Sludge lagoons in Green Bay are a poor choice for Hazardous Waste disposal.
sludge lagoons, georgia-pacific, TOSCA, contaminated sediment treatment, sediment disposal, sediment landfill, toxic landfill, hazardous waste landfill
sludge lagoons, georgia-pacific, TOSCA, contaminated sediment treatment, sediment disposal, sediment landfill, toxic landfill, hazardous waste landfill
Old Sludge Lagoons Proposed for 
Hazardous Waste PCB Disposal

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sludge lagoons, georgia-pacific, TOSCA, contaminated sediment treatment, sediment disposal, sediment landfill, toxic landfill, hazardous waste landfill

sludge lagoons, georgia-pacific, TOSCA, contaminated sediment treatment, sediment disposal, sediment landfill, toxic landfill, hazardous waste landfill

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sludge lagoons, georgia-pacific, TOSCA, contaminated sediment treatment, sediment disposal, sediment landfill, toxic landfill, hazardous waste landfill

The Wisconsin Department of Natural Resources (DNR) and the U.S. Environmental Protection Agency (EPA) are proposing a major new Hazardous Waste Landfill in the middle of the old Fort Howard Sludge Lagoons. 
Public Hearing
The DNR and EPA will hold a public hearing to take comments on Georgia-Pacific’s proposal to create Hazardous Waste Landfill at the Sludge Lagoons.

Thursday, June 1
6:00 - 8:00 p.m. Brown County Central Library, 
515 Pine St., downtown Green Bay 

History of the Lagoons

The 293-acre Fort Howard Sludge Lagoons consist of 14 lagoons by the Oneida Casino and Brown County Airport, within the Oneida Indian Reservation.   It is bounded on the west by the Town of Hobart and on the east by the Village of Ashwaubenon and He-Nis-Ra Park.  It is one of the largest landfills in Wisconsin.

The site is now owned by Georgia-Pacific Corporation (recently purchased by Koch Industries.)

Fort Howard Corporation began disposing its paper recycling mill waste, fly ash and other wastes in the lagoons in 1964.  Recycling of post-consumer waste paper results in hundreds of toxic inks, dyes, pigments, carriers and coatings being washed off paper fibers, often using toxic solvents, leaving behind a toxic sludge.   During the entire life of the Lagoons, the sludges have been contaminated with PCBs (PolyChlorinated Biphenyls), dioxins and furans because carbonless copy paper was coated on the back with PCB oil.  The Corporation’s sludge is the same waste which contributed to the $400 million PCB clean-up now underway in the Fox River.

In 1977, the DNR approved the company’s plan for the continued operation of the landfill and development of up to 14 disposal lagoons.  The approval was contingent on the Corporation resolving serious disposal issues, including establishing a system to minimize surface water and odor at the site. 

The Corporation eventually responded to complaints by installing a leachate  collection system in 1982 and a perimeter groundwater containment and collection system in 1986.

This consisted of a 30-inch wide, 6,500-foot-long soil and bentonite clay trench averaging 45 feet deep, to collect lagoon surface water and leachate (liquids that have percolated through the waste).   This cut-off wall was designed to connect with a natural clay layer deep below the Lagoons. In addition, a 6,400-foot-long subsurface drain was installed inside the wall, running parallel to the trench, along with a lined water retention pond at the site to “prevent contaminants in the lagoons from seeping into area ground water.”

This cut-off wall was placed down-gradient to the groundwater flow and quickly blocked direct migration of underground water pollutants along that path.

In 1985, Fort Howard Corporation also installed sludge dewatering presses at the mill’s wastewater treatment plant to reduce the water content of the sludge down to 60 percent.  This reduced the water levels in the disposed sludge by roughly 61 million gallons per year.

In 1986, the DNR found evidence of groundwater contamination beneath the landfill and on property adjacent to the site owned by the Tribe.  The study showed several groundwater monitoring wells on and near the site were contaminated with benzene and chlorinated organic solvents, also called volatile organic compounds (VOCs). 

In 1988, the DNR recommended the lagoons be proposed for inclusion on the EPA’s Superfund National Priority List for federal hazardous waste cleanup.

EPA declined to add the site to the Superfund list, but the DNR, EPA, the Oneida Tribe and Fort Howard Corporation signed a legal agreement in 1990 to require the Corporation to complete a remedial investigation of the lagoons, because many questions still remained and scientific data was too limited.

The Corporation’s Remedial Investigation was completed in 1994, with the following results:

1. Sludge samples showed the presence of PCBs, dioxins, furans, toxic metals and volatile organic compounds (VOCs). 

2. Groundwater and Leachate showed pesticides, toxic metals and VOCs.

3. Drinking Water from nearby residential wells showed the presence 
of pesticides and toxic metals, but the DNR and EPA said the levels were acceptable.  (Health standards have changed since then.)

4. Surface Water from the site was contaminated with toxic metals, pesticides and dioxin.

5. Soil samples near the site showed PCBs, pesticides, toxic metals, dioxin and VOCs.

6. Air monitoring showed particulates and VOCs downwind from the Lagoons, but the EPA and DNR said the levels were acceptable.

Though all this contamination was found, the EPA and DNR determined that no further action was required at the Lagoons, because the highest health risk was found to be a 1-in-10,000 
cancer risk in people drinking from nearby wells in the upper aquifer, due 
to arsenic contamination.  (Arsenic drinking standards are much more strict now.)

The agencies also dismissed what they called “borderline risks” for a hypothetical nearby person who would breathe the air, ingest soil (through gardening etc.) and drink water from the limestone aquifer (beneath the upper aquifer).

The company has continued to add large volumes of waste to the site ever since, with quite a bit of remaining capacity.  Newer cells have been constructed in the Lagoon complex with better liners and controls (but the leachate is still sent to the sewage plant.)

Remaining Concerns at the Old Lagoons

1. No Liner exists beneath the original old lagoons, so the contaminated sludge and fly ash is in direct contact with the underground drinking water aquifers. 

2. Half a Bath Tub --- The so-called “perimeter groundwater containment” wall was installed only on the south side of the Sludge Lagoons, in the direction of most of the groundwater flow.  There is no containment on the north, east and west sides.  This is just like a bath tub with walls on only one side.  It can’t keep contaminated water inside the site.

3. Pumping Forever --- Because the Lagoons are not a closed system and the wastes are in direct contact with groundwater, the Corporation’s solution (accepted by the DNR and EPA) was to install large pumps to pull groundwater toward the site, to prevent toxins from escaping.   The resulting groundwater and leachate is pumped up and sent by sanitary sewer to the Green Bay Metropolitan Sewage District (GBMSD) by the mouth of the Fox River.  This pumping will need to continue for centuries into the future.  If the pumps fail, the toxins will escape again into nearby groundwater and surface waters fed by groundwater.  Will the Corporation be willing or even able to fund this pumping forever into the future?

4. Inadequate Treatment  --- GBMSD is not designed to properly treat the serious kinds of toxic substances found in the Lagoons or the leachate.  The toxins are simply being diluted with groundwater on site and added to millions of gallons of other municipal wastes at the sewage treatment plant.  In other words, the municipal wastes are being contaminated with landfill leachate.  GBMSD discharges their wastewater to the Fox River and they incinerate the solids, so Sludge Lagoon toxins many be released through those routes.

5. Self-Reporting Abuses? --- Throughout the last 30 years, the Corporation has been allowed to collect and analyze most of their own samples,  and conduct their own monitoring.  They might hire consultants to do some of the work, but those consultants are still under their control.  The DNR and EPA provide occasional oversight, but the Corporation’s study results are generally accepted as a matter of trust. 

This trust is a serious concern to us.  For example: the 1994 Remedial Investigation report by Fort Howard Corporation claimed that the Sludge Lagoons didn’t qualify for Superfund 
status partly because none of the sludge contained PCBs in concentrations higher than 50 ppm (parts per million), which is the official hazardous waste standard.  However, in the late 1990s, PCB hotspots in the Fox River just downstream from the Corporation’s discharge pipe showed concentrations over 700 ppm. 

How is it possible that the same sludge that produced this major river PCB hotspot somehow failed to leave any residues in the Sludge Lagoons over 50 ppm?  We simply don’t believe the Corporation’s study claims.

6. Unacceptable Risks --- The agencies said a 1-in-10,000 cancer risk was acceptable here, but normal government standards require public health protection to no more than a 1-in-a-million risk.  Why is such a lax standard being used here?

What is the New Proposal?

The Corporation now proposes to create a new cell within the existing Sludge Lagoons for the permanent disposal of dredge spoils from the Fox River PCB Clean-up.  Key concerns:

1. The Only Hazardous Waste Site in Wisconsin --- The Lagoons were used once before in the late 1990s for the one-time disposal of sediments from a dredging demonstration project.  We protested this disposal at the time. 

What makes this project worse?  The new proposal will involve highly concentrated toxins from the newly discovered PCB hotspot downstream of the DePere Dam, around 3,000 ppm PCBs.  Most sediments in the Fox River Clean-up project are only between 1 and 20 ppm PCBs.  This means the new cell will be a federally recognized Hazardous Waste Landfill, which is something that doesn’t currently exist anywhere in Wisconsin. 

2. Improper Leachate Treatment  --- Despite this new classification, the agencies propose to allow the liquid leachate to be pumped and sent to the Green Bay Metropolitan Sewage District treatment plant, just like the less contaminated old leachate.

3.  No Bonding for Long-term Care --- The company will also not be required to post any new bonding to cover future problems, because the landfill was permitted in 1977 before laws changed to require such bonding.   The agencies are allowing this NEW Hazardous Waste Landfill to be grandfathered under existing inadequate site rules.  The company is escaping long-term accountability.

4.  Inadequate River Clean-up --- DNR staff say they believe the new 200,000 cubic yard containment cell will be large enough to hold ALL the remaining Fox River sediments with concentrations over 50 ppm PCBs. 

This implies that the final Fox River Clean-up Plan, soon to be announced, will not include much dredging and will only cap most of the worst hotspots in the river.  This would not be a river clean-up; it would be a COVER-UP.  This is not good news. The PCB polluters are getting away with extremely CHEAP disposal and a short term fix, while escaping long-term liability.

Detoxification Treatment Is Needed

Since the beginning of the Fox River PCB Clean-up debate, Clean Water Action Council has argued that high-level PCB sediments should be treated and detoxified using one of several safer technologies that have been developed in recent years. When PCB concentrations are higher, treatment technologies become very effective and reasonable in cost.  (There are diminishing returns for lower concentration PCBs.)

For example, Thermal Desorption can be used to extract and further concentrate the PCBs, then one of several patented closed processes (not incineration) can break down the concentrated PCBs.   For more details on readily available technologies, visit this website:
Alternatives for POPs [Persistent Organic Pollutants] Disposal, Edition 2

Recent news articles on this proposal

Neighbors slam PCB landfill near casino - 5/26/06 PG
Ashwaubenon, Oneidas air concerns with PCB plan  --- 5/24/06 PG
G-P offers home for toxic PCBs --- 5/10/06 PG
Fox River cleanup set in De Pere --- 4/13/06 PG

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Fox River Watch is a project of

Clean Water Action Council
1270 Main Street, Suite 120, Green Bay, WI 54302 
Phone: 920-437-7304, Fax: 920-437-7326 

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CONTENT BY: Rebecca Leighton Katers
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