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Former Menasha Paper Plant What Did They Produce & Where Did It Go?? A Summary Of Publicly Available Documents & Information Contained In Menashas 104e Response By Dan Peabody Former Menasha Paper Mill 2 Business Operation


  1. Former Menasha Paper Plant – What Did They Produce & Where Did It Go?? A Summary Of Publicly Available Documents & Information Contained In Menasha’s 104e Response By Dan Peabody

  2. Former Menasha Paper Mill – 2 Business Operation Locations The Otsego Mill parcel south of River Road & a parcel north of river road.

  3. Former Menasha Paper Mill – Business History & Facility Operations • • Menasha never recycled or de-inked Constructed in 1887 as Bardeen CCP known to contain PCBs . Paper Mill • • Menasha did not bleach paper using Otsego Falls Paper Co. purchased the chlorine which is the process known Bardeen Mill approx. 1934-1939 to produce dioxins. • 1939-1955 Menasha had joint • At no time has Menasha purchased, ownership of Mill. Required recycled, deinked or otherwise used remaining interest in 1955 as NCR paper, or other PCB containing Menasha Wooden Ware Co. -> paper, at the Otsego Mill. Menasha Co. • In June 2005, Menasha announced the closing or sale of the Otsego plant • Purchased by USG in March 2006 for $18MM

  4. Former Menasha Paper Mill – Generated Wastes General Types of Waste 1. Solids a. Fly ash, scrap waste, and sludges 2. Liquids 1. Liquors and wastewater A total of 195 individual PCB tests results have been obtained for Menasha's process waste stream from 1971 to 1993. All were non- detect for PCBs. But what other contaminants WERE detected???

  5. Former Menasha Paper Mill – Fly Ash What Is Fly Ash?? What Contaminants Are In Fly Ash?? • • Fly ash is a residue by-product that forms during 1979: Metals- some low-level hits. coal combustion. – All samples below criteria for Metals • Where Did The Fly Ash Go?? 1982: Metals, PCBs- 20 test results on fly ash • and 5 test results on ash-lime wastewater Onsite Ponds & Landfill: Area 10 - Area 10 was a sludge two-pond system used to pretreat lime- – containing powerhouse wastewater which had All samples non-detect for PCBs been mixed with fly ash from the coal-fired – All samples below criteria for Metals boilers. Menasha installed these ponds in the mid-1970's and they were removed in 1983. • 1983: Metals After 1983, fly as was collected and disposed of off-site as a dry solid. A 5 acre on-site landfill – Non-detect or below criteria for all metals was operated from 1969 through 1984. • 1984: Metals- 1 sample was analyzed for Metals • Offsite Ponds: North of River Road- Area 13 is (As, Hg, Pb, Cu, Cr, Cd, Zn, Se) the former site of 22 unlined earthen basins – Sample below criteria. with a combined storage capacity of 28 million gallons. These basins were located North of River Road approximately three quarters of a mile from the Kalamazoo River. Menasha used these basins to anaerobically digest wastewater treatment Sludge from the early 1970's until final closure of the ponds in 1986.

  6. Former Menasha Paper Mill – Scrap Waste What Is Scrap Waste What Contaminants Are In Scrap Waste?? • • 1983: Metals- Secondary Fiber Rejects slated for Waste produced that is not suitable for placement in landfill were analyzed for Metals incorporation into or during the production of – paper products but are used in paper products All samples were below MDEQ Residential criteria or non-detect. due to be recycled. Materials can include tape, styrofoam, glue , sawdust, etc. • 1984: Pesticides- Menasha received boxes that were labeled as previously containing pesticides. Where Did The Scrap Waste Go?? Samples of the product were sent to an • Onsite Ponds & Landfill: Area 10 - Area 10 was a independent lab. two-pond system used to pretreat lime- – The tests results were non-detect for containing powerhouse wastewater which had Pesticides been mixed with fly ash from the coal-fired boilers. Menasha installed these ponds in the • 1985: Metals - Waste residues slated for placement mid-1970's and they were removed in 1983. in landfill were analyzed for Metals After 1983, fly as was collected and disposed of – Test results were non-detect or below MDEQ off-site as a dry solid. criteria • Offsite Ponds: North of River Road- Area 13 is • 1988: Metals the former site of 22 unlined earthen basins – Test results were non-detect or below MDEQ with a combined storage capacity of 28 million Residential Drinking Water Criteria for all gallons. These basins were located North of Metals. River Road approximately three quarters of a mile from the Kalamazoo River. Menasha used these basins to anaerobically digest wastewater treatment Sludge from the early 1970's until final closure of the ponds in 1986.

  7. Former Menasha Paper Mill – Sludge Handling What is Sludge?? • What Contaminants Were In The Sludge?? Sludge - Also known as Biosolids. Composed of • dead bacterial bodies from the aerobic digestion 1985-1986- VOCs, Cyanide, Metals . Samples of dissolved solids as well as other suspended collected during closure of landfill north of solids such as papermaking fibers, sand, and River Road. All detections are below MDEQ bark. Residential Criteria. Where Did The Sludge Go?? • Onsite: • 1991-1994- Metals. Some detections. All – Sludge was captured throughout the process detections are below MDEQ Residential – Approx. 24 million tons of sludge was generated Criteria. annually. • Offsite Ponds: Area 13 - Area 13 basins were located North of River Road approximately three quarters of a • 1993- PCBs & Pesticides - No detections of mile from the Kalamazoo River. Ponds were originally PCBs. Some detections of pesticides. All “natural depressions” but additional ponds were dug, as needed. detections are below MDEQ Residential – Area 13 consisted of 22 unlined earthen basins Criteria. with a combined storage capacity of 28 million gallons. – • Twenty of these ponds contained only wastewater 1993- VOCs & BNAs - Some detections. All treatment Sludge and two of the ponds contained detections are below MDEQ Residential a mixture of wastewater treatment Sludge and Criteria. Spent Liquor. • Land applied: – • Land application began in the 1970. 1992- Dioxins. Results range from ND-20ppt. – Sludge from the offsite ponds was land applied as a All detections are below MDEQ and EPA soil amendment to that area during closure. Residential Criteria. – 47 private farms -> 18 million pounds – Menasha owned farm land

  8. Former Menasha Paper Mill – Waste Water Handling Where Did The Wastewater Go?? What Contaminants Were In The Wastewater?? • Wastewaters were discharged • directly to the Kalamazoo 120 test results on wastewater River discharges from 1971 to 1993 – No wastewaters discharge to – All samples were non-detect sanitary sewer for PCBs • • Wastewater records available Wastewater samples were for part of 1970s and 1980- collected from the outfalls to 1989 determine if wastewater is toxic to aquatic organisms – 8,924,371,000 gallons (minnows and plankton) discharged. beginning in late 1970s thru • Wastewater treatment Sludges 1980s. were routinely been used as a – Most samples show limited or soil amendment at local area no toxicity to aquatic farms beginning in 1975. organisms.

  9. Former Menasha Paper Mill – Spent Liquor Handling What is Liquor?? Where Did The Liquor Go?? • • Road Binder: Spent liquor used for dust control Spent Liquor - A liquid washed from virgin on county roads. Program began in 1954. Pulp to remove and recover the cooking Spread at 4,000-8,000 gal./mile. Over 45 million chemical, sodium carbonate, from the gallons of Road Binder was used in Allegan liquor for reuse in the digesting process. County. The Spent Liquor is part of a virtual closed loop of chemical use in the digesting • Onsite Ponds: 2 Historic un-lined ponds on-Site process. The Pulp is washed with water, (Area 11 and Area 4). These ponds have been and the dissolved organic and inorganic since been closed and a new area, Area 12, materials in the Pulp are removed as constructed using concrete was built in 1982 to "liquor". The liquor contains lignin, the replace Areas 4 and 11. glue that held the fibers together in the original wood chip, as well as wood • Offsite Ponds: Area 13 - Area 13 basins were sugars, such as hemicellulose, and the located North of River Road approximately three spent sodium carbonate cooking chemical, quarters of a mile from the Kalamazoo River. which helps to modulate and buffer the – Area 13 consisted of 22 unlined earthen chemical reactions during the cooking basins with a combined storage capacity of 28 million gallons. process. Water is evaporated from the – liquor, the organic lignin is burnt as a fuel, Twenty of these ponds contained only wastewater treatment Sludge and two of and the sodium carbonate is regenerated the ponds contained a mixture of during the combustion as a solid. The solid wastewater treatment Sludge and Spent cooking chemical, now called SLI product, Liquor. is placed back in the Digester where it is reused to cook more wood chips into Pulp.

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