Polyfluoroalkylated chemicals – PFAs, are not only in the news, but in Michigan’s groundwater in at least 14 locations in game fish, and in the bloodstream of most Americans. PFAs were widely used for purposes including waterproofing fabrics and textiles, and in food packaging. They are now suspected as a possible cancer-causing agent, and an endocrine disruptor. The Michigan Department of Environmental Quality (MDEQ) has adopted a regulatory guidance from the U.S. EPA, determining that concentrations of certain specific PFAs in concentrations above 70 parts per trillion (ppt) are cause for concern in drinking water supplies.
Michigan has now directed local/municipal wastewater treatment plants (WWTPs), and especially those where PFAs are being detected in the wastewater, to question their industrial sewer users on past usage of PFAs (with some limited exceptions, most PFA users have voluntarily stopped using such chemicals in current manufacturing activities). Past users, and likely sources of PFAs, will have their wastewater discharges sampled and analyzed for two particularly troublesome forms of PFAs (referred to as PFOA and PFOS). Because the chemicals are heavy and persistent, they may continue to show up in waste streams, long after active usage has been discontinued. If these specific PFAs are detected in an industrial user’s wastewater discharge, WWTP operators are directed by the Michigan Department of Environmental Quality to take steps to require their industrial users to reduce the presence of these chemicals in their waste stream. According to a recent MDEQ notice letter:
“Source reduction and elimination efforts may include
- product substitution,
- operational controls,
- pretreatment, and
- clean-up of historical contamination”
All of these source reduction efforts may involve expense, but “cleanup of historical contamination” may involve significant expense. If you think your past manufacturing activities may have involved the use of PFAs, now is the time to prepare, by reviewing your manufacturing records, to see if they show any past use of PFOA or PFOS, and if so, the amounts and time periods involved, and especially any records showing disposal or diversion of waste PFA chemicals to a facility other than your sewer waste stream.