AN ABSTRACT of the CAPSTON PROJECT of Jamie Whitley for The

AN ABSTRACT OF THE CAPSTON PROJECT OF

Jamie Whitley for the degree of Master of Natural Resources presented on August 21, 2019

Title: Laws, Regulations and Action Plans for per- and polyfluoroalkyl substances found in Michigan drinking water supplies.

Abstract approved: ______Lynette de Silva

Per- and polyfluoroalkyl substances (PFASs) have emerged in the last half century as concerning global contaminants. PFASs have been found in drinking water systems causing negative health impacts for those who rely on this as their primary source of drinking water. PFASs are man- made industrial chemicals composed of carbon chains bonded to fluorine and other substances and cause detrimental impacts to the environment and human health (TOMWC, 2019c). While PFASs are not a new substance, the adverse effects are just starting to be realized. In response, Michigan is pursuing a leadership role in policy, research, training and clean-up/remediation plans for PFAS contamination with the implementation of the Michigan PFAS Action Response Team (MPART). The State of Michigan is poised to be one of the first states to enact Maximum Contamination Levels (MCLs) for some of the most impactful PFASs.

This capstone project seeks to determine the effectiveness of the current legislation and PFAS Action Plans in protecting Michigan citizens from PFAS contaminated drinking water. A review of the current and proposed federal and Michigan legislation was completed as well as the impacts associated with PFASs exposure which identified the success of current policies with regards to the environment, the ecosystem, human health, the economy and the socio-political scene. Additionally, local Northern Michigan government officials and employees of environmental organizations were surveyed to ascertain their opinions of the effectiveness of MPART, the current regulated PFASs levels and to determine what more can be done to assist

local areas with current and future PFAS contamination. Key findings of the literature review and the survey illustrate a need for stricter and more detailed legislation that include nationwide MCLs for individual PFASs, further research on the impacts, with emphasis on human health. In addition, it was found that while it might be too early to determine the effectiveness of MPART, there is evidence that local officials lack the necessary training to adequately administer best practices to help mitigate PFAS contamination.

Laws, Regulations and Action Plans for per- and polyfluoroalkyl substances found in Michigan drinking water supplies

by Jamie Whitley

A CAPSTONE PROJECT

submitted to

Oregon State University

in partial fulfillment of the requirements for the degree of

Master of Natural Resources

Presented on August 21, 2019

Master of Natural Resources Capstone of Jamie Whitley presented on Defense Date

APPROVED:

Lynette de Silva, representing Masters of Natural Resources

Janean Creighton, Director of the Department of Natural Resources

Dean of the Graduate School

I understand that my thesis will become part of the permanent collection of Oregon State University libraries. My signature below authorizes release of my thesis to any reader upon request

Jamie Whitley, author

ACKNOWLEDGEMENTS

This project would not have been possible without the continued guidance from my Capstone advisor Lynette de Silva. Your input, support and patience has been incredible. I would also like to thank my Committee members, Brent Steel and Kermit Cromack for your support, feedback and willingness to participate on this committee.

I would like to acknowledge Grenetta Thomassey. I have learned so much regarding the health and management of the waters within the Great Lakes Basin, specifically in Michigan. I appreciate the guidance and inspiration for this project.

My family and friends have been my unwavering support system throughout this entire process. Your patience, understanding and constant encouragement is more than I could have asked for. I know that this program and process would have been nearly impossible to complete without each of you. Thank you for everything that you have done to make this a reality for me.

TABLE OF CONTENTS

Page

1 Introduction…………………………………………………………………………… 1

1.1 Statement of the problem…………………………………………………… 1

1.2 Background-Historical Context………………………………………….…. 3

1.3 Regional Context…………………………………………………………… 6

1.4 Purpose of Study…………………………………………………………… 7

1.5 Research Questions………………………………………………………… 8

2 Desktop Literature Review…………………………………………………………... 10

2.1 Important Federal Legislation and Action Plans…………………………… 10

2.2 Important State of Michigan Legislation and Action Plans………………... 12

2.3 Proposed Legislation and Actions Plans…………………………………… 14

2.4 Impacts……………………………………………………………………... 16

2.4.1 Environmental/Physical Impacts………………………………… 16

2.4.2 Ecosystem Impacts………………………………………………. 18

2.4.3 Human Impacts…………………………………………………... 20

2.4.4 Economic Impacts………………………………………………... 23

2.4.5 Socio-Political Impacts…………………………………………… 25

2.5 Knowledge Gaps……………………………………………………………. 27

3 Materials and Methods………………………………………………………………... 28

3.1 Desktop Literature Review…………………………………………………. 28

3.2 Survey………………………………………………………………………. 29

3.2.1 Survey Strategy…………………………………………………… 29

TABLE OF CONTENTS (Continued)

Page

3.2.2 Survey Questions………………………………………………….. 30

4 Results…………………………………………………………………………………. 32

4.1 Desktop Literature Review Results………………………………………..... 32

4.2 Survey Results……………………………………………………………..... 42

4.3 Results Summary………………………………………………………..…... 52

5 Limitations……………………………………………………………………………... 53

6 Discussion and Conclusion……………………………………………………………. 54

6.1 Desktop Literature Review Discussion………………………………………. 54

6.2 Survey Discussion……………………………………………………………. 57

6.3 Next Steps……………………………………………………………………. 60

6.4 Conclusion…………………………………………………………………… 63

7 Bibliography………………………………………………………………………….... 64

Appendices………………………………………………………………………………. 72

Appendix A: Acronyms…………………………………………………………. 73

Appendix B: Survey Description and Consent…………………………………. 74

Appendix C: Sample PFASs Water Test Results………………………………. 75

LIST OF FIGURES

Figure Page

Figure 1 General Classification of common per-and polyfluoroalkyl substances……….. 1

Figure 2 Exposure routes of PFASs to humans and environment…………………….…. 5

Figure 3 Watersheds within Charlevoix and Emmet Counties……………………….…. 7

Figure 4 Pathways of PFASs into the environment……………………………………... 17

Figure 5 Possible indirect pathways of PFASs entering autotrophic and heterotrophic food webs………………………………………………………………………………. 19

Figure 6 PFASs Cycle and Pathways to Food Sources…………………………………. 21

Figure 7 DoD Groundwater and Known/Suspected Release site testing results for PFOA/PFOS…………………………….…………………………………………... 26

Figure 8 Desktop Literature Review Result 1 Chart 1………………………………… 34

Figure 9 Desktop Literature Review Result 1 Chart 2………………………………… 35

Figure 10 Desktop Literature Review Result 2 Chart………………………………….. 36

Figure 11 Desktop Literature Review Result 2: Location of known PFASs contamination sites………………………………………………….………………… 37

Figure 12 Desktop Literature Review Result 3 Chart………………………………….. 39

Figure 13 Desktop Literature Review Result 4 Flow Chart…………………………… 40

Figure 14 Desktop Literature Review Result 5 Chart…………………………………. 41

Figure 15 Survey Results Question 1………………………………………………….. 44

Figure 16 Survey Results Question 2………………………………………………….. 44

Figure 17 Survey Results Question 5………………………………………………….. 46

Figure 18 Survey Results Question 8………………………………………………….. 48

LIST OF FIGURES (Continued)

Figure Page

Figure 19 Survey Results Question 10………………………………………………… 49

Figure 20 Survey Results Question 11………………………………………………… 50

LIST OF TABLES

Table Page

Table 1 Types of PFASs found in common items………………………………………. 4

Table 2 Desktop Literature Review Result 1: Summary of Current Federal Regulations and Laws Regarding PFASs…………………………………………….…. 34

Table 3 Desktop Literature Review Result 2: Summary of Current Michigan Regulations and Laws Regarding PFASs…………………………………………….…. 36

Table 4 Desktop Literature Review Result 3: Summary of Proposed Federal and Michigan Regulations and Laws Regarding PFASs……………….………….…… 38

Table 5 Desktop Literature Review Result 5: Michigan Sites with PFOA/PFOS levels above 70 ppt ……………………………………………………………………… 41

Table 6 Survey Results Question 3……………………………………………………… 45

Table 7 Survey Results Question 4……………………………………………………… 45

Table 8 Survey Results Question 6……………………………………………………… 46

Table 9 Survey Results Question 7……………………………………………………… 47

Table 10 Survey Results Question 9……………………………………………………… 48

Table 11 Survey Results Question 12…………………………………………………… 50

Table 12 Survey Results Question 13…………………………………………………… 51

Table 13 Summary of Hypothesis Results………………………………………………. 52

1 Introduction

1.1 Statement of the problem

Per-and polyfluoroalkyl substances (PFASs) consist of a large group of man-made chemicals, used extensively in manufacturing common consumer products. According to the Michigan Environmental Council (MEC), there are more than 3000 different PFAS chemicals divided into two sub-groups: short (<6 carbons) and long-chain (>6 carbons) (MEC, 2018). PFASs are organic molecules that have replaced most or all of the hydrogen in the carbon chain with fluorine. Figure 1 shows the general classification and relationship between subgroups of some common PFASs, including examples of substances that are comprised of these PFASs. Each color corresponds with a separate class of PFASs (Reade, Quinn & Schreiber, 2019).

Figure 1: General Classification of common per-and polyfluoroalkyl substances (PFASs). The following acronyms are used in the figure: PFPE= perfluoropolyether, PFAA= perfluoralkyl acid, PFCA= perfluorinated carboxylic acid, PFOA= perfluorooctanoic acid, PFNA= perfluorononanoic acid, PFSA= perfluorinated sulfonic acid, PFOS = perfluorooctanesulfonic acid, PFHxS = perfluorohexanesulphonc acid, PFECA= perfluoroalkyl ether carboxylic acids, PFESA= perfluoroalkyl ether sulfonic acids, FTOH= fluorotelomer alcohol, PASF= perfluoroalkane sulfonyl fluoride, NEtFOSAA= N-ethyl perfluorooctanesulfonamidoacetic acid, PAP= para amino phenol (Reade, Quinn & Schreiber, 2019)

Different forms of PFASs exhibit distinct behaviors. These include variability in mobility, dissociation of ions, bioaccumulation levels in the environment and biota, leaching into groundwater, resistance to any natural breakdown and transformation in the environment (Beecher & Rainey, 2018). Of these behaviors, the greatest concerns are the resistance to breakdown and high levels of bioaccumulation in living organisms, due to the strong bond between carbon and fluorine and the high polarity of the molecules (Scher, et al., 2018). These characteristics led the Environmental Protection Agency (EPA) to identify long-chain PFASs as detrimental to the physical environment, ecosystems and human health (EPA, 2018). PFASs have been detected throughout the world in the environment, biota, humans and our food sources (Kabore, et al., 2018). Two of the most commonly detected PFASs, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonate (PFOS), are long chains classified as Persistent Organic Chemicals by the Stockholm Convention. It is currently believed by many in the industrial process that short-chain PFASs may be less harmful than long-chain PFASs, however there is little to no research to back this. Many short-chain PFASs are being used as a replacement for long-chain PFASs in the manufacturing process (Wang et al., 2017). There is research that shows that microbes have the ability to break down PFAS precursors into PFOA, PFOS and other PFASs, however to date, there is no confirmed research to show that microbes will have the ability to break down PFASs (Liu & Avendano, 2013). At the University of California there is current research using Dechloromonasand azospira to break down perchlorates, but this does not include PFAS at this time (Thomasy, 2019).

Due to a lack of known control measures, the abundance of PFASs in the marketplace and the specific chemical properties, PFASs have the potential to be a continuous problem for the global community. Worldwide, there are no mandated regulations for PFASs, only voluntary recommendations with countries implementing varying regulations. Thousands of products made from PFASs are still being produced and sold globally, many of which display similar detrimental properties to PFOA and PFOS (Wang et al., 2017). As recently as 2017, 40 new classes of PFAS were identified (Barzen-Hanson et al., 2017). In addition, the source of the PFAS contamination is not always easily identified. PFASs high mobility can cause it to move far from the place of origin and its persistence in the environment makes it difficult to determine

the exact location of contaminants. While many detections have occurred near military and manufacturing sites that can be traced, PFASs have also been detected in locations far from any traceable contamination (Rahman, et al, 2013).

A study by Kabore and associates (2018), showed the Great Lakes and the St. Lawrence river ecosystem tested significantly higher for PFASs than other areas in North America. Of the five Great Lakes, Lake Michigan, Ontario and Erie have the highest concentrations of PFASs (Codling, et al., 2018). On November 13, 2017 The State of Michigan and the Michigan Department of Environmental Quality (MDEQ) announced plans to become more proactive and transparent regarding further contamination issues (Executive Order 2017-4, 2017). This has started with the formation of the Michigan PFAS Action Response Team (MPART), a division within the MDEQ. MPART is tasked with guiding the state’s response to the concerns associated with PFAS contamination in drinking water systems.

There are no enforceable regulations for PFASs at the federal level and very few state regulations that would ensure the public’s safety from PFASs (Reade, Quinn & Schreiber, 2019). Addressing the health and environmental issues will require diligence and collaboration from every level of government. Such coordinated action is essential to formulating a plan to curb the production and use of PFASs, properly monitor drinking water systems, determining swift action to clean up any contaminated sites and providing clearing outlined remediation steps for these sites. Also needed is public outreach and training initiatives to inform Michigan residents and government officials about these contaminants.

1.2 Background-Historical Context

According to the United Nations Committee on Economic, Social and Cultural Rights (CESCR), all humans are entitled to safe water for personal and domestic use. This includes water that is free from harmful contaminants that could lead to negative health effects. Governments and other international organizations are held responsible for any financial resources, capacity building and technology needs that are required to ensure and enforce this right (UN CESCR,

2003). In addition, the United States affords it residents the protection of clean water under the 1974 Safe Drinking Water Act. Even with these rights and regulations, water contamination is all too often a reality due to faulty or outdated public drinking water systems and pollution or chemicals that reach water supplies.

First manufactured in the late 1940’s, PFASs are found in many common products due to their water and oil repellent properties. These products include carpet, coating materials (ex: Teflon), fire and water resistant objects, cleaning and beauty products, clothing, leather, upholstery, waxes and polishes, pesticides and firefighting foam (Kunacheva et al, 2009; Wang et al., 2017). Table 1 shows the type(s) of PFASs found in these items. Many of these items are comprised of multiple PFASs in which case the most common type(s) are listed. The aviation and automotive industries, the energy sector and companies involved in oil production have historically used large amounts of PFASs in their manufactured materials (UNEP, 2013). It was not until the early 2000s that increased health concerns prompted Europe and North America to ask for a voluntary stop in production of some long-chain PFASs and replace them with short-chain PFASs. However, these long-chain PFASs are still being produced in many developing areas of the world, including Asia; and the limited research on the replacement of short-chain PFASs does not relieve concerns (Hu, et al., 2016).

Item Type(s) of PFAS Non-stick cookware (ex: Teflon) PFOA or PTFE Take-out food containers/microwaveable PFOA, PFOS popcorn bags Clothing (water and stain resistant) PFOA, other PFCs Carpet/Stain resistant Upholstery PFOA Firefighting foam PFOS Make-up/Cosmetics PFOA

Table 1- Types of PFASs found in common items. The following acronyms are used in the table; PFOA = polyfluoroalkyl octanoic acid, PTFE = polytetrafluoroethylene, PFOS= polyfluorooctanesulfonic acid, PFC = perfluorinated compounds (MEC, 2018; Nestler, Montgomery, Heine, 2019; TOMWC, 2019c)

Humans can be exposed to PFAS in one of three ways; through their occupation, general exposure (ex: drinking water) and exposure between mother and fetus/infant while pregnant or nursing (UNEP, 2013). Simply stopping the production of certain PFASs may be enough to curb some levels contamination, such as exposure through employment, but it most likely will not be effective in protecting the majority of the population from coming into contact with these contaminants. Figure 2 demonstrates possible PFASs exposure routes to humans and the environment through production, use and disposal of a substance manufactured using PFASs. The blue font shows how PFASs can be exposed to the environment and the orange font demonstrates the possible exposure routes to humans.

Figure 2: Exposure routes of PFASs to humans and environment. WWTP = wastewater treatment plants (UNEP, 2013)

MPART was created in 2017, in Michigan, as a temporary body to identify locations of PFAS contamination, as well as investigate any possible direct contamination sources. Through an executive order in 2019, it was changed from a temporary body to a permanent and enduring government body through the State of Michigan (Executive Order 2019-03, 2019). Beginning in 2018, MPART began testing drinking water systems in all state schools, child care facilities and Michigan Head Start Programs, as well as all state public water systems.

To date, there has been a total of 1461 public water systems tested and two tested samples were found to be above the EPA’s lifetime health advisory level (LFHA) of 70 parts per trillion (ppt). MPART has yet to mandate the testing of private drinking wells. As of August 1, 2019, 63 groundwater sites in Michigan have groundwater samples that test over 70 ppt, and it is estimated that more than 11,000 groundwater sites could test higher than 70 ppt (Matheny, 2019 & Michigan.gov, 2019c). Testing in Charlevoix and Emmet County (shown in Figure 3) was completed at the end of 2018, and the entire state is expected to be completed at the end of 2019. Although there are no sites in Charlevoix and Emmet Counties that have tested higher than the current advisory level of 70 ppt, there were five samples in Charlevoix County that tested positive for PFAS below the regulated amount, including one public school system (Michigan.gov, 2019c).

1.3 Regional Context

The geographic area of focus for this study is Michigan, with emphasis on Charlevoix and Emmet counties (Figure 3). These counties are found in the northern portion of the lower peninsula of Michigan and border Lake Michigan, which has one of the highest concentrations of PFASs within the Great Lakes ecosystem (Codling, et al., 2018). The county is comprised of three larger watersheds; Lake Charlevoix Watershed, Cheboygan River Watershed and Little Traverse Bay Watershed, with multiple smaller watersheds, each with inland lakes (including Lake Charlevoix, Michigan’s third largest lake) and river systems (TOMWC, 2019a). The three main watershed connect with and into two neighboring counties, Antrim and Cheboygan. All cities, townships and villages within Charlevoix and Emmet county acquire the needed water for the public water system from underground wells, with the exception of the City of Charlevoix, which pulls its water supply directly from Lake Michigan (TOMWC, 2019a).

Figure 3: Watersheds within Charlevoix and Emmet Counties. Image from the Tip of the Mitt Watershed Council, 2019. Tourism is the main industry for these counties, and they rely heavily on Lake Michigan and the other surface waters to fuel the economy. The land cover is mostly made up of forests (primarily beech, maple, white pine) and wetlands. These account for approximately 77% of the land cover, with agricultural lands consisting of 15% and the urban/small town areas making up 4% (TOMWC, 2019b). The growing season is longer and warmer than the surrounding areas due to the proximity of Lake Michigan and the many inland surface waters (EPA, 2017a).

1.4 Purpose of Study

The purpose of this study is to better understand what laws and regulations are currently in place and what is needed to improve protection of human health and the environment from PFAS contamination. There is much unknown regarding PFAS, including what exposure levels lead to human health concerns, how to minimize or eliminate PFAS contamination, and what effect PFASs have on the ecosystem. By assessing the current readiness of local governments and any implementation plans, as well as the impacts of PFASs, this study aims to identify knowledge gaps and what local governments need to be better equipped to deal with PFAS contamination.

This study will review relevant literature, to demonstrate if the lifetime health advisory levels (LTHA) set by the federal government are appropriate to protect human health, as well as review any proposed legislation or plans by state and local governments that could be used regionally to protect drinking water systems from PFASs. The study includes a desktop literature review and a survey to garner knowledge from local officials and professionals with expertise in drinking water supplies. The results and discussion will provide local and regional governments with assistance and tools to better manage the ongoing challenges associated with PFAS water contamination.

1.5 Research Questions

The following research questions are asked to understand how prepared the federal, state and local governments and groups are to address PFAS contaminated waters. The primary research question for this study is: are current laws, regulations and action plans sufficient to protect Michigan’s residents and their drinking water systems from PFAS contamination?

Secondary research questions include: (1) What laws, regulations and plans are in place or recently proposed to protect drinking water systems from PFAS contamination? (2) Is the current health advisory level of 70 ppt for PFOS and PFOA set at an appropriate level to protect Michigan’s residents? (3) What environmental, ecosystem, human, economic and socio-political impacts are associated with PFAS contamination? (4) Has the implementation of MPART improved the ability of the State of Michigan to identify and clean up PFAS contaminated sites?

Based on these research questions, three hypotheses were developed: (H1) Current laws and regulations have not protected Michigan’s residents from health effects associated with PFAS contaminated drinking water systems.

(H2) The current health advisory level of 70 ppt for PFOA and PFOS is set too high and will cause adverse impacts. (H3) Implementation of MPART has improved the ability to identify PFAS contaminated drinking water systems.

The goal of this research is to better understand the current efforts of the local, state and federal levels of government regarding PFAS contamination and to identify how the state and federal government can better assist local governments in protecting their residents. The desktop literature review will help in understanding impacts from PFAS contamination on the environment, human, economy, ecosystem and socio-political factors; including military impacts, as the armed forces are one of the greatest users of PFASs.

2 Desktop Literature Review There are multiple laws and regulations at the state and federal level that are connected to the safety of drinking water. These laws and regulations outline the parameters of natural and manufactured substances, and the levels of concentration that are deemed “unhealthy” for the public. Such regulations determine how local, state and federal governments should remediate contaminants, and mitigate the release. The following section provides a historical context of relevant laws, regulations and action plans, including proposed legislation that apply to PFASs.

2.1 Important Federal Legislation and Action Plans

The Clean Water Act of 1972 The Clean Water Act (CWA), originally the Federal Water Pollution Control Act of 1948, was amended in 1972 with other amendments and revisions to follow. The United States Environmental Protection Agency (EPA) administers the CWA and implements it throughout the United States. The CWA is one of the most powerful tools that the EPA has to regulate water quality, helping to address pollutant discharges, quality standards of contaminants in surface water and assess non-point source pollution.

While there are no direct mentions in the CWA to PFASs, there are multiple sections that apply. Within Section 101 of the CWA (§101), toxic amounts of any pollutants are banned and it further states that “the objective is to restore and maintain the chemical, physical and biological integrity of the Nation’s waters”. This section incorporates regulations to address both point and nonpoint pollutants. Section 104 further promotes national programs to be developed that deal with prevention, reduction and elimination of pollution and §108 provides specific protections to the Great Lakes.

The Safe Drinking Water Act of 1974 The Safe Drinking Water Act (SDWA) was first enacted in 1974 to protect the public’s health from issues connected to drinking water supplies. Like the CWA, it is federally regulated by the EPA, and in Michigan it is the primary tool that the MDEQ uses to ensure safe drinking water

for all residents and visitors. The primary focus of the SDWA is to set national standards through the National Primary Drinking Water Regulations (NPDWR), including maximum contaminant levels (MCL) and water treatment plans to remove contaminants.

On May 19, 2016, the EPA issued the current lifetime health advisory (LTHA) for PFOA and PFOS at 70 ppt (individual or combined); however, this is not enforceable or required. The only state to establish a regulated MCL is New Jersey. The MCL levels set by the New Jersey Department of Environmental Protection (NJDEP) include 13 ppt - Perfluorononanoic Acid (PFNA), 10 ppt - PFOA and 10 ppt - PFOS (NJDEP, 2019).

The EPA requires water companies and utilities to test for over 90 chemicals. PFASs is not one of these regulated contaminants but was added to the Unregulated Contaminant Monitoring Rule which is used by the EPA to collect data on chemicals that are suspected to be in drinking water and cause heath concerns. The third cycle was completed between 2013 and 2015 and is known as the Third Unregulated Contaminant Monitoring Rule (UCMR 3). Six PFAS chemicals were included in the List 1 Contaminant. The inclusion of PFOA and PFOS and the subsequent occurrence levels detected by the UCMR 3 prompted the current combined 70 ppt LTHA set by the EPA (EPA, 2017b).

Nationwide PFAS Action Plan In February 2019, the EPA announced the first nationwide PFAS Action Plan. Comprised of short-term solutions and long-term strategies, this plan aims to give needed tools to states and local governments to protect human health through any release and exposure (land, water and air); with emphasis in this study on water. The plan also endeavors to address PFASs sources rather than waiting for impacts to affect water systems and those who use them. The EPA determined that a nationwide PFAS Action Plan was needed after the National Leadership Summit in 2018, which required site visits to areas with direct PFAS impacts; and was also influenced by over 120,000 public comments left in regards to the need for more assistance by the federal government (EPA, 2019).

This action plan is comprised of six components; drinking water, clean up, enforcement, monitoring, research, and risk communication. The goals of each component is as follows (EPA, 2019c): 1. Drinking water- establish MCLs for PFOA and PFOS separately. The regulatory determination for this is expected by the end of 2019. 2. Clean up- lists PFOA and PFOS as hazardous substances, gives groundwater clean-up recommendations and will support locations with established contamination. In the original plan it was announced that removal actions for any site over 400 ppt for PFOA and/or PFOS would be immediate. This was later removed from the action plan. 3. Enforcement- allows the EPA to assist states and local communities with pollution and clean-up enforcement. 4. Monitoring- the EPA will suggest that PFASs be once again included in the monitoring list in the next Unregulated Contaminant Monitoring Program and for PFASs to be considered as additions to the Toxics Release Inventory. 5. Research- increase the methods of analysis so that more PFAS types be detected in samples and further research new technologies. 6. Risk Communication- The EPA will work with other federal agencies to develop a “PFAS risk communication toolbox” to assist states communicate risks with the public.

2.2 Important State of Michigan Legislation and Action Plans

Michigan Safe Drinking Water Act 399 of 1976 The intent of the Michigan Safe Drinking Water Act (MSDWA) is to supply the public with clean water and delegate authority and duties to the MDEQ through the Community Water Supply Program which protects community (year round/permanent) and non-community (non- year round, such as schools) water supplies. The MDEQ works with local health departments to monitor sites across the state to check for known contaminants. MSDWA closely follows the Federal SDWA Act of 1974 with regards to PFASs, including the lack of a set MCL. Currently there are no statewide drinking water standards related to PFASs in Michigan.

Natural Resources and Environmental Protection Act 451 of 1994 The scope of the Natural Resources and Environmental Protection Act 451 of 1994 (NREPA), is administered by the Michigan Department of Natural Resources (MDNR), and is designed to protect the environment and natural resources within the state of Michigan. This includes the protection of waters and control of discharge of harmful substances into the environment. The NREPA can provide environmental remediation with funds from the Environmental Fund, which is funded through the state’s treasury department.

Water resources protection (Part 31 of NREPA), specifies water quality standards that must be met in all state waters. Part 4 of the water quality standards regulates eight physical properties, including foams and dissolved solids/toxic substances, which PFASs is categorized by. PFASs are currently not directly stated in Part 4 but does qualify as a toxic substance. Currently this allows the state to monitor and asses PFASs at any level (Michigan.gov, 2006).

MPART Action Plan Recently, the MDEQ and Governor Gretchen Whitmer announced the MPART Action Plan, which includes building on current research to identify and address PFAS contamination within the state. This includes testing all of Michigan’s public drinking water systems, identifying and remedying communities that are over 70 ppt LTHA, working with the U.S. military to reduce the amount of PFASs that are used and released on bases and identifying PFASs concerns in wildlife and fish used for human consumption. They have brought together professionals from the health and environmental fields, along with government officials to complete these actions (Michigan.gov, 2019c). On March 26, 2019, Governor Whitmer directed the MPART team to establish MCLs for PFASs in Michigan by July 1, 2019, including directives to be able to enforce these guidelines. The regulations will be communicated to residents and other stakeholders by October 1, 2019 (The Office of Governor Whitmer, 2019).

2.3 Proposed Legislation and Action Plans

PFAS Action Act of 2019 (H.R. 535 and S. 638) The PFAS Action Act was introduced in the House of Representatives by Representative Debbie Dingell from Michigan on January 14, 2019 and in the Senate by Senator Thomas Carper from Delaware on February 28, 2019. This bill would require the EPA to identify PFASs as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. Currently the bills have been introduced and sent to committees for review. HR-535 is being reviewed by the Energy and Commerce subcommittee on Environment and Climate Change and the Railroads, Pipelines and Hazardous Materials Subcommittee on Transportation and Infrastructure. S-638 has been referred to the Committee on Environment and Public Works. (Congress, 2019a & h).

PFAS Detection Act of 2019 (H.R. 1976 and S. 950) The PFAS Detection Act of 2019 would require the United States Geological Survey (USGS) to carry out a nationwide survey of PFASs to detect as many types of PFASs as possible and to determine a standard of detection. HR-1976 was introduced on March 29, 2019 by Representative Daniel Kildee from Michigan. It has been referred to the Committee on Natural Resources. S-950 was introduced to the Senate on March 28, 2019 by Michigan Senator Debbie Stabenow. This version has been referred to the Committee on Environment and Public Works (Congress, 2019b & i).

PFAS Registry Act (H.R. 2195 and S. 1105) The PFAS Registry Act would require the Secretary of Veterans Affairs to start a registry for anyone who has been exposed to PFASs on military sites due to the release of aqueous film- forming foam (AFFF). This will monitor the health effects due to the exposure of PFASs for military members and to notify any members of treatments, studies, etc. that are available. H.R. 2195 was introduced on April 10, 2019 by Representative Chris Pappas of New Hampshire and has been referred to the Committee on Veterans' Affairs and the Committee on Armed Services. S. 1105 was also introduced on April 10, 2019, by Senator Jeanne Shaheen from New

Hampshire. This bill was sent to the Senate Committee on Veterans’ Affairs (Congress, 2019c & g).

Protecting Military Firefighters from PFAS Act (H.R. 1863 and S. 858) The Protecting Military Firefighters from PFAS Act, S 858, was introduced on March 24, 2019 by Senator Jeanne Shaheen of New Hampshire. Similar legislation, HR 1863, was introduced to the House of Representatives on March 25, 2019, by Representative Donald Norcross from New Jersey. This legislation would require that the Secretary of Defense be responsible for making blood testing available to determine exposure to PFASs available to firefighters who work for the Department of Defense. S.858 is currently being reviewed by the Committee on Armed Services, while HR1863 is being reviewed by the House Committee on Armed Services’ Subcommittee on Military Personnel (Congress, 2019 e & k).

VET PFAS Act (H.R. 2102) and Veterans Exposed to Toxic PFAS Act (S. 2013) The Vet PFAS Act (H.R. 2102) was introduced to the House of Representatives on April 4, 2019 by Representative Daniel Kildee of Michigan. It has been referred to the House Committee on Veterans’ Affairs. Similar legislation, Veterans Exposed to Toxic PFAS Act (S. 2013), was introduced to the Senate on April 3, 2019, by Senator Debbie Stabenow of Michigan. These bills would amend Title 38 of the United States Code, to mandate that medical and hospital care be granted to veterans, current members of the military and any dependents who were exposed to PFASs (Congress, 2019 f & l).

Prompt and Fast Action to Stop Damages Act of 2019 (H.R. 1567 and S. 675) Prompt and Fast Action to Stop Damages Act of 2019 would permit the Department of Defense (DoD) to provide uncontaminated water to areas that have been affected from PFASs due to the military. H.R. 1567 was introduced on March 6, 2019 by Representative Ben Ray Lujan of New Mexico and it is being reviewed by the Committee on Armed Services (subcommittee on Readiness), the Committee on Energy and Commerce and the Committee on Transportation and Infrastructure (subcommittee on Water Resources and Environment). S. 675 was introduced by

Senator Tom Udall of New Mexico on March 6, 2019. It is currently being reviewed by the Committee on Armed Services (Congress, 2019 d & j)

Senate Bill 14- A Bill to Amend 1976 PA 399 “Safe Drinking Water Act- Section 6 “(MCL 325.1006) On January 15, 2019, Michigan State Senator Brinks, introduced Senate Bill 14 to the Michigan Legislature which would make amendments to the SDWA. This amendment would add MCLs for PFOA and PFOS. The MCL will be individually set at 5 ppt for PFOA and PFOS.

2.4 Impacts

PFASs have been found globally in the atmosphere, soil and aquatic environments (Kabore, et al., 2018). In a 2012 test by the U.S. National Health and Nutrition Examination Survey, it was found that 98% of all individuals involved tested positive for levels of PFAS concentrations (Hu, et al. 2016). The following sections detail the impacts to the environment, ecosystem, humans, economy and the socio-political and military systems.

2.4.1 Environmental/Physical Impacts Detected PFAS profiles in the environment are known to move through several pathways (runoff, evaporation, seepage, direct discharge), partitioning and transformation processes as demonstrated in Figure 4. Figure 4 shows how PFASs move from production/usage into either the atmosphere, landfills or sewage treatment plants (STP) and the path showing how they end in the terrestrial or aquatic ecosystems (Dauchy, et al., 2017). PFASs have long range transport ability through both the atmosphere and water. Water transport is estimated to be two orders of magnitude higher than atmospheric transport. While any transport is concerning, the increased order of water transport has additional concerns because the majority of PFASs are found in oceans and sediment (Ahrens & Bundschuh, 2014). PFASs concentration within aquatic environments generally remains consistent with few fluctuations, while concentration in sediments tends to vary based on season and environmental conditions (Pignotti, et al., 2017). Environmental conditions such as organic content, temperature and salinity, along with type

specific properties of PFASs, determine how well the environment is able to cycle out PFASs. Short-chain PFASs tend to exhibit hydrophilic properties, which increase mobility, while long- chains are hydrophobic, allowing them to bind to other particles with increased accumulation.

Figure 4: Pathways of PFASs after production and usage into the environment and their ultimate fates. STP= sewage treatment plant (Ahrens & Bundschuh, 2014)

Combinations of PFASs have shown in experiment that the detrimental impacts to the environment multiplied (Ahrens & Bundschuh, 2014). Studies on partitioning behaviors have supported these findings, including a decreased ability to measure environmental impacts of short-chain PFASs in sediment, due to their ease in mobility out of sediment samples into nearby groundwater reservoirs or aquatic environments. This is concerning as the frequency of short- chain use is increasing, while there have been no improvements to understanding their impacts (Codling, et al., 2018).

Sites that commonly use AFFF’s as fire suppressants, such as airports and military bases, have groundwater with the highest recorded concentrations of PFASs in any aquatic environment. Many of these samples have tested higher than the current LTHA level (Backe, et al., 2013). Dauchy and colleagues (2017) tested multiple sites associated with prior use of AFFFs, including storage containers, a military airport, a civilian airport and a training facility for firefighters. The storage containers had been exposed to AFFFs at one time 28 years prior to the study and results

showed groundwater levels still testing above the LTHA level, supporting the evidence that PFASs are not able to degrade or bio transform rapidly. At both airport sites, every groundwater sample and half of the sediment samples detected PFASs. At the training facility, the groundwater tested positive for PFAS in one sample, while the sediment tested positive in all samples. PFASs concentrations within the vicinity of AFFF use are among the highest recorded in groundwater and sediment samples (Dauchy, et al. 2017).

2.4.2 Ecosystem Impacts

PFASs, especially long-chain, are capable of altering the functional ability of cell membranes within the producer level of food webs, such as algae. This lowers the food quality for algae eating organisms, allowing higher trophic level organisms to be both directly and indirectly impacted by PFASs, as seen in Figure 5. This shows how grazing, filtering, lead shredding organisms and higher level and complex organisms can be affected by PFASs alterations in lower trophic and producer levels of food webs. Reproduction, development and organismal energy usage for maintenance and growth are all affected by the related stressors. PFASs are directly responsible for altering leaf composition and impacting the bacteria that commonly change the chemical structure of leaf materials. This reduces the nutritious quality of the leaf material affecting fitness levels of higher trophic levels and ultimately the health of the entire ecosystem (Ahrens & Bundschuh, 2014).

Figure 5: Possible indirect pathways of PFASs entering autotrophic and heterotrophic food webs (Ahrens & Bundschuh, 2014)

PFOS is the dominant PFAS detected in most ecosystems and food webs due to the high level of bioaccumulation and biomagnification. It is generally found in concentrations of up to three times as high as PFOA. It has a high binding ability to serum albumin and fatty acid proteins in many organisms, specifically freshwater aquatic invertebrates. The level of bioaccumulation can also be affected by the structure of the specific PFAS, including chain length, branched vs. linear chain and the presence of functional groups (Ahrens & Bundschuh, 2014). High concentrations of PFOS were found in many Great Lakes fish, Pacific and Atlantic fish and shellfish species (Fromme, et al, 2009). The European Food Safety Authority reported that PFASs have been consistently found in fish, seafood, meat, eggs and meat byproducts (Olsen, et al., 2017).

As PFASs bioaccumulate and biomagnify within food webs it negatively impacts those individuals in the higher trophic levels with greater frequency (Lipton & Turkewitz, 2019a). In Michigan, as fish and wildlife are now being tested for PFASs, resource managers are experiencing how widespread and invasive this issue is and will become. In 2018, Michigan was

the first state to issue a do not eat advisory for deer killed within a five-mile radius of Wurtsmith Air Force Base in Oscoda due to the deer testing positive for PFAS contamination. Currently, there are 17 rivers, lakes and streams in Michigan that have issued do not eat advisories for fish due to high levels of PFAS contamination (Matheny, 2018).

2.4.3 Human Impacts

Humans are exposed to PFASs through diet, drinking water, air and dust. It is thought that diet and drinking water are the two most direct pathways of exposure (Gebbink, et al, 2015). Figure 6 demonstrates possible pathways for PFASs to enter food sources and drinking water supplies. It shows how groundwater, soil, and residential homes can be exposed to PFASs further exposing humans through ingestion or contaminated materials that they live in or use in their daily life (Michigan.gov, 2019a). While overall exposure has been declining in the United States over the last fifteen years due to the elimination of PFOA and PFOS in manufactured goods, the half-lives of these substances range between 3.8 and 8.5 years (Daly, et al., 2018). In 2011, the CDC performed the National Health and Nutrition Examination Survey (NHANES) on a representative sample of people over the age of 12 in the U.S. The average PFASs found in blood levels were: ● PFOA Average = 0.0021 ppt (95% of the general population at or below 0.0057 ppt) ● PFOS Average = 0.0063 ppt (95% of the general population at or below 0.021 ppt) ● Perfluorohexane Sulfonic acid (PFHxS) Average = 0.0013 ppt (95% of the general population at or below 0.0054 ppt) (ATSDR, 2017)

Figure 6 PFASs Cycle and Pathways to Food Sources (Michigan.gov, 2019a)

PFAS levels in blood serum have tested higher in men than women. It is believed that this is due to female elimination of serum during menstrual blood losses and transfer during lactation and pregnancy. While studies have been conflicting relative to PFAS concentrations by age, recent studies have found that concentration levels increase with age, with the exception of very young children who test at much higher levels. It is believed to be elevated at early ages due to the transfer between mother and child during breastfeeding and through the placenta during pregnancy (Grandjean & Clapp, 2015). It is hypothesized that PFASs exposure has the greatest negative impact during pregnancy and infancy through adolescence, with the highest levels of PFAS found at 20 months of age (Winkens, et al., 2017). PFAS contamination is linked to changes in liver function, cardiometabolic disease/disorders, thyroid or hormone function, growth and development, immune function and certain cancers (Daly, et al., 2018).

Liver/Kidney Function A study completed between 2008-2011 studied liver function of adults that had been exposed to PFOA in West Virginia, near the DuPont Washington Works plant, where it was used from the 1950’s-1990’s. It was found that many of the participants suffered from hepatitis, fatty liver, enlarged liver, and cirrhosis. PFOA serum concentrations were associated with liver toxicity in these individuals due to the higher alanine aminotransferase levels, which is a marker of liver damage (Darrow, et al., 2016). Renal disease was found in children with high concentrations of PFASs, which causes increased levels of uric acid (Rappazzo, et al., 2017).

Cardiometabolic Coronary artery disease, stroke, type 2 diabetes, obesity, high levels of cholesterol (total cholesterol, LDL and HDL) and triglycerides have all been studied in association with high PFAS concentration levels. Many of these studies have found varying levels of correlation between PFASs exposure and high levels of total cholesterol, LDL, triglycerides, and obesity. One study found a positive correlation between type 2 diabetes and elevated PFAS concentrations (Rappazzo, et al., 2017).

Thyroid/Hormone Function Exposure to PFASs is linked to a negative disruption of thyroid functions and hormones (Laitinen, et al., 2014). Hypothyroidism has been found in individuals with high concentrations of PFOA in serum as well as increased levels of thyroid stimulating hormone in children (Rappazzo, et al. 2017).

Growth and Development Some childhood developmental milestones were delayed and showed correlation with PFASs exposure, specifically PFOS, including low muscle tone, delayed mental development at 6 months of age (caught up to average at 18 months), possible ADHD connections, increased hyperactivity and behavioral problems, inattention, impulsivity and oppositional defiant disorder (Rappazzo, et al., 2017).

Immune Function A reduced immune response in children ages 5-7, with high exposure concentrations of PFASs, has been seen when routine childhood immunizations have been given (UNEP, 2013). Differences in antibody levels for these children have been seen after influenza and rubella vaccinations. These children also tend to be more predisposed to a higher occurrence of the common cold and gastroenteritis (Grandjean & Clapp, 2015). A Japanese study found that there is a connection between young children (under 5) who had long-term prenatal exposure to perfluoroalkyl acids (PFAA) and the diagnosis of asthma and other allergy type symptoms and disorders (Goudarzi, et al., 2016).

Cancer The EPA has concluded that there is a suggestive risk of cancer caused by PFOA. A science advisory group within the EPA has recommended that PFOA be considered a carcinogenic agent to humans (EPA, 2006). Studies of DuPont and 3M exposed employees have shown higher cases of testicular, prostate, pancreatic, kidney, ovarian cancer and non-Hodgkin lymphoma (Grandjean & Clapp, 2015). Cancer caused by PFASs appears to be limited to individuals who have worked at manufacturing locations (Sunderland, et al., 2019).

2.4.4 Economic Impacts

The economic impacts surrounding PFASs are not fully understood. As the effects caused by PFASs are starting to become recognized, further collaboration between government agencies, environmental organizations, industry giants, and health care industries must become stronger. Research has been ramping up, including a $2.5-million-dollar venture to develop a non-PFAS firefighting foam, but this will need to continue in order to fully understand the economic impacts and costs. PFOA and PFOS are being phased out and replaced with other chemicals that have their own health and environmental concerns. These concerns have not been quantified (Matheny, 2019). At this time, it is difficult to determine who will be held responsible for these costs. Many of the manufacturers of PFASs are known, however, much of the contamination is

no longer point source and instead has made its way around the world through cycling processes or travelled and accumulated through food webs.

Many states and local governments are in the infancy stages of providing financial assistance to communities for PFAS related needs. Examples include Michigan, which has so far used $23.2 million for testing and monitoring public drinking water systems. North Carolina spent $9 million in 2018 for clean-up, while New Hampshire spent $14 million in clean-up costs and expects at least another $30 million to be used in remediation projects (SaferStates, 2019). The U.S. Military has spent $200 million to test sites and drinking water systems at bases which used AFFFs. They are estimating that it will cost taxpayers a minimum of $2 billion for clean-up at the 126 bases that tested above the current LTHA limit (SaferStates, 2019).

There are approximately six million U.S. residents with drinking water supplies testing over 70 ppt. If the EPA, or individual states lower the current LTHA, this number will greatly increase, along with the funding needed to provide safer water (bottled water and filters) and clean-up. Currently there are 16 known industrial sites within 11 states that will need massive clean-up efforts as they have been identified as Superfund sites (SaferStates, 2019). Projected health care costs are currently just approximations as well. As with most pollutants or contaminants, negative impacts are continually discovered even after the use of the contaminant has been phased out. While the majority of exposure to PFASs occurs through manufacturing or drinking water, food sources in Michigan are negatively influenced. With do not eat advisories being set, the commercial hunting and fishing industry is likely to lose up to 171,000 jobs and $11.2 billion in profits (Matheny, 2019). Health care impacts are currently being researched and as we learn more, costs will be more clearly defined. It is estimated that it will cost $13-14 billion to care for infants who were exposed to PFASs during pregnancy as it is possible they will have lifelong impacts of this exposure. Other healthcare costs have declined in their estimation due to the PFOA/PFOS phase out. It was originally projected to be close to $3 billion but has been reduced to $350 million (SaferStates, 2019).

In 2014, tourism generated $22.8 billion from 113.4 million domestic and international visitors and supported 214,000 jobs in Michigan alone (Michigan.gov, 2015). Many smaller towns, which rely heavily on revenue from tourism, are concerned that PFASs will deter tourists from visiting and could lower property and real-estate values. Real estate agents have noted that buyers are no longer willing to purchase homes close to former military bases. In Oscoda County, Kalitta Air is the largest employer with 1400 employees. They are interested in expanding into the former air force base, which would create at least 150 more jobs. However, the company will not proceed without protection from the U.S. government. They are concerned that they will be held liable for any pre-existing PFAS contamination. Currently the Air Force has refused to take on any responsibility and therefore the expansion has not proceeded (Matheny, 2019).

2.4.5 Socio-Political Impacts

The U.S. Navy and The 3M Company, developed AFFF’s as a fire suppression in the 1960’s. The United States Military is one of the largest users of PFASs due to the continued use of AFFFs (Anderson et al, 2016). AFFF’s are used to extinguish fires made from hydrocarbon fuels and chemical solvents by covering the fire and preventing any contact with oxygen (Laitinen, et al., 2014). Since the 1970’s, 3M has commanded the AFFF market, but in 2000 it announced that it would voluntarily phase out PFOS used in AFFFs. Instead, they are using similar fluorinated chemicals that are short-chained. The drawback to using short-chained chemicals as a fire suppressant is that a much higher concentration is needed to reach an efficiency that is acceptable and even with this it is still not comparable to long-chained PFASs efficiency (Daucy, et al., 2017). In a 2016 study, Anderson and colleagues tested ten active military sites and found PFAS contamination within the groundwater, soil (surface and subsurface), sediment and surface waters at all ten sites. PFOS was found to be of the highest concentration but PFOA was also detected. This study confirms an early analysis by Daucy and colleagues, which found that groundwater and soil at or near military bases tend to have the highest PFAS contamination of any tested site within the U.S. (Laitinen, et al., 2014).

The DoD directed all military departments in 2016 to test bases for PFOA and PFOS in any system in which the DoD supplies the drinking water. Figure 7 is a summary of these results divided based on military branch, including Army, Navy/United States Marine Corps (USMC), Air Force and Defense Logistics Agency (provides logistics support to each branch). The figure shows how many areas have known PFOA/PFOS releases, the number of sites that tested higher than the EPA’s LTHA, the number of groundwater wells tested and the number of wells that tested higher than the EPA’s LTHA. Further testing of off-base sites was completed in 2017. 60% of groundwater wells tested showed levels above the EPA’s LTHA and 22% of known or suspected release sites show contamination above that level (Sullivan, 2018).

Figure 7: DoD Known/Suspected Release site testing results for PFOA/PFOS (Sullivan, 2018)

While the DoD has been proactive with testing the groundwater at contaminated sites, they have not been as compliant with removal action plans. The original EPA Action Plan, which was submitted to the White House Office of Management and Budget for final approval, was met with major objections from the DoD. These objections were over the suggested guidelines that required cleanups at federally controlled sites to prevent seepage into groundwater and the inclusion of an immediate removal plan for any site that tested over 400 ppt for PFOA/PFOS (Lipton & Turkewitz, 2019b). The DoD has been very vocal regarding the language that was used in this Action Plan, specifically in terms of the addition of “immediate” and brought their concerns to the White House. In April 2019, the EPA released new proposed guidelines that has removed this immediate removal and instead proposes a more long-term plan with future studies

to be conducted prior to removal (Lipton & Turkewitz, 2019a). Multiple local and state governments, including the State of New Mexico, have filed lawsuits against the DoD because of this (Lipton & Turkewitz, 2019b).

2.5 Knowledge Gaps

The literature review provides a wealth of information regarding the current and proposed legislation regarding PFASs, as well as the impacts associated with PFAS exposure. However, the majority of the research has occurred outside of Michigan and there has been little research done with regards to how well local governments are prepared to deal with contamination. The recent additions of the National PFAS Action Plan, the Michigan PFAS Action Plane and MPART have great potential to be positive influences for local governments to use as road maps when dealing with PFAS contamination. All of these are so new that as of yet they are just being introduced or are used in theory and not in practice.

This research with focus on local Northern Michigan officials, both governmental and employees of environmental organizations and three factors of PFAS contamination all in an attempt to determine their readiness to deal with PFAS contamination if found in this area. The first is if they are already familiar with any PFAS policies and if so, which do they participate with. Secondly, their impressions of the current health advisories in place for PFOA and PFOS will be inquired. Lastly, this research will examine if they are familiar with MPART, if they believe that MPART is of value and what more would they wish MPART assist in.

3 Materials and Methods

The research section of this study includes a desktop literature review, survey and analysis of survey responses. The desktop literature review will include documents at the federal and state levels, while the survey focuses on local and state levels of government and environmental organizations.

3.1 Desktop Literature Review

The desktop review will provide essential information regarding four of the secondary research questions (Section 1.5) in the following manner:

Secondary Research Question 1: What laws, regulations and plans are in place or recently proposed to protect drinking water systems from PFAS contamination? Evaluation of current federal and state laws and regulations, and recently proposed regulations or amendments will showcase important aspects that are in place to protect drinking water supplies from PFAS contamination, as well as plans that are in place that address actions necessary for removal.

Secondary Research Question 2: Is the current health advisory level of 70 ppt for PFOS and PFOA set at an appropriate level to protect Michigan’s residents? Evaluation of the draft proposal assessment from Center for Disease Control (CDC) and the Agency for Toxic Substances and Disease Registry (ATSDR) has suggested that the MCL rates for PFOS and PFOA be lowered from a combined health advisory level from 70 ppt to 7 ppt for PFOS and 11 ppt for PFOA (ATSDR, 2019).

Secondary Research Question 3: What impacts are associated with PFAS contamination? Researching this question will assist in assessing the impacts to socio-political (military), economic, ecosystem, environmental and human health from PFASs contamination.

Over 40 Federal and State of Michigan documents and 52 peer reviewed scientific research articles were assessed for connections to PFAS contamination through the literature review process. A flow chart was created to summarize the researched impacts to the environment, ecosystems, human health, economy and socio-political scene. Tables were created to summarize the current and proposed legislation and action plans and graphs were devised to determine which researched impacts are associated with each piece of legislation. The graphs are color coded to match the impact flow-chart.

3.2 Survey

To supplement the desktop literature, a survey was conducted to collect information from public sources. The survey was sent to township, city and county elected officials and staff from local and statewide environmental organizations. Results from the survey will be used in conjunction with the desktop literature review for secondary research questions two and three. The survey will also assess secondary research question four (Has the implementation of MPART improved the ability of the State of Michigan to identify and clean up PFAS contaminated sites?).

3.2.1 Survey Strategy

The survey was aimed to reach individuals who work with drinking water supplies, primarily workers in Charlevoix or Emmet County, with a few subjects that work elsewhere in Michigan. It was written with the purpose to collect information regarding the county, city or organization. Survey subjects were selected based on their position within their organization or government. Local governments, water treatment plant managers, water department managers and township/city/county managers were invited to participate in the survey. The local tribal organization, Little Traverse Bay Bands of Odawa Indians (LTBB) employees that work with water quality were invited to participate in the survey. Other survey participants included, staff members of environmental groups that focus on local waters. The survey was set as a google form and was sent to 59 possible participants through email, sent out on April 10, 2019 with follow-up reminder emails sent on April 15, 2019 and April 22, 2019. Of those who were

requested to fill out the survey, 12 worked for an environmental organization, 8 were employed through LTBB and 39 were employees or elected government officials. Responses were sent between April 10, 2019 and May 6, 2019, with 10 of the 12 received within 24 hours. The majority of the individuals and their email addresses were located through city, county or the organization’s website. According to Saleh and Bista (2017), those most likely to participate in a survey have innate interest in the survey material. Using this information, it was theorized that those working in the environmental fields would be more likely to participate in this survey, as they have a more defined professional scope that closely matches the content of this survey. Local government officials have many fields that their job represents and may not be as interested in environmental issues. While the survey participants were not asked to give their names, they were asked to give their job title and organization or county that they work for, all of which is public information. Of the total 12 that responded, two are employed at environmental organizations (16.7%), two work for LTBB (25%) and eight are involved in local government (20.5%). All results published will not provide any information that identifies an individual. The survey description and consent statement are included in Appendix B.

3.2.2 Survey Questions 1. What is your title/position and what organization (or county/city/township) do you represent? 2. Does your organization participate in any programs and/or policies to address per and polyfluoroalkyl substances (PFAS) contamination in drinking water supply? 3. If yes, what programs and or policies does the organization participate with? 4. What issues take precedence to PFAS contamination in the organization you participate with? 5. Do you feel that your organization is prepared to deal with PFAS contamination if it is detected in drinking water systems? 6. If yes, please explain this process. 7. If no, why is this the case or what does your organization need in order to be better prepared?

8. Currently, the regulated level of PFOA and PFOS (the two most common PFAS contaminants) is set at 70 ppt (lifetime level). Do you believe that this number is set at an appropriate level to ensure that Michigan residents are protected from these contaminants? 9. If no, what would you propose is a more appropriate level of contamination that Michigan should be testing for? 10. Are you familiar with Michigan PFAS Action Response Team (MPART)? 11. If yes to #10, do you believe that MPART has adequately assisted organizations in dealing with PFAS contamination? 12. If no #11, what more would you like MPART to do or what services would you like them to add? 13. Is there anything else you would like to share about any planning/policies in regards to PFAS water contamination in context with your county or organization?

The majority of the survey questions are open-ended to allow the respondent to include as much information as possible and to use responses for multiple research questions when possible. Any information that is not relevant to the research questions is not included in the results.

4 Results

The results section is divided into two parts: Desktop Literature Review Results and Survey Results. The results from the desktop literature review correspond to all three hypotheses. The survey results relate to H2 and H3. Each section will include the hypothesis and analysis, including tables or charts.

4.1 Desktop Literature Review Results

H1. Current laws and regulations have not protected Michigan’s residents from health effects associated with PFAS contaminated drinking water systems. H1 was not rejected through desktop analysis results. All four results support this hypothesis. Result 1 exhibits that federal laws are not inclusive with regards to protection from PFASs. There is no direct mention or protections from PFASs within any part of the CWA. Within the SDWA, LTHA exist for PFOA and PFOS, and six PFASs have been included as a List 1 Contaminant in UCMR 3. This leaves thousands of PFASs without advisory limits. The MCL levels for PFOA and PFOS are currently voluntary and non-enforceable by any federal agency. The proposed National PFAS Action Plan recently removed the immediate removal plan for [PFAS] levels above 400 ppt within the cleanup standards. Result 2 indicates that current state laws are not adequately protecting Michigan residents. There is no statewide MCL for any PFAS, no statewide drinking water standards specific to PFASs within MSDWA, and there is an absence of inclusion of PFASs within Part 4 of the NREPA. Result 3 shows that both the current and federal laws are not enough to protect from PFAS impacts as six federal laws were introduced separately to the House of Representatives and the Senate with the first four months of the 116th Congress, which began on January 3, 2019. All proposed federal laws are inclusive of all PFASs, as opposed to most current legislation which includes only PFOA and PFOS. Michigan introduced one legislation piece to the Michigan Senate which would set new MCLs to replace the current national EPA LTHA in Michigan. Result 4 reveals the connection between the lack of current protection through federal and state laws and regulations and the negative impacts associated with exposure to PFASs.

H2. The current health advisory level of 70 ppt for PFOA and PFOS is set too high and will cause adverse impacts. H2 was not rejected through desktop analysis results. Results two, three, and four support this hypothesis. Result 2 shows that MPART has completed testing on 1744 samples from Public Water Supplies, Schools, Childcare/Head Starts and Tribal Water Supplies. Of these samples, only two tested higher than 70 ppt for PFOA and PFOS, but 177 tested positive for PFASs and 62 sites have been identified for further quarterly testing (Michigan.gov, 2019c). These 62 sites fall between 10-70 ppt and would be included in the remediation efforts if the MCL in Michigan are set at 5 ppt for PFOA and PFOS individually. Result 3 indicates that there is a need for lower limits on PFOA and PFOS as Michigan has introduced new legislation that would not only set drastically lower MCL than the current EPA voluntary LTHA levels for PFOA and PFOS, but also separates these two PFASs into separate categories of exposure. Result 4 shows that the human health effects are becoming too numerous at the current level and need to be reduced in order to curb how many people are greatly affected.

H3. Implementation of MPART has improved the ability to identify PFAS contaminated drinking water systems. H3 was not rejected through desktop analysis results. Result 5 supports this hypothesis as it demonstrates how MPART’s recent testing of public water supplies identified two locations with PFOS/PFOA concentrations above 70 ppt. Due to this testing, alternative water sources were provided to residents and students at these locations until their water supply was deemed below 70 ppt.

The breakdown of the desktop literature results follows:

Desktop Literature Review: Result 1 Current Federal Regulations and Laws

Federal Regulations PFASs included in PFAS Related Regulations and Laws regulation

Regulate pollutant discharges, quality No specific inclusion Clean Water Act standards in surface water of PFAS

Safe Drinking Water Lifetime Health Advisory level set at 70 ppt Act (lifetime combined) PFOA, PFOS

Third Unregulated Contaminant Included in List 1 Contaminants to be PFOA, PFOS, PFNA, Monitoring Rule monitored PFHxS, PFHpA, PFBS

Nationwide PFAS MCL set, Clean-up guidelines, Enforcement, Action Plan Monitoring, Research, Communication PFOA, PFOS

Table 2 Desktop Literature Review Result 1: Summary of Current Federal Regulations and Laws Regarding PFASs

Figure 8 Desktop Literature Review Result 1 Chart 1

Figure 9 Desktop Literature Review Result 1 Chart 2

The majority of current federal legislation is connected to PFOA and PFOS, not PFASs in general (See Table 2 and Figure 9). The Nationwide Action Plan for PFAS is the only piece of federal legislation that includes ties to all five impacts (See Figure 8). The impacts are referenced by the different colors in the stacked bars: environmental/physical (blue), ecosystem (red), human (yellow), economic (green) and socio-political (orange). This color scheme is used throughout the result section. Impacts to humans and the economy were included most frequently. Four out of the five federal legislations include reference to PFOA and PFOS. One piece does not specifically include any PFASs and another piece includes PFNA, PFHxS, PFHpA and PFBS in addition to PFOA and PFOS.

Desktop Literature Review: Result 2 Current Michigan Regulations and Laws

State Regulations and PFAS Regulations PFASs included in regulation Laws

Follows National SDWA Michigan Safe Drinking Regulations, monitors sites for Water Act contaminants PFOA, PFOS

Natural Resources and Protects environment and resources No specific inclusion of PFAS Environmental from known contaminants, regulates but is monitored as foam and Protection Act foams/dissolved toxins dissolved toxin

Tests all public drinking water systems, identifying sites > 70 ppt, MPART Action Plan identifies wildlife/fisheries concerns, sets MCL for PFASs PFOA, PFOS

Table 3 Desktop Literature Review Result 2: Summary of Current Michigan Regulations and Laws Regarding PFASs

Figure 10 Desktop Literature Review Result 2 Chart

Figure 11 Desktop Literature Review Result 2: Location of known PFASs contamination sites (EWG, 2019)

Similar to the current federal legislation, Michigan regulations and laws only address PFOA or PFOS, if included at all (See Table 3). MPART includes references to all researched impacts, while the MSDWA and NREPA include impacts to the environment, ecosystems, human and economic but do not make direction mention to the socio-political impacts as shown in Figure 10. Figure 11 graphically shows how concentrated PFAS contamination is in Michigan. PFAS contamination is divided into three groups, found on military sites (purple dot), detected in drinking water samples (blue dot) and “other” sites (red dot). Figure demonstrates the high level of PFAS contamination in comparison to other parts of the country and how the need for further legislative protections is essential.

Desktop Literature Review: Result 3 Proposed Federal and Michigan Regulations and Laws

Proposed State and Federal PFASs Included in PFAS Related Regulations Legislation Regulation

Identify all PFASs as hazardous PFAS Action Act substances All PFASs

Determine a standard for detection PFAS Detection Act and conduct a nationwide survey of As many as possible PFAS contamination with current technology

Start a registry to identify all humans PFAS Registry Act exposed to PFASs on military sites and monitor any health effects All PFASs

Ensuring availability of blood tests to Protecting Military Firefighters determine PFAS exposure to from PFAS Act firefighters working for the DoD All PFASs

Mandates that medical and hospital care be granted to veterans, current Vet PFAS & Veterans Exposed military members and their to Toxic PFAS Act dependents who were exposed to PFAS All PFASs

Requires the DoD to provide All PFASs Prompt and Fast Action to Stop uncontaminated water to areas that Damages Act have been affected by the military's use of PFASs in AFFFs

Amends the MSDWA to add MCL Michigan Senate Bill 14 limits of 5 ppt PFOA and PFOS

Table 4 Desktop Literature Review Result 3: Summary of Proposed Federal and Michigan Regulations and Laws Regarding PFASs

Figure 12 Desktop Literature Review Result 3 Chart

The greatest difference between the proposed and current legislation is that all PFASs are included in the majority of the proposed legislation (See Table 4). All of the proposed federal laws and regulations include all forms of PFASs, while the proposed legislation in Michigan is strictly to set MCL levels for PFOA and PFOS. Figure 12 demonstrates that PFAS Action Act and Protecting Military Firefighters from PFAS Act include reference to all five research impacts, while each of the others has referenced three impacts. The current legislation has little focus on socio-political issues, while all but one of the proposed legislations include it in some form.

Desktop Literature Review: Result 4 Summary of Impacts from PFAS contamination

Figure 13 Desktop Literature Review Result 4 Flow Chart

Figure 13 summarizes the detrimental impacts to the environmental/physical (blue), ecosystem (red), human (yellow), economic (green) and socio-political (orange) with regards to PFASs contamination and exposure.

Desktop Literature Review: Result 5 Contamination Results in Michigan with Elevated Levels of PFOA/PFOS (combined total >70 ppt).

Total Current # of PFOA/PFOS Other PFAS PFAS residents or Resolution Levels (ppt) Levels (ppt) (ppt) students

City of Parchment- Water is now Treatment Plant supplied from the Entry 1410 190 1600 3174 City of Kalamazoo

Using bottled water Robinson for drinking and Elementary School, PFOS = 101 PFBS = 14 cooking. Long-term Grand Haven MI PFOA = 9 PFHxS = 20 solution has not been Total 110 Total 34 144 362 determined

Table 5 Desktop Literature Review Result 5: Michigan Sites with PFOA/PFOS levels above 70 ppt

Figure 14 Desktop Literature Review Result 5 Chart

Table 5 and Figure 14 show the current concentrations of PFOA, PFOS and total PFAS at the two Michigan sites, identified through MPART testing, with levels above the LTHA. The alternative water source and number of people affected are included in the table. The number of humans affected are represented by the population of the city of Parchment and the number of students attending Robinson Elementary School at the time of testing. It is not known how long the concentrations of PFOA/PFOS were elevated, therefore it is impossible to know the exact number of humans affected by these contaminated water sources, as many may have moved from this area over time. The bars in the chart are color coded to represent the different tested substances; blue is combined PFOA and PFOS, red is other PFASs, and yellow is the total PFAS concentration level.

4.2 Survey Results

The external survey responses permitted local officials and employees of environmental organizations to share their interpretation of how or if MPART is helping to protect Michigan residents from PFAS contamination in drinking water supplies and what their organization’s (or county/city/township) plan is to deal with PFASs. A total of 59 individuals were invited to participate in the survey, with 12 individuals responding, for a response rate of 20.33%. This response rate is above the average for an external survey, which is 10-15% (Fryrear, 2015). H2 and H3 were covered in this survey.

H2. The current health advisory level of 70 ppt for PFOA and PFOS is set too high and will cause adverse impacts. H2 was not rejected by the survey results. The responses from question 8 (Currently the regulated level of PFOA and PFOS (the two most common PFAS contamination) is set at 70 ppt (lifetime combined level). Do you believe that this number is set at an appropriate level to ensure that Michigan residents are protected from these contaminants?) were used to test. Of the total 12 individuals that responded to the survey, eight responded to question 8. If the respondents answered no, they were asked question 9 (If not to #8, what would you propose is a more appropriate level of contamination that Michigan should be testing for?) Of those responses,

many answered that they were “unsure” or that Michigan should be testing for levels lower than 10 ppt.

H3. Implementation of MPART has improved the ability to identify PFAS contaminated drinking water systems. H3 was rejected by the survey results. The responses from question 10 and 11 (10- Are you familiar with Michigan PFAS Action Response Team (MPART)? 11- If yes to #10, do you believe that MPART has adequately assisted organizations in dealing with PFAS contamination?) were used to test this hypothesis. Of the total 12 responses to question 10 there were seven who responded that they were familiar with MPART. Of the seven respondents familiar with MPART, one responded that MPART has adequately assisted organizations, two responded that MPART has not adequately assisted organizations and four answered that did not have enough information or were unsure. Question 12 asked respondents what more could MPART do to help Michigan residents with PFAS contamination. The majority of the answers focus on increased funding, with mention of training, increased research/testing for health impacts and transparency of data.

The survey results are listed below: Q1: What is your title/position and what organization (or county/city/township) do you represent? The responses included city and township officials (township supervisor, city administrator/manager, chief water operator, public water utilities operator) as well as employees of environmental and tribal organizations (watershed policy director, environmental concerns specialists) (See Figure 15). The responses have been organized into three groups: city, township and environmental/tribal organization.

Figure 15 Survey Results Question 1

Q2: Does your organization participate in any programs and/or policies to address per- and polyfluoroalkyl substances (PFAS) contamination in drinking water supplies?

Figure 16 Survey Results Question 2

Q3: If yes to #2, what programs and/or policies does the organization participate with? There were five respondents who answered yes to the previous question.

Responses

We are new to the management of PFAS, but ultimately, we would like to be involved in the formulation of water quality standards specific to PFAS/PFOA

We are doing surface water testing

We do participate in AWOP (Area Wide Optimization Program)

Legislative and administrative strategy/advocacy. Outreach, education, monitoring.

Our water has been sampled by the DEQ as part of their PFAS sampling process.

Table 6 Survey Results Question 3

Q4: What issues take precedence to PFAS contamination in the organization that you participate?

Responses

Geographic coverage and drinking water

Too many to note: lots of water quality monitoring and restoration work

None

We work on a variety of issues concurrently.

Based on the detection levels in our system, there are other water quality issues that would more likely impact health than PFAS based on current guidance.

Lead and Copper leaching and disinfection by-products (DPSs)

Table 7 Survey Results Question 4

Q5: Do you feel that your organization is prepared to deal with PFAS contamination if it is detected in drinking water systems?

Figure 17 Survey Results Question 5 The response “we would not be responsible for addressing the contamination, we work with the agencies responsible for education and outreach to assist” corresponds to “other” in Figure 17.

Q6: If yes, please explain this process. Question 5 had three “yes” responses, to which all responded to question 6.

Responses

Not sure. Not my area

We will follow the guidance and direction of the Michigan DEQ

There are several large treatment plants in the area. All of them draw their water from intakes in Lake Michigan which, as far as I know, is not at risk from PFAS contamination.

Table 8 Survey Results Question 6

Q7: If not, why is this the case or what does your organization need in order to be better prepared? Seven respondents answered no to Q5. Their responses are:

Responses

Funding and resources

Lack of funding, resources or tools

PFAS is a relatively new issue as far as management goes. New issues take a while to fully understand/manage and while we are a smaller governmental agency, we are already busy monitoring various water bodies for various parameters. To include PFAS/PFOA into the fold, we will need to find a way to accommodate new management practices into our monitoring/management strategy

Better technical answers and finances

Research and funding for monitoring and identification of source(s), treatment technologies, and evaluation of human health impact.

We have no municipal water supplies, only Health Department approved water wells. Until we test for groundwater we do not know what help we need.

Our township is not a supplier of municipal water

Table 9 Survey Results Question 7

Q8: Currently, the regulated level of PFOA and PFOS (the two most common PFAS contamination) is set at 70 ppt (lifetime combined level). Do you believe that this number is set at an appropriate level to ensure that Michigan residents are protected from these contaminants? There were eight responses to this question. Six responded no and two responded yes (See Figure 18).

Figure 18 Survey Results Question 8

Q9: If no to #8, what would you propose is a more appropriate level of contamination that Michigan should be testing for?

Responses

We don’t know enough about how it is affecting our plants, wildlife and environment

I only clicked no because I’m not educated enough to really know what a “tolerable” level of these contaminants should be.

Not sure

Less than 10 ppm

Drinking water standard should be set below 10 for the entire class of PFAS

Responses (continued)

The amount of research that has been done into PFAS is relatively minimal at the moment as far as I know, and I think if they want to implement such a low limit on PFAS they should first determine more accurately how harmful/toxic it is first. Instituting such low limit could become very costly to treatment facilities/communities if this limit is upheld at such a stringent level.

Table 10 Survey Results Question 9

Q10: Are you familiar with Michigan PFAS Action Response Team (MPART)?

Figure 19 Survey Results Question 10

Q11: If yes to #10, do you believe that MPART has adequately assisted organizations in dealing with PFAS Contamination? All seven “yes” responses from #10 responded to #11. The responses fall into three categories: yes, no and not sure (See Figure 20). The “not sure” responses include comments such as, “I’ve

heard the group exists, but I don’t know what, if any, action they have taken or how they are or are not assisting” and “I don’t know enough about them to really know. I’ve only heard of them at a workshop/seminar.”

Figure 20 Survey Results Question 11

Q12: If no to #11, what more would you like MPART to do or what services would you like them to add?

Responses

All water in Wilson (twp) is well water and is handled by the Northwest Michigan Health Department

Funding, education and local assistance

The real issue is financial

Sorry, do not understand the issues.

Responses (continued)

Testing of human health impacts for impacted communities. Take-back programs for AFFF foam. Transparency with release of data. Promote polluter-pay legislation

Table 11 Survey Results Question 12

Q13: Is there anything else you would like to share about any planning/policies in regards to PFAS water contamination in context with your organization? This question was given to allow for respondents to include any other information regarding PFAS that they believed was not included in the other questions. Six responses were given and shown in Table 11.

Responses

Fortunately, PFAS has not been located within our municipality at this time. However, this doesn’t mean future tests won’t find positive samples or that policies don’t need to be established

We hope to be brought forward into the fold and become more involved with PFAS/PFOA issues in this part of northern Michigan

The Watershed Council will be convening key stakeholders in the summer for a discussion on what is needed in Northern Michigan to address PFAS adequately.

PFAS, for the most part hasn’t become a factor on the wastewater side of things yet, however there are certainly contaminated sources that contribute to wastewater in-fluents and ultimately, wastewater effluents. Whether or not these issues are handled on the wastewater side remains to be seen, but if they choose to make any actions in the wastewater field regarding PFAS it should be handled with a sensible scientific approach, just like the drinking water side should be right now.

Responses (continued)

We rely on the state to provide guidance to us since they are the regulator of the water system.

This has only been talked about for the last couple of years. Living in a small, rural community with private wells, we have not had any issues, nor the need to research the problem.

Table 12 Survey Results Question 13

4.3 Results Summary

Hypothesis Result

H1- Current laws and regulations have not protected Michigan’s Not rejected residents from health effects associated with PFAS contaminated drinking water systems.

H2- The current health advisory level of 70 ppt for PFOA and PFOS Not rejected is set too high and will cause adverse impacts.

H3- Implementation of MPART has improved the ability to identify Rejected-Survey PFAS contaminated drinking water systems. Not Rejected- Desktop Literature Review

Table 13 Summary of Hypothesis Results

5 Limitations

Multiple limitations influenced the analysis of this data. This included the small sample size (54) focused on two counties. The response rate was a modest a 20% response rate; however, it still meets the statistical average. Furthermore, many of the townships in this area do not use a public water supply and because MPART has not mandated the testing of private wells, many of those surveyed were not aware of PFAS issues.

Most of the responses from the survey which included PFAS concerns or that had specific assistance requests came from employees from the tribal environmental council or the watershed council. Employees from MPART, MDEQ and labs that test the water collected from MPART were asked to participate in the survey, and all agreed through email communication. After the survey was released, communication was received that MPART believed their responses would likely skew the data collected and asked the results be shared with them instead of their participation. Because of their lack of participation, the results may show bias towards local officials who are not trained in the topic or as motivated to find solutions.

This research is limited in not identifying and inviting a wider scope of individuals who work more closely with or have training in water contamination to complete the survey. Of the twelve survey participants, four (33.3%) are directly involved with or have training regarding water contamination, while the other eight participants (66.7%) work in local government with varying levels of knowledge and experience regarding water contamination in a broad scope. For example, individuals in this category answered questions #8 (Currently, the regulated level of PFOA and PFOS (the two most common PFAS contamination) is set at 70 ppt (lifetime level). Do you believe that this number is set at an appropriate level to ensure that Michigan residents are protected from these contaminations?) and #9 (If no to #8, what would you propose is a more appropriate level of contamination that Michigan should be testing for?) with nothing more than a guess. The results of those surveyed for these questions will be skewed as the majority of the participants do not have training or experience working with PFASs or water contamination.

6 Discussion and Conclusion

The desktop literature review and survey sought to answer the primary research question: are current laws, regulations and action plans sufficient to protect Michigan’s residents and their drinking water systems from PFAS contamination? The interpretation of current laws, regulations and action plans, in conjunction with the known impacts and survey analysis provide insight into the present state of protection that residents are afforded in Michigan. Synthesis of this information, together with the proposed legislation at the state and federal level support the hypothesis that Michigan residents are not adequately protected from PFAS contamination.

The desktop literature review and survey results support H1 (Implementations of current laws and regulations are not enough to fully protect Michigan’s residents from health effects associated with PFAS contaminated drinking water systems) and H2 (the health advisory level for PFOA and PFOS should be lower than 70 ppt, increasing the number of contaminated sites). The lack of adequate government research and an effective action plan and enforcement to ensure the protection of Michigan citizens; coupled with the vague understanding by survey respondents of associated impacts leaves much to be addressed. The desktop literature review and survey results conflict in terms of H3 (Implementation of MPART has improved the ability to identify PFAS contaminated drinking water systems). The ability of MPART to successfully meet the outlined goals is uncertain at this time.

6.1 Desktop Literature Review Discussion

Desktop literature review: Result 1 Current Federal Regulations and Laws, show the prevailing protections through the federal government including CWA, SDWA, UCMR 3 and the Nationwide PFAS Action Plan. In Section 309 of the CWA, EPA enforce punitive damages to a “person” who violates any of the sections. In Section 313 it is further explained that this terminology excludes government agencies and the military which only need comply with the CWA, which does not impose penalties. This results in the U.S. government and military having no real incentive to follow EPA rules other than goodwill. The U.S. military utilizes AFFFs on

its bases, making it one of the biggest users of PFAS products leading to contamination. military. Section 502(5) allows for the EPA to impose penalties and punitive damages on private contractors who work on military bases or specific individuals who work for federal agencies through Section309c. The EPA is not able to impose penalties and punitive damages on the U.S.

The Nationwide PFAS Action Plan, announced in February 2019, has the capacity to greatly enhance the current understanding of PFAS; through short and long term studies as well as add regulations to the SWDA, Toxic Substances Control Act (TSCA) and CERCLA. This would bring a wider scope to the EPA’s ability to regulate use, clean-up and remediation for sites affected by PFAS (EPA, 2019a). Unfortunately, the Nationwide PFAS Action Plan has already been revised due to pressures from federal agencies and military departments. Emergency actions for sites which test above a concentration of 400 ppt were removed. The EPA has shown that it is not willing to stand up to other federal agencies, to keep essential components in this plan; the possibility exists that additional protections might be removed.

Desktop Literature Review: Results 2 Current Michigan Regulations and Laws, illustrates Michigan’s desire to appear as more proactive with regards to PFAS than it recently displayed with the Flint Water Crisis. Knowing the limitations of the federal regulations, Nationwide Action Plan and current state regulations, MPART was developed to fast-track Michigan as a leader in PFAS contamination. It has yet to be seen if this is happening to the fullest capability. MPART has followed through on quick collection and analysis of water samples from all public drinking water supplies, as well as schools and licensed daycare facilities. However, with no immediate plan to sample and test private wells state-wide, it leaves many residents not knowing if they are consuming contaminated water. MPART has not conducted any public meetings in Northern Michigan as they are focused on the sites that have tested over or close to the LTHA limit. While it is understandable that these are the locations with immediate focus, it leaves many residents without the latest information regarding contamination and impacts.

Desktop Literature Review: Results 3 Proposed Federal and Michigan Regulations and Laws, exhibits the proposed laws and regulations that have been proposed to the current state and

federal legislation. Presently there are at least six bills introduced into the U.S. House of Representatives and Senate with PFAS connections. Many of these also have protections for members of the military or who worked on military bases and experienced exposure to PFASs. Most of these bills protect against the entire class of PFASs, rather than individualize them. This is markedly different from the current federal legislation, which either imply the inclusion of PFASs or limit distinctions to PFOA and/or PFOS. Michigan lawmakers have proposed an amendment to the MSDWA to set individual, enforceable MCLs for PFOA and PFOS. The inclusion of so many new bills nationwide within one year demonstrates how immediate the need is for increased protections and how inept the current laws are at protecting humans and the environment from PFAS exposure.

The known impacts from Desktop Literature Review: Results 4 Summary of Impacts from PFAS contamination, highlight how detrimental PFASs are to the environment, ecosystems, human health, economy and the socio-political scene, while at the same time recognizing how little is actually known about PFASs. There are many unknowns regarding each impact, which only raises additional issues. New concerns are frequently being identified, among them are the chemical reactions of PFAS foam with surface water. As an example, currently advisories are only based on ingesting of PFASs through food or drinking water. Occasional direct contact to the skin has not been a worry nor part of any advisories. However, in 2019, MPART released advisories for humans and pets to not touch PFASs foam on beaches (Michigan.gov, 2019b). While it is cautionary, it demonstrates the growing number of concerns and potential impacts.

Desktop Literature Review: Results 5 Contamination Results in Michigan with Elevated Levels of PFOA/PFOS (combined total >70 ppt), is specific to Michigan sites that have been sampled and tested over 70 ppt. Currently there are two public water supply locations and 63 groundwater sites identified over the LTHA limit. Michigan Department of Health and Human Services states that MDEQ must include mandatory groundwater testing (Michigan.gov, 2019c). The only actions that MPART has taken at this point include the initial water testing and switching water supply or bringing bottled water at two sites. The current action plans are not yet developed enough for next steps to happen in a timely manner. Education, which includes

training local officials, communicating efforts and next steps, and developing and implementing remediation plans needs to take place. In order to fully protect Michigan’s citizens, there needs to be a sense of urgency.

The desktop literature review revealed a lack of understanding by government agencies and the scientific community, of the impacts of PFASs to the environment, ecosystems, humans, economy and the socio-political scenes. The understanding of the impacts is in the infancy stages leading to much debate regarding the level of effect. There are few long-term studies, addressing the environmental, ecosystem and human health impacts; also, lacking are studies addressing contaminant removal. Additionally, there is confusion regarding the methods in which humans may be affected from PFASs. While ingestion of PFASs will cause human impacts, it is now speculated that touching and other methods of contact may cause health concerns.

6.2 Survey Discussion

The survey responses (primarily to questions #2- “Does your organization participate in any programs and/or policies to address per and polyfluoroalkyl substances (PFAS) contamination in drinking water supply?” and question #3- “If yes, what programs and or policies does the organization participate with?”) revealed a disconnect between issues with PFASs and the readiness of the Northern Michigan community to address concerns. This aligns with the desktop literature review, which highlights many gaps in research, including that residents are not protected from additional exposure; but not how remediation (if necessary), will be addressed. Unfortunately, question #4 (“What issues take precedence to PFAS contamination in the organization you participate with?”) highlights the many issues that are currently taking precedence over PFASs such as other water contamination (specifically lead) and quality issues.

Responses to question #5-7 (#5- “Do you feel that your organization is prepared to deal with PFAS contamination if it is detected in drinking water systems?”, #6 “If yes, please explain this process and #7, “If no, why is this the case or what does your organization need in order to be

better prepared) support the results in the desktop literature review in that more research is required regarding impacts, how much funding is necessary and available, and what process should be taken to effectively remove the contamination and clean-up affected sites.

The survey responses to questions #8 (“Currently, the regulated level of PFOA and PFOS, the two most common PFAS contaminants, is set at 70 ppt. Do you believe that this number is set at an appropriate level to ensure that Michigan residents are protected from these contaminants?”) and nine (“If not, what would you propose is a more appropriate level of contamination that Michigan should be testing for?”) demonstrate that the respondents do not have a full understanding of PFASs and the process to set a MCL or LTHA as the responses varied greatly and most could not give a specific suggestion.

In 2016 the EPA set the current LTHA level for PFASs at 70 ppt. The EPA has announced in the National PFAS Action Plan that MCL levels for PFASs will be set but have no timeline to complete this. The current LTHA advisory level is different from an MCL in that it is non- enforceable and only aim to provide guidance to other agencies, while MCLs are enforceable. The process to set MCLs is set forth in The SDWA. The first step is to determine if the contaminate meets three criteria: must have an adverse effect on human health, there is a high chance of the contaminant to be found in public water systems at a level high enough to affect human health and the regulation would lower the risk to human health (EPA, 2019b). Once the EPA has determined that it will regulate a contaminate, they must set a maximum contaminant level goal (MCLG). This is the level in drinking water that human health would experience adverse effects, specifically those who identify as a sensitive population, such as infants and the elderly. MCLG’s are not enforceable, but once determined the EPA is able to set an enforceable standard such as an MCL. To set an MCL, treatment techniques that are available and affordable for systems to use are listed, a health risk reduction and cost analysis (HRRCA) and perform subsequent health risks due to the new MCL. In general, public water systems must comply with the new standards within three years (EPA, 2019b).

States are able to set and enforce their own MCLs that are stricter than what is set by the EPA (EPA, 2019). Michigan is attempting to do this in two ways. First with Senate Bill 14 which will make amendments to the MSDWA. MDEQ was not consulted on the proposed MCLs for PFOA and PFOS. Communication was sent to Senator Brinks office to inquire how these values were determined, but the communication was not answered. Secondly, MPART and MDEQ have been tasked by Governor Gretchen Whitmore to have MCLs proposed by October 1, 2019 and adopted by April, 2020. In order to determine appropriate MCLs, three scientists were appointed to a Science Advisory Workgroup to review any existing or proposed standards for PFASs from around the United States. This Science Advisory Workgroup and MDEQ will set health-based values for PFASs by the end of June 2019, using a similar process to the EPA including examining the current available technologies to detect PFASs and conducting risk and cost analyses. Stakeholders will then be able to make comments before the proposed and eventually adopted standards are set by April 2020 (Helminski, 2019).

Setting MCLs lower than the EPA LTHA level has the potential for enormous impacts, both positive and unfavorable. Positive impacts will likely have been seen in human health, environmental and ecosystem fitness. As more sites are identified to be clean-ups, PFASs will be removed from more drinking water and groundwater systems, allowing humans fewer interactions with these contaminants. In contrast, the economic impacts of lowered MCLs will be more adverse. Currently in Michigan alone, 62 public drinking water sites alone would be added to the list of sites requiring remediation.

Survey responses to questions 10-12 (#10- “Are you familiar with Michigan PFAS Action Response Team (MPART)?”, #11- “If yes to #10, do you believe that MPART has adequately assisted organizations in dealing with PFAS contamination?” and #12- “If no to #11, what more would you like MPART to do or what services would you like them to add?”, reveal that the implementation of MPART has not yet reach its full potential. Increased visibility, testing, funding, training and research were all identified as needs that MPART has not filled. The desktop literature review, showed that these are all planned to be accomplished by MPART, while the survey shows that it has not yet been completely fulfilled.

The response to the final survey question, #13 (“Is there anything else you would like to share about any planning/policies in regards to PFAS water contamination in context with your county or organization?”) denote that for many PFASs is too new of an issue to this area to fully understand what steps should be taken next. All of these responses match the information in the desktop literature review demonstrating the need for further research, training of officials in regards to impacts of PFASs and a more acceptable limit to lessen these associated impacts.

6.3 Next Steps

Michigan has stated that it hopes to become a leader for other states to follow in terms of response to PFASs contamination. The implementation of MPART is a good start to this process but there is much more to be done if Michigan is to be successful. The following are crucial pieces that Michigan must implement or continue with in order to move forward.

Continued Research and Testing Clean-up and remediation plans must be in place to assist sites with elevated PFAS levels. So far, MPART provided bottled water for these sites but long-term clean-up plans and remediation contingencies are not in place. If Michigan sets the MCLs for PFOA and PFOS at 5 ppt individual as speculated in Senate Bill 14, many more sites will be identified for clean-up. Without accurate data, impacts will not be fully understood and clean-up procedures may not encompass the full needs of a community. Continued testing of public water systems will be needed to ensure that the PFAS contamination levels do not increase because of additional pollution or bioaccumulation in water. MDEQ must also begin testing private drinking water systems as groundwater tests throughout the states are showing elevated PFAS levels.

MCL’s Set for PFOA, PFOS and PFASs of all types Michigan has announced that MCLs will be set for PFOA and PFOS. Senate Bill 14 has recommended that the MCLs be 5 ppt for PFOA and PFOS and Governor Whitmer announced

on March 26, 2019 that MPART must form an advisory group that will look at current and proposed health based standards for drinking water from around the U.S. to advice the MCL rulemaking process by July 1, 2019. She also stated that the MDEQ would be responsible for setting the MCLs by October 1, 2019 (Michigan, 2019; Michigan.gov, 2019d). Although PFOA and PFOS are currently believed to cause the most detrimental impacts, there are thousands of other PFASs cycling through drinking water. To provide greater environmental protection, MDEQ must set standards for the whole class of PFASs in drinking water to fully protect. Plans for continued research must be defined that will lead to a full set of advisories or MCLs. Other states that Michigan could take cues from include California (14 ppt PFOA, 13 ppt PFOS) and New Hampshire (38 ppt PFOA, 70 ppt PFOS, 70 ppt PFOA/PFOS combined, 23 ppt PNFA and 85 ppt PFHxS), which have set state MCL for drinking water. New Jersey (10 ppt PFOA, 10 ppt PFOS) and New Hampshire (same as drinking water standards) have set groundwater standards (ECOS, 2019).

Communication with Residents The bulk of the communication in Michigan has been with areas that have elevated PFAS levels. Even local officials in non-elevated sites have had little communication beyond the mandatory water testing. The preponderance of information shared with residents in Charlevoix and Emmet Counties has been through Tip of the Mitt Watershed Council and Freshwater Futures training sessions that are open to the public. To increase the number of Michigan residents educated about the possible contamination in their area, MPART must disperse this information in various ways. Delivery of information through the MPART website or social media is not effectively reaching all residents. It is estimated that 39.9% of Detroit households do not have access to the internet, including service through a cellular device. State wide, 37% of the rural residents do not have access to Wi-Fi and for residents in four Michigan counties, that number reaches 75% or higher (Brodkin, 2019). The survey results support that members of the local governments are also not educated on PFASs enough to speak to their residents about the issues. MPART needs to incorporate local meetings, training at schools and business, and mailings to reach as many residents as possible.

Transparency of information MDEQ has thus far shown transparency with the availability of the water testing results. It is essential that this continues as the trust that Michigan residents have in regards to MDEQ is very low due to the mismanagement of the Flint Water Crisis. At a town hall meeting on March 9, 2019 in Genesee County (of Flint, Michigan), sponsored by state House members, specialists from the MDEQ and MDHHS took part in a panel regarding PFASs. After receiving information regarding the issues for that specific county, multiple audience participants and local citizens mistrust government officials, saying to officials, “This community won’t trust any of you”, “We’re tired of people coming and lying to us” and “I’ve seen foam on the river and we don’t trust anyone” (Rozycki, 2019).

Detailed Clean-up and Remediation Plans The technology that has been developed to identify PFASs is more advanced than the technology available to clean-up these sites and remove the contamination (Gryczan, 2019). While many residents are frustrated at the lack of clear cleanup expectations, many who work in the environmental fields believe that Michigan is doing all that they can with the current research and technology available. The next steps for Michigan will be to identify the methods to remove PFASs from the environment and find ways to store the contaminants. It is likely that these methods will be developed prior to any methods that will break down PFASs. While this is a short-term solution, it is the best option at this time (Gryczan, 2019). It has been suggested that Michigan use similar efforts to those that are currently being implemented to battle Polybrominated biphenyl and Polychlorinated biphenyl, which belong to the same class of contaminants as PFASs (Gryczan, 2019).

Releasing these plans, even in their beginning stages, could promote increased trust between residents and those involved in the cleanup efforts as well as increased financial support from environmental groups. Michigan may also benefit from identifying and holding those who caused the contamination financially responsible, this money could help fund continued research and remediation. Michigan could look to (and/or join) New Mexico, which has filed a suit against the U.S. Air Force as a way to force the military into addressing the issue of

contaminated military bases and the surrounding areas (ECOS, 2019). New Jersey and New Hampshire have held the chemical manufacturers and industries responsible for paying for testing, treatment and providing safe drinking water to areas that they have affected over the years (ECOS, 2019). Michigan will likely spend billions to properly address these issues and should hold those financially responsible to offset some of these costs rather than relying on taxpayers to fund the process.

6.4 Conclusion

PFASs are likely to persist as a global issue with costly and long term impacts if many of the proposed legislation do not become law. The current legislation and action plans are neither enforceable nor comprehensive enough to protect Michigan citizens. The addition of MPART has the potential to assist local governments and communities affected by PFAS contamination through research, training, and resources for clean-up and remediation. The majority of local officials are not trained to address the impacts and effects of PFASs. This research shows that many are waiting for the MDEQ to provide that training and research-based information. MPART must ensure transparency and a drive to enact and enforce policies that will put Michigan’s citizens, environment and ecosystems in front of big business or the military. Michigan must hold those responsible for this contamination to a standard in which they not only take financial responsibility but continue forward in a more socially and environmentally conscious manner. This research suggests that increased legislation in conjunction with detailed actions plans from MPART and the EPA are fundamental, to efficiently and effectively combatting PFAS contamination.

7 Bibliography

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Laws

Clean Water Act of 1972 [33 U.S.C. 1251 et seq.], (US)

Michigan Safe Drinking Water Act 399 of 1976 [MCL §§325.1001-325.1023], (MI)

Natural Resources and Environmental Protection Act 451 of 1994 [MCL §324.101-324.90106], (MI)

Safe Drinking Water Act of 1974 [42 U.S.C. §300f et seq.], (US)

APPENDICES

Appendix A: List of Acronyms

AFFF Aqueous Film Forming Foam ASDWA Association of State Drinking Water Administrators ATSDR Agency for Toxic Substances and Disease Registry CDC Center for Disease Control CERCLA The Comprehensive Environmental Response, Compensation and Liability Act CESCR UN Committee on Economic, Social and Cultural Rights CWA Clean Water Act of 1972 DoD Department of Defense ECOS The Environmental Council of the States EGLE Michigan Department of Environment, Great Lakes and Energy EPA Environmental Protection Agency HRRCA Health Risk Reduction and Cost Analysis IPP Industrial Pretreatment Program LTBB Little Traverse Bay Bands LTHA Lifetime Health Advisory MCL Maximum Contaminant Level MCLG Maximum Contaminant Level Goal MDEQ Michigan Department of Environmental Quality MDNR Michigan Department of Natural Resources MEC Michigan Environmental Council MPART Michigan Per-and Polyfluoroalkyl Substance Action Response Team MSDWA Michigan Safe Drinking Water Act of 1976 NHANES The National Health and Nutrition Examination Survey NJDEP The New Jersey Department of Environmental Protection NPDWR National Primary Drinking Water Regulations NRDC Natural Resources Defense Council NREPA Natural Resources and Environmental Protection Act 451 of 1994 PFAA Perfluoroalkyl Acid PFAS Per- and polyfluoroalkyl substances PFBS Perfluorobutanesulfonic Acid PFC Per-and Polyfluorinated Chemicals PFHpA Perfluoroheptanoic Acid PFHxS Perfluorohexane Sulfonic Acid PFNA Perfluorononanoic Acid PFOA Perfluorooctanoic Acid PFOS Perfluorooctanesulfonate ppt Parts per trillion SDWA Safe Drinking Water Act of 1974 TOMWC Tip of the Mitt Watershed Council TSCA Toxic Substances Control Act UCMR 3 Third Unregulated Contaminant Monitoring Rule UNEP United Nations Environment Programme USGS United States Geological Survey

Appendix B: Survey Description and Consent

You are invited to participate in an online survey on Per- and Polyfluoroalkyl Substances (PFASs). This is a research project being conducted by Jamie Whitley, a student at Oregon State University. It should take approximately 5-10 minutes to complete the 13 total questions.

Purpose This survey has been designed to support a desktop literature review for laws, regulations and plans regarding PFAS water contamination. This survey is for the entire State of Michigan, but is focused on Emmet and Charlevoix Counties. The survey will assist in analyzing the counties preparedness to deal with PFAS contamination should it be necessary and the current ability of state and federal regulations to protect Michigan residents from PFAS. The intent is to gather information about the county or organization that the individual represents, not the individual themselves.

Agreement to Participate If you have received this survey and agree to participate, please click the link below to begin. There will be no direct benefits from participating in this research study, although your responses may help to learn more about PFASs. Your participation is completely voluntary and you are free to withdraw at any time or skip any question on the survey.

Thank you for your participation in this capstone project.

Appendix C: Sample PFASs Water Test Results