KALAMAZOO, MI (From news reports) -- State of Michigan environmental investigators have issued Graphic Packaging International multiple violations after an unannounced inspection in July, including one violation for releasing a chemical at a rate that exceeds the permitted emission limit.
On July 28, 2022, Environment, Great Lakes, and Energy Air Quality staff conducted an unannounced inspection at Graphic Packaging's Kalamazoo facility at 1500 N. Pitcher Street.
A violation notice was issued to Graphic Packaging on Sept. 8, for emission, reporting, and equipment design and stack vent restrictions that were not met under Permit to Install No. 133-19A, Environment, Great Lakes, and Energy Spokesperson Jill Greenberg told MLive/Kalamazoo Gazette.
Records showed 37 hours of noncompliance with the limit for oxides of nitrogen (referred to as NOx) in the facility's air permit.
The limit for NOx is 13.6 pounds per hour. Reported emissions ranged from 14.2 to 26.6 pounds per hour on Aug. 20-21, 2022. There were three other noncompliance instances noted, in August 2022 and going back to July 2021, for NOx limit based on a 24-hour average.
Graphic Packaging did not send all the required records until over a month after the inspection, which is why August 2022 data is included. While looking at their records for 2021, officials observed a July 15 exceedance, Greenberg said. The July 15, 2021, exceedance was not reported properly, EGLE said.
Graphic Packaging said it takes its permit obligations and responsibility as a community partner very seriously and is working with Environment, Great Lakes, and Energy to bring the matter to a full resolution.
"The issues are largely technical in nature and do not reflect any meaningful increase in emissions to the community," Graphic Packaging told MLive/Kalamazoo Gazette.
"The exceedance of NOx 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," Graphic Packaging said.
The report does not provide measurements of concentrations of the chemical in the air.
Nitrogen oxides are a mixture of gases that are composed of nitrogen and oxygen. Two of the most toxicologically significant nitrogen oxides are nitric oxide and nitrogen dioxide, according to the Agency for Toxic Substances and Disease Registry.
Low levels of nitrogen oxides in the air can irritate eyes, nose, throat, and lungs, possibly causing a cough and shortness of breath, tiredness, and nausea. Exposure to low levels can also result in fluid build-up in the lungs one or two days after exposure. Breathing high levels of nitrogen oxides can cause rapid burning, spasms, and swelling of tissues in the throat and upper respiratory tract, reduced oxygenation of body tissues, a build-up of fluid in your lungs, and death, the Agency for Toxic Substances and Disease Registry said.
Exposure of pregnant animals to nitrogen oxides has resulted in toxic effects in developing fetuses. Nitrogen oxides have also caused changes in the genetic material of animal cells. It is not know if exposure to nitrogen oxides might cause developmental effects in humans, the agency said.
Nitrogen oxides are broken down rapidly in the atmosphere by reacting with other substances commonly found in the air. The reaction of nitrogen dioxide with chemicals produced by sunlight leads to the formation of nitric acid, which is a major constituent of acid rain. Nitrogen dioxide also reacts with sunlight, which leads to the formation of ozone and smog conditions in the air we breathe, the agency said.
The Environmental Protection Agency has established that the average concentration of nitrogen dioxide in ambient air in a calendar year should not exceed 0.053 parts of nitrogen dioxide per million parts of air.
Nitric oxide is a sharp sweet-smelling gas at room temperature, whereas nitrogen dioxide has a strong, harsh odor and is a liquid at room temperature, becoming a reddish-brown gas above 70 degrees Fahrenheit.
Neighborhood residents have looked at the plumes in the air coming from Graphic Packaging, and wonder what the changing colors or the material means. Some residents have complained about dark "smoke" or vapor coming from the factory this year.
EGLE did not immediately answer questions about whether the agency measured the concentrations of the chemicals in the air, which is a different metric than pounds per hour used for emissions.
The five other violations issued by EGLE were:
Noncompliance with emission limit for PM10/2.5 on a boiler based on a June 8, 2022, test
A violation because a maximum heat capacity of a piece of equipment was above the limit
Two violations because records were insufficient to demonstrate compliance with material usage limitations
Three stacks at the facility were installed with a maximum exhaust diameter over the 144-inch limit
At the time of the inspection, Graphic Packaging was determined to be compliant with all their volatile organic compound and hazardous air pollutants permit emission limits, Greenberg said.
Environment, Great Lakes, and Energy flew a drone equipped with sensors over the city wastewater treatment plant in May and discovered levels of formaldehyde over Minimal Risk Levels set by the federal government. The exceedances mean investigators should look closer at a facility, according to a state health department official.
The state is not planning to include the Graphic Packaging facility in any drone flight studies until 2023, which could provide more data about the chemicals in the air around the facility. The reason for the delay the flight over Graphic Packaging was to allow the facility to "work out the kinks" of its new facility, according to an EGLE official.
EGLE has not done any other drone sampling in Kalamazoo besides the sampling done at the Kalamazoo Water Reclamation facility in May 2022.
The violation notice instructs Graphic Packaging to initiate actions necessary to correct the cited violations and submit a written response to EGLE by Sept. 29, 2022.
The response should include the dates the violations occurred; an explanation of the causes and duration of the violations; whether the violations are ongoing; a summary of the actions that have been taken and are proposed to be taken to correct the violations and the dates by which these actions will take place; and what steps are being taken to prevent a reoccurrence, the letter states.
Graphic Packaging may also choose to contest the violations, and is asked to provide factual information if it does, the letter states.
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