In Northeast Wisconsin, we're in the middle of a PR battle over several proposed sludge incinerators for the pulp and paper industry. (We have 24 mills on 38 miles of the Fox River, which flows into Green Bay, then Lake Michigan.) Several incinerators are proposed, planned, or under investigation:

1. Fort Howard Corporation Sludge 'Combustor' --- 250 tons/day of recycle mill sludge, in Green Bay. Final permit has been issued.

2. Minergy Corporation 'Glass Aggregate Plant' --- 1000 tons/day from 4 different recycling paper mills, in Neenah. Bottom slag processed into fine gravel for roofing tiles and road construction. Final permit has been issued. Company already interested in expanding their operation once first permit is cleared. Lawsuit is underway challenging siting on top of public trust land.

3. Neutralysis 'Aggregate Plant' --- Unknown tons of recycle mill sludge from Fox River Fiber Corporation, in De Pere. (Together, Fox River Fiber and James River Corp. generate 350 tons of sludge per day.) Sludge mixed with virgin clay from local soil, burned into aggregate to be used for construction. Application not filed yet, but PR campaign already underway.

4. Greengrove 'Aggregate Plant' --- Unknown tons of recycle mill sludge from James River Corporation. (Mill is undergoing expansion right now.) Sludge mixed with flyash from local 260 megawatt coal-fired Pulliam Power Plant and ash from local municipal wastewater treatment plant sludge incinerator. Burned in a kiln into an aggregate to be used for construction. Application not filed yet, but PR campaign already underway.

5. Thilmany Paper Company 'Boiler' --- Unknown tons of mixed virgin and recycle mill sludge from Thilmany (an International Paper plant), in Kaukauna. If this works, International Paper will undoubtedly want to repeat the process at their Nicolet Paper plant in De Pere. Have already done in-house pilot tests in existing boilers. Application status unknown.

6. Green Bay Packaging 'Boiler' --- Unknown tons of recycle mill sludge to be burned in Green Bay. Manufactures corrugated cardboard, so less contaminated with chlorine. Have already done in-house pilot tests in existing boilers. Application status unknown.

7. Granulation Technologies, Inc. --- 250 tons of recycle mill sludge from Fort Howard Corporation are dried each year in Green Bay and turned into a 'carrier' for pesticides and fertilizers. (The 'inert' ingredient.) No scrubber was required on the stack --- resulted in serious toxic air emissions, including dioxin. Plant failed air test, by a wide margin, after construction. The DNR merely increased the permit limits and required a taller smokestack. Three years ago, citizens tried to challenge this facility at a Administrative Hearing, but won only a small improvement (additional tests). It continues to operate, and more facilities may be built elsewhere. This plant takes only half of Fort Howard's sludge, therefore, 250 tons are still available for new sludge incinerator.

Obviously, this is the beginning of a serious trend. We've called around the country and haven't found any other incinerators or aggregate plants which fit our situtation. Precedents are being set here in Wisconsin.

The sludges which result from paper recycling are contaminated with the original dioxins, furans, PCBs and other chlorinated compounds. Massive amounts of chlorine (or chlorine compounds) and solvents are used as part of the de-inking and re-bleaching processes. In addition, the inks, dyes, pigments, clays and plastic coatings also contaminate the sludge with heavy metals and other exotic materials. Burning this sludge will create more dioxin and will distribute the heavy metals (including mercury and lead) through the air and ash. When chlorine compounds are burned, this also results in large amounts of Hydrogen chloride (hydrochloric acid) So far, no scrubbers are required on any of these incinerators.

Northeast Wisconsin is already a seriously polluted area. We are a center for paper recycling, importing waste paper from all over the country --- so we end up with all the contamination. We can't eat the fish or ducks (PCBs and mercury), we can't use the Fox River or Green Bay as a drinking water source, we can't swim in these waters, we have some of the worst wildlife deformity rates in the entire Great Lakes region, we have more than 100 abandoned dumps in Brown County, we have millions of pounds of toxic air pollutants to breathe each year, and dredging the river is extremely expensive because of the contaminated sediments.... It's a disaster area. No human health studies have been conducted.

The incinerators will only add insult to injury.