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    Complaint

    23216
    WPC
    10/24/2011
    Phone
    Other
    Improper disposal of industrial sludge
    10/24/2011
    12-SEP-2019 01:28PM

    Location based on SITE_ID

    Site ID
    4853
    Site
    Packaging Corporation of America
    Location
    6715 Highway 57
    City
    Counce
    Description
    4.66 acre clearing inside PCA property for use of lay-down and project staging
    County
    Hardin
    EFO Name
    Jackson
    Site Owner
    Packaging Corporation of America

    Investigation Results

    No Problem Found
    10/27/2011
    None
    10/27/2011
    Yes

    Description and Writeup

    PCA has dug a 40 ac. lake on Highway 142 just north of intersection with 57. Have been trucking black sludge to lake and odor is terrible. He is only five miles from the mill, but has never had odor like this. Sludge is all over the ground and road.

    (10/31/11 JEB) On 10/27/11, I investigated this complaint concerning the disposal of sludge by PCA on a site off Hwy 142, northwest of the mill. I found no evidence of the large lake of sludge that was reported by the complainant. It must be assumed that what he saw was the pit that was dug near the front of the site, where the sludge was held until it could be transferred to off the road spreader trucks. The sludge, being land applied in accordance with the disposal plan approved by the DWSM, comes from Treatment Pond #2 and is soupier than their normal primary sludge. The site was very well designed and very strict buffer zones were maintained around the unnamed tributary (UNT) of Leath creek, which runs through the middle of the site, as well neighboring houses. Storm water ponds were constructed on each of the drainage-ways off the site. I found no evidence of any sludge below the ponds I checked or in the UNT. Some of the smaller ponds were dry. Others had pools of water. The appearance of this water varied from clear to somewhat brown. Based on the debris lines on the rock filter outlets from the ponds, storm water never reached the top of the rock filters.
    At the time of my inspection, the application of sludge had ended for the year. Much of the site has diced and smoothed out and has been or was soon will be seeded with winter wheat as cover vegetation for this winter. Some of the wheat had already sprouted. One section of the site remained as it was when the sludge was applied and incorporated with a forest dice. No odor was apparent from this area. The sludge holding pit at the front of the site has been filled in. Therefore, any odor coming from this source has been eliminated. As for the report by the complainant that sludge had been spilled all over Hwy. 57 and Hwy. 142 by the trucks hauling the sludge, I found no evidence of spillage. I was told that there had been some complaints of such spillage, but none had been substantiated. Even an investigation by the THP found no basis for the complaints. Therefore, this portion of the complaint could not be verified. In conclusion, no issues were found that require any further action by the DWPC.

    (11/1/11 JEB Follow-Up) I spoke to Mr. Jackson, the complainant, on the afternoon of 10/31/11 and reported what I had observed. He could not quite understand why I did not see the big lake of black sludge, which he had seen when he actually went to the site. He indicated that he was not allowed to go any further than the entrance area to the site. I described the holding pit (10¿X100¿) near the entrance which he should have seen and I told him it must have been an area where they had spread sludge that just looked like it was a big pool. When I told him I could not confirm any spilling of the sludge by the trucks hauling it from the mill, he was sure he had seen ¿white material¿ blowing off the trucks coming from the mill. When I told him the sludge should have been dark brown or black, he indicated what he had seen was piled up higher than the board of the top of dump beds and was blowing off as the trucks drove by. After speaking to Mr. Jackson again, he seemed very rational and he appeared to be just reported what he believed he had seen.
    Because of this conflict in information, I contacted Richard Holland, Environmental Director with PCA Counce Mill, to discuss this matter further. It was our conclusion that if Mr. Jackson had been at the site just after some of the sludge had been poured out on the ground; it was liquid enough to level out to about 2¿ deep over the application area before it could be diced in.
    (A more complete narrative is found in the document attached below)