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Since The Conservancy Initiative (TCI) discovered and reported the non-compliant discharge of PFAS contaminated stormwater from the Arbor Hills Landfill to Johnson Creek, it has been very difficult to obtain meaningful updates.
TCI and interested citizens have grown frustrated as some basic questions cannot be answered:
Is the contamination continuing?
Have follow-up samples of the stormwater been taken? Was the single day of sampling representative of the stormwater?
Has a schedule been established to sample the stormwater discharge and Johnson Creek regularly?
Mark Abbo, Northville Township Supervisor, and Brian Turnbull, City of Northville Mayor have both sent letters requesting EGLE reassess the resources they have dedicated to the Arbor Hills problem and provide our community with a townhall type update. The Conservancy Initiative is extremely grateful to our local leadership, and we hope other community leaders will join Supervisor Abbo and Mayor Turnbull in calling for EGLE to step up their response to the expanding Arbor Hills’ PFAS issue. <Northville Township Letter> <City of Northville Letter>
Background
On April 27, 2021, The Conservancy Initiative (TCI) notified the Water Resource Division (WRD) of EGLE of testing showing the stormwater being discharged from the Arbor Hills Landfill into Johnson Creek contained PFAS chemicals above Water Quality Standards (WQS). The testing report was contained in a report which was previously submitted to the EGLE by the landfill owner, Green or Life (GFL) but was not clearly identified as being discharged to Johnson Creek. TCI obtained the report through a Freedom of Information (FOIA) request. The troubling stormwater testing was conducted in April 2020, and we are not aware of any additional stormwater testing conducted since.
TCI has been tracking very slow efforts being made to address PFAS contamination of surface water ponds located south of the railroad tracks at Arbor Hills. The contamination has been known since 2016 but little has been accomplished to address the contamination being held in open water ponds.
Current Status
EGLE has been taking very deliberate steps to resolve the ongoing violation. Obtaining information regarding the status has been difficult.
EGLE issued a violation notice on June 14, 2021 (VN-011821), which clearly identifies the violation as ongoing since April 2020. The violation notice requires GFL to agree to an Administrative Consent Order or EGLE will start the process to cancel GFL’s stormwater discharge permit. The violation notice requires GFL to perform extensive testing to characterize all potential stormwater sources for PFAS chemicals.
GFL provided EGLE with additional information related to a PFAS contaminated groundwater well located near the railroad track crossing at Napier Road. The report provided little new information.
GFL was to update EGLE on surface water contamination south of the railroad tracks (contamination has been known since 2016) and their plans to address the contaminated ponds by the end of June. TCI has submitted a FOIA request for this information but has not received it yet.
Arbor Hills Surface and Groundwater locations of interest. Orange shaded descriptions indicate areas containing PFAS chemicals above Water Quality Standards
Description of Points of Interest on Map
Pond 2 and 3 and the wetlands around Pond 2 are contaminated with PFAS chemicals. The contamination is believed to have resulted from the use of fire suppression materials during a fire at the site in 2016. No effective mitigation efforts have been taken.
Pond 1 is the stormwater detention pond that regularly discharges (following rain events) to Johnson Creek. PFAS contamination was identified in April 2020 but was not properly reported to EGLE. No mitigation efforts have been taken.
The groundwater well was identified with PFAS contamination in 2019 as part of a sampling program of all landfills in Michigan. The investigation of the contamination of this well resulted in the stormwater detention pond (Pond 1) being sampled.
Leachate contains PFAS and is discharged to the sanitary sewer daily. A temporary restriction in the sanitary sewer system resulted in a significant spill of leachate in 2016.
Note - the PFAS acronym refers to a large family of chemicals, Per- and polyfluoroalkyl substances which are man-made chemicals that includes PFOA, PFOS, GenX, and many other chemicals. The predominant PFAS contamination found at Arbor Hills is PFOS or Perfluorooctane sulfonate, which is regulated in Michigan as a water contaminate.