Featured May 16, 2023

Graphic Packaging’s Statement on MDHHS Study & Odor Action Plan

Graphic Packaging International (GPI) continues to place a high priority on the health and safety of employees and community neighbors. As a part of this commitment, GPI has published its ongoing Odor Action Plan, which is a critical part of the company’s continued investment in the Kalamazoo community. Graphic Packaging first began addressing the odor issue voluntarily more than a decade ago, and in February of this year, incorporated its findings and recommendations into a consent agreement with the state of Michigan.  

“We’ve been a part of Kalamazoo for more than 100 years, and we are committed to improving not just the air quality but the quality of life in the community we call home,” said Scott LeBeau, vice president of recycled mills at Graphic Packaging. “We have made progress in recent years, but we know we need to continue to work in lockstep with Kalamazoo’s Water Reclamation Plant (KWRP) to make the impact that we are all striving to achieve. We will relentlessly pursue improved air quality in our community.” 

Graphic Packaging and the Michigan Department of Environment, Great Lakes, and Energy (EGLE) agreed in a February 2023 consent agreement that GPI would investigate any readings exceeding 25 parts per billion (ppb) of H2S over a two-hour period, or 50 ppb over a half hour. The targets are based in part on guidance from the U.S. Agency for Toxic Substances and Disease Registry (ATSDR), which set a minimum level of concern for mid-term exposure (15-364 days) of 20 ppb. Graphic Packaging has consistently complied with the terms put forth in the EGLE consent agreement.  

Odor Action Plan

Graphic Packaging expects to complete its $8 million commitment for odor mitigation equipment by the end of 2023. The company also increased its annual wastewater treatment operating costs to $2 million to further reduce the potential for odors. In addition, Graphic Packaging actively participates in the City’s Odor Task Force, chartered to address odor issues at the Kalamazoo Water Reclamation Plant, the mill and any other potential sources.  

“This is a top priority for our leadership team,” said LeBeau, who works in Graphic Packaging’s Kalamazoo plant. “Every day, we take several actions to help us proactively address odors. Leadership reviews odor observations in our morning meetings. We have staff who conduct daily inspections along a set route through neighboring residential areas, keep a log of their observations and report to the leadership team. We continuously monitor the Envirosuite readings for H2S spikes. These actions provide essential data that we can then use to deploy countermeasures to curb emissions.”  

Some of Graphic Packaging’s most impactful air quality measures to date include:

  • Capping a city-owned sewer vent that was identified as a potential source of nuisance odors in 2009.
  • Optimizing the chemicals used in key processes to reduce the potential to generate odors. 
  • Installing and continuously monitoring 16 Envirosuite odor monitors throughout GPI’s property, with real-time data posted on KalamazooRecycles.com. 
  • Conducting independent evaluations to identify the most effective methods to mitigate the potential for nuisance odors. 
  • Investing in discharge water flow control to ensure predictable water flow through the sewer system to KWRP. 
  • Holding daily mill leader team meetings to assess facility odors.

Additional initiatives planned this year are: 

  • Installing a wet scrubber system designed to remove H2S emissions from equipment in the mill wastewater treatment plant. 
  • Replacing the current oxygen rental system with a permanent system. This decision was made after the rental system proved to be highly effective at reducing H2S. 
  • Working with the City of Kalamazoo to reroute discharged water away from a junction chamber that has been identified as a source of nuisance odors. 

“We are dedicated to remaining compliant with all health, safety and environmental regulations,” LeBeau said. “Our commitment runs deeper than checking the box. This is a complex issue. We want to find effective and long-lasting solutions so our community can thrive for years to come.”  

Read the details of Graphic Packaging’s Odor Action Plan.

Health Assessment

A recently released health consultation by the Michigan Department of Health and Human Services (MDHHS) has driven even more urgency around odor mitigation. A key finding from the MDHHS report, issued May 8, cites that continuous long-term exposure to hydrogen sulfide at levels found near KWRP’s sewage treatment center and GPI’s paperboard mill could potentially produce nasal or eye irritation in some people, which could become chronic over a lifetime of exposure.  

GPI has engaged third-party experts to analyze the report and determine any updates to the company’s action plan. The company is also requesting clarification from MDHHS on whether 1.4 ppb is meant to be a new statewide standard for H2S emissions.  

“We appreciate the work that went into the MDHHS assessment,” LeBeau said. “It is very disappointing to learn that any irritant, temporary or chronic, might result from the air surrounding our property and the City’s wastewater facility. It is a positive sign that no correlation was found between H2S presence and asthma or other potentially life-threatening illnesses.” 

“As one of the largest employers in this community, our primary concern will always be the health and wellbeing of our 750 Kalamazoo employees and all of our neighbors,” LeBeau said. “We are optimistic that the actions we are taking in the months ahead with the City’s wastewater reclamation plant will make an even bigger difference for everyone living and working in this area. We are in this for the long haul.”  

For updates on Graphic Packaging’s efforts to invest in the community and tackle odor issues, visit KalamazooRecycles.com.  

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Featured May 16, 2023

Odor Action Plan

At Graphic Packaging, we are proud to call Kalamazoo home. That’s why we have invested more than $800 million in the past several years in a new, state-of-the art mill and upgraded equipment and have implemented environmental controls to reduce the potential for nuisance odors near our operations. 

Since 2019, we have been an active participant on the City of Kalamazoo’s Odor Task Force, which has been studying and addressing the potential for nuisance odors from our operations, the Kalamazoo Water Reclamation Plant (KWRP), and other potential community sources. Graphic Packaging expects to complete its $8 million commitment for odor mitigation equipment by the end of 2023. The company also increased its annual wastewater treatment operating costs to $2 million to further reduce the potential for odors. 

This action plan outlines the steps we have taken and will continue to take – both individually and through our position on the Odor Task Force – to address the potential for nuisance odors in our community. 

We know this work has taken on even greater importance in light of the findings by the Michigan Department of Health & Human Services that lifetime exposure to hydrogen sulfide (H2S) in the air has the potential to cause chronic nasal irritation in some people.  

We take this issue seriously and will continue to work alongside City of Kalamazoo leaders and state officials to identify, assess and address potential sources of H2S and other emissions in our community.

Past Odor Mitigation Activities

2009

  • June: The City of Kalamazoo’s Water Reclamation Plant (KWRP) owns a junction box that is located on Graphic Packaging’s campus. It was identified as a significant source of H2S. Graphic Packaging sealed it to prevent outgassing of H2S on behalf of the City of Kalamazoo.

2017

  • July: After listening to community feedback, we added an odor treatment product to the wastewater in the clarifier to reduce the potential for odors. 

2019

  • September: We joined the City of Kalamazoo’s Odor Task Force, which is primarily a partnership of Graphic Packaging, KWRP and concerned stakeholders. 
  • September: We supported the City of Kalamazoo’s creation of the Odor Hotline, which attempts to address odor concerns in real-time. 

2020

  • September: We installed 10 Envirosuite monitors throughout our Kalamazoo campus. 
  • September: We began a peroxide feed to replace the previous odor treatment product. This improvement treats the process water in our operations and mitigates odors. 
  • November: We had an independent third party, RK & Associates, conduct an odor study. It concluded we do not generate odors rising to the level of “nuisance odors,” although we do emit odors typically associated with a mill. This study established baseline metrics that further informed future odor reduction measures. 

2021

  • January: We began feeding oxygen (O2) to the clarifier, in addition to peroxide, to better control residual levels of dissolved oxygen to minimize the potential for hydrogen sulfide generation. This is our current process to manage odors, and we are continuously optimizing a combination of oxygen, peroxide, bleach and biocide to improve our Oxidation Reduction Potential (ORP) values. 
  • March: We installed six additional Envirosuite monitors, totaling 16 units throughout the property. 
  • April – August: We commissioned an independent third-party expert in industrial wastewater engineering, GDH, to evaluate our odor management practices and recommend a path forward. GDH concluded the most effective way to address H2S was through the use of chemical additives, which were already in use to significantly reduce H2S generation in the mill wastewater system. EGLE supported the continued usage of our chemical strategies. 
  • December: We retained former Kalamazoo City Commissioner Eric Cunningham as a community liaison to engage with area residents. His main responsibilities include: 
    • Cultivating meaningful relationships with community leaders and residents 
    • Identifying desired community programs and prioritizing them based on community feedback 
    • Measuring community engagement impact 

2022

  • January – August: We worked with EGLE to finalize the details of a state-approved Nuisance Minimization Plan for Odors (NMPO) and the details of the Administrative Consent Order (ACO). The NMPO stipulated we must investigate H2S readings over certain thresholds.  
  • August: To deepen our relationships within our community, we created the Community Advisory Committee, comprised of local leaders from business, government and nonprofit organizations. This group meets regularly to identify areas where Graphic Packaging could positively impact local initiatives and to hear local feedback on areas of improvement. 
  • December: We had an alert set up in the Envirosuite system whereby the Environmental Manager or his/her designee will investigate if a monitor has two consecutive 15-minute averages of H2S concentration exceeding 50 ppb or if the 15-minute average H2S concentration in a monitor exceeds 25 ppb for a duration exceeding 2 hours. 

2023

    • January: We finalized a Consent Agreement with EGLE, which included an agreement to investigate Dissolved Oxygen (DO) levels below a certain threshold (to help determine if conditions exist to produce H2S) and to provide our real-time Envirosuite data on a publicly available website. In addition to these items, we also agreed to complete the following: 
      • Installed continuous monitoring of ORP and DO levels at the clarifier. 
      • Will complete the installation of the permanent oxygen system 180 days after final permit approval by the City of Kalamazoo. We lease our current system, and we are hopeful to receive approval from the city soon. 
      • Will complete the installation of the wet scrubber system for the AES building (a building that houses additional water equipment) and Graphic Packaging’s wastewater treatment plant (WWTP) equipment by Dec. 31, 2023. This scrubber will remove hydrogen sulfide gases from the treated water, thus eliminating this source of H2S. April: We worked with Envirosuite to filter the real-time data of the monitors throughout our campus to our community blog, KalamazooRecycles.com. 
    • April: We worked with Envirosuite to filter the real-time data of the monitors throughout our campus to our community blog, KalamazooRecycles.com. 

Planned Improvements

We hear the community’s feedback that there is still work to be done. In addition to partnering with the City of Kalamazoo, this year we will be taking the following actions: 

    • Installing the permanent oxygen system, once receiving permit approval from the City of Kalamazoo. 
    • Installing the wet scrubber system in the AES building. 
    • Working with KWRP as they complete the re-route of the effluent line from the Graphic Packaging WWTP to the KWRP, bypassing the existing/covered junction box. Re-routing this sewer line will eliminate the potential for this old city sewer line to emit gases from the industrial sewer.  
    • Continuing to seek guidance from MDHHS regarding their health assessment, and clarifying their findings to address inconsistencies with guidance we have received from other regulatory bodies, including EGLE and the Michigan Occupational Safety and Health Administration.  
Featured May 8, 2023

Backpack Drive Benefiting Big Brothers Big Sisters is Underway

On May 1, Graphic Packaging’s Kalamazoo mill kicked off its backpack drive benefiting Big Brothers Big Sisters of Southwest Michigan. The drive, which runs through June 30, collects backpacks for “littles” ages six to 16 involved in the nonprofit’s programming.

Created in 1958, Big Brothers Big Sisters of Southwest Michigan positively impacts the lives of youth throughout Kalamazoo and surrounding counties. It makes meaningful, monitored matches between mentors (Bigs) and children (Littles). Graphic Packaging is proud to support an organization making such a difference in our local community!

The drive has only just kicked off, but we are already seeing extraordinary involvement from our employees. One employee in particular showcased his philanthropic spirit by visiting multiple stores to clear out their backpack inventory, ultimately donating 40 backpacks to the cause. We are grateful for the generosity of our employees, and we have set a goal of donating 150 backpacks from the mill.

Graphic Packaging employee, Alton, and his wife, Briana, donated 40 backpacks to the drive benefiting Big Brothers Big Sisters of Southwest Michigan

At Graphic Packaging, our three community pillars, which guide our sustainable business practices, community service activities and philanthropic commitments are:

    1. Putting Food on the Table
    2. Investing in Education
    3. Preserving the Environment

We are happy to invest in the education of local students by giving them refreshed school gear through this drive.

Featured April 28, 2023

Hillside Courtyard Revitalization Project Well Underway

Graphic Packaging is proud to announce that the courtyard revitalization project we are sponsoring at Hillside Middle School is well underway and on target to be complete this June. On March 24, we broke ground on the project, which will update two courtyards at the school into urban greenspaces and incorporate refreshed landscaping and seating areas.

The first courtyard is in honor of the Hillside robotics team. This beautification project will give the robotics team a usable space for practices and team building. We have brought in benches where students and staff can enjoy being outdoors and connecting with one another.

The second courtyard is in memory of Hillside staff and students who have passed away. We are humbled and honored to create a greenspace honoring their lives and legacies. This space has been filled with young trees, which will eventually grow tall and bring shade and comfort to those who spend time in this significant memorial space.

Graphic Packaging has three community pillars, which guide our sustainable business practices, our community service activities and our philanthropic commitments:

      1. Putting Food on the Table
      2. Investing in Education
      3. Preserving the Environment

Our work at Hillside supports the second and third goals, and we are excited to be supporting a school filled with bright students and exemplary teachers and staff. We are looking forward to completing this project over the summertime, with students having full access to the courtyards at the beginning of the 2023-2024 school year.

Featured April 27, 2023

Graphic Packaging Celebrates Earth Day with TICCIT Program at Northeastern Elementary

In celebration of Earth Day, Graphic Packaging hosted Trees Into Cartons, Cartons Into Trees (TICCIT… pronounced “ticket”) at Northeastern Elementary on April 27 to teach students about the importance of recycling paper and paperboard packaging.

Graphic Packaging volunteers and Northeastern Elementary students at the 2023 TICCIT event

Volunteers from Graphic Packaging walked students through a hands-on presentation of how paper is made into cartons, which can then be recycled many times. After the presentation, students and volunteers rolled up their sleeves and planted around 110 tree saplings in paperboard cartons to take with them and plant at home!

Planting the sapling in the paperboard carton creates a natural water funnel and protection. Eventually, as the tree grows, the paperboard carton breaks down – which is where “trees into cartons, cartons into trees” comes from. We are excited to see the students’ saplings sprout and grow in the Kalamazoo community!

Graphic Packaging volunteers and Northeastern Elementary students at the 2023 TICCIT event

We were honored to bring the TICCIT program to students in celebration of Earth Week, especially given our focus on recycling and the impact we make on reducing our community’s trash stream. The recycled paperboard manufactured at our Kalamazoo mill will reduce greenhouse gases by 3.2 million tons annually, as the material will be made into something new and not placed in a landfill.

TICCIT is an educational outreach program created by the Paperboard Packaging Council, and Graphic Packaging has been hosting TICCIT in schools across the globe since 2008. We are proud to have worked with over 120,000 students on this initiative to date.

Featured February 22, 2022

With Construction of K2 Project Complete, Graphic Packaging Turns Attention to Campus Improvements

Here at Graphic Packaging, we have been hard at work in Kalamazoo for nearly two years constructing a new $600 million paper machine that expands our processing capacity and ensures job security for our local employees for years to come.

Today, we are thrilled to say that construction was largely completed at the end of 2021 and our new machine, which we refer to as K2, is now producing paperboard. Once it is operating at full capacity, the new four-story machine will produce more than 1,400 tons per day of the highest-quality recycled paperboard in the industry. Here is what it looks like inside:

The new, four-story, coated recycled paperboard machine, or K2, in Kalamazoo

Phase 2: Exterior Campus Improvements

Now we are looking forward to the next phase of our project, which will be focused on renovating the exterior of all of the existing buildings at our Kalamazoo campus.

The purpose of this phase of the project is to improve the exterior looks of our existing buildings so that they match the exterior of our new K2 building, fit in better with the community, and include improved safety and weatherization elements for our employees. Once completed, the aesthetic of our buildings will be transformed from a traditional, no-frills manufacturing look to one that is far more modern and appealing to the community.

Work on our Kalamazoo beautification project, which has been approved by the city’s zoning board, is expected to begin this spring and continue into 2023. The project includes plans to overhaul all seven entrances to our buildings along North Pitcher Street.

The upgrades will include improved lighting, increased usage of bricks for facades, awnings over entrances and increased Graphic Packaging signage. We expect that the security entrance to our K1 machine will look like this architectural rendering when it is complete:

Security entrance

At our south entrance, we plan to overhaul the façade with upgraded materials, provide weatherization elements designed to reduce slips and falls, and improve the lighting. When completed, this entrance will look like this architectural rendering:

South entrance

We are also renovating the interior of our operations. Here is a look at our control center where we monitor all aspects of the production process and product quality.

Control room

Securing Local Jobs for the Future Making Sustainable Products

All of these upgrades are in addition to the construction of our K2 machine, which is a state-of-the-art machine and the industry’s newest in more than thirty years.

In 2019, Graphic Packaging made a commitment to the state of Michigan and Kalamazoo that it would invest $600 million to expand our operations and create 25 new jobs. In return, the state and the city provided an economic incentive package. Since then, we have hired 140 new employees and now employ a total of 650 in Kalamazoo when we include those who work at our carton manufacturing plant. Additionally, economic estimates indicate that every direct job at Graphic Packaging in Kalamazoo supports up to three indirect jobs in the Kalamazoo community. These jobs include people with trade skills, security contractors and hospitality workers.

What’s even more important is that this project positions Kalamazoo as a global leader in recycling for years to come. When K2 is fully operational, more than 40% of the recycled paperboard for the North American market will come from Kalamazoo.  

We are also proud of the impact this project makes on our global footprint. Based on initial estimates, K2 will reduce our greenhouse gas emissions by nearly 20%, reduce water usage by 300 million gallons annually and reduce purchased energy by 18% across our coated recycled board manufacturing platform in North America.  We believe our investment in Kalamazoo benefits the community, the environment, our employees and our customers.

K2 and Kalamazoo in the National Spotlight

Aerial image of the K2 building

Our investment in Kalamazoo has been generating industry attention. Trade industry publications and even the Wall Street Journal have been writing about our project because of the interest in paperboard products as a better, more environmentally friendly, and sustainable option for product packaging than plastic. The Wall Street Journal said this in its Jan. 3rd edition when it took an in-depth look our Kalamazoo plant:

KALAMAZOO, Mich.—When a new building-size machine cranks up this month, it will begin turning mountains of recycled cardboard into paperboard suitable for greener forms of packaging.

The $600-million project, the first new paperboard production line built in the U.S. in decades, represents an enormous bet by owner Graphic Packaging Holding Co. …on a future without foam cups, plastic clamshell containers or six-pack rings.

Wall Street Journal subscribers can read the full story HERE.

Featured September 13, 2021

Graphic Packaging CEO Provides Update on Kalamazoo Project As It Nears Completion

Our CEO, Michael Doss, recently traveled “back home” to Kalamazoo for a progress update on the construction of our new $600 million coated recycled board (CRB) machine.

The new state-of-the-art machine – which we also call “K2” – is equipped with the latest technology and is almost fully automated, which will further reduce the risk of on-site incidents and help ensure Graphic Packaging maintains its already strong safety record.

Continue reading “Graphic Packaging CEO Provides Update on Kalamazoo Project As It Nears Completion”

Featured June 29, 2021

Graphic Packaging Committed to Kalamazoo as Project Comes to Life

As a major employer in Kalamazoo, we at Graphic Packaging recognize our duty to partner with the community when it comes being a good neighbor and we know it is more important now than ever as we work towards the completion of an expansion project.

In Kalamazoo, we are currently in the midst of a $600 million project to build a new mill that will improve the competitiveness of our local operations and help to ensure job security for employees at our Kalamazoo operations for years to come.

Continue reading “Graphic Packaging Committed to Kalamazoo as Project Comes to Life”

May 30, 2023

How to Interpret Emissions Data from EnviroSuite Monitors

The EnviroSuite monitors located on Graphic Packaging property are publicly available so our neighbors and community can view H2S data in real-time. These are useful indicators of air quality, however they should not be the only tool used when evaluating odor emissions.

What is Graphic Packaging doing to address air quality?

We have taken a number of measures as part of our Odor Action Plan, including placing EnviroSuite monitors in key areas around our facilities to provide real-time tracking.
Since the timeframe the Michigan Department of Health and Human Services (MDHHS) study was conducted (using data from 2019-2021), our emissions reports have shown significant declines in H2S levels surrounding our mill and the City of Kalamazoo’s Water Reclamation Plant. Air quality has steadily improved, and emissions levels are well within regulatory limits. We take the health and safety of our employees and neighbors very seriously. We are working closely with the city, state and other stakeholders to address community concerns.

How should data from EnviroSuite monitors be interpreted?

The monitors can be extremely helpful to identify potential levels of hydrogen sulfide (H2S), but they are screening tools only and not designed to be compliance-grade monitors. The data should be reviewed, verified and cross-checked against other variables, including wind speed and direction, temperature, readings on nearby sensors, and in some cases, more sensitive, portable monitoring equipment.

Are EnviroSuite monitors 100% accurate?

While the EnviroSuite monitors provide helpful data signals, they are not precision tools and tend to overestimate the H2S concentration.
The monitors can produce false readings, or false positives, which are sometimes caused by battery malfunctions or other technical issues. The batteries are solar-powered, which can also contribute to intermittent issues.
Short, sporadic spikes are often false positives. They are easy to spot when the surrounding monitors reflect zero in the same timeframe.

Why do emissions sometime appear sporadically higher, such as at night?

Sometimes short-lived spikes occur due to temporary influences in the environment. This could happen when a monitor is in an area with high car traffic, due to diesel emissions from vehicles.
We have seen instances of unexplained elevated readings, similar to false positives, occurring at night for longer durations. These readings have proven to be erroneous upon investigation, and the Kalamazoo Water Reclamation Plant (KWRP) has reported the same phenomenon with its sensors. We have raised this concern with the manufacturer and look forward to hearing their recommendations on mitigating these inaccurate readings.

Why did you install EnviroSuite monitors instead of another brand?

EnviroSuite is widely regarded as the best online monitoring technology available. Graphic Packaging inquired with the Michigan Department of Environment, Great Lakes and Energy (EGLE) prior to purchasing the monitors, and the agencies confirmed that EnviroSuite was the best option. The Kalamazoo Wastewater Reclamation Plant (KWRP) next door also opted to purchase EnviroSuite monitors to measure its H2S levels.

How is Graphic Packaging’s emissions data monitored?

Graphic Packaging keeps a close watch on emissions data and has an alert system set up tracking all monitor activity. Experienced staff conduct thorough investigations into abnormal sensor activity. We abide by the standards listed in our publicly available Nuisance Minimization Odor Plan (NMOP) with EGLE. This stipulates that our Environmental Manager will investigate if a monitor has two consecutive 15-minute averages of H2S over 50 ppb OR if a monitor’s 15-minute average H2S level is over 25 ppb for more than two hours.

November 4, 2022

Graphic Self-Reported Minor Sump Discharge on October 20

On Thursday, October 20, Graphic Packaging contacted the Department of Environment, Great Lakes and Energy (EGLE) and the City of Kalamazoo to self-report a minor incident involving a sump that overflowed paper fiber and water into the city’s stormwater system. The overflow occurred at 1810 Pitcher Street, near a section of the Kalamazoo River undergoing a Superfund cleanup unrelated to Graphic Packaging.

In Graphic’s notification to the state and city, we explained this release was clarified process water. In other words, it would be similar in nature to a cardboard box being broken down by a rainstorm and washing into a stormwater drain. Even though the incident was minor, we recognize and understand concerns community members may have when they hear about an inadvertent discharge.

We are working with the City of Kalamazoo to take all appropriate corrective actions to prevent any future discharge at this site. Those efforts include reviewing the retention area design in collaboration with the city officials who are involved in the site plan review to ensure the approved designs are operating as expected. We are also committed to communicating with area residents on an ongoing basis to ensure their voices and concerns are heard.

November 4, 2022

Graphic Packaging Updates Community on Permit Issues

On September 8, 2022, the Michigan Department of Environment, Great Lakes and Energy (EGLE), issued a Violation Notice (VN) to Graphic Packaging in connection to air permit deviations. Graphic reached out to EGLE in early July to inform EGLE that we had certain deviations from our air permit, and that we would be submitting a proposed modification to our air permit as a result. EGLE visited the facility in late July and confirmed the deviations that we self-reported before issuing the VN. It is important to note that these issues are largely technical in nature and do not reflect any meaningful increase in emissions to the community.

In an effort to increase the line of communication with our neighbors, below is a detailed glimpse into the nature of the violations listed in the VN and the efforts we are taking in response.

  • The new recycled paperboard manufacturing plant was constructed and built with the latest and most advanced paperboard making equipment. The facility has efficient and environmentally responsible manufacturing equipment to minimize the impact on the environment.
  • Drying is an important step in the paper producing process, and our new state-of-the-art K2 machine has nine dryers. Eight of the dryers have maximum heat inputs that are lower than the amount allowed by the permit. This means the net potential emissions from the machine are actually lower than the emissions allowed by the permit today. However – even given this lower potential – we received a violation because one dryer exceeded the maximum heat input for an individual dryer. With this in mind, we are requesting a modification to our permit to accurately document the current engineering and overall reduction in the heat input capacity for these dryers.
  • There are cooling systems throughout the paper producing process to ensure systems do not overheat. Through cooling tower stacks, water vapor is released from our facilities. A common misconception is that the visible vapor from our stacks is smog – in reality, it is water vapor or steam from our production process. In our permit’s current language, each stack is required to be a minimum of 66 feet tall. Our stacks are 84 feet high, which is more favorable because there is greater dispersion at the higher level. The stated deviation related to the maximum diameter of the stacks. The maximum diameter of the top of the stack was listed in the permit as 144 inches. The diameter of the stack five feet below the top is 144 inches, but because this cooling stack flares out, the diameter at the top of the stack is 160 inches, so we have requested that change to the permit as well. This does not impact the volume of emissions from the facility.
  • We were cited for slightly exceeding a particulate matter limit from a boiler based on a test that turned out to be faulty. We brought in a third-party to conduct additional testing, and those tests confirmed that the levels from the boiler were well below permitted maximums.
  • There was an exceedance of NOx, which resulted from a temporary malfunction that has been fixed. We operated in accordance with protocol, notifying EGLE both by phone and writing of the malfunction.
  • The final portion of the VN we’d like to address is related to recordkeeping. We are confident we have always been in compliance with our material usage limits, and we have provided the necessary documents to EGLE that demonstrate that we, in fact, have all the appropriate records. They simply had not been provided to EGLE within their requested time frame. We have modified our process to ensure that our response is within EGLE’s expectations.

We remain committed to our responsibility as a community partner and take our permit obligations very seriously. Currently, we are working with EGLE to bring this matter to a full resolution.

March 7, 2022

Work Underway Along the Kalamazoo River

With spring near, you may now notice cleanup work underway in and along the banks of the Kalamazoo River. Graphic Packaging is pleased to see this U.S. EPA-directed cleanup is being done for the community as it is part of a larger cleanup of the Kalamazoo River. Part of the work now underway is occurring near our operations. The cleanup work is not related to Graphic Packaging or our Kalamazoo operations.

The EPA is overseeing the removal of PCB-contaminated sediment within Verburg Park Pond and along the banks of the Kalamazoo River. This work is part of a larger cleanup of a section of the Kalamazoo River EPA has designated as Area 1. Cleanup activities are being conducted by Georgia-Pacific LLC and International Paper Company. We understand the cleanup activities starting in March are expected to take three years to complete.

For more details, read EPA FACT SHEET – WORK BEGINS AT VERBURG PARK, PARK AND TRAIL CLOSURES (2 pp, 345.9 KB, About PDF) or visit www.epa.gov/superfund/allied-paper-kalamazoo.