November 2024 2B WQC Draft V2

PFAS Source Reduction Concept
November 13, 2024
Julie Grzyb, DWR Deputy Director
Topics Covered
•September 2024 Water Quality Committee Motions
•Human Health Benefits – PFAS in Food
•PFAS Monitoring and Source Reduction Plans
•Example of a State with a PFAS Monitoring and Source Reduction
program
•NC PFAS Monitoring and Minimization Concept Feedback
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Water Quality Committee Motions Related to
Proposed PFAS Surface Water Rules
At the September 11, 2024, WQC meeting passed two motions shown below
as articulated by the committee:
1.The EMC WQC does not accept nor take any action related to the RIA
Benefits category “human health benefits”, also cited as human health
in Table 20 or in Appendix F in the section titled “estimated exposure to
food containing PFAS in NC”, until members of the EMC meet with FDA
and receive a written response that the information related to the food
in the US and NC is accurate.
2.Direct the department to propose a draft rule and a draft RIA to
establish monitoring for every industrial and NPDES permit and require
PFAS source reduction plans as part of every industrial and SIU
municipal pretreatment program.
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Example State Program:Michigan's
Dept. Of Environment, Great Lakes, and Energy's PFAS Initiative
•Water Quality Values (WQVs) established for PFOA and PFOS based on toxicity
information available at the time
•The Industrial Pretreatment Program (IPP) PFAS Initiative, started in 2018, for all
municipal WWTPs with Industrial Pretreatment Programs. Focused on:
•Determining if these facilities were passing through PFOS and/or PFOA to surface waters
•If pass through was observed, facilities were required to reduce and eliminate any sources
•Under the Initiative, WWTPs were required to:
•Identify significant industrial users in their system that were potential sources of PFAS.
•Sample probable sources and require source reduction for confirmed SIUs.
•Samples WWTP effluent for PFAS
•Submit reports and monitoring results as required by EGLE's Water Resources Division.
•Direct Industrial Dischargers follow a similar approach in terms of identifying if they have
PFOA or PFOS in their discharge, minimize (if necessary) to avoid pass through and
exceeding WQVs.
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Goal is to meet PFOA and PFOS water quality values
Michigan Program Timeline
•2014-2022: Developed PFAS WQVs under Michigan Rule 57
•Used toxicity data available at the time - PFOS (2014) and PFOA (2022) before EPA assessed the
toxicity data and labeled them as carcinogens.
•Clean Water Act compliant narrative process (similar to NC 02B .0208 narrative standards rule)is
used to calculate WQVs.
•Values are posted on the EGLE website and not codified in rules. No Regulatory Impact Analysis
required.
•2018 – PFAS source evaluation and reduction requirements through February 20, 2018 letter
•Includes requirements for initial screening, source reduction, and monitoring.
•Interim Reports due June 29, 2018
•Summary Reports due October 26, 2018
•2021 – present: PFOA/PFOS limits evaluated for NPDES Permits issued after October 1, 2021
•First permit with limits expected in 2024.
•Future: Revisiting and Updating WQVs using latest PFOA and PFOS toxicity data.
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Michigan Development of Human Health Surface Water
Quality Values for five PFAS between 2014 & 2023
•Michigan has incorporated a narrative process for developing water quality
values (WQVs) for toxic substances within their Surface Water Quality
Standards.
•The narrative process allows Michigan to use a standardized and
transparent process to develop and update WQVs when new toxicological
data are available.
•PFAS WQVs are not codified in rule
•WQVs derived for non-carcinogenic health effects based on toxicity
information available at the time
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Narrative process codified in Rule 57 (R 323.1057) of Michigan’s Part 4 Rules, Water Quality Standards and
based on the EPA Final Water Quality Guidance for the Great Lakes System (Guidance)
Michigan – Development of PFAS Water Quality Values
MI WQV human health equations are similar to NC equations in 15A NCAC
02B .0208. The main difference being MI use of two trophic levels for
fish consumption rates (FCR) & bioconcentration factors (BCF).
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𝑉𝑄𝑄=𝑄𝑓𝐵× 𝑄𝑄𝐵× 𝐵𝑉
𝑉𝐵𝑄+(𝐹𝐵𝑄 𝑥 𝐵𝐵𝐹)
❖NC 15A NCAC 02B .0208 non-cancer human health criteria equation:
❖MI Rule 57 non-cancer human health criteria equation:
𝑉𝑄𝑉=𝑄𝑓𝐵× 𝑄𝑄𝐵× 𝐵𝑉
(𝑉𝐵𝑄+{𝐹𝐵𝑄TL3 𝑥 𝐵𝐵𝐹TL3 +𝐹𝐵𝑄TL4 𝑥 𝐵𝐵𝐹TL4 })
A trophic level is the position an aquatic
organism occupies in the food chain
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HNV = Human Non-cancer Value
Michigan PFAS Rule 57 Human Health Water Quality Values (WQVs)
Parameter Human Non-cancer Value (HNV)Year WQVs were
EstablishedDrinking (ng/L)Non-drinking (ng/L)
Perfluorooctane sulfonate (PFOS)11 12 2014
Perfluorooctanoic acid (PFOA)66 170 2022
Implementation based Targeted PFAS Levels for POTWs
•Michigan used a binned approach that mirrors the tiered approach proposed by NCDEQ
in 02B .0404.
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Bins PFOS Levels Requirements Monitoring Frequency for
POTW Effluent
1 No PFOS/PFOS Sources Completed 4 times over 5 years or 3
times per year
2 Sources found but POTW effluent for PFOS is
≤ 12 ng/L
•Source reduction recommended
(written request by EGLE)
•Local limits and pollution
minimization plan recommended
Semi - annual
3a Sources found and POTW effluent PFOS is
>12 and <50 ng/L
•Source reduction required
•Local limits recommended Quarterly
3b Sources found and POTW effluent PFOS is
≥50 ng/L
•Source reduction required
•Local limits recommended Monthly
NC PFAS Source Reduction
Rule Design Questions
DEQ is requesting guidance from the WQC on the following
aspects of Source Reduction Plans to bring forward draft rules
and RIA as required in the 2nd motion:
1.Who will be required to monitor?
2.Who will be required to evaluate source reduction options
and submit minimization plans?
3.What PFAS levels trigger a minimization plan and what
reduction targets ensures success?
4.What is the implementation timeline?
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Links to Michigan's Industrial Pretreatment Program PFAS Initiative
Industrial Pretreatment Program PFAS Initiative:IPP PFAS Initiative
2/20/2018 PFAS Source Evaluation and Reduction Requirements Letter
4/18/2018 PFAS Source Evaluation Follow-Up Letter.
12/3/2019 Update on IPP PFAS Initiative Status and Continued Efforts.
9/10/2020 Update on IPP PFAS Initiative and Continued Efforts.
Municipal NPDES Permitting Strategy for PFOS and PFOA
Michigan PFAS Action Response Team:Wastewater Treatment Plants /
Industrial Pretreatment Program
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