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The Packaging Corporation of America site was placed on the United States Environmental Protection Agency (U.S. EPA) National Priorities List (NPL) on September 8, 1983. The site, located in Stronach Township, Manistee County, Michigan, was the site of eight lagoons used from 1951 to 1974 for the disposal of liquid wastes from a Packaging Corporation of America corrugated cardboard plant in nearby Filer City, Michigan. Wastes from the lagoons have seeped into the groundwater and produced a plume of discolored groundwater ("black water"), that contains organic chemicals and heavy metals, that extends from the site to nearby Manistee Lake. There are some indications that the groundwater that discharges to the lake may have some impact on the biota of the lake.

Access to the site is partially restricted but evidence of trespass has been seen on the site. There is no current use of the groundwater. A brine processing plant near the site has had occasional problems with discolored water entering their drinking-water wells, probably through corroded well-casings. The facility abandoned and replaced the affected wells, and recently, following Michigan Department of Public Health (MDPH) direction, obtained Filer City municipal water for its potable water source.

The site poses an indeterminate public health hazard under current conditions, since actual surface material has not been sampled. Based on the results of shallow sub-surface soil samples, trespassers are not likely to experience significant exposure to the chemicals on the site. The contaminated groundwater is not used nor is it likely to be used for any purpose. Recommendations in this assessment include sampling of the surface material, restriction of access to the lagoons area, and monitoring of the groundwater contamination plume to determine whether the plume threatens any residential wells.


The Packaging Corporation of America site was placed on the United States Environmental Protection Agency (U.S. EPA) National Priorities List (NPL) on September 8, 1983.

A. Site Description and History

The Packaging Corporation of America site occupies approximately 700 acres on the east side of Manistee Lake, between the villages of East Lake and Stronach in Stronach Township, Manistee County, Michigan (Figure 1).

In 1947, the American Box Board Company (ABBCo) bought a kraft-process paper mill in Filer City, Michigan, on the west side of Manistee Lake, for the production of corrugated cardboard for boxes. In 1949, ABBCo adopted a neutral sulfite semi-chemical (NSSC) method. At first, ABBCo discharged the spent cooking liquor ("black liquor") from the mill directly into Manistee Lake. The biochemical oxygen demand (BOD) of the liquor, however, depressed dissolved oxygen levels in the lake, resulting in several fish kills. In 1951, under direction from the Michigan Department of Natural Resources (MDNR), ABBCo discontinued the lake discharges and began discharging the black liquor into a series of eight seepage lagoons, natural depressions that were somewhat modified for the purpose, located on the east side of Manistee Lake. The lagoons were used from 1951 through 1974, and received a total of 7.2 billion gallons of waste materials. In 1959, ABBCo merged with the Central Fiber Products Company and the Ohio Box Board Company to form a new corporation, the Packaging Corporation of America (PCA). PCA continues to produce corrugated cardboard at the Filer City plant.

The company used eight lagoons, numbered 1 through 8 (see Figure 2), and pumped the waste water through lagoons 1 through 7 in numerical order. That is, the waste water was first piped to lagoon 1, where it overflowed to lagoon 2, which overflowed to lagoon 3, from which the water was pumped to lagoon 4, etc. Lagoon 8 was an alternative receptor for water from lagoon 3.

Lagooning of the pulp mill effluents was phased out in the early 1970s. Between 1970 and 1976, the standing water in lagoons #3, #4, #5, #6, #7, and #8 was pumped out and sprayed onto four level areas near them (Areas A, B, C, and D in Figure 2), where it seeped into the ground. Lagoon #1 had no standing water and lagoon #2 was full of cellulose sludge. The lagoons and seepage areas occupy a total of 105 acres. In 1972, PCA began operating a secondary wastewater treatment plant. All lagooning of effluents ended in 1974. Effluents from the PCA plant are currently treated in the plant's wastewater treatment plant, then discharged to Lake Michigan under a National Pollutant Discharge Elimination System (NPDES) permit.

One former lagoon (#3) has been used by PCA as a solid waste landfill under a license from Michigan Department of Natural Resources (MDNR). The company disposed of bark, construction debris, and recycling wastes (e.g. tape and plastics from recycled boxes that cannot be reprocessed) in the landfill. In late 1992, PCA stopped using the landfill in former lagoon #3. The company is dredging cellulose sludge from lagoon 2, mixing the sludge with fly ash, and using the mixture to fill and regrade the former landfill in lagoon #3. Approximately one-third of lagoon #3 was filled in mid-August 1993.

The bottoms of lagoons #2 and #3 are impermeable to water, sealed by cellulose fiber sludge from the wastes pumped into them. Lagoon # 2 contained 30 feet of sludge before the current removal began (1). Lagoon #2 contains standing water, mainly rainwater mixed with remnants of the "black liquor" that was pumped into it. Lagoon #3 was pumped dry when the lagoon system was abandoned, but it sometimes contains pools of rain water or leachate from the landfill in its west end. This water is pumped to the PCA plant water treatment system through the same pipe that had carried the "black liquor" from the plant to the lagoons. The other lagoons are typically dry, though they occasionally contain some accumulated rain water, and are heavily overgrown with trees, shrubs, and ground cover. One of these other lagoons was only identifiable on a Michigan Department of Public Health (MDPH) site visit by a large visible amount of lime that had been put into the lagoon to abate the odor caused by PCA effluent.

In 1956, an industrial supply well located approximately 2,200 feet south of lagoon 3 on the PCA site found black water. The well was drilled deeper, beyond the black water. While seeking a location for a municipal well in 1976, workers for the Village of East Lake, north of the site, drilled a test well west of the lagoons. The test well contained black water, so the Village abandoned the test well and placed their municipal well elsewhere.

The wastes in the lagoons seeped into an underlying shallow aquifer, resulting in highly discolored, black, contaminated groundwater. Hydrogeological investigations performed by the company have established that groundwater contamination from the lagoons moves west toward Manistee Lake. No residential wells in the area have been affected. The presence of heavy metals (lead, chromium, and arsenic) in the groundwater and the lagoon sediments formed a basis for including the PCA site on the NPL. The site was proposed for the NPL on December 30, 1982, and placed on the list on September 8, 1983. PCA and the U.S. EPA signed a Consent Order for a Remedial Investigation and Feasibility Study (RI/FS) in May 1985.

The Michigan Department of Public Health (MDPH), working under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR), prepared a Preliminary Health Assessment (PHA) for the PCA site on March 10, 1989. The PHA concluded that the site was of potential public health concern because of possible exposure to contaminants in groundwater. The PHA cited the following possible receptors for the contaminated groundwater: Manistee Lake, the Martin Marietta Plant and its supply wells, and private wells in Stronach and East Lake. Surface water in Manistee Lake was considered to be of greatest concern. The PHA recommended further monitoring of the groundwater. No health effects studies were recommended, since there was no indication in the data analyzed for the PHA that human exposure had actually occurred (2).

The final report on the RI of the site was issued in April 1991 (3). A draft FS was released in February 1992 (4). An MDNR contractor released a draft study of the potential impact of the PCA groundwater contamination plume on Manistee Lake in December 1992 (5). On September 24, 1993, the U.S. EPA signed a Record of Decision (ROD) for the Groundwater Operable Unit at the site, stating that no remedial action was necessary, but the groundwater at and near the site and fish and sediment in the lake would be monitored (6).

Site Area Hydrogeology

The site area sits on a 600-foot thick layer of unconsolidated glacial deposits atop bedrock of the Antrim Shale formation. The Antrim Shale is not water-bearing, and the deeper bedrock layers tend to contain highly saline waters, therefore any wells for potable use in the area must draw from aquifers in the glacial deposits. At the site, the uppermost layer of glacial deposits is between 60 and 250 feet of sand, with interbedded lenses of clay, gravel, or silt. A 10-to-30-foot-thick layer of clay underlies the sand, then a sand layer of up to 50 feet thick, and then clay till of unknown thickness. The two sand layers are water-bearing, and form the shallow and deeper aquifer. The first clay layer ends under Manistee Lake, and there is only one aquifer west of the lake. The second sand layer is not known to extend beyond the PCA property either to the east, north, or south.

The shallow aquifer varies from 40 to 150 feet thick, with an average thickness of 125 feet under most of the site. The water table is approximately 75 feet below ground surface. Water in both aquifers flows generally to the west to southwest, and is thought to discharge into Manistee Lake. Though the available data are limited, the data indicates that groundwater on the west side of Manistee Lake flows eastward, which would confine any groundwater contamination from the site to the east side of the lake. Aquifer permeability, as determined by slug tests, is highly variable, making accurate estimation of groundwater flow rates difficult. The two aquifer system characteristic of the east side of the lake is not known to exist under or on the west side of Manistee Lake. A primary concern regarding this site is that the clay layer is thought to end under Manistee Lake and may even be discontinuous on the east side of the lake, in which case contaminated water may migrate downward into the deeper aquifer, which has been used for water supplies.

B. Site Visits

MDPH personnel visited the PCA site in September 1988. Observations and information obtained on this visit are included in this public health assessment. While touring the site with a representative of the site owner, they observed that part of the site perimeter was fenced, but there was access to the lagoon area via a utility company right-of-way across the site. They also observed signs of trespass in the lagoon area, such as picnickers' litter and two- and four-wheel vehicle tracks.

John Filpus and Michael Lee of the MDPH visited the site on August 10, 1993. They toured the lagoons area with a representative of PCA, who took them by each of the lagoons, starting with the closure activity for the landfill in former lagoon #3. Lagoons #2 and 3, the working areas, were enclosed by a temporary fence with gates. The gates were open, as the closure activity was going on and the U.S. EPA had visited the site earlier that day. The company representative closed and locked the gates that were not being used for worker access after them.

Filpus, Lee, and the company representative inspected the outlet of the pipe that had originally carried liquor from the PCA plant to the lagoons, and the company representative pointed out the lime that remained in the channel connecting the pipe and the first lagoon from an attempt to abate odors emitted from the lagoons. At the site of lagoon #1, the company representative dug up a sample of "soap skimmings", a component of the liquor that had settled out in the first lagoon and which the company was planning to excavate and transfer to lagoon #3 as the latter was filled and closed.(1) Near the building where the dredged sludge was being mixed with fly ash for deposition in the former lagoon #3, there was a sharp, acrid, hydrogen-sulfide-like odor. The company representative said this odor only occurred while they were handling the dredged-up sludge. Several of the former lagoons still contained lime from the attempt to suppress odors. Lagoon #8 was only identified by the presence of the lime. After they had visited all the lagoons, the company representative pointed out the nearest residences to the site, south of the site and outside the contaminant plume, and some of the brine wells between the site and the lake. That evening, the U.S. EPA held a public meeting in Stronach to announce their proposed plan for the site, and Filpus and Lee attended to address any expressed health concerns.

C. Demographics, Land Use, and Natural Resource Use

Approximately 10,200 people live within a 3-mile radius of the PCA lagoons. The populations of various civil divisions around the site, from the 1990 Census (7) or other estimates, are given in Table 1. The community of Stronach is approximately 0.5 miles south of the site and East Lake is approximately 1 mile to the north. Filer City is approximately 1 mile southwest of the site, on the west side of Manistee Lake. The City of Manistee is located on the west side of the lake, about 1.25 miles northwest of the lagoons at the city's nearest point. The site is located in the northwest corner of Stronach Township, on the Township's border with Manistee Township to the north. Filer Township is located west of the lake and south of the City of Manistee. The closest residence to the lagoon area is about 0.5 mile south of the site in Stronach Township.

U.S. Census data from 1990 indicate that the population of Manistee County was 1.5% Hispanic, 0.9% Native American, 0.25% Black, 0.25% Asian or Pacific Islander, and 0.3% other race, with the vast majority being non-Hispanic white. Twenty-five percent of the County population was 18 or younger, 19% was 65 or older (7).

The City of Manistee and the communities of Filer City and Oak Hill in Filer Township are served by municipal water systems that use wells for their supply. The Filer Township municipal wells are located approximately 1.5 miles west-southwest of the PCA lagoons, on the west side of Manistee Lake. The Manistee city wells are located approximately 3 miles west of the PCA lagoons, also west of Manistee Lake. All other areas of Filer, Stronach, and Manistee Townships are served by individual wells.

Manistee Lake is located approximately 0.5 mile from the lagoons. Manistee Lake is connected directly to Lake Michigan by the Manistee River. The shore of Lake Michigan is approximately 3 miles west of the lagoons. Manistee Lake, Lake Michigan, and the Manistee River are heavily used for recreation, including swimming, boating, and fishing. There are three public boat launching ramps on Manistee Lake: one at the south end of the lake, between Stronach and Filer City; one north of East Lake, near the mouth of the Manistee River; and one in downtown Manistee, near the outlet to Lake Michigan. There are no municipal water supply intakes on Manistee Lake or the Manistee River. The nearest municipal water supply intakes on Lake Michigan are at Ludington, approximately 20 miles south of Manistee, and Traverse City, approximately 50 miles northeast of Manistee.

The land east of the site is largely undeveloped and part of the Manistee National Forest. The land west of the PCA site, between the site and Manistee Lake, is zoned for industrial use. The largest property owner is a Martin Marietta Corporation brine recovery and processing plant. The National Forest lands east of the site are used for recreation, including hiking, camping, hunting, and fishing. The nearest public campground is approximately 10 miles east of the site. People using public lands for recreation sometimes stray onto private lands, in defiance of or in ignorance of any postings.

D. Health Outcome Data

Community members have expressed concern about the cancer incidence in Manistee County, though there are no indications in the material reviewed for this assessment that human exposure to site-related contaminants at levels of public health concern has occurred at this site. The assessors have obtained cancer incidence and mortality data from the Michigan Department of Public Health's Office of the State Registrar and Center for Health Statistics. These data are discussed in the Health Outcome Data Evaluation section later in this assessment.


During a U.S. EPA-sponsored public meeting relating to the site in July 1992, some residents of the area expressed concern whether the cancer incidence rate in Manistee County was high compared to other areas of the state (8). In response to these concerns, the assessors have obtained cancer incidence and mortality data from the Michigan Department of Public Health's Office of the State Registrar and Center for Health Statistics. These data are discussed in the Health Outcome Data Evaluation section later in this assessment.

The MDPH released a draft of this Public Health Assessment for public comment on March 29, 1995. The public comment period was open until April 28, 1995. Responses to comments received are included in the Responsiveness Summary appended to this Assessment.

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