In an operation as big as the Environmental Protection Agency, it's not always easy for the right hand to keep up with what the left hand is doing.
That may explain EPA's handling of the sludge situation at Kimberly-Clark Corp.'s big tissue-products plant on the Fox River here.
For many years Kimberly-Clark, like the other paper mills that line the Fox River Valley between Appleton and Green Bay, used the river as a depository for much of the chemical and slurry by-product of its productive operations.
Over the last two decades, spurred by government regulations and its growing environmental consciousness, the firm has spent large sums to find other ways to dispose of its wastes.
But EPA deals with far more than rivers, the Kimberly-Clark has discovered that there is no place it can dump waste products without triggering alarms at some branch of that agency. Even when the firm took advice from another federal agency it managed to run afoul of environmental rules.
"We are still working on it, and it may work out," said Elmer Dickson, the firm's chief environmental officer. "But you sort of get the idea that you can't win."
Dickson's point is a common one here among business people, who sometimes see the federal regulatory apparatus as a Hydra-headed creature.
Businesses here, as in other cities, regularly have to deal with several dozen regulatory agencies. And in some cases, like that of Kimberly-Clark's sludge, they have to deal with several divisions of a single agency.
In the beginning, the problem was water pollution, which brought the tissue plant under the jurisdiction of EPA's Office of Water Programs.
To comply with that office's regulations for cleaning up despoiled rivers, the firm began to trap pollutants it had once discharged into the Fox River. Today, those pollutants are caught in filters and collected in a slimy solid called sludge.
The result was a signal environmental success. The river has made a remarkable recovery in the past decade, and Dickson said that "the regulations had a great deal to do with that, no doubt about it."
On the shore, however, the sludge was building up rapidly, and that brought the plant under the jurisdiction of a different EPA branch, the Office of Solid Waste. The firm worked for years to find an acceptable means of disposing of all its sludge, and still doesn't have the problem solved.
A year or two ago, though, EPA's solid-waste people and another federal agency, the Department of Energy, came up with a neat solution for the sludge situation: the material could be burned for heat, eliminating the sludge and saving fuel in the bargain.
With encouragement and advice from the Energy Department, the firm began planning a "fluidized bed boiler" to burn up its sludge.
That idea, though, brought the EPA back into the picture, this time the Office of Air Quality. The problem is that burning sludge pours particulate and gaseous emissions into the air. This is a particular problem here, because part of the Appleton area still has not met the government's basic guidelines for a healthy atmosphere.
If Kimberly-Clark, DOE and EPA's solid-waste people want to build the new boiler, they will have to spend a year or more negotiating with EPA's air-quality regulators to obtain the necessary permits.