NO NEW LANDFILL!
ENOUGH IS ENOUGH!
Arbor Hills has completed the construction of Cell 6 and has been issued an operating license to begin placing waste in Cell 6. The bad news for Northville Township residents is the landfill just moved closer. Cell 6 is approximately 1/2 mile closer to the eastern property lines than the current active landfill section.
The PFAS issues at the Arbor Hills Landfill (AHL) are complex issues. The Conservancy Initiative has been trying to draw more attention to the impacts AHL is having on Johnson Creek and received some unexpected help from MLIVE. MLIVE did a very nice job simplifying the issues in an article he published on MLIVE on June 30, 2022. Please take a moment to review this article.
If you want to understand what the big fuss is over PFAS chemicals or forever chemicals, stream the movie Dark Waters (Mark Ruffalo, Anne Hathaway, and Tim Robbins) this weekend. We don’t want to endorse the movie, but it does tell a frightening story.
The MLIVE article and the sampling recently completed by The Conservancy Initiative highlight that the stormwater runoff from AHL is being discharged into Johnson Creek with PFOS, a regulated “forever chemical” with concentrations higher than Michigan Water Quality Standards for Lakes and Streams. The landfill owner, Green for Life, and EGLE are aware of the issues but we have been unable to force periodic sampling of the discharges. The problem is not going to be corrected until it is at least measured.
We hope to have much more discussion on this issue.
In May of this year, an amended complaint was filed on behalf of the Township and included two Northville Township residents as co-plaintiffs. The addition of the Northville Township residents to the lawsuit strengthens Northville Township’s and its resident’s position. For information about possibly joining the lawsuit contact The Mike Cox Law offices at (734) 591-4002.
On May 22, 2023, The Conservancy Initiative lost our patience and obtained a sample from the unnamed tributary to Johnson Creek that the Arbor Hills Landfill uses to discharge both its stormwater runoff. We found PFOS concentrations of 49 ng/l, over 4 times the Michigan water quality standards of 12 ng/l for surface water (test report). In addition to this test, a study published by the Ecology Center found alarming levels of PFOS in a Creek Chad caught in Johnson Creek at the Fish Hatchery Park near downtown Northville. Arbor Hills Landfill is the most likely source of the PFOS found in the creek and the fish sample.
The Michigan Department of Environment, Great Lakes, and Energy (EGLE) recently announced a public comment period for two proposed air permit applications submitted by the Arbor Hills Landfill. We encourage all residents to attend the virtual public hearing scheduled for May 18, 2023, and anyone with comments on the permits to submit the comments in writing before the end of the comment period. <CLICK HERE> for a link to the Public Comment Period and the Public Hearing.
One hundred fish were collected from the Rouge, Huron, and Detroit River watersheds as part of a partnership with the Ecology Center to test whole fish for these forever chemicals. The results of their study are alarming, all the fish tested contained PFAS. 9 fish tested from the Rouge River Watershed (includes Northville and Johnson Creek) contained between 11 to 59 parts per billion PFAS. Most alarming for the Northville community was a Creek Chub harvested from Johnson Creek, in the area of the historic fish hatchery, containing 38 parts per billion PFAS.
Tonight, February 28th, the Arbor Hills Landfill caused a significant odor event which impacted several Northville Township neighborhoods but seem to impact the Northville Ridge neighborhood the hardest. The Conservancy Initiative checked the perimeter monitoring system data and sent the following email to EGLE and other local elected officials to make sure they are aware of the event and request follow-up actions.
When The Conservancy Initiative is occasionally asked, “How can I help?” We will respond that the two most important and simple things any resident can do are:
Report Noxious Odors using The Conservancy Initiative Odor Report. Odor reports are immediately shared with landfill personnel, EGLE, and several local elected officials. The odor reports are used to identify and correct issues as well as track the landfill’s performance.
Contact your elected politicians and make sure they understand your issues with the landfill and your opinion on a potential expansion. Your elected politicians are your representatives; make sure they understand your opinion.
Thank you to Northville Township Supervisor Mark Abbo and his team. Supervisor Abbo sent a letter to EGLE making it clear that Northville Township is opposed to any proposal from Arbor Hills to soften or weaken the Consent Judgment. <CLICK HERE> to read Supervisor Abbo’s letter.
The Arbor Hills Landfill is nearing the end of its life. Arbor Hills is expected to reach its permitted capacity in approximately 6 years. The landfill is actually filling at a faster rate than necessary since Green for Life (GFL) became the landfill owner because a significant amount of Canadian trash is being accepted. The Conservancy Initiative expects GFL to request a permit to expand the landfill, and extend its life, using the property they own North of Six Mile Road very soon.
EGLE issued Violations Notices to Arbor Hills in October and December for not inadequately responding when action levels were reached. The violation notices cited 54 separate days from June 10, 2022 - December 6, 2022, when CH4 exceed action levels and Arbor Hill’s response was inadequate.
Green for Life (GFL), the current owner of the Arbor Hills Landfill, believes most of the high CH4 concentrations are due to atmospheric conditions, occur during times when odor complaints are not normally received (overnight hours with very calm conditions), and do not warrant corrective actions. GFL has requested changes to the perimeter monitoring system and the response requirements contained in the Consent Judgement.
The Conservancy Initiative, Northville Township, and the City of Northville Leadership believe all instances of high CH4 concentrations will eventually result in odors and must be investigated and corrected immediately. We strongly oppose the changes suggested by Arbor Hills.
Shortly after EGLE received GFL’s response to the October 13th Violation Notice a second violation notice was issued. EGLE stated GFL’s response to the initial Violation Notice as inadequate and since the initial violation, there have been 20 more days with methane exceedances. EGLE also informed GFL they consider the portable methane detection equipment used by landfill personnel to locate methane leakage to be inadequate.
For the past 5 years, residents who live in the shadow of the ever-growing Riverview Land Preserve have organized to oppose a proposed expansion of the landfill. The expansion plans are based solely on the economic needs of the City of Riverview as there is plenty of alternative landfill capacity already existing in Wayne County. …. They were rewarded when the Wayne County Solid Waste Facility Inclusion Committee denied the landfill’s expansion request.
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.
On August 23rd EGLE issued a violation to Arbor Hills Energy (a.k.a. Fortistar) for beginning construction of a Renewable Natural Gas (RNG) facility prior to obtaining the required air permits (commonly called Permits to Install or PTI). On September 1st EGLE announced changes to the AHE Consent Decree. This Consent Decree requires AHE to significantly reduce Sulfur Dioxide (SO2) by March 31, 2023. AHE has reported supply chain issues that are delaying the installation of the Renewable Natural Gas (RNG) plant they have announced.
On the evening of August 4th, the Arbor Hills Landfill reported a leachate spill into Johnson Creek using EGLE’s Pollution Emergency Alert System (PEAS). The Conservancy Initiative has obtained the incident reports submitted by GFL and documents from the EGLE inspection which occurred immediately following the incident.
The Conservancy Initiative learned there was a leachate spill at the Arbor Hills Landfill on Thursday evening, August 4th which resulted in an unknown quantity of leachate being discharged into Johnson Creek. Based on verbal reports, a leachate collection sump pump at the landfill plugged (i.e. – the pump stopped pumping), leachate overflowed into the stormwater collection system and was discharged to Johnson Creek. GFL operating personnel responding to the incident reported the leachate spill (as required) using EGLE’s Pollution Emergency Alert System (PEAS).
The Arbor Hills Landfill has two permitted discharge points (outfalls) which impact Johnson Creek. Both of these permits are expiring and are in the process of being renewed (i.e. – basically new permits issued). The Conservancy Initiative recently submitted comments requesting EGLE add requirements for Arbor Hills to regularly monitor their discharges to Johnson Creek for regulated PFAS[1] chemical concentration. We believe the additional monitoring requirements are warranted due to the widespread PFAS contamination discovered at the site and the Arbor Hills Landfill’s poor environmental compliance record.
During the first 23 days of June, residents downwind of the landfill submitted over 100 valid odor complaints. The odor complaints were mainly the neighborhoods located very near the landfill, Steeple Chase and Northville Ridge. The Perimeter Monitoring System data gave very little indication of excess emissions or noxious odors during this time period (see analysis below). Methane (CH4) concentrations never approached the action level of 40 parts per million (ppm) required in the Settlement Agreement.
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