The Conservancy Initiative has learned the Michigan Department of Environment, Great Lakes, and Energy (EGLE) has issued another significant Violation Notice dated 7/28/20 to the Arbor Hills Landfill owner/operator, Advanced Disposal Services. The Violation Notice provides detail that many of the gas recovery wells at the landfill are restricted by leachate accumulation which is blocking or restricting gas flow in the wells.
This violation is the most significant violation at Arbor Hills. The Conservancy Initiative believes it is the root cause of the excess emissions and odors from the landfill. Putting this violation into very simple terms, the Arbor Hills Landfill is Water-Logged, and until the landfill is dewatered the community will continue to experience excess fugitive emissions and odors. Below are excerpts from the Violation Notice:
The GCCS [Gas Collection and Control System] ability to collect landfill gas continues to be impaired at least in part due to high liquid levels in the gas wells. This problem was first identified in 2016 and continues to get worse. This violation was previously cited in Violation Notices dated 3/14/19 and 10/21/19. It was also cited by the USEPA in a violation on 9/29/16.
… at least 185 vertical gas wells had more than 50% of the well screen blocked by liquid. 48 vertical wells were listed as having at least 100% well screen submerged. 73 vertical gas wells were listed as needing to be completely replaced. More than 80 wells that despite having existing liquid pumps installed, still have more than 50% of the screen flooded. Furthermore, of the 192 vertical wells listed as having pumps, nearly half of the pumps had operational problems over the January to April 2020 reporting period.
ADS has also received Violations Notices for improperly managing the leachate on the liner at the bottom of the landfill dated 4/16/20 and 1/24/19.
EGLE asserts the current leachate problems represent a violation of ADS’s responsibility to operate the landfill and the associated emission control equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions [40 CFR (e)(1)(i)]. This Violation Notice clearly states that actions taken to date by the landfill have not been acceptable and have not corrected the leachate accumulation problem. Leachate accumulation and restrictions to gas wells have increased since the problem was first detected.
A surface emission monitor (SEM) is used to detect fugitive emissions from the surface of the landfill. All municipal landfills are required to conduct SEMs scan for methane using a 30-meter grid at least twice per year to identify and correct fugitive emissions. EGLE recently purchased equipment to conduct their own SEM and conducted an abbreviated methane SEM survey on June 25, 2020. EGLE quickly found numerous areas with significant surface methane emissions (i.e. – excess emission and odor sources). Many of these methane surface exceedances occurred above areas with flooded wells, showing that the GCCS system remains impaired.
The water-logged landfill issue is not a secret and it is not surprising ADS is searching for a low cost alternative to dispose of leachate (ADS recently applied for permits to discharge to Johnson Creek). A previous landfill manager, Mark Johnson, recognized leachate management as a significant problem and was making plans to increase leachate removal in the spring of 2019. He shared his plans with EGLE during multiple meetings. Below are excerpts from an EGLE inspection report (N2688_SAR_20190402.pdf page 2):
... Mark was very frustrated that talks with him are going nowhere regarding increasing the amount of leachate through the township sewers to Yucca [Ypsilanti Community Utilities Authority] from 100,000 to 250,000 gallons per day. (He thinks it will take at least year to return to normal levels).
The landfill “dewatering” plans all ended with the announcement of the potential Waste Management merger and a change to the management team at the landfill.
The Conservancy Initiative is continuing efforts to encourage our elected Attorney General to take legal actions to force the landfill owners to implement effective corrective actions and impose penalties commensurate with the landfill’s continuing violations. Recently, the leadership from Northville Township, Plymouth Township, and the City of Northville co-signed a letter to the Attorney General demanding action. We are awaiting a response.