Water Quality Information | Written By Actual Experts
Michigan's Fight Against PFAS
Analies Dyjak, M.A. | Policy Nerd
The newest threat to Michigan drinking water comes just five years after lead contamination crippled the the community of Flint. Despite nation-wide coverage and support, communities in Michigan are still dealing with contaminated drinking water. A new category of emerging contaminants called Per and Polyfluoroalkyl Substances (PFAS) is now threatening a majority of the state, as public officials try to gain back trust.
Where Are PFAS Found In Michigan?
The Michigan Department of Environment, Great Lakes, and Energy (EGLE) mapped out numerous groundwater locations where PFAS have recently been identified. Shockingly, PFAS contamination in Michigan is extremely widespread. Almost every country. It's important to keep in mind that the Michigan EGLE did not test every single groundwater site for PFAS, and that these data might not be representative of the actual scope.
Michigan Sues 17 Companies For PFAS Exposure
Numerous lawsuits, including one filed just last week, aim to hold PFAS manufacturers and producers accountable. The state of Michigan is suing 17 companies for concealing scientific information regarding the health effects of PFAS in drinking water, while continuing to produce, distribute, and improperly dispose of these toxic chemicals. Some of the more well known companies involved in the suit are 3M, DuPont, and Chemours. If you’re following this closely like us, you probably recognize these three names.
Michigan Leading The Charge In Congress
In early January the U.S. House of Representatives passed the most sweeping piece of PFAS legislation to date. The bill was sponsored by Michigan representative Debbie Dingel (D). She’s been an extraordinary advocate for PFAS legislation and regulation from EPA. The PFAS Action Act of 2019 includes important strides to protect individuals from this emerging and unregulated category of contaminant.
If this legislation passes, the following would happen:
EPA would be required to set a national standard under the National Primary Drinking Water Standards for both PFOA and PFOS.
EPA would require action under its Superfund program, also known at the Comprehensive Environmental Response Compensation and Liability (CERCLA) to hold responsible parties accountable for mitigation.
EPA would be required to designate all PFAS as “hazardous air pollutants” under the Clean Air Act.
EPA would be required to authorize funding ($500 million over five years) to help municipalities across the country comply with new PFAS laws.
State Maximum Contaminant Levels
Michigan is also proposing state drinking water standards for seven different types of PFAS. These proposed levels are much more stringent than the nationally-proposed standards. For a bit of context, EPA is proposing a total combined PFAS standard of 70 parts per trillion (ppt). The Michigan standard would regulate seven different PFAS variations individually:
- PFNA: 6 ppt
- PFOA: 8 ppt
- PFOS: 16 ppt
- PFHxS: 51 ppt
- GenX 370 ppt
- PFBS: 420 ppt
- PFHxA: 400,000 ppt
Private Wells Are Exempt From Legislation
This isn’t anything new. Private wells are not regulated and therefore aren’t required to meet any federal or state drinking water standards. They are completely on their own to test, monitor, and remove contaminants from their drinking water. This is especially scaring for private wells users that live in areas where PFAS is known.
There’s no denying that this bill has the potential to be a huge win for communities across the country. It’s sweeping scope will force states to acknowledge a problem that’s been ignored for years. However, it’s important to point out some of the things this bill will not accomplish. Like all other National Primary Drinking Water Standards, private wells are not covered under this proposed bill. This huge oversight puts millions of Americans at risk. Homeowners that have a private well are responsible for testing, monitoring, and removing any potentially harmful contaminants from their water, whereas those on “city water” rely on the municipalities water treatment capabilities. Testing PFAS at an accredited laboratory is extremely expensive and might not be a reality for some private well users.
Removing PFAS At The Municipal Level Is Expensive
It would be shortsighted not to mention the cost of removing PFAS at the municipal level. The Cape Fear Public Utility Authority in Wilmington, North Carolina spent $35.9 million for PFAS removal equipment at one of their three water treatment facilities. Even with the $500 million added to a state revolving fund, the PFAS Action Act will put a serious financial burden on municipalities. This would absolutely accomplish some of what so many advocacy groups have been begging for for years: EPA’s acknowledgement that PFAS is bad and accountability for companies that produce it.Other Articles You Might Enjoy:
Hydroviv's 2020 PFAS Update
What Are Per and Polyfluroalkyl Substances (PFAS)?
Military Bases Have High Levels Of PFAS
- Analies Dyjak
Chromium 6 From Electroplating Facility In Michigan Threatens Drinking Water
Analies Ross-Dyjak, M.A. | Policy Nerd
Another environmental tragedy is threatening drinking water in a Detroit suburb. A chromium 6 spill startled commuters traveling on Interstate 696 just days before Christmas. Michigan has been dealing with polluted drinking water, including state-wide contamination from both chromium 6 and PFAS.
Images courtesy of Michigan Department of Environmental Quality
What Happened In Madison Heights, Michigan?
Lime-green sludge spilled over onto Interstate 696 in Michigan just days before Christmas. The source of the pollution was a closed electroplating facility in Madison Heights, Michigan. The owner of Electro Plating Services is currently serving a year in federal prison for improperly disposing various toxic contaminants including chromium 6, trichloroethylene (TCE), and cyanide. A dug pit was also identified on the property. The owner had apparently been illegally disposing of the effluent for years, resulting in an extremely unsightly pit of chemicals. After the operation closed in 2017, the Environmental Protection Agency (EPA) and Michigan Department of Environment, Great Lakes, and Energy (formerly known as Michigan Department of Environmental Quality) allegedly removed the contents in the facility but failed to remediate the surrounding soil and groundwater. In the initial remedial efforts in 2017, EPA found 37,000 gallons of chromium 6-contaminated water in the basement of the facility.
What Is Chromium 6?
The National Institute of Health (NIH) has determined that chromium 6 causes "clear carcinogenic effects" and that it should be classified as likely to be a human carcinogen through ingestion of drinking water. Chromium 6 is used in various industrial processes including metal plating, steel production, leather tanning, textile manufacturing, and electroplating. Discharge from any number of these industries can cause chromium 6 to flow through surface or groundwater and enter a drinking water source. Chromium 6 is still not regulated by the United States Environmental Protection Agency. 20 years later after the 2000 blockbuster movie starring Julia Roberts brought national attention to this human carcinogen, the federal government has yet to set an “allowable level” in drinking water.
As we’ve been watching this disaster slowly unfold, we’ve seen numerous instances of false information regarding chromium 6 and the spill. For example, some news agencies have made false statements claiming that chromium 6 is not dangerous when ingested through drinking water, and that it’s only toxic to humans through inhalation or dermal contact. NIH and other public health organizations have determined that it is in fact carcinogenic to humans. Additionally, the state of California tried to set a state Maximum Contaminant Level (MCL) of 20 parts per trillion in drinking water, confirming its toxicity to humans. A second news source claimed that if chromium 6 from the spill made its way to Lake St. Clair, the levels would be “well below the standard.” As previously stated, there is no federal or state standard for chromium 6.
We cannot rely only on environmental regulations alone to protect us from hazards. In this case, post-production remedial efforts by the EPA and Michigan EGLE failed miserably.
The owner of the facility most likely had no other choice but to dump pollution into a pit because proper handling and disposal of chromium 6 is expensive. Incentives for proper disposal serve the best interest for workers and the public.
People who rely on private wells for drinking water should pay close attention to this incident. Private wells are not regulated by the federal government and do not need to comply with National Primary Drinking Water Regulations. The basic analysis that most private wells undergo only tests for 5 or 6 contaminants, most of which are biological and certainly nothing that isn't regulated.
Consumers need to be responsible for protecting their families from environmental exposures.
Chromium 6 In Drinking Water: Background, Exposure, Toxicology
How To Filter Chromium 6 From Drinking Water
Chromium 6 Spilled Into Lake Michigan: What You Need To Know
- Analies Dyjak
Hydroviv's 2020 PFAS Update
*Updated 1/22/20 to include EWG map*
Analies Dyjak, M.A. | Policy Nerd
The Environmental Working Group (EWG) recently updated its map of PFAS effected communities, which includes an extensive list of new cities. Residents, city and state officials, and the federal government are working to figure out how to respond. We wanted to provide an update as to what’s going on with PFAS contamination in the nation's drinking water.
What Are PFAS And Why Are They Dangerous?
Per and Polyfluoroalkyl Substances (PFAS) are a category of emerging contaminants and are both mobile and persistent in the environment. PFAS are found in a variety of products including Scotchguard, Teflon, firefighting foam, metal plating, heat and water repellent products, and stain resistant fabrics. Health effects associated with PFAS contaminated drinking water are becoming more widely accepted throughout regulatory bodies. According to the Agency for Toxic Substance and Disease Registry, PFAS are associated with a long list of health effects including an increased risk of cancer, lowered fertility rates, increased cholesterol, and developmental issues in young children and infants.
PFAS Action Act of 2019
At the beginning of January, 2020, the U.S. House of Representatives passed the most sweeping piece of PFAS legislation to date. The PFAS Action Act of 2019 is sponsored by Representative Debbie Dingell (D-Mich). The bill is currently making its way through the legislative process and waiting on a senate vote.
If this legislation passes, the following would happen:
- EPA would be required to set a national standard under the National Primary Drinking Water Standards for both PFOA and PFOS.
- EPA would require action under its Superfund program, also known at the Comprehensive Environmental Response Compensation and Liability (CERCLA) to hold responsible parties accountable for mitigation.
- EPA would be required to designate all PFAS as “hazardous air pollutants” under the Clean Air Act.
- EPA would be required to authorize funding ($500 million over five years) to help municipalities across the country comply with new PFAS laws.
How Will The PFAS Action Act Impact My Community?
There is no denying that this bill has the potential to be a huge win for communities across the country. It’s sweeping scope will force states to acknowledge a problem that has been ignored for years. However, it is important to point out some of the things this bill will not accomplish. Like all other National Primary Drinking Water Standards, private wells are not covered under this proposed bill. This major oversight puts millions of Americans at risk. Homeowners who drink from private wells are responsible for testing, monitoring, and removing any potentially harmful contaminants from their water, whereas those on city water rely on their municipalities' water treatment capabilities.
Then there is the cost of removing PFAS at the municipal level. The Cape Fear Public Utility Authority in Wilmington, North Carolina spent $35.9 million for PFAS removal equipment at one of their three water treatment facilities. Even with the $500 million added to a state-revolving fund, the PFAS Action Act would place a serious financial burden on municipalities.
Key Players: Department of Defense
The Department of Defense is also leading the charge to address PFAS, which might be surprising considering they have played a large role in contributing to the problem. PFAS are a key ingredient in firefighting foam which is often used for training purposes on military bases. Many bases do not rely on the public system for drinking water, but rather have their own dug wells for military families. DoD has created an inventory of bases and wells show levels of PFAS. As of August 2017, DoD identified 401 military installments that are suspected to have released PFAS. That being said, DoD has spent $200 million on investigating and mitigating these releases since the contamination has became public.
The National Defense Authorization Act, which includes the annual military budget for 2020, prohibits the Department of Defense from using PFAS-containing firefighting foam starting October 1, 2022. DoD is also funding research to come up with an alternative to PFAS. The twist, however, is military bases are not required to comply with federal and state drinking water standards. Even if a federal regulation were to be set, it would be under the discretion of DoD to determine how to proceed.
PFAS Update: Is A Regulation Coming?
Possibly. It typically takes decades for EPA to regulate a contaminant under the National Primary Drinking Water Standards. For example, Chromium 6 still remains unregulated after decades spent in the regulatory funnel. Additionally, Chromium 6 was highlighted in the 2000 blockbuster film Erin Brockovich, starring Julie Roberts. Despite widespread attention on these contaminants, drinking water regulations take such a long time in part due to push back from chemical manufacturers and industry who produce these types of toxic contaminants. In 2018, EPA set a non-enforceable health advisory level of 70 parts per trillion. An important caveat is public health goals, guidance levels, and health advisory levels are all non-enforceable, and therefore municipal water systems do not need to comply. That being said, a regulation submitted to the Office of Information and Regulatory Affairs (OIRA) was recently sent back to the Environmental Protection Agency for revisions, or to be published in the Federal Register.
States Leading the Charge
In 2019, several states in the U.S. stepped up to tackle PFAS head on. Because there is no federal consensus on what the standard should be, it is at the discretion of states to determine an acceptable level in drinking water. States run into similar obstacles as the federal government when setting standards. It is important to remember that as of now right now, most state standards are non-enforceable public health goals or advisory levels. Minnesota in particular has done a great job paving the way for other states. In 2018 Minnesota settled with 3M, a major manufacturer of PFAS in an $850 million lawsuit.
The bottom line is removing PFAS at the municipal level is expensive. Even if these regulations were enacted, communities would need to solve the problem of purchasing multi-million dollar equipment. Financial roadblocks are just one of the hurdles that EPA needs to overcome when developing a benefit-cost analysis: For example, do the benefits associated with regulating PFAS outweigh the costs? This factor is heavily examined when a regulation is being considered.
The current arsenic standard is the best example of this. EPA scientists agreed on establishing the Maximum Contaminant Level (MCL) as 3 parts per billion for arsenic in drinking water, which is consistent with public health recommendations. Ultimately the agency settled on the current level of 10 parts per billion because they could not justify the cost of removing arsenic at the municipal level with the health benefits.
Only a handful of communities have been able to purchase this type of expensive equipment. For example, the public utility for Wilmington, North Carolina purchased a $46 million Granular Activated Carbon (GAC) filtration system. This type of investment is not viable for most communities in the United States.Other Articles We Think You Might Enjoy:
What Are Per and Polyfluoroalkyl Substances?
Military Bases Have High Levels of PFAS
EPA Admits GenX Linked To Cancer
- Analies Dyjak
Error Found In Media Coverage Of Hydroviv's Flint Donation Program
I needed to take a break from prepping for Black Friday/Cyber Monday because I found some media coverage that had some errors in it, and I wanted to take a moment to set the record straight on our website, because it’s important.
I came across an article tonight where there was an inaccurate figure about the number of filters that Hydroviv (which was just me at the time) donated to Flint. The article (which was published right before our episode aired) put this number incorrectly put this number at 1000. The real number is somewhere between 100 and 200 (our record keeping is poor from 2015). Unfortunately, other articles published after the Shark Tank episode repeated the incorrect number. I've reached out to the authors in an attempt to get them to correct it.
While I’m here, I also wanted to also clarify a couple minor things.
- When I was talking about a lab in the kitchen/bathroom, we’re talking about a prototyping lab where we refined the design of the under sink filtration systems, not a wet chemistry lab using hazardous chemicals. Operating a chemistry lab in the bathroom would be unsafe and illegal.
- I was working for a company that developed technology for DoD and First Responders, not active duty military.
- The person who tipped me off to Flint was retired EPA, not actively employed by the agency.
- Hydroviv was started in July 2015, not June 2015.
While we're thrilled that Hydroviv has grown to be a real company now and have the capacity to partner with an amazing activist and make an actual impact with water filter donations (whose reach is well-over 1000 filters), we have no desire to overstate the scope of grassroots donation program that got Hydroviv started.
- Eric Roy
- Tags: flint
How Are Public and Private Water Systems Susceptible To Temporary Water Outages?
Paula R. Buchanan | Graduate Intern Nerd
As a water nerd who also has education and experience in healthcare , I am especially concerned with how the human impact on the natural water cycle can negatively impact population and public health. This report focuses on how the “small” disasters such as temporary water outages in hospitals and other healthcare facilities can also negatively impact water availability and access in our individual households.
What Are the Federal Procedures that Municipalities Must Follow?
Community and private water systems are vulnerable to a number of different threats. Such susceptibilities include natural disasters, crumbling infrastructure and bioterrorism - the scale of which may be extrapolated depending on how many individuals are reliant on a single water distribution system. Federal, state, and local utility-level legislation govern what to do when temporary water outages occur. At the federal level, the Safe Drinking Water Act was amended in 2002 to include the Bioterrorism Act to address emergency water supplies for public water systems under 42 U.S.C. 300i-4 (b), including having a backup water supply plan in case primary water supplies are contaminated. But this legislation only includes information dissemination to water systems, not the individuals whose residences are negatively impacted by temporary water outages.
State and Local Procedures that Protect Drinking Water
Under 42 U.S.C. 300g–2, states are required to create their own emergency drinking water plans, especially for smaller municipalities. For larger municipalities, it is common for the federal government to take a more active role. Water systems in local municipalities that have more than 3,300 residents must follow 42 U.S.C. 300i-2, which requires them to have an emergency water supply plan, but does not include specific information on how to communicate with the public. Unfortunately, how each level of government actually communicates with the public about the water outage can differ, which can be confusing. This makes it even more important for individuals and their households to be prepared for temporary water outages, by arming themselves with the most accurate information on what to do when these emergencies occur.
How Healthcare Facilities Respond to Temporary Water Outages:
We are too familiar with the gut-wrenching images and videos of patients and their caregivers being trapped in downtown New Orleans hospitals during the aftermath of Hurricane Katrina in 2005. Power and water outages made it close to impossible to take care of patients. What we are less familiar with are the temporary water outages that happen more often, but still negatively impact patient care and healthcare facilities’ ability to function.
Fortunately, The Joint Commission, a nonprofit organization that functions as the only accreditation entity for most healthcare facilities in our country and around the world, mandates that all healthcare facilities have and follow an Emergency Water Supply Plan (EWSP). In partnership with the Centers for Medicare and Medicaid Services, The Joint Commission mandates Standard EM.02.02.09 of all healthcare facilities’ Emergency Operations Plan (EOP), which requires hospitals to identify alternative water sources needed to conduct essential consumption and care activities for both patients and equipment to ensure that the facility continues to be a sanitary environment for medical treatment. EWSPs are also required as a component of healthcare facilities’ Joint Commission accreditation.
Even if you think your household is prepared for temporary water outages, you should also take into consideration how area hospitals, clinics, and other healthcare facilities impact the availability of and access to drinking water. This is especially relevant because – unlike when larger water outages occur – you might not know that the smaller water outages are occurring until it is too late. Information, and information-sharing, is power. Use that power to ensure that you, your household, and your community are prepared for the “smaller” types of disasters that can negatively impact our lives.
How Can Water Outages at Healthcare Facilities Affect Your Household Water Supply?
While The Joint Commission ensures that healthcare facilities must identify alternative water supplies to maintain the “sanitary integrity” of medical treatment facilities, there is no mandate from water supply entities to ensure that increased use of water resources won’t surpass their area’s water systems capacity. This could result in enough water for healthcare facilities, but not enough water for individual households and neighborhoods.
Temporary water outage events can take a healthcare facility by surprise, disrupting daily operations. These disruptions create a ripple effect that also negatively impact water supplies in individual households. If, for example, your house is located near a hospital and both the hospital and residential households are on the sample water supply infrastructure, your house could also be negatively impacted by temporary water outages. Unfortunately, this “small” water outages are less likely to be publicized, since they are less likely to garner media attention and interest.
What Can You Do To Be Better Prepared?
Fortunately, there are online resources produced by government entities that can help individual households be better prepared for inevitable temporary water outages. U.S. Department of Health and Human Services Public Health Emergency (PHE) website provides “Planning for Water Supply Interruptions: A Guide for Hospitals and Healthcare Facilities” to help healthcare facilities to plan for water supply interruptions. This guide also includes helpful resources for individual homes and households, including a checklist of what questions to ask that can better prepare you for temporary water outages.
It is also beneficial for households to have individual emergency water supplies. You should also know where your area fire department, community center, and other public facilities are located, since they are often used to disperse emergency water supplies.
The Takeaway: Water Systems Can, and Do, Fail. Be Prepared for Them.
Even if you think your household is prepared for temporary water outages, you should also take into consideration how area hospitals, clinics, and other healthcare facilities impact the availability of and access to drinking water. This is especially relevant because – unlike when larger water outages occur – you might not know that the smaller water outages are occurring until it is too late.
Center for Disease Control and Prevention’s Emergency Water Supply Planning Guide for Hospitals
Environmental Protection Agency (EPA’s) Planning for an Emergency Drinking Water Supply
- Analies Dyjak
Newark Lead Crisis: Why Are the Water Filters Not Working?
Eric Roy, Ph.D.
As a chemist, I was disappointed (but not surprised) to learn that a water filter made by Pur is having performance failures in Newark, despite being certified to remove lead. The goal of this article is to explain how water filter testing/certifications work, and to point out the most common reasons why a certified product can fail under real-world conditions
How Does Water Filter Certification Work?
Before going into the specific technical reasons why filters could have failed, it’s important to understand how and why water filter companies undergo 3rd party certifications from organizations like National Sanitation Foundation (NSF).
Any water filter company that wants to get their product "certified" must:
- Pay the certification agency to test that the product meets the specifications of the test protocol (more on this below).
- Pay for project management, site visits, and listing fees to "maintain" the certification.
In addition to strengthening their marking claims, there are business reasons why water filter companies elect to pay the high cost of obtaining certifications instead of demonstrating that their product works through independent laboratories. For example, certain government entities require that products carry specific certifications to back marketing claims, and often times carrying these certifications opens up the door to large-scale government procurement (the City of Newark purchased over 35,000 of these filters for their citizens).
NSF/ANSI Standard 53 Test Protocol For Lead Removal
A lot of the people we talk to are surprised to learn that the criteria used to performance test water filters is standardized and, and may not apply to their water.
In the case of “NSF certified” filters for lead removal, the filter must reduce lead from 150 parts per billion to a certain level in room temperature water that is free of other of harmful contaminants. These tests are run at 2 different pH values (6.5 & 8.5), for the manufacturer-specified lifetime of the filter (in gallons), at a manufacturer-specified flow rate (in gallons per minute).
Water filter companies don’t get extra points for: reducing lead to undetectable levels, being able to handle higher lead concentrations, performance in the presence of other metals, having consistent performance across the entire gallon capacity, operating at higher flow rates, or performing tests at different pH values. In the eyes of certification bodies, filters either meet the performance specification or they don't.
Understanding the framework of "certification" is important in understanding why products that are certified to remove lead can fail under real-world conditions.
Newark's Water May Not Be Well Represented by Product Testing Procedure
As we discussed earlier, “certified” filters undergo a standardized testing protocol in a controlled laboratory environment. Unfortunately, controlled laboratory studies don't always match the real-world conditions found in customer's homes.
For example, the filter's real-world performance can break down if:
- The water’s initial lead levels are above 150 parts per billion
- The filter was flowing at a faster flow rate than specified
- The temperature of the water is different than the test protocol
- If other contaminants are present in the water that consume the lead removal media
The End User May Have Used the Filter Outside of Manufacturer's Specifications
Sometimes the consumer misunderstands how to read the manufacturer's specs. For example, water filters are rated for a gallon capacity, which the manufacturers translate to an approximate filter lifetime, based on normal usage. For example, a filter that is rated to handle 100 gallons of water with 150 ppb lead might have a 3 month estimated lifetime based on "normal use." However, if the end user passes 100 gallons of water through the filter in a single day, the capacity will be saturated in a day. During the Flint lead crisis, we learned that families were using a single filter to fill up large water jugs for bathing, because they thought that the water filter's expiration was time based, not a gallon capacity. Unfortunately, this practice saturated the filter with lead much more quickly than the estimated lifetime.
Poor Manufacturing QA/QC or Changes to the Filter
It's well-understood that quality control can suffer when manufacturing is transitioned to low-cost factories. If the cartridge manufacturing facility quietyly changed anything about the filter's construction, or there was a QA/QC lapse in production, the certification agencies may not catch the performance change until the next testing cycle (which is typically every 5 years).
The Type of Filter Distributed by Newark Allows Users to Easily Operate the Filter out of Spec
One of the negative things “end of faucet” filters is that the user can easily run hot water through the filter. Manufacturers of these products issue guidance against it in their spec sheets, but people regularly ignore the warnings so they can have filtered hot water (or so they think). What isn’t necessarily obvious to the consumer is that hot water can impact the performance of a water filter because hot water typically has much higher lead and other heavy metal levels than cold water. This is due to a number of factors (e.g. residence time in hot water tanks, temperature dependence of metal leaching). If an unexpectedly high “slug” of heavy metals flowed through the cartridge, the lead removal media will become saturated faster than the gallon rating on the package. Once the filter is saturated, it's useless. On top of this, hot water often has higher concentrations of bacterial and other particles that can “foul” a filter and negatively impact the performance.
Unfortunately, the filters in Newark are not performing to the levels that the customer (City and Citizens of Newark) was led to believe by the filter manufacturer. Hopefully, this event will prompt cities to independently test water filters before using public funds to purchase them.
Full Disclosure: Despite being critical of the “pay-to-play” nature of certification, Hydroviv's products are in the process of undergoing product certification by NSF. The decision to do so is purely a business decision (some governments require that products be NSF certified). The reality is that Hydroviv filters have always exceeded the performance requirements set by NSF/ANSI Standard 53.