In this communication we will take a closer look at the odor complaint data to spotlight the increasing odor complaints and make sure that community leaders are aware the landfill may have a new owner but, in many ways, they are still the same old Arbor Hills. In a future communication, we will update the PFAS issues.

The Conservancy Initiative recently received data from the Michigan Department of Environment, Great Lakes, and Energy (EGLE) which show the volume of waste being accepted from Canada dramatically increased since Green for Life (GFL) took control of the Arbor Hills Landfill in October 2020.

Data Highlights

• In the 3 years prior to GFL, Arbor Hills accepted ZERO waste from Canada.

• From April – June of 2021 (the most recent data available), 15% of the total waste volume received at Arbor Hills originated in Canada and,

• 20% of the municipal and commercial waste (typically residential like waste) originated in Canada.

The Michigan Department of Environment, Great Lakes and Energy (EGLE), the US Department of Justice (DOJ), the US Environmental Protection Agency (EPA) and the Michigan Attorney General (AG) announced a $750,000 penalty and a settlement with Arbor Hills Energy (AHE) to finally settle the environmental violations alleged by the USEPA in 2016 and subsequent violations issued to AHE by EGLE from 2016 – 2020.

Arbor Hills received notification from Fortistar that DTE has asked them to halt operations until further notice. The estimated downtime is wide-ranging and can be anywhere from 8 hours to 2 days. All flares onsite will be in operation to accommodate gas during this period.

Although The Conservancy Initiative understands the road outage is the result of an act of nature and should only be temporary, we question the logic of routing the heaving truck traffic past an elementary school, utilizing a gravel road, and through residential neighborhoods when a better route is clearly available. A much better detour route would be Six Mile Road between Napier Road and Chubb Road and Chubb Road between Five Mile and Six Mile Roads.

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 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.

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.

… Gas construction at Arbor Hills is set to commence June 23, 2021. The remainder of this week will consist primarily of gas well drilling. During well drilling, in an effort to minimize odors, the contractor will be utilizing a vacuum box to capture fugitive emissions. Beginning next week, the pipe crew is scheduled to arrive to begin vacuum pipe installation. The entire construction project is anticipated to be completed by October 31, 2021.

On June 14, 2021, the Water Resource Division (WRD) of the Department of Environment, Great Lakes and Energy (EGLE) issued a violation (Violation Notice No VN-0011821) to Green for Life (GFL), the owner of the Arbor Hills Landfill in Salem, Michigan, for discharging PFOS[1] to Johnson Creek in concentrations above Michigan’s Water Quality Standards (WQS). The non-compliant discharge was first detected over a year ago (April 2020) but was not reported to EGLE until it was uncovered through a Freedom of Information Act Request by The Conservancy Initiative.

The Conservancy Initiative of Northville Township is announcing their support of the Township’s efforts to enforce environmental compliance at the landfill and protect Johnson Creek. Last week, the Board of Trustees authorized Supervisor Mark Abbo to file a lawsuit if Green for Life (GFL) fails to take the meaningful action they had promised in prior meetings.

Northville Township has received inquiries from residents in the Northville Ridge subdivision concerning the noise from the landfill property. The landfill was contacted and has informed the Township they are performing maintenance, cleaning out the large ponds on the property. The work involves the use of vacuum trucks and will be continuing on a Monday through Friday schedule and may last for two months, although not continuously.

There have been several alarming events at the Arbor Hills Landfill (AHL) which The Conservancy Initiative (TCI)[1] believes are a threat to the long-term health of our area’s only cold-water stream, Johnson Creek. The most alarming event involves the discharge of PFAS contaminated water for over a year. This questionable discharge should have been addressed when the stormwater pond was sampled in April 2020, however, TCI only became aware of it over a year later. We immediately notified the Department of Environment, Great Lakes, and Energy (EGLE) Jackson District Office. Now, two weeks after making our notification, we have been alert that EGLE is in the process of issuing a violation notice, but we are not aware of any responses taken by AHL.

In April 2020, Arbor Hills Landfill sampled the main stormwater detention pond for PFAS contamination as part of their investigation into PFAS groundwater contamination at the landfill. The samples revealed up to 33 times the allowable level of Perfluorooctane suffonate (PFOS)[1]. This material has been allowed to discharge directly into Johnson Creek and potentially may be continuing today.

[GFL is] …reaching out to inform the group that a DTE forced plant outage is scheduled for the weekend of April 17 through April 19. The reason for the plant outage is that DTE needs to conduct line maintenance. All flares onsite will be in operation to accommodate gas during this period. Please note, the timeframe noted was given to Arbor Hills by Fortistar Methane Group and is an estimate. Arbor Hills will remain in close contact with Fortistar plant operators and their management team throughout this duration. The plant will resume operation once clearance is given from DTE.

On Monday, April 5, 2021, construction will begin on our leachate tank expansion project located on the southeast side of the property. The construction is estimated to be from April 5, 2021, to April 9, 2021. Although we do not foresee any odor associated with this project, we have developed a contingency plan to address any issues. – Green for Life

A previous article discussed Surface Emission Monitoring (SEM). All landfills are required to conduct SEMs of the entire landfill on a quarterly basis to identify potential areas of landfill gas leaks. Corrective areas must be taken on a progressive basis until the excess emissions are corrected.

EGLE recently published a video explaining how SEM surveys are performed. We wanted to share the video.

The Michigan Department of Environment, Great Lakes, and Energy (EGLE) released its annual Report of Solid Waste Landfilled in Michigan covering the 2020 fiscal year. The current report and reports from past years are available on the EGLE website <CLICK HERE>. Our best estimate of the landfill life is 6 – 7 years based on data submitted by the landfill to EGLE over the past several years.

All large landfills are required to perform Surface Emission Monitoring (SEM) surveys on a quarterly basis to locate landfill gas venting from the landfill. EGLE Air Quality Division recently sent all Michigan landfills a letter announcing they will be conducting compliance (i.e. – violations may be issued if necessary) to verify the quality of the SEMs being conducted. The Conservancy Initiative applauds the Air Quality Division for taking this initiative and believes these more aggressive enforcement measures will pay dividends.

Green for Life (GFL), the new owner of the Arbor Hills Landfill, has begun operating the hydrogen sulfide (H2S) air monitoring station at Ridge Wood Elementary School. The air monitoring station is part of an agreement between the previous landfill owner, Advanced Disposal Services, and the USEPA to settle compliance violations cited in 2016. The air monitoring station will be operated by a third-party firm (Barr Engineering) for at least 5 years.

Most people are unaware the Arbor Hills landfill has an on-site wastewater treatment plant and a permit that allows the discharge of up to 100,000 gallons per day of “treated” groundwater into the region’s only cold-water trout stream, Johnson Creek, from December 1st through April 30th each year. The Conservancy Initiative has become aware that Arbor Hills has violated the allowable limits for ammonia as nitrogen being discharged. The exceedances are particularly troubling as the water being discharged is accumulated in two large ponds for up to a year before being discharged. These are the same ponds that were inadvertently discharged in violation of the permit in July 2020.