Fluorosurfactants and the Great Lakes
Great Lakes PFASs Awareness Ramps Up
Over the past couple of years, various municipalities in Great Lakes states and provinces have detected per- and polyfluoroalkyl substances (PFASs) in drinking water sources—some above and some below safe levels. This group of substances includes the mainly phased out chemical compounds perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), as well as the less researched GenX chemicals. Due to their persistence in the environment, PFASs are present at some level in many waterways, groundwater and the blood of humans and other animals. In samples from 2015 to 2017 of fish in the Great Lakes in Canada, PFOS was found to be below the limits harmful to fish health, but above guidance levels that would be safe for predators that eat those fish due to its tendency towards bioaccumulation.
Evidence suggests PFASs can bioaccumulate and biomagnify when ingested. Ingestion of large quantities of some PFASs have been shown to result in harmful effects to human health. Knowledge about these harmful effects is only fairly recent and PFASs were used in American and Canadian products for decades before being phased out. PFASs may still be used in imported goods especially in products that are intended to resist heat, stains, grease and/or water. They are also still used in Aqueous Fire Fighting Foam (AFFF) in the U.S. and Canada. Although the Canadian Government only allows the use of PFASs containing AFFF under certain exceptions, U.S. states have been left to implement their own regulations as the federal government has not made any yet. The Government of Michigan, for example, has implemented a task force to deal with these Forever Chemicals. They have asked firefighting departments to take several specific actions that will limit the release of PFASs into the environment, such as not using PFAS containing AFFF in training exercises.
Although U.S. federal regulations of PFASs are lacking, in February of this year, the U.S. Environmental Protection Agency (EPA) released an action plan to manage PFASs. Meanwhile, the International Joint Commission (IJC) is working on a draft Binational Strategy for PFASs under the Great Lakes Water Quality Agreement. There has recently been a resurgence in awareness of PFASs due to these new efforts, but progress toward federally managing PFASs in Canada began back in 2006.
History of Canadian Regulation
In July 2006, the final ecological screening assessment report for perfluorooctane sulfonate (PFOS), a member of the PFASs group, was published in the Canada Gazette (the government of Canada’s official newspaper). In this report, Environment Canada and Health Canada concluded that the levels of PFOS entering into the environment at the time was, or would become, harmful to ecosystems and biodiversity. The risk management strategy that was developed in response to these findings, recommended that levels of PFOS being released into the environment should be reduced as much as technically and economically possible. In 2009, pursuant to the Perfluorooctane Sulfonate Virtual Elimination Act, the Minister of the Environment and Minister of Health added PFOS to the Virtual Elimination List compiled under subsection 65(2) of the Canadian Environmental Protection Act, 1999.
A screening assessment and risk management strategy was also developed in 2012 for another member of the PFAS group—perfluorooctanoic acid (PFOA). In August 2012 the Final Screening Assesment on PFOA was released in the Canada Gazette. A proposed risk management approach for the substance was also released in August 2012. PFOA was also added to the List of Toxic Substances under the Canadian Environmental Protection Act, 1999 following these assessments. PFOA compounds are subject to the Prohibition of Certain Toxic Substances, 2012, which also incorporates the Perfluorooctane Sulfonate and its Salts and Certain Other Compounds Regulations.
Links
Government of Canada
- PFOS Fact Sheet
- PFOS Regulations Fact Sheet
- Guidelines for Canadian Drinking Water Quality: Guideline Technical Document – Perfluorooctane Sulfonate (PFOS)
- PFOA Fact Sheet
- Guidelines for Canadian Drinking Water Quality: Guideline Technical Document – Perfluorooctanoic Acid (PFOA)
- CEPA List of Toxic Substances
U.S. Government and Agencies
- EPA’s Per- and Polyfluoroalkyl (PFAS) Substances Aciont Plan and Summary of Key Actions
- PFAS summary and role of FDA
- Agency for Toxic Substance and Disease Registry: PFAS Health Effects
- Wisconsin PFAS Community Campaign
- Pensylvania Department of Environmental Protections – PFAS overview and actions
- Michigan Department of Environmental Quality – PFAS response
Interactive Map – PFAS contamination in the U.S.
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Progress at Lake Superior Contaminated Sites
Several specific locations in the waters of Lake Superior were contaminated by the industrial legacy of decades past. Considerable progress has been made when it comes to cleanup but significant challenges remain.
In Canada, these locations include:
• The harbour at the Town of Marathon, called Peninsula Harbour
• Jackfish Bay, east of Terrace Bay, along with Blackbird Creek which flows into it
• Thunder Bay
On the U.S. side of Superior, contaminated sites exist at:
• Duluth – Superior Harbour including the St. Louis River estuary
• Torch Lake (on Michigan’s Upper Peninsular)
All of the above Canadian and U.S. locations have been designated as Great Lakes “Areas of Concern.” A cleanup for mercury contamination at Deer Lake, Michigan has been completed and, as a result, this area has been removed from the list of Areas of Concern. The legacy of pulp and paper on both sides of the border and also mining, specifically refining on the U.S. side, are associated with these contaminated sites. Today, much more stringent environmental regulations are in effect.
Buffalo Reef, near Gay, Michigan on the Upper Peninsula, is not an Area of Concern but is being encroached upon by stamp sands from metal refining. The reef is an important area of fish habitat and plans are underway to stop the encroachment.
Peninsula Harbour Cleanup Carried Out in 2012
Mercury in harbour sediment was the major concern at Peninsula Harbour, but this issue was addressed in 2012 when Environment and Climate Change Canada (ECCC), the provincial Ministry of the Environment, Conservation and Parks (MOECP) and private industry carried out a $7 million cleanup. A layer of sand, along with more coarse material for “high energy” portions of the harbour, was laid down on the harbour floor over the area of highest contamination. A primary aim of the project was to allow benthic organisms to recolonize this area. Benthic organisms are small, sometimes microscopic organisms, which inhabit sediment. Environmental monitoring is ongoing to quantify recolonization and other parameters.
Creosote Contamination Cleaned Up in 2003
In Thunder Bay, a $25 million project was completed in 2003 to clean up creosote contamination around the former Northern Wood preservers property. This industrial facility was located in the central portion of the harbour. The project involved sealing off the area of highest contamination with a berm, dredging out the contaminated sediment and then back filling the area with clean fill. A large area of habitat was also created at this former industrial site. In effect, shallow embayments and wetlands were created for many species of fish, birds and other wildlife. The project was carried out by ECCC, MOECP and private industry.
While there has been considerable progress to address contamination in Lake Superior, significant challenges remain. Jackfish Bay is a deep indentation in Superior’s coastline. Blackbird Creek, into which the mill at Terrace Bay has discharged wastewater for decades, meanders several miles before flowing into the bay. Legacy contamination in both creek and bay sediment includes dioxins and other chemicals.
Jackfish Bay Presents Complex Issues
The Jackfish Bay/Blackbird Creek situation is complex. Even local residents have conceded that cleaning up a creek which is miles in length would be extremely difficult, to say nothing of prohibitively expensive. Environmental monitoring is considering sedimentation rates and whether such sedimentation may, eventually, bring about gradual environmental recovery. As such, in 2012, Jackfish Bay, including Blackbird Creek, were deemed an “Area of Concern in Recovery.” This designation refers to an area that was originally identified as an area of concern where, based on community and government consensus, all scientifically feasible and economically reasonable actions have been implemented and additional time is required for the environment to recover.
Thunder Bay’s North Harbour – Can Cleanup Costs be Lowered?
In Thunder Bay, the northern portion of the harbour, adjacent to the mouth of the Current River and within the break wall, contains some 400,000 cubic meters of pulpy material contaminated with mercury and other chemicals. This material is suspended within Superior’s waters. Contaminated material is 3 or more meters thick in some areas and covers 26 hectares of the harbour. The site is near a former paper mill.
The pulpy, or porridge-like, nature of this material, along with its very large volume, means this location may be both difficult and expensive to clean up. Currently, considerable effort is being expended by a steering committee comprised of government agencies and local stakeholders to identify low-cost cleanup options. Such options include the following:
• transport across the harbour for disposal at an existing facility designed to contain material from navigational dredging
• disposal at existing effluent lagoons on the nearby former nearby mill.
Cleanup options will be presented to the public in the coming months.
U. S. Side – Progress at Duluth
Considerable contamination exists at multiple locations within Duluth-Superior Harbour including the St. Louis River Estuary; also at Torch Lake in Michigan. In the case of Duluth-Superior, considerable cleanup progress has been made at several locations and work is proceeding according to a very ambitious master plan.
We live in an era with multiple environmental issues coming to the fore. This includes everything from microplastics to climate change. It is important to remember that cleanup of the above mentioned locations is fundamental to the health of Lake Superior. Hopefully, the gradual success being achieved on both sides of Superior will lead to resolution at Superior’s remaining contaminated sites. Hopefully, the extremely expensive costs of cleanup will be borne in mind in order that prevention prevails, before more cleanups are required.
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Opposition to Enbridge Line 5 Shows No Signs of Waning
Last time Infosuperior covered updates on Enbridge Energy’s Line 5, then Governor Rick Snyder had made a deal with Enbridge to allow them continued use of the aging pipeline that runs through the Straights of Mackinac. Plans were approved to work towards a replacement for the pipeline by building an underground tunnel. Gretchen Whitmer, who was slated to take Snyder’s place, had expressed support for the decommissioning of Line 5.
Upon her election as Governor of Michigan, Gretchen Whitmer immediately got to work on taking action against the pipeline. Whitmer requested Attorney General Dana Nessel’s opinion on the legalities of the deal made between Enbridge and Snyder. In an official statement on March 28, 2019, Nessel described specific provisions of the agreement as unconstitutional. On the same day, Governor Whitmer ordered that all work on the Enbridge Tunnel cease.
On June 6, 2019, Enbridge responded to the attorney General’s opinion by filing legal action with the Michigan Court of Claims in order “to establish the constitutional validity and enforceability of previous agreements signed between the Company and the State of Michigan.” By June 27, 2019, the Attorney General responded with legal action of her own. AG Dana Nessel maintained her position and filed legal action in an effort to permanently decommission Line 5. In her lawsuit, filed in Ingham County Circuit Court, she argues that the the terms of 1953 easement that allows Enbridge Energy to operate Line 5 in the Straights of Mackinac have been violated by the changes made in the deal with Snyder. AG Nessel also filed a motion to dismiss Enbridges lawsuit. Meanwhile Governor Whitmer created the UP Energy Task Force to explore alternatives to provide energy to Michigan residence in the event that Line 5 is shut down. Despite these efforts, on July 11, 2019, Enbridge announced plans to begin geologic sampling to finalize the designs of the tunnel.
Mashkiiziibi (Bad River) Band also filed suit against Enbridge Energy over Line 5 on July 23, 2019. Line 5 passes through 12 miles of sensitive habitat in the Bad River Reservation. Easements allowing the pipeline to operate there expired in 2013 and the line is in danger of being exposed due to shoreline erosion, which would put stresses on the pipeline that were not accounted for when it was created. Due to the threat the pipeline poses to the environment and their treaty protected rights, Mashkiiziibi Band resolved in 2017 not to consent to a new easement. The Band is calling for the decommissioning and removal of the pipeline from the Bad River watershed.
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Thunder Bay RAP Milestone: Bird/Animal Deformities Not Impaired
This, among other findings, led to the conclusion that Bird and Animal Deformities are not impaired within the Thunder Bay Area of Concern
Another significant milestone has been achieved bringing the Thunder Bay Harbour one more step closer to removal from the list of Great Lakes “Areas of Concern”.
In a letter to Remedial Action Plan Coordinator Samuel Pegg, Sandra Kok and Daniel Joyce, the Annex 4 (Areas of Concern) leads for the Canada-Ontario Agreement on Great Lakes Water Quality and Ecosystem Health, supported the conclusion that this important animal health impairments should be designated “not impaired”.
In 1987, when Thunder Bay was first identified as an Area of Concern, discharges of pollutants from local pulp and paper industries and wastewater treatment plants, as well as atmospheric deposition and urban runoff impaired the ecosystem health. Contaminants of concern included dioxins and furans, mercury, and polychlorinated biphenyls (PCBs), which were identified as a potential risk for deformities in birds and animals.
Studies were planned to determine if deformities and reproduction problems were occurring due to chemical contamination and so the beneficial use was identified as “requires further assessment”.
Environment and Climate Change Canada undertook a number of studies to assess the reproductive health and contaminant levels of colonial waterbirds nesting within the Thunder Bay area from 2000-2008 and again in 2012, 2014 and 2015. The results of these studies demonstrated that there are no bird deformities or reproductive problems within Thunder Bay.
READ THE COMPLETE ASSESSMENT REPORT HERE
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