<CLICK HERE> for pdf version
PFAS contamination at the Arbor Hills Landfill has been a complicated issue since at least 2016. The Landfill has changed ownership from Advanced Disposal Service to Green for Life (GFL) and there have been 10 – 15 representatives from the Michigan Department of Environment, Great Lakes, and Energy (EGLE) involved with the PFAS issue. There were few serious actions taken to address the contamination until the public became involved in 2021 and began pressuring GFL and EGLE to act. It is important for the public to remain involved to protect Johnson Creek, the area’s only cold-water trout stream.
The Michigan PFAS Action Response Team (MPART) will be holding a virtual Town Hall to update the public on the status of PFAS contamination at the Arbor Hills Landfill on February 24th at 6:00 PM. <CLICK HERE> for townhall information.
Arbor Hills Landfill PFAS Contaminated Ponds
In 2016, a fire at the Great Lakes Recycling facility, located at the south side of the property, near the Five Mile Road entrance, was extinguished using Aqueous Film Forming Foam (AFFF). The AFFF contained PFAS chemicals. The AFFF was contained in Ponds 1 and 2 shown in the picture above. Shortly after the fire incident, the ponds were emptied by hauling the impacted water (believed to be approximately 1 million gallons) to a permitted treatment and disposal facility. Subsequent testing of the water which refilled the ponds found the ponds remained contaminated.
The Conservancy Initiative is unaware of any actions taken to address the contaminated ponds from 2017 to 2019. In March of 2020, MPART held a virtual town hall to update the community on PFAS contamination of a groundwater well located near Napier Road and the Railroad Track crossing. The message received at this town hall was “the contamination was contained, was not a threat to drinking water wells in the area, and EGLE was working with the Advanced Disposal Services to develop a remediation plan.” There was no mention of the contaminated stormwater ponds, even though they are in the same general area of the contaminated shallow groundwater well. Later in 2020, Advanced Disposal Service began making attempts to gain approval to treat the contaminated pond water on-site and pump the treated water to either Johnson Creek or the Ypsilanti Communities Utilities Authority (YCUA) using Northville Township sewers. These proposals had little chance of success due to the public opposition and significant permitting challenges related to utilizing Johnson Creek and the Arbor Hills Landfill has been operating as in “Significant Noncompliance” with the permit it holds with YCUA for several years.
In April of 2021, we learned the PFAS issue at Arbor Hills is much more serious. During a public records review, The Conservancy Initiative learned the Arbor Hills Landfill had sampled the stormwater detention pond as part of an investigation into the source of PFAS. The samples were taken a year earlier, in April 2020, and contained PFOS concentrations over 30x the allowable concentrations of PFOS (two samples taken on 4/2/2020 contained 94 ng/l and 400 ng/l of PFOS. Michigan Rule 57 limit for PFOS in surface water is 12 ng/l.) The detention pond regularly discharges to Johnson Creek, but the violation was not self-reported, and no corrective actions were initiated. The discharge of stormwater contaminated with PFOS into Johnson Creek is continuing today and likely began at the time of the 2016 fire event. EGLE issued a significant Violation Notice (VN-011821) on June 14, 2021.
Stormwater Detention Pond Outlet Weir
The Violation Notice will result in a Consent Order being issued to GFL that will define a pathway and a timeline for the Arbor Hills Landfill to stop the non-compliant PFAS discharges to Johnson Creek and remediate the impacted areas. The first step in this process has been a Short-Term Stormwater Characterization Study (STSWCS). The STSWCS is a methodical attempt to characterize the stormwater runoff from the landfill property by sampling the runoff at key locations during precipitation events.
An interim report from the STSWCS has been submitted to EGLE and is available to the public <CLICK HERE>. When reviewing the figures and tables in the STSWCS it is important to know the water quality standard for PFOS entering Johnson Creek is 12 ng/l (Rule 323.1057). Approximately 80% of the over 130 stormwater runoff samples taken during the STSWCS contained PFOS with concentrations greater than this water quality standard. Here are some of The Conservancy Initiative’s observations from the study:
The Arbor Hills Landfill is continuing to discharge stormwater with PFOS above Michigan Water Quality Standards to Johnson Creek. Samples taken in the Fall of 2021 from the unnamed tributary to Johnson Creek directly downstream of the landfill contained PFOS above water quality standards (see Figure 3 in the STSWCS).
The wetlands (Wetlands 1) adjacent to Pond 2 have significant contamination. Either the AFFF was not contained as originally believed or there is another source (see Figure 6 in the STSWCS).
There is significant PFOS contamination near leachate handling areas (leachate tanks, transfer piping, loading areas, leachate treatment equipment). (See Figure 7 in the STSWCS, the gold lines labeled FM are pressurized underground leachate transfer pipes). Leachate equipment should be leak tested.
All the water samples taken from the stormwater detention pond contained PFOS above water quality standards. All the inlet samples to the stormwater detention pond, even inlets across the pond from the AFFF usage area, contained PFOS above water quality standards. This appears to indicate the landfill is impacting stormwater runoff. (See Figure 7 in the STSWCS).
The AFF used during the 2016 fire is believed to be the primary source of the PFAS contamination. Although the report does not mention it, the stormwater runoff from the landfill may also be contributing to PFAS exceedances in the discharge to Johnson Creek.
The Conservancy Initiative will continue to track the PFAS contamination issue and post updates when warranted. If possible, please plan to attend the upcoming virtual town hall to hear the current plan to update the PFAS contamination.
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.