The Conservancy Initiative is reporting another result from our random sampling of the Johson Creek Tributary directly downstream of the landfill. Our samples are as representative of the landfill’s stormwater runoff as we can obtain without gaining access to the landfill’s property. The sample contained PFOS at a concentration of 54 ng/l which is more than 4x higher than Michigan’s Water Quality Standards (12 ng/l). This result is consistent with our previous results.
PFOS (perfluorooctane sulfonic acid) is one of a group of related chemicals known as perfluorinated alkylated substances (PFAS). This group of chemicals is commonly used in a wide range of products including stain and water-resistant fabrics, carpeting, cleaning products, paints, and fire-fighting foams. PFAS chemicals are known as forever chemicals. Epidemiological evidence has shown higher rates of several cancers are associated with exposure to PFAS chemicals.
One of the main sources of the non-compliant PFOS discharges is believed to be the use of fire suppression foam at the landfill. In 2016 Aqueous Film Forming Foam (AFFF) was used to extinguish a fire at Arbor Hills. The AFFF entered two ponds at the site but was not properly removed and cleaned until 2022. This issue is especially frustrating for The Conservancy Initiative (TCI) as we feel we have been responsible for pushing the PFOS investigation to this point.
In 2021 TCI discovered the ongoing noncompliant discharges to Johnson Creek when a Freedom of Information Act (FOIA) request uncovered test reports that indicated the Arbor Hills storm pond was contaminated. EGLE issued a violation and promised a consent order to define corrective actions to eliminate the PFOS discharges but there has been little progress. The site investigation has progressed to the point where EGLE and GFL know what needs to be done, but actions have stalled. We can’t even get periodic testing of the discharges to Johnson Creek performed to establish a baseline for measuring progress when the remediation final begins. It has been 2 ½ years since TCI discovered the PFOS discharges and they are continuing.
2 ½ years ago, EGLE issued a violation notice that required GFL to agree to submit to a consent order which will define how the PFOS contamination will be remediated or lose their discharge permit. GFL agreed to the process but there has been little progress.
Negotiating a consent order to define the remediation is being held up in EGLE’s bureaucracy.
GFL knows what needs to be done but will not proceed until ordered by EGLE.
In the meantime, GFL had a significant leachate spill into Johnson Creek in addition to the PFOS which is being discharged into Johson Creek daily. The forever chemical, PFOS, continues to contaminate the creek and aquatic life in the creek.
Table 1 is a summary of the publicly available PFOS test results. TCI believes periodic testing of the discharges to Johnson Creek is imperative. A baseline must be established to allow the progress of any remediation to be measured.
TCI suspects there are other sources of PFOS (or other PFAS chemicals) that originate from normal day-to-day landfill operations (leachate drips, spills, and seeps that find their way to the stormwater collection system) impacting Johnson Creek. Periodic testing of the discharge to Johnson Creek may help prove or disprove our suspicions.
Table 1 - Summary of PFOS Samples - Arbor Hills Landfill’s Impact on Johnson Creek
We will be contacting EGLE to see if a Consent Order is any closer. We also know Arbor Hills Landfill personnel monitor our communications and hopefully, they will begin remediation of the PFOS contamination regardless of the status of the consent order. We will continue to conduct random periodic testing and publish our results.
Notes on PFOS Samples
1 Samples taken by The Conservancy Initiative (TCI) were taken from the unnamed tributary to Johnson Creek approximately 2500 feet downstream of the Arbor Hills Landfill, south of the Northville Ridge Subdivision.
2 Response to August 31, 2022, EGLE Violation Notice, GFL Environmental, October 7, 2022 [Effluent Pond = P3-15, NPDES Sample Johnson Creek = Outfall-CR]
3 First Interim Short-Term Storm Water Characterization Study, Arbor Hills Landfill, GFL Environmental, December 3, 2021
4 PFAS Site Characterization Report, Golder Associates Inc., Oct 2020
5 EGLE Surface Water Sampling Interactive Map, August 4, 2021, EGLE, sample taken from Johnson Creek on near Ridge Road,