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Land Application Workgroup

A vibrant green agricultural field with rich brown soil mixed with biosolids

Land Application Workgroup

Mission

To examine the presence and impacts of land application of residuals (biosolids, industrial residuals, and byproducts) containing PFAS 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.

 

Are you a farmer or landowner looking for more information on biosolids?

 

This workgroup, previously known as the Michigan PFAS Action Response Team (MPART) Biosolids Land Application Workgroup, is led by the Department of Environment, Great Lakes, and Energy (EGLE) and consists of representatives from the Michigan Department of Agriculture and Rural Development (MDARD) and Michigan Department of Health and Human Services (MDHHS).

Contact

Stephanie Kammer
Emerging Pollutants Section Manager
Department of Environment, Great Lakes, and Energy (EGLE)

Sydney Ruhala
Emerging Pollutants Section
Department of Environment, Great Lakes, and Energy (EGLE)

Frequently Asked Questions

  • Land Application is the use and/or disposal of 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).

  • 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.

  • Biosolids are the nutrient-rich organic materials resulting from the treatment of domestic sewage in a wastewater treatment plant (WWTP).  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, visit Michigan.gov/Biosolids.

    A large machine resting on dirt and grass, used to inject biosolids underground

    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 can be applied to land.

    For more information on PFAS and biosolids see MPART’s PFAS and Biosolids/Land Application Frequently Asked Questions document.

Recent Accomplishments

  • The Land Application Workgroup formed a Land Application Legacy Site Review Subcommittee to identify, prioritize, and evaluate facilities of most concern that have historically used PFAS in industrial production and may have engaged in land application of residuals (biosolids, industrial residuals, byproducts) to ensure protection of public health and the environment.
    • Conducted surface water sampling in the Menominee and Cedar-Ford Watersheds to assess PFAS impacts from potential land application of paper mill residuals. 
  • Updated EGLE’s Interim Strategy – Land Application of Biosolids Containing PFAS in April 2022
    • 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.
    • Additional information on the Interim Strategy is available on the Michigan Biosolids PFAS webpage.
  • Updated the 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:
  • EGLE completed a second, statewide evaluation of PFAS in WWTP influent, effluent, biosolids/sludge, and groundwater (only at select sites) in 2021, which included 44 WWTPs. This statewide sampling helps expand EGLE’s dataset and allows for evaluation of the effectiveness of industrial source control on reducing PFOS and PFOA at municipal WWTPs since the Industrial Pretreatment Program (IPP) PFAS Initiative was implemented in 2018. A summary report is expected to be published in 2023.  
  • EGLE resampled groundwater monitoring wells at agricultural fields that received biosolids from high priority WWTPs, which were WWTPs known to have industrially impacted biosolids with high concentrations of PFAS. Findings are summarized in Field Report Addendums published in 2023.
  • EGLE conducted a surface water and soil sampling investigation in the Eastern St. Clair County Area of Interest (expanded from the Fort Gratiot Township investigation).

    Next Steps

    • EGLE will continue to implement and update as appropriate the Interim Strategy for Land Application of Biosolids Containing PFAS.
    • Continue efforts to evaluate PFAS in the land application of other (non-biosolids) residuals and industrial byproducts/sludges, including identifying and prioritizing legacy sites.
    • Continue investigations in the Eastern St Clair County Area of Interest, Wixom WWTP Biosolids Fields Area of Interest, and Palo Area of Interest.
    • 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. 
    • EGLE will continue to work with WWTPs to manage industrially impacted biosolids/sludge, including Surface Water Quality Initiatives Fund (SWQIF) grant implementation. 
    • Continue communication efforts between WWTPs, landowners, and farmers on PFAS in biosolids and other beneficially used residuals. 
    • Continue to support USEPA in the development of risk-based standards for PFAS in biosolids. 

    • 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. EGLE hired AECOM Technical Services Inc. to investigate PFAS issues related to Lapeer's biosolids in late 2017/early 2018.

      Reports (linked above) 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, EGLE conducted a review of available research to better understand how common PFAS might be in biosolids.

      A tractor hauling a bright red tank through a farm field applying biosolids
      • EGLE expanded the Lapeer Biosolids PFAS Investigation to a Statewide WWTP and Biosolids/Sludge 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 2018 Statewide WWTP and Biosolids/Sludge 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.
      • 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 2018 Statewide WWTP and Biosolids/Sludge 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 Application Workgroup 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 Northeast Biosolids & Residuals Association.
        • EGLE conducted residential well sampling and installed/sampled shallow groundwater monitoring wells for PFAS around biosolids land application sites in the Palo Area of Interest 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.
      A large yellow tanker driving through a farm field applying biosolids
      • 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 the Eastern St. Clair County Area of Interest and associated source tracking efforts. Investigated historical (1980-2000) biosolids land application. EGLE conducted soils, surface water, and residential well sampling.  The report is expected to be released in 2020. Results are published in the Port Huron WWTP (Fort Gratiot) Field Report (linked above). 
      • Investigated biosolids land application sites that historically received industrially impacted biosolids from the Wixom WWTP. Conducted soils, surface water, groundwater, plant tissue, manure, beef, and residential well sampling within the Wixom WWTP Biosolids Fields Area of Interest.  

      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.

    • 2017

      • 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 - visit Lapeer Plating & Plastics (LP&P).
        • September 2017 - Sampling of Lapeer WWTP biosolids led to designation of industrially impacted biosolids and suspending the city's land application.  Worked with the city and LP&P to find suitable disposal options.
        • December 2017 - EGLE conducted first round of soil sampling from City of Lapeer land application site.

      2018

      • April/May 2018 - EGLE installed permanent monitoring wells at the city owned Lapeer land application site. Soils/Surface Water/Groundwater samples collected.  Monitoring wells surveyed, and groundwater samples collected.
      • 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 Land Application Workgroup
      • July 23, 2018 - MDHHS conducted literature search and prepared draft background in PFAS document.
      • November 2018 - EGLE initiated statewide WWTP and Biosolids/Sludge PFAS Study.
      • December 20, 2018 and October 7, 2019 - Conducted Biosolids Stakeholders Meetings.

      2019

      • SWQIF-SPHRP Grants
        • September/December 2019 - EGLE met with and advised representatives of the Cities of Bronson, Lapeer, Ionia, and Wixom on submission of a SWQIF-SPHRP grant to assist in addressing 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 Township investigation and field sampling (site now called the Eastern St. Clair County Area of Interest)

      2020

      2021

      • February - September 2021 - EGLE sampled additional residential wells in the Palo Area of Interest.
      • 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:  Initiatives to Evaluate the Presence of PFAS in Municipal Wastewater and Associated Residuals (Sludge/Biosolids) in Michigan. Report link provided above. 
      • April 2021 - Residual Management Plan PFAS Modification Letters were sent to all WWTPs by EGLE.
      • 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 - EGLE completed surface water sampling investigation in the Eastern St. Clair County Area of Interest.
      • July 2021 - EGLE's Interim Strategy - Land Application of Biosolids Containing PFAS in effect as of July 1, 2021.
      • September - November 2021 - EGLE installed/sampled shallow groundwater monitoring wells for PFAS around biosolids land application sites in the Palo Area of Interest. 
      • November 2021 - EGLE initiated second Statewide WWTP and Biosolids/Sludge PFAS Study which evaluated PFAS in influent, effluent, biosolids/sludge and groundwater (only at select sites) at 44 WWTPs. Report expected to be published in 2023. 

      2022

      • March 2021 – April 2022 – EGLE resampled groundwater monitoring wells at agricultural fields that received biosolids from high priority WWTPs, which were WWTPs known to have industrially impacted biosolids with high concentrations of PFAS. Findings are summarized in Field Report Addendums linked above. 
      • April 2022 - EGLE updated the Interim Strategy – Land Application of Biosolids Containing PFAS. The updated Interim Strategy includes a lowered industrially impacted threshold, and clarification on sample requirements.
      • April – November 2022 – EGLE sampled additional residential wells in the Palo Area of Interest.
      • April 2019 - May 2022 – Investigated biosolids land application sites that historically received industrially impacted biosolids from the Wixom WWTP. Conducted soils, surface water, groundwater, plant tissue, manure, beef, and residential well sampling within the Wixom WWTP Biosolids Fields Area of Interest. 

        2023

        • March 2023 – EGLE sampled additional residential wells in the Palo Area of Interest.
        • April 2023 – EGLE completed a surface water and soil sampling investigation in the Eastern St Clair County Area of Interest.
        • July 2023 – EGLE completed a surface water sampling investigation in the Menominee and Cedar-Ford Watersheds.