Michigan has increased efforts to protect its residents from the emerging threat of per- and polyfluoroalkyl substances (PFAS) with a pair of regulatory actions aimed at reducing the presence of these chemicals in the state’s water supply:
Per- and polyfluoroalkyl substances (PFAS) – synthetic organic chemicals manufactured for more than 70 years for their unique inert nature as non-stick coatings, stain and water proofing agents, demisting agents in metal plating operations and as fire-fighting foam – are now recognized as an emerging contaminant with the potential to cause significant human health risks. Because of their inert nature, they resist photolytic, biological and chemical degradation, and therefore are found ubiquitously in the environment.
Following the EPA’s Lead
In 2016 the EPA issued a Lifetime Health Advisory (LHA) for two of the most widely detected PFAS – perfluorooctanoate and perfluorooctane sulfonate – and established an acceptable threshold for these compounds in drinking water at 70 ng/L (nanograms/liter, or parts per trillion).
In the wake of that advisory, the State of Michigan created the Michigan PFAS Action Response Team to research, identify and establish PFAS response actions relative to the discovery, communication and mitigation of PFAS.
By adopting the EPA’s LHA for these contaminants, Michigan may now take regulatory enforcement actions against any responsible party that violates the state’s cleanup rules for these contaminants. These enforcement actions will require a responsible party to conduct activities to address the contamination to reduce risk to human health and the environment.
The Industrial Pretreatment Program
The state’s Industrial Pretreatment Program is designed to assess whether wastewater treatment plants may be violating Michigan’s Rule 57 Water Quality Standards for PFOS and PFOA.
The program requires the following actions be taken by treatment plant operators:
Because current drinking water standards are higher than the imposed discharge standards, some plant operators may show evidence of high PFOS or PFOA in the effluent simply because the community’s water supply in which it serves contains elevated concentrations of PFOS and PFOA.
What This Means
IPP dischargers should review their operation records for evidence of the use of any product containing PFAS or their use in firefighting operations. They should also work with the local treatment plant personnel so they can gather appropriate samples for PFAS analysis.
If you are a significant discharger of PFAS to your wastewater treatment plant, TRC can help you set up a subsequent confirmation sampling program to verify or refute treatment plant sampling results. If verified, TRC can assist with mitigation plans and remedial measures to address PFAS discharges from your facility.