Background
The Water Resource Division of the Michigan Department of Environment, Great Lakes and Energy (EGLE) issued a Violation Notice (VN-0011821) on June 14, 2021, to Green for Life (GFL) when they became aware of testing results showing PFAS chemicals with concentrations significantly higher than the allowable levels in the stormwater detention pond. This pond regularly discharges to Johnson Creek following rain events. The PFAS chemical test results were not properly reported to EGLE for over 1 year and GFL did not initiate any response actions. See previous posts for details of the Violation Notice.
Update
The Water Resource Division of EGLE has agreed to hold a Townhall type event to update concerned citizens on the status of the PFAS contamination at the Arbor Hills Landfill. The logistics of the Townhall are currently being worked out. An announcement will be made as soon as plans are finalized.
On July 15, 2021, GFL responded to EGLE’s Violation Notice and accepted EGLE’s offer of an Administrative Consent Order to bring the unauthorized stormwater discharge into compliance. GFL has also proposed plans to begin addressing the PFAS issues at the Arbor Hills Landfill. The plans include.
Treatment and removal of the PFAS contaminated water which has been contained in two unlined ponds at the southern portion of the property. These ponds were contaminated with fire suppression foam (which contains PFAS) during a fire in 2016. GFL plans to complete this action in 2021.
Removal of PFAS impacted soils from both ponds once the water has been removed. GFL plans to complete this action in 2021.
A proposed sampling plan to investigate the source of PFAS chemicals that are impacting the stormwater being discharged. Samples will be taken at all know PFAS sources and at all stormwater outfalls during rain events. The testing program will be completed, and a report will be submitted to EGLE in the 4th quarter of this year.
The investigatory sampling will likely be an iterative process and may involve several rounds of sampling designed to find the source of the PFAS contamination.
The Conservancy Initiative is reviewing the proposal submitted by GFL and looks forward to the Townhall meeting with EGLE. We hope to have detailed comments after our review is complete.