Major sources of PFAS come from industries that have used PFAS-containing chemicals (such as chrome platers and paper manufacturers) and industrial users that may have accepted wastes from industries that used PFAS-containing chemicals in their processes and/or products (such as landfills and centralized waste treaters).  Although chemical manufacturers in the United States voluntarily stopped making PFOS and PFOA years ago, these persistent chemicals can be found in factories decades after they were used.  Sites contaminated by firefighting foams or PFAS-contaminated industrial wastes have also been found to be sources for municipal WWTPs when those sites discharge to the sanitary sewer.

Unfortunately, conventional WWTP treatment does not effectively remove PFAS if it is discharged into the sewer system.  Instead, PFAS may be passed through treatment to lakes, rivers, streams, and groundwater, as well as interfere with management of solids from the treatment process referred to as sludge or biosolids, dependent on the disposal method. WWTPs are therefore a critical control point in reducing the discharge of PFAS into the environment. EGLE launched the IPP PFAS Initiative in February 2018. 

EGLE developed a Municipal NPDES Permitting Strategy for PFAS.  The goal of the strategy is to continue to identify, reduce, and remove PFAS at municipal WWTPs with NPDES permits. EGLE also developed the Compliance Strategy for Addressing PFAS from Public and Private Municipal Groundwater Discharges. The goal of the strategy is to evaluate, prioritize, and reduce or eliminate PFAS at public and private municipal WWTPs with Groundwater Discharge permits to ensure protection of public health and groundwaters used for drinking water.

The information gained by the IPP PFAS Initiative was used to develop the Interim Strategy – Land Application of Biosolids Containing PFAS. The goals of the strategy are to prohibit land application of industrially impacted biosolids; reduce PFAS concentrations in biosolids while meeting Water Quality Values for WWTP effluent through source identification and reduction efforts; mitigate risks moving forward; inform landowners, farmers, and WWTPs about PFAS while empowering landowners and farmers to make informed decisions on biosolids. 

Industrial discharges to groundwater

Some industrial and commercial facilities can obtain a Groundwater Discharge Permit to discharge process wastewater directly to groundwater. This includes but is not limited to vehicle wash water, laundromat wastewater, carpet cleaning wastewater, non-contact cooling water, food processing wastewater, and hydrostatic test water.  To address PFAS in these discharges, EGLE is working to expand the Compliance Strategy for Addressing PFAS in Public and Private Municipal Groundwater Discharges to include industrial discharges. EGLE’s goal in expanding the strategy is to evaluate, prioritize, and reduce or eliminate PFAS at industrial facilities with Groundwater Discharge permits to ensure protection of public health and groundwaters used for drinking water. 

Industrial discharges to surface water

Some industrial facilities discharge process wastewater directly to surface waters (or  via separate storm sewer systems) and are known as industrial direct discharges.   These facilities obtain individual NPDES discharge permits or certificates of coverage under general permits to discharge various types of wastewater. This includes but is not limited to industrial process wastewater, non-contact cooling water, hydrostatic pressure test water, fire suppression system test water, groundwater intrusion, contaminated groundwaters, and industrial stormwater. 

Industrial facilities that only discharge stormwater, are called industrial stormwater facilities and obtain certificates of coverage under a general NPDES permit to discharge stormwater associated with industrial activity that meets permit conditions to surface waters of the state. 

These wastewaters and stormwaters may contain or become contaminated with PFAS, which is then released to the environment through these discharges as shown in the PFAS From Industrial Direct and Industrial Stormwater Discharges diagram below.