<CLICK HERE> for pdf version
GFL Environmental took ownership of the Arbor Hills Landfill on October 30th as part of the Waste Management acquisition of Advanced Disposal Services. GFL became the owner when Waste Management divested itself of certain Advanced Disposal assets to meet the requirements of the US Department of Justice.
This past week, The Conservancy Initiative obtained copies of letters GFL sent to the Michigan Department of Environment, Great Lakes, and Energy (EGLE) in response to Violation Notices issued to Advanced Disposal Services for malfunctions to the flare system in late September. This is our first experience with GFL. The response letters are well written and appear to have been approved by GFL counsel. The letters (mainly letter 2) disputed several legal citations made by EGLE, asserted the upset to flare system operation was unavoidable, claimed the upset to the flares did not meet the legal definition of a malfunction, and the flares had operated as intended.
Links to the original Violation Notices and the response letters are provided.
Violation Notice No. 2 (most critical) Response Letter No. 2
Violation Notice No. 1 Response Letter No. 1
Instead of getting into the weeds and dissecting the GFL response letters, The Conservancy Initiative has a simple suggestion for GFL. We recommend GFL prioritize protecting its integrity and attempt to improve its relationship with the community which is weary from the past 5 years of ADS’s mismanagement and broken promises.
Instead of making nonsensical arguments like
“… the flares did function … as designed.” and
“Blown fuses and transformer damage are mechanical failures that cannot be prevented…”
It would be refreshing if GFL would simply own the obvious problem (flares repeated shutdown when they were needed), describe the structured problem-solving technique used to develop corrective actions, and a timetable for implementation of the corrective actions.