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Michigan initiates PFAS investigations for industrial pretreatment programs

Jeff Ramey

The regulatory and enforcement climate concerning per- and polyfluoroalkyl substances (PFAS) is rapidly evolving, and particularly fast in the state of Michigan. On February 20, the Michigan Department of Environmental Quality (MDEQ) issued letters to all wastewater treatment plants (WWTPs) with Industrial Pretreatment Programs (IPPs) to evaluate potential sources of PFAS. Investigations include sampling for and analysis of two terminal breakdown PFAS compounds: perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA). 

This directive places the onus for identification of potential significant sources of PFOS and PFOA on the WWTPs, which in turn will be targeting potential source industries like: 

  • Metal finishers and platers 
  • Landfills 
  • Tanneries, fabric/leather treaters, paper manufacturers 
  • Centralized waste treatment facilities 
  • Any other industrial users that use, or have used, PFAS-containing chemicals

By June 29, 2018, each WWTP with an IPP must submit an interim report to the MDEQ with the results of the WWTP performed source monitoring and must demonstrate that efforts are underway to reduce / eliminate sources and evaluate impacts. 

The lowest standard for evaluating effluent will be the Water Quality Standards established by Michigan Rule 57 for PFOS: 12 ng/L (streams not used for drinking water) and 11 ng/L (streams used for drinking water). The very low action levels established by the standards, combined with the widespread use of PFAS compounds in consumer products and environmental sampling media, creates potential cross-contamination risks to industrial IPP permit holders during these investigations compared to sampling for more traditional contaminants of concern. 

How can OBG help?

OBG recommends strategies to protect targeted industries, such as: 

Risk Exposure Evaluation. Performing an evaluation of the likelihood of potential previous uses of PFAS based on a review of site use and production history. 

Response Management. Providing industry clients with the necessary information to make informed responses to any requests for sampling.

Sample Collection and Analysis. Split sampling utilizing a sampling and analysis plan, use of a laboratory analyzing the proper compound list and certified or accepted methodology, and data validation services to protect sample integrity.

Project Management and Support Following the Investigation. OBG has performed a broad variety of services for our industrial partners at multiple “sites with known PFAS levels” as identified by MDEQ. As an owner who is potentially facing a request for PFAS sampling to be conducted or would benefit from an understanding of available options, our team of multi-disciplinary experts and thought leaders is available to you. 

Meet the OBG Emerging Contaminants – Michigan PFAS team: 

John Newsted, PhD 
PFAS Subject Matter Expert  
Ecotoxicology, risk assessment, fate and transport, expert witness  

Cliff Yantz, PG
Senior Hydrogeologist
regulatory and Part 201 expert, multi-media investigations, characterization, monitoring, remediation, landfills and leachate, wastewater 

Jeff Ramey
Project Development & Managing Chemist
Analytical methodology, quality assurance/ quality control, multi-media investigations, wastewater

Dusty Tazelaar
Ecological risk assessment, field studies, natural resource damage assessments  

Marcus Byker, PE
Senior Engineer  
Pretreatment design and implementation, remediation technologies 

Paul Hare, CPG, PG
Emerging Contaminants Senior Technical Director 


Members of our team will be presenting at the upcoming Battelle Chlorinated Conference on April 8-10, 2018 in Palm Springs, California. 

About Jeff Ramey: Jeff is a manager of project development at OBG and a managing chemist on the company’s emerging contaminants team. He has 14 years of experience as an analytical chemist in the environmental industry. Jeff can be contacted at Jeff.Ramey@obg.com