When the Michigan Attorney General and the Department of Environmental, Great Lakes, and Energy (EGLE) announced a settlement with the Arbor Hills Landfill it included a requirement for a Perimeter Monitoring System on the eastern perimeter of the landfill. The Perimeter Monitoring System detects Methane (CH4) and Hydrogen Sulfide (H2S) emissions leaving the landfill property that may impact neighborhoods in Northville Township. Six monitoring stations are visible at the fence line adjacent to Napier Road. Monitoring results from the Perimeter Monitoring System are available for the public to view and download at https://arborhillsmonitoring.com/Home/.
Fig 1 - Monitoring Station on eastern border of Arbor Hills
The Consent Judgement requires the landfill owner, Green for Life (GFL) to promptly respond and implement corrective actions whenever methane concentrations exceed 40 ppm. On October 13, 2022, EGLE issued a Violation Notice to Arbor Hills citing 34 separate days from June 10 – September 20, 2022, where Arbor Hills failed to promptly identify and correct the cause(s) for methane concentrations exceeding 40 ppm. The Violation Notice states that during a site visit on September 20, EGLE identified a large source of methane (landfill gas) leakage that was likely one of the main sources for the exceedances. It appears EGLE believes Arbor Hills should have been able to locate this source themselves based on the tone of the Violation Notice.
In a letter to EGLE dated November 18th GFL suggested that most of the methane exceedances detected occurred during late night or early morning hours and could be discounted as odor complaints are rarely received during these times. Instead of correcting the methane leakage, GFL requested a meeting with EGLE to discuss modifying the methane trigger level in the Consent Judgement and possibly relocating the monitoring with methane detections.
Shortly after EGLE received GFL’s response to the October 13th Violation Notice a second violation notice was issued. EGLE stated GFL’s response to the initial Violation Notice as inadequate and since the initial violation, there have been 20 more days with methane exceedances. EGLE also informed GFL they consider the portable methane detection equipment used by landfill personnel to locate methane leakage to be inadequate. EGLE has put GLF on notice by stating that the Company may be subject to stipulated penalties for ongoing violations. The stipulated penalties start at $500 per day per violation.
The Conservancy Initiative is encouraged by the aggressive approach EGLE appears to be taking. EGLE believes the perimeter monitoring system exceedances are a very important issue that will become even more important when Arbor Hills begins to utilize cell 6 in 2023 as this cell is much closer to Northville neighborhoods. [Cell 6 is the landfill cell being constructed near the entrance at Six Mile and Napier Roads].
We have included a diagram showing the location of landfill cell 6. The active portion of the landfill will be moving closer to Northville when this cell becomes active. The Conservancy Initiative will continue to monitor the status of these violations and report updates as appropriate.
Fig 2 - Arbor Hills Cell 6 will bring active landfill operations closer to Northville