WRD PFAS Related Actions Fish Contaminant Monitoring Program Surface Water Sampling Point Source Monitoring Industrial Pretreatment Program (IPP) PFAS Initiative MPART Technical Workgroups with WRD Lead

Surface Water Wastewater Biosolids Treatment Technology

Source Tracking

PFAS in wastewater

PFOS is contaminant of concern. No exceedances of WQS from PFOA in wastewater identified to date

Potentially found in wastewater from: Platers: Chemical fume suppressants, demisters, defoamers, wetting agents, surfactants Leather and fabric treaters, tanneries Paper and packaging manufacturers Manufacturers of parts with PTFE coatings (bearings, wire, etc.) Landfills (leachate) Centralized waste treaters AFFF fire fighting foam Groundwater cleanup sites (cleaners, former plating and automotive manufacturing, etc.)

Point Source Monitoring

WRD # of wastewater discharges authorized ~6,541 (all NPDES permits) There were 40 PFAS sampling events in 2017 and 2018 as of

September 27, 2018; 13 in 2017 and 27 in 2018 Incorporate PFAS monitoring into regular Compliance Sampling

Inspections (CSI) In 2018 there were 10 facilities that were tested for PFAS during CSIs

Prioritize sampling of point sources based on fish tissue and surface water data (source tracking) and those with high potential for PFAS use (historical and/or current); 17 of the 27 sampling events in 2018 were in response to source tracking and high potential for PFAS

Industrial Pretreatment Program (IPP) PFAS Initiative• Conventional wastewater treatment processes are not

effective in the removal of PFAS• Pass thru to waters of the state• Concentrate in sludge/biosolids?

• Goal of IPP PFAS Initiative• Identify Industrial Users (IU) that use/have used

PFOS/PFOA and are discharging elevated levels to POTW• Identify POTW effluents > WQS• Reduce/eliminate/control PFOS/PFOA discharges

from IUs and ultimately to waters of the state

Industrial Pretreatment Program (IPP) PFAS Initiative February 2018 – Required PFAS screening at 93 Publicly Owned

Treatment Works (POTW) with IPPs Survey Industrial Users with potential sources of PFAS Follow-up sampling of probable sources Sample POTW effluent if sources above screening criteria (12 ppt PFOS) Interim Reports were due June 29, 2018, unless extension requested

35 extension requests Summary Reports due October 26, 2018, unless extension requested

Additional information on IPP PFAS Initiative:https://www.michigan.gov/pfasresponse/0,9038,7-365-86510---,00.html

93 POTWs with IPPsIPP PFAS Interim Reports:• 85 Reports Submitted• 1 Report Outstanding• 7 Extensions

Bin 2: 10Sources found but

POTW Effluent ≤WQS1

Bin 1: 19No sources

PFOS/PFOA found

Bin 3: 18Sources found and

POTW Effluent >WQS

IPP PFAS Requirements Complete

• Source reduction recommended• Semi-annual PFAS monitoring required• Local limits and PMP recommended

3a: 12Effluent conc. of moderate priority (≤49 ppt)• Source reduction required• Quarterly POTW effluent monitoring required• Local limits recommended• Pollutant Min Plan SUO provisions

recommended

3b: 6Effluent conc. at highest priority (≥50 ppt) • Source reduction required• Monthly POTW effluent monitoring required• Biosolids monitoring required• Local limits recommended• Pollutant Min Plan SUO provisions

recommended

IPP PFAS Initiative Status Update 9-20-2018

Bin TBD: 38Interim Report submitted but a bin determination cannot be made as staff have not yet reviewed the report, the report was determined to be incomplete, or sample results (from IUs and/or POTW effluent) are still pending

Tracking Huron River Case Study• Multi-media approach

o Drinking Water Monitoringo Fish Tissue Analysiso Surface Water Samplingo Industrial Pretreatment

Program PFAS Initiativeo Point Source Monitoringo Potential Site Inspections

and Evaluations• Iterative process, follow the

data

2014 - 2018 Drinking Water• Drinking water source for the

City of Ann Arbor• Ann Arbor sampled for PFAS

compounds in finished drinking water and raw river water

• PFAS compounds detected• All drinking water samples

< 70 ppt PFOA/PFOS combined EPA health advisory level

• River samples > WQS of 11 ppt PFOS

2018 Fish Tissue• Due to elevated PFOS detected

in the river by Ann Arbor, frozen and freshly collected fish provided to DHHS for PFAS analysis

• Results received August 3, 2018• Highly elevated levels in fish

tissue in Kent Lake, Baseline Lake, and Argo Pond

• DHHS issued Do Not Eat fish advisory

2018 Surface Water Sampling• Identify PFOS levels in Huron

River; identify potential source areas

• Results received August 23, 2018

• Priority Source Area - Norton Creek (5,500 ppt PFOS)

• One known source – Wixom WWTP

Huron River Surface Water SamplingJuly 24, 2018

PFOS Concentration Range (ng/L)

Wixom WWTP – IPP PFAS Initiative City of Wixom WWTP discharges treated wastewater to Norton Creek

Spring 2018 - Surveyed Industrial Users with potential sources of PFAS - 3 probable sources identified May 2018 - Sampled probable sources. One Industrial User (decorative chrome plater on plastics) identified with high

PFAS levels (28,000 ng/L PFOS) in their wastewater discharge to the WWTP

June 2018 – Sampled final effluent (treated wastewater) at WWTP – 290 ng/L PFOS

City requiring Industrial User to reduce/control PFOS discharges Monthly WWTP effluent monitoring Biosolids – Sampling required. Currently being landfilled.

Addition information on IPP PFAS Initiative: https://www.michigan.gov/pfasresponse/0,9038,7-365-86510---,00.html

12

13

Wixom WWTP

Huron River

Industrial User

Former Automotive Facility

Huron River

290

Other Sources?• Intensive surface water

sampling of Norton Creek to bracket potential sources

• Storm water samples from potential sites

• Samples collected on August 30, 2018

• WRD sampled permitted discharges in area of concern on August 14 and 30, 2018

• Milford WWTP, South Lyon WWTP, and GM Proving Grounds – all ≤11 ppt PFOS

• Coes Cleaners in Milford (state funded groundwater cleanup site) PFOS 1,000 ppt

• DEQ contractor reviewing treatment options

• Does not discharge to Norton Creek but is above Kent Lake

2018 Point Source MonitoringCoes Cleaners

Activities to Identify Other Potential SourcesClosed landfill in Lyon Township

Working with responsible party to sample groundwater monitoring wells

Former automotive facility upstream of Ann Arbor PFAS detected in groundwater. Results: None above

criteria; additional sample results expected end of September 2018

Analysis of 4 permitted discharges in the vicinity of Kent Lake Results: All below WQS (Milford WWTP, South Lyon

WWTP, Seamless Tube, and GM Proving Grounds)6 WWTPs participating in IPP PFAS Initiative

Results: 1 above WQS (Wixom); 2 no sources (Ann Arbor and Lyon Twp.); 3 yet TBD (Brighton, Dexter, and South Huron Valley Utility Authority)

Willow Run Creek – elevated result (26 ppt) Potential sources – former automotive manufacturing

facility, airport, and landfill

15

Willow Run Creek

Closed Landfill

Former Automotive Facility

Next StepsContinue to coordinate activities with MPART agencies and DEQ divisions to protect public health and restore designated uses to the Huron River through implementation of core WRD programs.

• Ongoing work with City of Wixom and Tribar to control/reduce discharges to the WWTP with goal of meeting water quality standards in Norton Creek under the Industrial Pretreatment Program PFAS Initiative.

• Fall 2018 – in conjunction with the DNR, collect additional fish samples for PFAS analysis in the Huron River Watershed.

• Follow-up sampling of surface water, storm water, and point source discharges as necessary for source identification.

Water Withdrawal Quality and Quantity• Great Lakes Compact• Part 327• PA 209• WUAC

Water Use

Michigan 2016 Consumptive Water Use -by Sector