PFAS in Michigan. MWEA June 25, 2018 Michigan Department of Environmental Quality Water Resources Division

Transcription

1 PFAS in Michigan MWEA June 25, 2018 Michigan Department of Environmental Quality Water Resources Division

2 Michigan PFAS Action Response Team (MPART) Multi Agency action team Governor s Office (Carol Issacs) Looking into PFAS, particularly PFOS (perfluorooctanesulfonic acid) and PFOA (perfluoroocatanoic acid) Water Resources Division (WRD) is part of this effort, along with other divisions in the MDEQ Primary WRD representatives are Teresa Seidel, Christine Alexander, and Jon Russell

3 PFAS Persistent and in a wide variety of household and industrial products Present in sanitary wastewater from multiple sources Conventional wastewater treatment not designed to treat PFAS Partitioning of PFOA and PFOS Fate through a facility is not well understood; likely depends on the type of treatment process(es) PFOS appears to better associate with solids; PFOA with water Granular Activated Carbon or ion exchange makes the most sense though chain length important

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5 Water Resources Division Strategy Based on our WRD regulations Monitor PFAS in surface waters and fish Coordinate with other Divisions (AQD, WMRPD) Identify, eliminate or minimize potential sources Monitor point sources (Direct Discharges) Industrial Pretreatment Program Initiative (Indirect Discharges) Develop knowledge of PFOS in Biosolids and seek assistance

6 Ambient Monitoring Up to 180 receiving water samples in 2018 Source tracking St. Joseph, Kalamazoo, Clinton, Huron Rivers, Raisin Source water near Drinking Water Critical Assessment Zones and the Great Lakes Recon waterbodies with potential sources

7 Fish fish samples collected from 25 sites 2018 Analysis of the 2017 fish samples Additional wild fish samples and/or caged fish studies in the Flint, Rogue, and AuSable

8 Point Source Monitoring Identify/control sources through existing regulatory programs, including NPDES permits Sample PFAS at select WWTPs with routine monitoring Sample direct industrial dischargers with potential for PFAS Sample point sources (wastewater/stormwater) related to source tracking activities

9 Point Source Monitoring Results To Date

10 NPDES program DEQ administers the National Pollution Discharge Elimination System Permit program under state and federal law DEQ must establish permit requirements compliant with the federal Clean Water Act meeting technology requirements and state water quality standards (WQS) WQS for 2 PFAS compounds PFOS (bioaccumulative chemical of concern; no dilution allowed): 11 ppt (drinking water source) 12 ppt (non-drinking water source) PFOA: 420 ppt (drinking water source) 12,000 ppt (non-drinking water source)

11 Municipal Wastewater Treatment Secondary Treatment (technology requirement) Physical process - solids removal Biological process removal dissolved and suspended organic compounds (using living organisms) Tertiary Treatment (to meet WQS for conventional pollutants) Additional biological treatment plus a filtration step to remove additional solids/other pollutants Meet WQS for toxic pollutants Utilizing Industrial Pretreatment Program (IPP)

12 Sources of PFOS & PFOA for WWTPs Platers using fume suppressants/demisters/wetting agents Leather and fabric treaters, tanneries Paper and packaging manufacturers Manufacturers of parts w/ptfe coatings Landfills (leachate) Centralized Waste Treaters AFFF fire fighting foam

13 Research ideas at existing wastewater treatment plants 2 wastewater treatment plants with carbon treatment Bay City WWTP (12 million gallons per day) Tertiary treatment process to adsorb industrial wastes Utilizes 20 carbon pressure filtration units; each capable of treating 1 MGD per day Possible to sample PFAS at the following treatment locations: influent (prior to treatment) Secondary effluent Tertiary effluent (after the carbon pressure filters) Provide an evaluation of secondary and particularly tertiary carbon pressure filters on PFAS removal

14 Research ideas at wastewater treatment plants, cont. Kalamazoo Water Reclamation Plant (53.5 MGD) Biological nutrient removal secondary treatment process Utilizes powdered activated carbon added into secondary treatment to adsorb industrial wastes Possible to sample PFAS at the following treatment locations: Primary clarifier before addition of carbon slurry Secondary clarifier effluent following addition of carbon slurry Waste activated sludge with spent carbon Research Variation: Discontinue carbon slurry addition until equilibrium reached in the treatment train and sample 3 locations above Compare results with/without carbon slurry addition

15 NPDES Requirement: Industrial Pretreatment Program (IPP) Industrial Pretreatment Program A federallymandated program to control industrial discharges into POTWs to protect against WWTP interference, meet WQS, and protect biosolids. IPP is REQUIRED when a POTW has significant industrial users such as metal finishers, chemical plants, etc. PFOS and PFOA are new, emerging pollutants with Water Quality Standards (WQS). For POTWs w/ipps: DEQ is requiring PFOS/PFOA source identification, evaluation and follow-up to protect against WQS exceedances by the POTW.

16 IPP FFAS Initiative Requirements Potential Source Screening Monitor Probable Sources If sources found: Reduce/Eliminate PFOS & PFOA Sources Monitor POTW effluent; report if exceeds standards Submit Interim Report due 6/29 Continue Source Reduction & Monitoring Submit Summary Report due 10/26 Alternative Plan: -More time -Fewer samples -For larger POTWs

17 Industrial Pretreatment Program (IPP) PFAS Initiative 95 IPPs participating 32 submitted extension requests 63+ interim reports due June 29, 2018 (some partial) Additional data may be required (biosolids, effluent) Many IPPs will be done after June (no sources found)

18 Biosolids Biosolids are treated sludge from a municipal WWTP. Sewage sludge refers to the waste residuals generated during the treatment of domestic wastewater; primary and secondary sludge Biosolids refers to sewage sludge that has undergone treatment and stabilization and meets state and federal standards for beneficial reuse as a slow release fertilizer and soil conditioner

19 Nutrient Value of Typical Biosolids* Nutrient lbs/acre Value/Acre Nitrogen 150 $ Phosphorus 150 $ Potassium 30 $ 4.00 Copper 3 $ 3.60 Zinc 5 $ 2.50 calcium 1200 $ Total Value $ *Source MDARD estimates Assumes lime addition

20 FY 17 Biosolids Land App / Sludge Disposal FY 17 Reported Dry Tons 10% 47% 43% Land Applied Landfilled Incinerated

21 Historical Perspective Waste to Beneficial Use Act 29, PA 1997 (amends Part 31/Act 451) Important Elements MDEQ Oversight (EPA delegation) Fee Based Program (tonnage fee & $400 generation fee) Preempts Local Ordinances Notification to Twps & Co HDs on new sites Opportunity for local program oversight Promulgation of Administrative Rules

22 Michigan Part 24 Administrative Rules BIOSOLIDS - key points Majority basis is Federal 40 CFR 503 pathogen / vector attraction reduction Pollutant limits Part 24 Rules Residuals Management Program Approval Resource management for annual agronomic crop uptake 300# /acre PO4 limit Isolation distance requirements groundwater / water well / surface water

23 Michigan Biosolids Program Permitting/Approval process A generator or distributor must have a valid permit before commencing biosolids land application or distribution activity in the State of Michigan. Valid permit includes- NPDES, Groundwater Permit or Biosolids General Permit. Valid permit requires submittal/approval of the Residuals Management Program (RMP). RMPs must include (R (3)(b)) Volumes/Concentrations of Pollutants Treatment Processes /Storage volume Transportation / Spill Prevention Plan Land application methods Site List /Site packets Pathogen /Vector Attraction Reduction Sampling Plan

24 What do we think we know? Longer chain PFAS appear to adhere to solids, more so with increasing carbon content (PFOS) PFOS concentrate in biosolids. Literature review indicates that PFAS (PFOS) are commonly found in biosolids in the low PPB level (up to approximately 200 PPB based on the literature). There are no state or federal standards for PFAS in biosolids

25 What we do not know How PFAS are affected by treatment technologies at WWTP s. It appears that some PFAS may be converted during traditional biological treatment. The relationship between concentrations of PFAS in wastewater and resulting concentrations in biosolids. How PFAS move in soils and leach to groundwater from biosolid land application. (Lapeer investigation may begin to help) How crops take up PFAS. The risks posed by crop uptake based on plant and end use of the crop.

26 Other research considerations Track the treatment type of each wastewater treatment plant sampled Track the cell residence time for possible correlation with removal of each plant sampled. Longer cell residence times may correlate with PFAS uptake from water column by organisms. Consider sampling PFAS in the waste activated sludge Sample biosolids at differing solids concentrations to see how PFOS and PFOA are effected Any additional treatment beyond secondary, including filtration, to remove solids, phosphorus, ammonia Granular activated carbon treatment for industrial pollutants

27 Next steps 1. Review evaluations of treatment (municipal and industrial). 2. What is crop uptake of PFAS on fields where PFAS is present in the soil (compounds, crop type, risk to human and animal health)? Is land application affected? 3. Offer additional research ideas regarding treatment 4. Determine treatment options that are appropriate and practical for facilities to meet PFOS and PFOA limits.

28 Questions and Discussion Christine Alexander, Manager Permits Section or (517) Industrial and municipal treatment, water quality standards Jon Russell, Manager Field Operations Lake Huron and Erie or (517) Point Source Monitoring, IPP, biosolids