Below are excerpts of the comments submitted by the Conservancy Initiative related to a permit that authorizes the Arbor Hills Landfill to discharge approximately 100,000 gallons per day into Johnson Creek from December 1 through April 30 each year. This permit covers the large lagoons on the property just east of Napier Road, near the Northville Ridge subdivision. The permit is being re-issued by EGLE and is in the “Public Comment” phase of the permitting process. <CLICK HERE> for a complete version of the comments we submitted.
The Conservancy Initiative was disappointed to learn the proposed NPDES permit for the Arbor Hills Landfill Remediation Site does not contain monitoring requirements for PFOS and PFOA. The Conservancy Initiative believes the nature of the water being treated at this site; contaminated groundwater which originates from near a slurry wall surrounding an un-lined municipal waste landfill poses a significant risk for PFAS[1] chemicals. Periodic monitoring for regulated PFAS chemicals is a low-cost, proactive, common-sense approach that should be taken to protect Johnson Creek.
We question EGLE justifying no PFAS monitoring is needed based on a few grab samples, especially given the widespread PFAS contamination and historic leachate handling problems at the site. It appears the only piece of evidence that may have triggered the Water Resource Division to require PFAS monitoring would have been a non-compliant concentration of PFOS or PFOA at the NPDES discharge point. The public expects EGLE to be more proactive in protecting the waters of Michigan, especially the only cold-water trout stream in western Wayne County.
We respectfully ask EGLE to reconsider and at a minimum require monitoring for regulated PFAS chemicals in each gradient pond near the start of the discharging season[2] to ensure the gradient ponds are not contaminated. The cost of once-per-season monitoring is estimated to be less than $1,000, a small price to require the landfill operator to pay to protect Johnson Creek.
[1] 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.
[2] The proposed permit allows discharges from Dec 1 – Apr 30 each year. Groundwater is accumulated in gradient ponds throughout the year and held until the cold weather discharge season. Once per year monitoring at the start of each discharging season would be a minimal burden monitoring solution.