs could be passing through elevated levels of PFAS through their treatment systems to lakes and streams, EGLE launched the IPP PFAS Initiative in February of 2018.  The IPP PFAS Initiative required all municipal WWTPs with required IPPs (95 statewide) to find out whether they may be passing through PFOS and/or PFOA to surface waters and reduce and eliminate any sources if found.  Under the Initiative, WWTPs were required to:

• Identify industrial users to their system that were potential sources of PFAS.
• Sample probable sources and their WWTP discharge (effluent) if sources were above screening criteria (12 ppt PFOS).
• Require source reductions at confirmed sources.  This is being accomplished through pollutant minimization plans, equipment/tank change out/clean outs, product replacements, and installation of treatment to remove PFAS, specifically PFOS, prior to discharge (pretreatment).
• Monitor compliance of industrial user with local IPP PFAS requirements.
• Submit required reports and monitoring results as required by WRD.

As a part of this effort WRD developed numerous documents including Frequently Asked Questions (FAQ) document, Wastewater PFAS Sampling Guidance, and Recommended PFAS Screening and Evaluation Guidance.  A listing of documents produced or made available through that effort can be found at Michigan.gov/IPP. 

IPP PFAS Initiative Status – February 2018 through August 2019

A little over a year after implementation, significant progress has been made in identifying sources of PFAS, specifically PFOS, to WWTPs and reducing levels released to the environment.  

Some key observations WRD has made to date (October 1, 2019):

• Sixty-eight (68) of 95 of WWTPs with IPPs (or 68%) either have no sources or have sources but have discharges at or less than the PFOS WQS.
• 93 out of 95 WWTPs were able to complete the initial screening of their industrial users within one year of starting the initiative.  Most were able to complete within 6 months. 
• Low levels of PFOS (approxmiately 3 ppt - 7 ppt) were detected in wastewater even when no significant industrial sources were present.  This suggests that background levels of PFAS may be found in most communities. 
• Source reduction efforts have resulted in substantial drops in PFOS concentrations being discharged at the WWTPs. (See Table 1)

**as of October 15, 2019
*Effluent exceeds WQS of 12 ng/L or ppt

Monitoring results, if applicable, are provided for each WWTP that participated in the IPP PFAS Initiative in the interactive map below.  Additional information for each WWTP can be found in WRD’s online permitting and compliance database at Michigan.gov/MiWaters.

Moving forward, WRD has developed a Municipal NPDES Permitting Strategy for PFOS and PFOA.  The goal of the strategy is to continue to identify, reduce, and remove PFOS and PFOA at WWTPs. Read the Municipal NPDES Permitting Strategy for PFOS and PFOA from the WRD.