Michigan Chapter of the National Association for Surface Finishing Lansing Summit. November 17, 2017 Michael McClellan, Deputy Director

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1 Department of Environmental Quality Michigan Chapter of the National Association for Surface Finishing Lansing Summit November 17, 2017 Michael McClellan, Deputy Director

2 DEQ Mission The Michigan Department of Environmental Quality promotes wise management of Michigan s air, land, and water resources to support a sustainable environment, healthy communities, and a vibrant economy.

3 DEQ Overview 1,100 Employees 3 Offices 6 Divisions 11 District Offices 3

4 Organizational Structure

5 DEQ Organizational Structure Air Quality Division Drinking Water and Municipal Assistance Division Oil, Gas, and Minerals Division Remediation and Redevelopment Division Waste Management and Radiological Protection Division Water Resources Division

6 DEQ Priorities Protect public health and environment Assist Michigan communities with addressing infrastructure needs Build external partnerships to address Michigan s environmental issues

7 2018 State of Michigan Budget Education 29% Jobs 11% Government Services 7% Public Safety 6% Quality of Life 2% Total: $56.3 Billion Health & Human Services 45% 7

8 2018 DEQ Budget by Fund Source Restricted Funds $201.3 Million 40% State GF/GP $51.3 Million 10% Bond Funds $88.2 Million 17% Total: $510.8 Million Federal Funds $170 Million 33%

9 2018 DEQ Budget by Category Waste Management $16.5 Million, 3% Air Quality $27.1 Million, 5% Oil, Gas, Mineral $10.7 Million, 2% Environmental Assistance $6.4 Million, 1% Administration $34.8 Million, 7% Water Resources $96.5 Million, 19% Local Grants & Loans $218.3 Million, 43% Remediation & Redevelopment $100.9 Million, 20% Total: $510.8 Million

10 Clean Environment Initiative Top DEQ Budget Priority Environmental Cleanup and Brownfield Redevelopment Waste Management and Recycling Emerging Contaminants (PFAS) Water Quality State and Local Parks Address risk at 3,000 sites Double Michigan s Recycling Rate 10

11 Other Budget Priorities Modernize information technology systems Support oil and gas program Provide water infrastructure financing to local communities 11

12 PFAS **Per and Polyfluoroalkyl Substances** USEPA designation national emerging contaminant PFAS suite of chemicals with thousands of applications Used in industrial, food, and textile industries Characteristics Incredibly stable Break down very slowly Highly soluble Easily transferred through soil to groundwater

13 Statewide Concerns PFAS contamination identified in several locations in Michigan Currently 14 locations, 28 sites Sources include: Current and former military installations Tanneries Plating operations Legal and illegal disposal sites

14 Confirmed PFAS Locations/# sites Alpena/2 Ann Arbor/1 Escanaba/1 Flint/1 Grayling/3 Gwinn/1 Lansing/2 Lapeer/2 Mt. Clemens/2 Mt. Pleasant/1 Oscoda/7 Plainfield Township/2 Rockford/2 Tawas/1 14 location 28 sites

15 State Response Governor Snyder s Executive Directive Michigan PFAS Action Response Team Comprehensive, cohesive, and timely response Team lead Carol Issacs Team advisor Dr. David Savitz, Brown University Team composition: DEQ DHHS DMVA MDARD Other agencies as needed

16 Challenges Funding Test analysis time frame Lack of public health and environmental standards Unsettled science 16

17 Next Steps Secure additional financial support Stand up state laboratory capabilities Work with USEPA, pass state cleanup criteria standards PFAS technical team MPART Web site: 17

18 2013/2014 Statewide Surface Water PFAS Monitoring DHHS & DEQ s Water Resources Division obtained a Great Lakes Restoration Initiative (GLRI) grant to perform statewide PFAS monitoring (ambient and fish tissue) of select rivers. PFASs have been measured in all surface water samples collected to date, and PFOS was measureable at 85% of sites sampled. Flint River PFOS levels in the Flint River exceeded the Rule 57 Human Non cancer Value of 12 ng/l and DHHS screening values for fish DHHS updated the Eat Safe Fish Guide to include fish consumption advice due to PFOS in the Flint River.

19 Flint River Surface Water Monitoring to Find Source 2016 Additional PFAS surface water and fish monitoring was conducted on the Flint River and its tributaries. Initial focus was on the Flint area due to historical presence of industrial sites, unregulated dump sites, and landfills. Surface water and fish results both indicated a source was further upstream Surface water monitoring expanded to include upstream locations, including the North Branch and South Branch (Lapeer area) of the Flint River. Effluents from three wastewater treatment plants were also sampled.

20 ng/l (ppt) 4.2 Genesee WWTP 3 May 2017 ND Brent Run Lapeer WWTP 440 ND Flint WWTP 28 Swartz Creek Gilkey Creek

21 PFOS Source Tracked to Lapeer WWTP Effluent results identified the City of Lapeer WWTP as the source. The high effluent levels led the WRD to look at the city s biosolids. High biosolids results caused the WRD to suspend Lapeer s residual management program cannot land apply. City has hired contractors to press their biosolids for landfill disposal and treat the filtrate water through activated carbon prior to returning to the WWTP. Where did it come from? The city implements an Industrial Pretreatment Program and permits industrial process wastewater from a categorical industrial user to their system, Lapeer Plating & Plastics.

22 Lapeer Plating & Plastics Lapeer Plating & Plastics is a decorative chrome plater located within the city of Lapeer. Process involves etching, copper plating, nickel plating, and chrome plating on plastics Historically, LP&P used PFOS as a foam suppressant in electroplating tanks as a control measure for hexavalent chromium air emissions However, use of PFOS was phased out by LP&P in 2013, and a PFOS free product has been in use since that time The DEQ conducted multimedia inspections at LP&P and confirmed the facility as the source of PFOS to the Lapeer sanitary sewer system. Samples of storm water taken at the facility were also found to be at levels of concern.

23 Next steps... Continue working with LP&P and the Lapeer WWTP to eliminate the discharge of PFOS at the source Initial efforts by LP&P to remove PFOS from their discharge by cleaning out tanks and associated process lines/units were not successful. Activated carbon treatment of the process wastewater may be best short term solution. City of Lapeer biosolids land application sites conduct monitoring to determine potential impacts Implementation of an Industrial Pretreatment Program strategy to address potential sources of PFAS discharges to WWTPs Work with USEPA Biosolids need assistance on developing criteria for land application Explore potential of PFOS free products being converted to PFOS during electroplating and/or etching process Work with plating associations to understand operational practices that may impact PFAS discharges from these facilities

24 Waste Management and Radiological Protection Education and Outreach Michigan Waste and Materials Management Conference December 13 14, 2017 Materials Management Solid Waste Law Market Development Survey Hazardous Waste Rules Pollution Prevention Assessment Program

25 AIR QUALITY DIVISION Air Quality Division (AQD) 2018 Priorities Michigan and Ozone Initiatives Affecting Finishers

26 2018 AQD Priorities Staff focus Reduce risks to public health and the environment Build partnerships to address Michigan s environmental issues

27 Staff Focus Lean Permit to Install (Rd 3), Title V (Rd 2), and Enforcement Planning for AQD division wide database to replace existing systems (ORR & audit findings) Training and technology Title V Fees Sunset in September 2019 Succession planning to address retirements

28 Reduce Risks to Public Health and the Environment Ensure demolition of structures comply with the asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP) Address areas not meeting the National Ambient Air Quality Standards sulfur dioxide and ozone(?) Inspect hard chrome platers

29 Build Partnerships to Address Michigan s Environmental Issues Continue to meet with the regulated community Continue to update the public participation process Continue to provide outreach materials LPI implementation MDEQ Minute Implement the Gordie Howe Bridge monitoring program Continued involvement in the Integrated Resource Planning (IRP) process Continued involvement with issues such as vapor intrusion, PFAS, etc.

30 Michigan and Ozone November 6, 2017, the United States Environmental Protection Agency (USEPA) designated areas in Michigan as attainment/unclassifiable USEPA took no action on designations for the rest of Michigan What does this mean? Short term there are no areas designated as non attainment so there are no non attainment permitting requirements USEPA will eventually take action, at which time a plan to reduce ozone will be needed, as well as non attainment permitting requirements will kick in

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32 National Emission Standard 40 CFR Part 63 Subpart N Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks After September 21, 2015, subject facilities shall not add PFOS based fume suppressants to any open or closed hard chromium electroplating tank Facilities can demonstrate compliance through fume suppressant safety data sheets and/or waste manifests

33 Initiatives Affecting Surface Finishing/Finishers MDEQ focus on PFAS AQD to inspect hard chrome platers subject to the NESHAP during Fiscal Year 2018 Subject sources include chrome electroplating or chromium anodizing tanks at facilities performing hard chromium electroplating, decorative chromium plating, or chromium anodizing Sources not subject include process tanks associated with chromium electroplating or chromium anodizing processes but in which neither chromium electroplating nor chromium anodizing is taking place (rinse tanks, etching tanks, cleaning tanks, and tanks containing chromium solution but no electrolytic process)

34 Cleanup Criteria Rules Joshua Mosher, Acting Assistant Director Remediation and Redevelopment Division 34

35 Rules Promulgation Process Draft Rules Published Public Comment Period Public Hearing Final Draft Rules submitted to JCAR Promulgated Rules

36 Cleanup Criteria Rules Overview Scope of Rule Changes 1. Revisions and Reorganization 2. Equations and Inputs 3. Volatilization to Indoor Air Tiered Approach Implementation 36

37 VI Tiered Process VI Tier 1 VI Tier 2 VI Tier 3A Generic Screening Level *University of Wisconsin Facility specific inputs to establish Generic Unrestricted Residential Criteria *images from vastree.com Facility specific inputs to establish Generic Restricted Criteria 37

38 Implementation Extended effective date for rules [6 months after promulgated] Grace Period Part 201 NFA reports and Part 213 Closure Reports submitted 6 months before promulgation up to the effective date will be reviewed under 2013 criteria unless DEQ Director determines the actions taken are no longer protective 38

39 Implementation Effective Date & Grace Period December 15, 2017 * June 30, 2018 * December 30, 2018 * August 31, 2017 Proposed revisions available for review Rules/Criteria Promulgated Rules/Criteria Effective * Note: Dates for demonstration purposes only 39

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41 Questions