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



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.



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



We joined the City of Kalamazoo’s Odor Task Force, which is primarily a partnership of Graphic Packaging, KWRP and concerned stakeholders.

We supported the City of Kalamazoo’s creation of the Odor Hotline, which attempts to address odor concerns in real-time.



We installed 10 Envirosuite monitors throughout our Kalamazoo campus.

We began a peroxide feed to replace the previous odor treatment product. This improvement treats the process water in our operations and mitigates odors.


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.



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.


We installed six additional Envirosuite monitors, totaling 16 units throughout the property.


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.


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



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.


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.


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.



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.


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.