Tiffany Myers (by email)
District Supervisor
Water Resource Division
EGLE Jackson District Office
301 E. Louis Glick Highway
Jackson, MI 49201-1556
Re: PFAS Impacted Stormwater Pond - Arbor Hills Landfill
10690 West Six Mile Road, Northville, MI 48197
<CLICK HERE> for pdf version
Ms. Myers,
In 2016, two Stormwater Ponds at the Arbor Hills Landfill became contaminated with PFAS chemicals[1]. The landfill owner at that time, Advanced Disposal Services (ADS), appeared to be focused on addressing the contamination immediately. The outlet from the ponds to Johnson Creek was plugged, MDEQ was consulted, and both ponds were sampled and analyzed. All progress stopped in December 2016 when the analysis indicated the ponds contained PFAS chemicals significantly above levels of concern and the ponds could not be discharged to Johnson Creek without an NPDES Permit[2].
Since November 2016, the PFAS impacted stormwater has been stored in the unlined, uncovered ponds without any meaningful steps being taken to advance the remediation until the summer of 2020 when ADS requested permission to treat the water on-site and discharge it to a cold water trout stream, Johnson Creek[3]. The permit application required to authorize this action was put on hold shortly after being submitted.
The Conservancy Initiative has the Following Questions
How are the ponds staying hydrologically balanced; what prevents a pond designed to collect stormwater from overfilling when the outlet is plugged?
Are the ponds connected to the groundwater or surface waters?
Is the pond’s contamination and the groundwater contamination reported by the Michigan PFAS Action Response Team (MPART) related?[4] Why was the stormwater ponds’ contamination not included during the MPART townhall for Arbor Hills?
What impact are the PFAS impacted ponds having on wildlife?
Green for Life (GFL) assumed ownership of the landfill on October 30, 2020, and recently submitted an update on the remediation status of the stormwater ponds[5]. This document included two options for disposal of the contaminated water.
Disposal via sanitary sewer
This option requires additional sanitary sewer capacity which is unlikely.
Arbor Hills has unsuccessfully sought additional sanitary sewer capacity for more than a year.
Reuse the impacted water for dust suppression or irrigation
TCI does not believe this is viable as the runoff would impact stormwater.
Although not mentioned in GFL’s status update, a third option is to haul the impacted water to a properly permitted disposal facility. This option is costly.
Recommendations
The Conservancy Initiative (TCI) offers the following recommendations.
EGLE must impose a short-term deadline for the disposal of the PFAS contaminated stormwater. The contamination issue has been known since December 2016 and it appears the only hold-up to disposing of this water is cost. Storing the water in unlined, uncovered, unprotected ponds is only making the issue worse.
EGLE should require periodic sampling of the Arbor Hills Landfill stormwater effluent for PFAS chemicals to determine if contaminated water is impacting the stormwater outfall.
TCI requests EGLE clarifies the use of dust control suppressants at Arbor Hills. Based on conversations with several EGLE staff members we believe there may be significant confusion on this topic:
An August 18, 2018 Compliance Concern (CC-001168) indicates only clean water can be used for dust suppression on landfill roads[6].
The GFL status update suggests using the PFAS contaminated water for dust control or irrigation.
TCI believes any material used for dust control on landfill roads or irrigation would runoff the site similar to stormwater and therefore must be clean water.
Remediation of the ponds must include an investigation of groundwater in the area of the ponds to determine if groundwater has been impacted.
MPART information for Arbor Hills Landfill should be updated to include the stormwater ponds.
The Conservancy Initiative will continue to track the remediation of the stormwater ponds and provide updates to the community. We are available to discuss the status of the remediation and our recommendations.
Sincerely,
/s/
Dave Drinan
Director, The Conservancy Initiative
cc: R. Lassel (TCI), D. Horan (TCI), R. Mummineni (TCI), J. Cordina (TCI), C. Alexander (EGLE), T. Buckmaster (EGLE), M. Konieczki (EGLE), M. Steffler EGLE), R. Burns (EGLE), S. Miller (EGLE), L. Bean (EGLE), J. Camilleri (EGLE). S. Sliver (EGLE), M. Abbo, M. Kolesczar, D. Polhanki (all by email)
[1] “Arbor Hills PFAS/PFOS Contaminated Stormwater Concern", The Conservancy Initiative, Sept 13, 2020
[2] Email from Alexander Whitlow to Anthony Testa, Dave Rettell, Paul Roberts, “Stormwater Pond Sampling”, December 15, 2016
[3] PFAS Removal from Impacted Stormwater Pond, June 2, 2020, Don Kinding, Advanced Disposal Services
[4] Michigan PFAS Action Response Team, Washtenaw County, Salem Township, Arbor Hills Landfill, Inc.
[5] Green for Life Environmental – Arbor Hills Landfill, Inc., Arbor Hills Landfill Storm Water Ponds, David Seegert, November 10, 2020
[6] Michigan Department of Environmental Quality, Compliance Concern (CC-001168) item 3, August 2, 2018, Rachel Burns