The web Browser you are currently using is unsupported, and some features of this site may not work as intended. Please update to a modern browser such as Chrome, Firefox or Edge to experience all features Michigan.gov has to offer.
Industrial Stormwater PFAS-related information and links
Industrial Stormwater PFAS-related information and links
About PFAS in Industrial Stormwater and Industrial Direct Discharges to Surface Waters
Per- and Polyfluoroalkyl Substances (PFAS) are a group of chemicals known for their water-, oil-, and fire-resistance. PFAS were used in various industrial processes for decades, and the properties that made them useful also make them persistent in the environment and difficult to destroy. Even if PFAS are no longer in use at a facility, they can still be present and continue to make their way into rivers, lakes, and wetlands, which can have harmful effects to human health and the environment. Visit the Michigan PFAS Action Response Team (MPART) website to learn more about PFAS.
Industrial Stormwater (ISW) Screening
Industrial stormwater regulations apply to a wide range of industrial and municipal facilities. A phased, methodical approach to conduct screening at facilities regulated under the ISW program began in 2019. This approach focuses on prioritized facilities with known use of PFAS containing products (i.e. chrome platers and airports) and where elevated concentrations of PFAS in stormwater are suspected due to known PFAS concentrations in groundwater, process industrial wastewater, soils, and/or surface waters associated with the facility. If PFAS stormwater sampling results have the reasonable potential to exceed applicable surface water criteria, then the facility will be required to take actions to reduce PFAS concentrations in their stormwater discharges.
Industrial Direct Discharger and Industrial Stormwater Compliance Strategy
Facilities operating under the National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater and Industrial Direct permits are authorized to discharge stormwater and process wastewater to surface waters of the state. Under the NPDES permitting strategy, permittees are required to implement controls at their facilities to reduce pollutants in their discharges, including PFAS. Michigan has developed surface Water Quality Values (WQVs) for five PFAS: perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), perfluorobutanesulfonic acid (PFBS), perfluorononanoic acid (PFNA), and perfluorohexanesufonic acid (PFHxS). In 2020, the Water Resources Division (WRD) developed and implemented the Compliance Strategy for Addressing PFAS in Industrial Direct and Industrial Stormwater Discharges, which addresses exceedances of PFAS for which Michigan has established WQVs from industrial direct and industrial stormwater discharges. Updated in 2024, the compliance strategy establishes a compliance program and enforceable timeline to reduce or eliminate PFAS from discharges at regulated industrial stormwater facilities to meet applicable criteria.
If a facility is identified as having a high potential for PFAS in their discharge, the WRD must determine whether the current permit coverage is adequate to protect waters of the state and ensure compliance with federal and state regulations. This is accomplished by requiring the facility to conduct a Short-Term Stormwater Characterization Study (STSWCS) and/or Short-Term Wastewater Characterization Study (STWCS) as appropriate. If after completion of the study, the facility’s discharges are found to contain concentrations above applicable criteria, the facility will be directed to address the unauthorized contaminants of concern in the discharge as expeditiously as possible. The WRD acknowledges that the identification of PFAS in these discharges may be new information and may require additional source investigation and development of site-specific corrective action plans to achieve compliance. As such, under the Compliance Strategy for addressing PFAS in Industrial Direct and Industrial Stormwater Discharges, most facilities will be offered the opportunity to enter an Administrative Consent Order (ACO) which will establish a compliance program and timeline for achieving compliance. Over the course of the ACO’s timeline, the facility may be required to create and conduct a Source Investigation and Identification Plan (SIIP), a Corrective Action Plan (CAP) or Pollutant Minimization Plan (PMP), and to conduct discharge monitoring. Once implementation of the CAP is complete, the facility will be required to demonstrate compliance at the discharge point with applicable criteria. In Fall 2024, EGLE began offering eligible ISW facilities entry into a General Administrative Consent Order (GACO) specifically to address PFAS in stormwater discharges. While the GACO and ACOs both address PFAS contamination, ACOs are individually drafted for specific facilities and the GACO was drafted to apply to all eligible facilities.
If a facility chooses not to enter into the ACO/GACO, the WRD may revoke and reissue the existing Certificate of Coverage (COC)/permit to include applicable monitoring and compliance schedules for compliance with the applicable criteria or terminate the COC/permit after notice and opportunity for hearing. If terminated, any discharge by the facility would be an unauthorized discharge and a violation of Part 31. The WRD would then pursue enforcement in accordance with Part 31.
Guidance and Related Documents
EGLE has developed many guidance documents to assist facilities in addressing PFAS.
PFAS Minimum Required Laboratory Analyte List
The PFAS Minimum Required Laboratory Analyte List is a list of the PFAS chemicals that the WRD requires to be included in PFAS analysis for groundwater, stormwater, surface water, and wastewater effluent samples.
PFAS Sampling Guidance
The following documents provide guidance for surface water or wastewater sampling:
Sampling guidance for additional media such as drinking water and groundwater can be found on MPART’s PFAS Sampling Guidance webpage.
PFAS Short-Term Stormwater Characterization Study (STSWCS) Plan Template
The PFAS STSWCS Plan Template outlines the requirements and methods for planning a Short-Term Stormwater Characterization Study at an industrial facility that the WRD has determined to have a high potential to be discharging stormwater contaminated with PFAS above applicable criteria to surface waters of the state.
General Administrative Consent Order (GACO) for Addressing Per- and Polyfluoroalkyl Substances in Industrial Stormwater Discharges to Surface Waters (Five-Year)
The ISW PFAS GACO details the framework for achieving compliance with effluent goals for PFAS (and other pollutants of concern as applicable) in stormwater discharges at eligible industrial facilities. The primary elements of the GACO include effluent goals, ongoing compliance monitoring, source investigation and identification, corrective actions, and reporting requirements. Facility-specific information is described in the Certificate of Entry.
Example Five-Year ISW PFAS GACO Certificate of Entry (COE)
This is an example of the ISW PFAS GACO COE, which is signed to certify entry into the ISW PFAS GACO. This document will be completed as appropriate to include the facility’s location and contact information, the designated pollutant(s) of concern and the corresponding effluent goal(s), the applicable discharge point(s), and the signature of the facility’s owner.
PFAS GACO Summary Guidance Document for Industrial Stormwater Facilities
The PFAS ISW GACO Guidance Document outlines the timeline and components of the GACO.
ISW PFAS GACO Submittal Form Names
The ISW PFAS GACO Forms Submittals document contains the submittal form names and dates for MiEnviro Portal submissions throughout the term of the GACO.
PFAS Source Investigation and Identification Plan (SIIP) – General
The PFAS General SIIP is a guidance document that outlines a methodical approach for determining potential sources of PFAS across various locations at an industrial facility.
PFAS Source Investigation and Identification Plan for Airports
The PFAS Airport SIIP is a guidance document that outlines a methodical approach for determining potential sources of PFAS across various locations at an airport.
PFAS Substantially Identical Discharge Guidance
The PFAS Substantially Identical Discharge Guidance document explains how a facility may be eligible for reduced monitoring if discharge points are determined by EGLE to be substantially identical.
PFAS GACO Discharge Monitoring Report (DMR)
The DMR FAQs provide guidance for the DMR submission process and may provide answers to other questions you may have. For other National Pollutant Discharge Elimination System (NPDES) compliance questions, please refer to the NPDES Compliance Assistance webpage.
ISW PFAS GACO Webinars
EGLE hosted a two-part webinar for industrial facilities that provided a detailed overview of Michigan’s approach to address PFAS contamination in industrial stormwater. The webinars discussed the GACO, the Certificate of Entry (COE) process, and other forms and compliance documents associated with the GACO.
- Webinar 1 – Overview of the ISW PFAS GACO components and requirements. (1 hour 7 minutes, recorded November 12, 2024)
- Webinar 2 – Walk-through of the process of submitting GACO compliance documents to the MiEnviro Portal. (45 minutes, recorded November 21, 2024)
MiEnviro Portal Guidance
If you are encountering issues using the Portal, the MiEnviro Portal FAQs can potentially answer your questions or help you find additional assistance.
2022 Summary of Industrial Stormwater and Industrial Direct PFAS Facilities
The WRD is working to address surface water discharges that are contaminated with PFAS at facilities that are known to have PFAS in their discharge or that are determined to have a high potential for PFAS in their discharge. Prioritization of high potential PFAS facilities is determined by industrial sector type, current or historical use of PFAS chemicals as part of their industrial process, training or historical use of Aqueous Film Forming Foam (AFFF) onsite, and existing samples that identify PFAS at the facility (e.g., PFAS impacted groundwater). The sector types that have a high potential for PFAS presence in their discharge include but are not limited to metal plating and finishing, airports and military bases, chemical manufacturing and petroleum refining, landfills, sites with legacy contamination, bulk fuel transfer sites, paper or pulp facilities, groundwater clean-up (GWCU) sites, plastics molding and forming, and sites identified through WRD watershed investigations. Below is a figure showing the number of facilities in each sector type that has been identified as high priority for PFAS discharge investigations.
MPART Resources
The Michigan PFAS Action Response Team (MPART) is a unique, multi-agency proactive approach for coordinating state resources to address PFAS contamination. Agencies responsible for environmental protection, public health, natural resources, agriculture, military installations, commercial airports, and fire departments work together to ensure the most efficient and effective response.
The MPART Wastewater Workgroup consists of staff from multiple programs within the WRD and develops other strategies to investigate and address PFAS in municipal and industrial wastewater, biosolids, stormwater, and groundwater through existing regulatory programs.
MPART Investigations and Sites – for more information about ongoing remediation at specific sites.
MPART PFAS Foam on Lakes and Streams – for more information about foam on surface water, and what you should do if you see any.