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.