FAQs: Proposed Air Permit Modifications at Graphic Packaging

Why is Graphic Packaging requesting a modified air permit?
The Michigan Department of Environment, Great Lakes, and Energy (EGLE) approved Graphic Packaging’s original air permit request in early March 2020. In June 2020, Graphic Packaging asked EGLE to approve a revised air permit to accommodate two smaller natural gas boilers for our proposed plant expansion instead of one larger boiler.

Graphic Packaging is seeking the modified air permit primarily because operating the plant with two smaller boilers instead of one will improve reliability and efficiency.

Will Graphic Packaging’s requested modifications and plant expansion cause an increase in CO2 emissions?
The increase in potential CO2 emissions from switching to two boilers instead of one is approximately 29% for the facility. Additionally, the overall increase in GHG emissions from the entire project is approximately 42% in Kalamazoo. The net increase for the State of Michigan resulting from the project is about 12%, because of the impact of a shutdown of the less efficient boiler in Battle Creek.

Graphic Packaging is in fact reducing its CO2 emissions nationwide. This is due to consolidation, adding state-of-the-art boilers to replace less efficient boilers in Kalamazoo and elsewhere, and other sustainability efforts.

What is Graphic Packaging doing to investigate the odors in Kalamazoo?
To thoroughly investigate the odors at Graphic Packaging’s Kalamazoo facility, we hired RK & Associates – a third-party environmental contractor – who has completed its field work as part of an Odor Investigation Plan that was approved by EGLE on June 4, 2020.

While the final investigation report is still under development, Graphic Packaging provided preliminary results to EGLE to support our air permit request.

Graphic Packaging expects to submit the official results from the Odor Investigation Plan to EGLE for review in November.

Graphic Packaging has been actively working to study odor issues in our area and has made the following commitments to the city of Kalamazoo:

  • We will continue to participate on the Odor Taskforce. We will provide quarterly reports to the city of Kalamazoo to keep the community informed of Graphic Packaging’s actions and progress.
  • We will work with the city and Kalamazoo Water Treatment Plant on additional steps that can be taken to enhance the quality of life in the community.
  • We will continue working on the Odor Investigation Plan that was approved by EGLE on June 4, 2020 and will take appropriate actions that the results present. A report is due to EGLE in November and we will develop an odor mitigation plan based on the findings.
  • Graphic Packaging initiated the use of the Envirosuite H2S monitoring network in September 2020 and is regularly tracking air quality data.
  • We will provide the Envirosuite data to EGLE so that odors can be assessed and addressed and have plans to install additional sensors. The data from the sensors placed September 10 will be used by Graphic Packaging to help us address potential odors.
  • We currently spend more than $1.2 million annually on chemical treatments of waste product at our clarifier before it is sent to the city’s wastewater plant.
  • We agree with the J&H study that found that the city’s legacy oversized infrastructure needs to be addressed.
  • We will include state-of-the-art odor control technology in our expansion project. This includes an investment of more than $4 million to minimize total effluent and reduce surges to the city – which will help mitigate potential odor issues. We expect to realize the full benefits from this program once the machine is fully commercial. That timing is estimated to be the first quarter of 2022.

What does the Graphic Packaging mill expansion project entail?
Graphic Packaging is pursuing a $600 million expansion of its operations in Kalamazoo. This project ensures that our Kalamazoo operations will remain cost efficient and competitive, allowing us to retain 325 jobs and add 25 new jobs.

Once fully operational, the new state-of-the-art coated recycled board machine will have an annual capacity of approximately 500,000 tons, significantly increasing our Kalamazoo mill’s production output. Successful completion of the project will position Michigan as the largest manufacturing location of coated recycled board in North America.

The plant produces coated recycled paperboard used to manufacture cartons for dry grocery products, including cereal, tissue, pasta, baking mixes and N95 masks – all of which are critical during this time. We believe the investment will position us as the most technically advanced producer in our industry, benefitting our customers, our employees, our shareholders, the environment and surrounding communities.

Why did Graphic Packaging receive a tax incentive from the City of Kalamazoo for its mill expansion project, and how big was that tax incentive?
The Kalamazoo City Commission approved a $1.6 million tax abatement for the mill expansion project on September 21. It is spread out over 12 years, for an average of $133,333 per year. We are grateful for the unanimous and thoughtful support demonstrated by the city commissioners. Graphic Packaging is committed to being a good community partner and will continue to work closely with the city to identify and address odor issues.

What is Graphic Packaging’s track record over the past decade in terms of regulatory actions?
EGLE has issued Graphic Packaging eight notices of violation over the past 10 years. We investigated each and every one of those cases and responded to EGLE. Out of those eight notices, there has only been one case – in 2019 – where EGLE required our company to take additional action.

As a community partner, we take these complaints very seriously and understand our responsibility to work with neighbors and the city to address odor concerns. Graphic Packaging is firmly invested in the community, and we will continue to do our part to listen to and address concerns. We will also take whatever steps are appropriate based on the results of odor investigations.