sappi cloquet new paper machine project environmental

p-ear1-04 TDD (for hearing and speech impaired only): 651-282-5332

Printed on recycled paper containing 30% fibers from paper recycled by consumers

ENVIRONMENTAL ASSESSMENT WORKSHEET

Note to reviewers: The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects. This EAW was prepared by the Minnesota Pollution Control Agency (MPCA), acting as the Responsible Governmental Unit (RGU), to determine whether an Environmental Impact Statement (EIS) should be prepared. The project proposer supplied reasonably accessible data for, but did not complete the final worksheet. Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) Monitor. Comments on the EAW should address the accuracy and completeness of information, potential impacts that are reasonably expected to occur that warrant further investigation, and the need for an EIS. A copy of the EAW may be obtained from the MPCA by calling 651-757-2101. An electronic version of the completed EAW is available at the MPCA Web site http://www.pca.state.mn.us/news/eaw/index.html#open-eaw. 1. Project Title: Sappi Cloquet New Paper Machine Project 2. Proposer: Sappi Cloquet, LLC 3. RGU: Minnesota Pollution Control Agency Contact Person Rob Schilling Contact Person Kevin J. Kain and Title Environmental Manager and Title Project Manager Address 2201 Avenue B Address 520 Lafayette Road North Cloquet, Minnesota 55720 St. Paul, Minnesota 55155-4194 Phone 218-879-0638 Phone 651-757-2482 Fax 218-879-0649 Fax 651-297-2343 E-mail [email protected] E-mail [email protected] 4. Reason for EAW Preparation:

EIS Scoping

Mandatory EAW

X

Citizen Petition

RGU Discretion

Proposer Volunteered

If EAW or EIS is mandatory give EQB rule

category subpart number and name: Minn. R. 4410.4300, subp. 13. Paper or Pulp Processing Mills

Minn. R. 4410.4300, subp. 13 requires an EAW for “expansion of an existing paper processing facility that

will increase production capacity by 50 percent or more.” The proposed Sappi Cloquet New Paper Machine Project (Project) will increase Sappi Cloquet, LLC’s (or Sappi) production capacity by more than 50 percent.

Another consideration made while determining the level of environmental review required for the proposed Project included an evaluation of a mandatory EIS threshold under Minn. R. 4410.4400, subp. 11 – Industrial, commercial, and institutional facilities, lists thresholds pertaining to building square footage. These thresholds indicate that the proposed Project’s approximately 620,000 square feet within a third class city would require an EIS. However, the EQB determined that the mandatory EAW triggered under the pulp and paper industry specific environmental review threshold in part 4100.4300, subpart 13 supersedes the building square footage threshold in part 4410.4400, subpart 11 and, therefore, this EIS threshold does not apply. See Attachment 1 for the decision letter from EQB regarding this item.

http://www.pca.state.mn.us/news/eaw/index.html#open-eaw

Sappi Cloquet New Paper Machine Project Environmental Assessment Cloquet, Minnesota 2 Worksheet

5. Project Location: County Carlton City Cloquet 1/4 1/4 Sections 13, 24, 19 Township 49N, 49N Range 17W, 16W

Tables, Figures, and Appendices attached to the EAW:

The following Figures are attached to the EAW:

1. General location map of the project 2. Aerial Photograph displaying the Site Plan with all significant project and natural features 3. U.S. Geological Survey Quadrangle Map displaying the Site Plan with all significant projects and

natural features 4. Proposed New Mill Power Boiler Configuration 4a. Current Mill Power Boiler Configuration 5. Project Land Use 6. Project Land Cover Types 7. Carlton County Soil Survey with National Wetlands Inventory 8. Lake Superior Water Line Diagram 9. Existing Mill Water Use Process Flow Diagram 10. Proposed Project plus Existing Mill Water Use Process Flow Diagram 11. Floodplain Map 12. Zoning Map 13. New Equipment Locations and Sappi Property Boundaries 14. Adjacent Property Owners 15. Known and Potential Sources of Soil and Ground Water Contamination 16. Nearby Permitted Air Emission Facilities 17. Wastewater Capacity Allocation Table for Western Lake Superior Sanitary District 18. Sappi Cloquet Self-Monitoring Report Form 19. Contaminated Soil/Water Assessment Protocol

The following Attachments are attached to the EAW:

Attachment 1: Decision letter from EQB on EAW vs. EIS Attachment 2: Response Letter from State Historic Preservation Office Attachment 3: Response letter from Minnesota Department of Natural Resources (DNR) Attachment 4: Sappi Cloquet Industrial Wastewater Discharge Permit from October 1, 2006, to

September 30, 2011 6. Description:

a. Provide a project summary of 50 words or less to be published in the EQB Monitor. Sappi proposes to construct a new paper machine to produce 671,000 net tons per year of fine coated paper on the site of its existing mill in the city of Cloquet (or City). The new paper machine complex will include ancillary operations such as stock and coating preparation, finishing, converting, warehousing, and shipping. A new package boiler fired by natural gas will be installed to provide steam for the new paper machine. The former tree nursery area will be converted to a wood storage yard, which will require the rerouting of Avenue B. The proposed Project does not require an increase in pulp production or timber harvesting.


b. Give a complete description of the proposed Project and related new construction. Attach additional sheets as necessary. Emphasize construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes. Include modifications to existing equipment or industrial processes and significant demolition, removal or remodeling of existing structures. Indicate the timing and duration of construction activities. Existing Mill The Sappi Cloquet, LLC Mill (Existing Mill) has two existing paper machines and one off-machine coater. Paper Machine #12 produces 180,000 tons of paper per year and Paper Machine #4 produces 160,000 tons of paper per year, for a total of 340,000 tons of fine coated paper per year produced by the Existing Mill. Most paper produced on Paper Machines #4 and #12 is used as feed stock on the Off-Machine Coater #13; however, a portion of the paper is converted and sold directly to customers. The coater is subject to the Paper Coating Maximum Achievable Control Technology (MACT), and complies by the use of water-based low Volatile Organic Compounds (VOC)/Hazardous Air Pollutants (HAP) coating raw materials. Steam and electricity are needed for pulp and paper-making. There are three power boilers and one recovery boiler at the Existing Mill, producing steam that is utilized by three steam turbines, which co-generate electricity and process steam for use as a source of heat in pulp or paper making (Figure 4a). The Existing Mill generates approximately 98 percent of the electricity it needs to operate. Additional electrical power is purchased from Minnesota Power. Approximately 93 percent of the steam and electricity produced at the Existing Mill is derived from renewable biomass. Biomass fuel consists of bark or off-spec chips not suitable for use in other processes. The biomass is transported to the Existing Mill by truck and stored in piles in the fuel yard of the Existing Mill for use as a fuel in the power boilers. Located on Sappi property is a company called Specialty Minerals, which is an independently owned, operated and permitted facility. Specialty Minerals is under contract with Sappi to produces Precipitated Calcium Carbonate (PCC) in slurry form that is used by Sappi in its paper making process. PCC is a product of precipitation from the reaction of Carbon Dioxide (CO2) gas with slaked lime. Lime is brought in by trucks or railcars. The source of CO2 is stack gas from the Existing Mill limekiln or boiler #9. The PCC slurry is used as a filler and coating agent in making paper. The main emission units at Specialty Minerals are the carbonators. These carbonators take CO2 contained in the exhaust gas from the boiler or limekiln located at the Existing Mill, and releases the other components of exhaust gas. Estimated carbonator emissions of nitrogen oxides (NOx), sulfur dioxide (SO2), carbon monoxide (CO), and VOCs are based on the most recent test results from the Existing Mill’s lime kiln and Boiler #9 exhaust. Specialty Minerals is a separately permitted facility; however, because of its location on Sappi property, the emissions from Specialty Minerals have been accounted for in the air modeling completed for the air permitting process and for the EAW review for the proposed Project. With the construction of the new paper machine, the demand for PCC will increase. At this time, the MPCA is not aware of any plans that Specialty Minerals has to expand it current operation. However, if Specialty Minerals should choose to expand, it may be subject to environmental review prior to permitting. PCC is available to Sappi from other suppliers; therefore, the expansion of Specialty Minerals is not required for the operation of the proposed new paper machine.


Project Description Sappi proposes to construct a new paper machine complex (the Project) to produce 671,000 net tons per year of fine coated paper. The proposed Project will include ancillary operations such as stock and coating preparation, finishing, converting, warehousing, and shipping. To provide steam for the proposed Project, a new 350-million British Thermal Units (BTU) (250,000 pounds steam per hour) package boiler (# 11 power boiler) fired by natural gas will be installed (Figure 5). In addition, selective non-catalytic reduction (SNCR) and a new over-fire air system will be installed on the existing #9 power boiler to reduce emissions of NOx, particulate matter (PM), particulate matter less than 10 microns (PM10), and CO. The improvements to Power Boiler #9 will allow a 15,000-ton per year increase in biomass firing to produce steam and electricity. Because the proposed Project will be constructed in the existing on-site wood yard area, the proposed Project also includes creating a new wood storage yard to an open area that at one time was used as a tree nursery area. Sappi is also proposing to annex portions of Avenue B and rerouting traffic to 18th Street between the exiting scale road and Highway 45. Currently, the Existing Mill produces approximately 475,000 tons per year of pulp that can be used by two existing paper machines on site. This pulp is called “market pulp” and currently 10 to 15 percent is sold in Minnesota and the remaining 85 to 90 percent is sold out of state. With the construction of the proposed Project, the Existing Mill will discontinue the sale of its “market pulp” and use all of it the 475,000 tons per year for making paper on site. The Existing Mill plus proposed Project will increase its purchase of post-consumer fiber and softwood market pulp from 20,000 to approximately 80,000 ton per year to supply the proposed Project (see Table 1 below). There are no sources of softwood market pulp in Minnesota; therefore, Sappi anticipates that the source of the needed additional softwood pulp will be either the Southeastern United States or Canada. This usage is also driven by customer demand, as demand for paper with higher amounts of post-consumer fiber may increase in the future. The amount of timber harvesting for the Existing Mill plus proposed Project will not increase as a result of the proposed Project. See Section 29, Timber Harvesting, for more detailed information on this topic.

Table 1 – Comparison of Paper and Pulp Production at Existing Mill

and Existing Mill plus Proposed Project

Existing Mill Conditions(1)

Existing Mill plus proposed

Project(1) Paper Production Paper Machine #4 160,000 160,000 Paper Machine #12 180,000 180,000 New Paper Machine -- 671,000 Total Paper Production 340,000 1,011,000 Pulp Production Pulp Produced On-site 475,000 475,000 Pulp Used for On-site Paper Production 175,000 475,000 Pulp Sold Offsite 300,000 0 Purchased Post Consumer Waste (PCW) and Softwood Pulp Used for On-site Paper Production

20,000

80,000

(1) Figures reported in tons per year.


The Project plan includes an estimated 3.5 million gallons per day (mgd) increase in the average daily use of water from Lake Superior and an estimated 1.8 mgd decrease in the average daily use of water from St. Louis River. The new paper machine will be equipped with state of the art technology for water conservation and will use water more efficiently than paper machines #4 and #12. These efficiencies will make it possible to increase paper production at the Existing Mill plus the proposed Project by 197 percent, while only increasing water consumption by 10 percent. The company intends to implement water conservation projects on the existing paper machines #4 and #12 to further increase the overall water efficiency of the Existing Mill. Currently, the Existing Mill as a whole uses 17,400 gallons of water per ton of paper. After startup of the new paper machine, the Existing Mill plus the proposed Project as a whole will use 6,500 gallons of water per ton of paper. Additional water will be taken from Lake Superior, allowing the Existing Mill to reduce the amount of water appropriated from the St. Louis River (see Section 13 below for more details). The reduction in St. Louis River water usage will be beneficial to the river system during late summer when low river flows sometimes occur. The Project will also have an effect on air emissions. Because the Existing Mill is a major source for Prevention of Significant Deterioration (PSD), Sappi is required to conduct netting calculations to determine the net increases and decreases in emissions of regulated pollutants. There is a complete discussion of air emissions and the netting calculations in Section 23 below. The construction of the proposed Project will also increase the overall energy efficiency of the Existing Mill plus proposed Project as a whole. Currently, the Existing Mill uses 45 million BTU of energy per ton of paper; however, after startup, the Existing Mill plus proposed Project will use 17.3 million BTU of energy per ton of paper. In addition, the Existing Mill currently emits 24.3 pounds of criteria pollutants per ton of paper; however, after startup, the Existing Mill plus proposed Project will emit 7.5 pounds of criteria pollutants per ton of paper. The proposed Project is expected to employ approximately 100 to 200 additional people. The Existing Mill plus proposed Project will operate 24 hours per day. Each shift will have approximately 30 people working. The proposed Project will require an additional 1,300 to 2,600 gallons of potable water per day total. for the additional 100 to 200 new employees that would be needed at the Existing Mill plus proposed Project. The additional potable water will come from the city of Cloquet.

c. Explain the project purpose; if the project will be carried out by a governmental unit, explain the need for the project and identify its beneficiaries. The purpose of the proposed Project is to increase paper production capacity at the Existing Mill to allow Sappi to compete in the global paper market place, become more efficient in overall paper production and processing, and ultimately ensure its long-term economic viability.

d. Are future stages of this development including development on any outlots planned or likely to happen? Yes No If yes, briefly describe future stages, relationship to present project, time line and plans for environmental review.


e. Is this project a subsequent stage of an earlier project? Yes No

If yes, briefly describe the past development, time line, and any past environmental review.

Mill Historical Time Line 1898 Construction of Northwest Paper Company in Cloquet commenced April 8, 1899 First roll of newsprint produced 1899 Mill consisted of a 550-foot dam, hydro generators, one power boiler, groundwood pulp

mill (using the river flow), and one paper machine (PM1) producing 20 tons per day of newsprint

1900 Second paper machine (PM2) added 1901 Second groundwood mill built about a half-mile upstream – operated until 1920 1915 Sulfite pulp mill built in Cloquet to eliminate the need to buy chemical pulp from other

companies 1920s Canadian newsprint flooded the U.S. market causing difficult market conditions.

Cloquet mill adapted by converting to mill to manufacture higher grades of paper. 1923 Sulfite pulp mill built to supply higher grade of pulp needed for new paper grades

(included RB6) Dec. 1924 Mill ceased producing newsprint 1925 Third paper machine (PM3) added – specifically designed to manufacture printing

papers 1929 Construction started on PM4 1931 PM4 starts up 1940 Groundwood mill shut down 1948 Bleach plant added to mill 1955 Tree nursery built in Cloquet (across Ave B from mill) 1962 Feltless pulp machine started up 1964 Northwest Paper Company merged with Potlatch Forests, Inc. 1965 Power Boiler 7 built 1968 Construction of an off machine coater (OMC8) begins 1970 OMC8 starts up 1973 Mill renamed Potlatch Corp. 1973 Pulp mill expansion – 90 tons per day, included RB8 and calciner 1974 Agreement signed with Western Lake Superior Sanitary District (WLSSD) to join a

regional wastewater treatment plant in Duluth 1976 Sulfite pulp mill shut down 1977 Pulp mill modernization started – included upgrade to bleach plant, replace wood

handling system, increase pulping efficiency and install PB9 1979 Connection to WLSSD complete 1982 Pulp mill modernization complete 1983 PM4 rebuilt 1988 PM12 added – PM1, 2 and 3 decommissioned. PM1, 2 & 3 ultimately dismantled &

sold. PM1 and PM2 are currently running in Columbia and PM3 is running in China. 1989 Off Machine Coater 13 built – OMC8 decommissioned and removed. 1992 Environmental Impact Statement concluded for proposed plant expansion 1992 Pulp mill modernization started – included RB10, Lime Kiln, fiberline with O2 delig,

evaporators, new bleach plant and market pulp machine 1994 Elemental Chlorine bleaching eliminated 2002 Pulp Mill modernization complete


7. Project Magnitude Data Total Project Area (acres) 36.9 or Length (miles)

Number of Residential Units:

Unattached

Attached

Maximum Units Per Building:

Commercial/Industrial/Institutional Building Area (gross floor space):

total square feet

620.100

Indicate area of specific uses (in square feet):

Office 15,800 Manufacturing 531,100 Retail 0 Other Industrial 0 Warehouse 73,800 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Building height See below If over 2 stories, compare to heights of nearby buildings

The proposed Project includes several buildings that will be connected. The paper machine building will be approximately 87 feet tall. The converting building will be approximately 93 feet tall, and the associated loading and shipping operation will be 33 feet tall. The pulp make-down building will be 34 feet tall. The heights of the proposed Project buildings are similar to the paper manufacturing buildings already constructed and in operation on the Existing Mill site.

8. Permits and approvals required. List all known local, state and federal permits, approvals and

financial assistance for the project. Include modifications of any existing permits, governmental review of plans, and all direct and indirect forms of public financial assistance including bond guarantees, Tax Increment Financing and infrastructure.

Table 2 – Permits and Approvals Required

Unit of government Type of application or update 1 Status Major Amendment to Title V Operating Permit

Application for permit amendment submitted

NPDES Stormwater Construction Permit Application to be submitted NPDES Industrial Stormwater Permit Application for permit

amendment to be submitted

MPCA

Aboveground Storage Tank Permit Application for permit amendment to be submitted

DNR City of Cloquet Water Appropriations Permit

Application for permit amendment to be submitted

WLSSD Capacity Allocation Agreement Application to amend current agreement to be submitted.

City of Cloquet Building Permit Application to be City of Cloquet JOBZ District participation agreement Application to be submitted City of Cloquet Grading Permit – related to stormwater

pollution prevention planning Application to be submitted

City of Cloquet Road Relocation To be approved 1 The Existing Mill holds other environmental permits or licenses that are not affected by the proposed Project and, therefore, not listed in the table above.


9. Land use. Describe current and recent past land use and development on the site and on adjacent

lands. Discuss project compatibility with adjacent and nearby land uses. Indicate whether any potential conflicts involve environmental matters. Identify any potential environmental hazards due to past site uses, such as soil contamination or abandoned storage tanks, or proximity to nearby hazardous liquid or gas pipelines. The proposed Project site is located along the banks of the St. Louis River in the city of Cloquet (Figure 2). The proposed Project will be a paper production expansion of what has historically been the site of pulp and paper making since 1899. The land used for construction of the proposed Project is currently being used as a wood storage yard. The land use at the existing site will remain industrial manufacturing as a result of the proposed Project. A new paper machine building complex will be constructed at the Existing Mill site by removing portions of the current wood storage yard and several spur rail lines. The wood storage yard will be relocated to the former tree nursery area, which lies adjacent to the proposed Project site on the south side of Avenue B. The former tree nursery site is currently classified as industrial land use in the City of Cloquet 2008 Comprehensive Plan and the land use classification for this portion of the proposed Project will not change. The spur rail lines removed to construct the new paper machine building complex will not be reconstructed.

The land use adjacent to and surrounding the proposed Project site is a mix of residential, light commercial, industrial, rural, and forested lands (Figure 6). The St. Louis River borders the proposed Project site to the north and northeast. Across the river, the land use consists of forested open space land, park land, low-density residential, and rural residential/agricultural. The existing land use to the south and southwest of the proposed Project site consists of commercial and medium-density residential areas. Existing land use to the southeast of the proposed Project site includes industrial and medium-density residential uses. There are several schools, a hospital, and nursing home facility located less than one mile from the Existing Mill. The nearest schools include two elementary schools (one within one-half mile of the proposed Project) and a middle school/early childhood education center.

There are no environmental hazards due to past site uses expected in the proposed Project area. Should any potentially contaminated soils be encountered during construction excavation, Sappi will follow its “Site Excavation Contingency Plan” (Figure 20).

10. Cover Types. Estimate the acreage of the site with each of the following cover types before and after

development: Before After Before After Types 1-8 wetlands 0 0 Lawn/landscaping 0 0 Wooded/forest 0 0 Impervious Surfaces 22.5 35.9 Brush/grassland 0 0 Other (describe)* 14.4 1 Cropland 0 0 TOTAL 36.9 36.9

*The former tree nursery site located south of Avenue B from the Existing Mill is being developed as the new wood storage yard as a part of this proposed Project. This area is 16.8 acres in size, of which 2.4 is existing impervious surface in the form of a parking lot. The remaining 14.4 acres is mowed turf grass and shrubs. When the tree nursery area is converted to the new wood storage yard, the area will be mainly converted to an impervious surface area. The 16.8 acres will now be 15.8 aces of impervious surface with the remaining 1 acre comprised of grass and shrubs to provide visual screening for the wood piles.


11. Fish, Wildlife, and Ecologically Sensitive Resources. a. Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project. Describe any measures to be taken to minimize or avoid impacts. The St. Louis River begins near Hoyt Lakes, Minnesota and flows southwesterly for 179 miles before forming an estuary. The estuary then empties into Lake Superior, with the St. Louis River representing the largest U.S. tributary to Lake Superior. The St. Louis River provides habitat for a variety of fish and wildlife species. The DNR identifies walleye, northern pike, smallmouth bass and channel catfish as the primary recreational game fish in the St. Louis River. A fish community survey conducted by the MPCA on the St. Louis River downstream of Scanlon in 1997 found yellow perch, smallmouth bass, log perch, and johnny darters to be the most abundant species. Wildlife species identified by the DNR along the St. Louis River include timber (gray) wolves, bobcat, Canada lynx, beaver, otter, whitetail deer, bald eagle, and osprey. The DNR has designated the approximately 78 miles of the St. Louis River as a state canoe route, providing recreational opportunities for a variety of camping and paddling experiences. The section of the St. Louis River between the Knife Falls and Scanlon dams is not accessible to the public for canoeing or any other recreational activity. Canoers take out prior to the Knife Falls dam and put in downstream of the Scanlon dam. The proposed Project site is located along the banks of the St. Louis River in the city of Cloquet, and has been historically used for paper production since 1899. The land used for construction of the proposed Project is currently being used as a wood storage yard and has little or marginal wildlife habitat. Impacts to wildlife living in the vicinity of the proposed Project are not anticipated.

b. Are any state (endangered or threatened) species, rare plant communities or other sensitive ecological resources such as native prairie habitat, colonial water bird nesting colonies or regionally rare plant communities on or near the site? Yes No

If yes, describe the resource and how it would be affected by the project. Indicate if a site survey of the resources has been conducted and describe the results. If the DNR Natural Heritage and Nongame Research program has been contacted give the correspondence

reference number: ERDB20080695

Describe measures to minimize or avoid adverse impacts.

The DNR’s Minnesota Heritage Database was queried to determine whether rare, endangered or special concern species exist in the vicinity of the proposed Project site. The results of the search returned one known record of a single species within the proposed Project vicinity. The species previously recorded in the proposed Project vicinity is the Black sandshell (Ligumia recta), which is a state-listed freshwater mussel species of special concern. Black sandshell mussels are associated with medium to large sized rivers with continuous flow and are often found in firm sand to gravel substrates. The known record of the Black sandshell in the proposed Project vicinity is associated with the St. Louis River (Attachment 3). The DNR response states that the proposed Project is unlikely to impact the species, provided that the proposed Project does not negatively impact the water quality of the St. Louis River.


The proposed Project will be conducted within the Existing Mill site. Stormwater runoff associated with the construction proposed Project will be managed in accordance with NPDES requirements and best management practices (BMPs). (See sections 17 and 18 below for additional information) New stormwater infrastructure (storm sewers, detention ponds, etc.) will be installed to manage runoff associated with the proposed Project according to city of Cloquet regulations. No process wastewater from the existing industrial facilities at the Existing Mill is discharged to the St. Louis River. Wastewater from the Existing Mill is regulated through an industrial wastewater discharge permit, which requires pretreatment prior to discharge into the WLSSD, where the water is processed by the treatment plant. Wastewater from the Existing Mill plus proposed Project will continue to undergo pretreatment prior to discharge to the WLSSD wastewater treatment plant. No process water from the Existing Mill plus proposed Project will be directly discharged to the St. Louis River. Impacts to the water quality of the St. Louis River, and its associated biological community, are not anticipated as a result of the proposed Project.

12. Physical Impacts on Water Resources. Will the project involve the physical or hydrologic alteration

(dredging, filling, stream diversion, outfall structure, diking, and impoundment) of any surface waters such as a lake, pond, wetland, stream or drainage ditch? Yes No If yes, identify water resource affected. Describe alternatives considered and proposed mitigation measures to minimize impacts. Give the DNR Protected Waters Inventory (PWI) number(s) if the water resources affected are on the PWI.

13. Water Use. Will the involve installation or abandonment of any water wells, connection to or changes

in any public water supply or appropriation of any ground or surface water (including dewatering)? Yes No

If yes, as applicable, give location an d purpose of any new wells; public supply affected, changes to be made, and water quantities to be used; the source, duration, quantity and purpose of any appropriations; and unique well numbers and DNR appropriation permit numbers, if known. Identify any existing and new wells on the site map. If there are no wells known on site, explain methodology used to determine.

Sappi currently holds DNR Water Appropriations Permit #75-2165 for the Existing Mill to appropriate water from the St. Louis River, and the city of Cloquet holds DNR Water Appropriations Permit #78-2174 to appropriate water from Lake Superior. The city of Cloquet also provides Sappi with potable water from several groundwater wells. The proposed Project will require an additional 1,300 to 2,600 gallons of potable water per day total for the additional 100 to 200 new employees that would be needed at the Existing Mill plus proposed Project. Water is used in the pulp and paper-making process. The Existing Mill has two sources of water for use in pulp and paper making: the St. Louis River and Lake Superior. The St. Louis River is also the source for noncontact cooling water and fire water for the Existing Mill. The Existing Mill treats and uses approximately 4.2 mgd of water from the St. Louis River for pulp and paper making. In addition, the Existing Mill uses 11.5 mgd of water from Lake Superior for pulp and paper making. Approximately 0.5 mgd of untreated river water is supplied to the Existing Mill from the St. Louis River for use as fire water and noncontact cooling water. There are two water intakes to appropriate water from the St. Louis River. One intake brings untreated water directly into the Existing Mill for use as noncontact cooling water. The other intake brings water through a settling clarifier and sand filter system to produce water of sufficient quality for paper making. Water from Lake Superior is brought to the Existing Mill via a pipeline and associated pump stations and reservoirs that are owned and operated by the city of Cloquet. Lake Superior water requires only biological treatment prior to use in pulp or paper making.


Occasionally, due to high winds and re-suspension of sediments, water from Lake Superior becomes too turbid for use in paper making. When this occurs (typically a few times per year for a few days), the appropriation of water from the St. Louis River is increased to supply 100 percent of the Existing Mill’s pulp and paper making water demand. The city of Cloquet began using Lake Superior Water (LSW) as its domestic water supply in 1969. The city of Cloquet discontinued using LSW as its domestic water supply in 1986 and now only operates and maintains the LSW line to serve Sappi, and also to provide backup fire water to the cities of Thomson and Cloquet. The city of Cloquet conducted an LSW line capacity study in 2000 to assess the need for repairs or upgrades that would be required to meet Sappi’s request for increased water use. The report established that the maximum hydraulic capacity of the LSW line is 17.7 mgd. The report also determined that repairs and upgrades to the system were required to address leaks and water losses and that increased pumping capacity would be needed at Station #2 to meet projected future water demands. Work has been completed to replace the stressed concrete cylinder pipe with ductile iron pipe through much of the system, as well as upgrade the 54-inch line under Interstate Highway #35. Upgrades to the #2 pumping station, which would increase the pumping capacity of the system, have not been completed. These upgrades will be made whether the proposed Project moves forward or not. Based on the information provided in the “Lake Superior Water System Report,” the upgrades include installing larger impellers on existing pumps and also replacing existing pump motors with larger 1,250-horsepower motors. These improvements can be conducted within the existing #2 pump station and would not create significant construction impacts (such as disturbed land, digging, grading, additional right-of-way, etc.). The improvements will allow water to be moved more efficiently within the existing line (operate only two pumps under certain scenarios to meet demand) and also increase the total pumping capacity of the line if all three pumps were operating. The proposed improvements of the line are within the boundaries of the existing pumping station 2. Water is used in the papermaking process to convey fibers from the pulp mill to the paper machines. A Water Use Process Flow Diagram for water use at the Existing Mill is shown in Figure 10. The new paper machine will use water much more efficiently than paper machines #4 and #12. Increased water recycling by the new paper machine and improvements to #4 and #12 paper machines will make it possible to increase paper production by 197 percent, while only increasing water consumption by 10 percent. The proposed Project plan includes an estimated 3.5 mgd increase in the average daily use of water from Lake Superior and an estimated 1.8 mgd decrease in the average daily use of water from St. Louis River. A detailed Water Use Flow Diagram for the Existing Mill plus proposed Project is shown in Figure 11. The company intends to implement water conservation projects on the existing paper machines #4 and #12 to further increase the overall water efficiency of the Existing Mill whether the Project goes ahead of not. The company anticipates that the overall water efficiency will increase by 63 percent on gallons of water used per ton of paper basis.


14. Water-related land use management districts. Does any part of the project involve a shoreland

zoning district, a delineated 100-year flood plain, or a state or federally designated wild or scenic river land use district? Yes No If yes, identify the district and discuss project compatibility with district land use restrictions. Portions of the Existing Mill are located within the Federal Emergency Management Agency (FEMA) designated 100-year flood zone (Figure 12). The Minnesota Flood Plain Ordinance requires building low floors to be constructed one foot above the FEMA 100-year flood elevation, which is defined as the Regulatory Flood Protection Elevation (RFPE). Additionally, the state rules require that fill used to increase the building low floor elevation to the RFPE be extended out 15 feet beyond the edge of the structure. The city of Cloquet has adopted an ordinance addressing floodplain regulations (No. 185A) that includes additional controls beyond the state rule. The Cloquet floodplain ordinance states that all structures, including accessory structures and additions to existing structures, shall be constructed on fill so that the basement floor, or the first floor if there is no basement, is at or above the RFPE. Sappi intends to construct the new paper building at an elevation that is equal to or above the RFPE, in compliance with state and city rules. The 100-year flood elevations were set by FEMA for areas of the flood plain associated with the Knife Falls dam located upstream of the Existing Mill. The 100-year flood elevation at the Knife Falls dam was set at 1,181 feet. Based on a flood surge of 3.6 feet, the associated flood plain areas associated with the Knife Falls dam was set at 1,184 feet. The 100-year flood elevation for the areas associated with the Sappi Cloquet dam has not been set by FEMA. However, in order to set building elevations for the new paper machine complex and finishing and converting complex, estimates for the flood plain elevation have been made by Sappi. The 100-year flood elevation was calculated by applying the flood surge associated with the Knife Falls dam to the Sappi Cloquet dam. The Sappi Cloquet dam elevation is 1,167.8 feet and applying the same 3.6-foot flood surge, the 100-year flood elevation would be 1,171.4 feet. Based on these calculations and the existing elevations at the proposed Project site, Sappi proposes to construct the new paper machine complex at an elevation of 1,171 feet and the new converting and finishing complex at an elevation of 1,173 feet. This will place the building low floors of each complex above the 100-year flood elevation associated with the Existing Mill Dam. The permit to work or build within the 100-year floodplain is covered under the city of Cloquet zoning permit, which will be issued as part of the City building permit for the proposed Project. The final building elevations will be reviewed during the City zoning permit and state National Pollutant Discharge Elimination System (NPDES) construction permitting process. Additionally, as-built certification of the actual constructed low floor elevations of the proposed Project is required by the city of Cloquet to ensure the requirements of its Ordinance 185A have been met.

15. Water Surface Use. Will the project change the number or type of watercraft on any water body? Yes No

If yes, indicate the current and projected watercraft usage and discuss any potential overcrowding or conflicts with other uses.


16. Erosion and Sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil to be moved: 36.92 acres; 64,940 cubic yards. Describe any steep slopes or highly erodible soils and identify them on the site map. Describe any erosion and sedimentation control

measures to be used during and after project construction. The land used for construction of the proposed Project is currently being used as a wood storage yard. The land use at the existing site will remain industrial manufacturing as a result of the proposed Project. A new paper machine building complex will be constructed at the Existing Mill site by removing portions of the current wood storage yard and several spur rail lines. The wood storage yard will be relocated to the former tree nursery area, which lies adjacent to the proposed Project site on the south side of Avenue B. The area in and around the site is fairly flat with no steep slopes. The soils at the proposed Project site are primarily the Cloquet series, which are typically fine sandy loams, which are not considered highly erodible. Before construction begins, an NPDES Stormwater Construction Permit will be obtained from the MPCA. This NPDES Permit requires a Stormwater Pollution Prevention Plan (SWPPP) to be implemented for the proposed Project site prior to construction. The SWPPP addresses erosion and sedimentation prevention measures. The proposed Project will use both temporary and permanent erosion and sediment control measures. As outlined in the SWPPP for the Existing Mill plus proposed Project, these measures may include: 1. Source reduction: maintain good housekeeping and reduce or eliminate the significant materials that

are exposed to stormwater. The significant materials may also be moved indoors or covered (e.g., with a tarp or structure) to eliminate contact with precipitation.

2. Diversion: divert stormwater away from exposed significant materials through the use of curbing, berms, sewers, or other forms of drainage control, or elevate the exposed significant material above surrounding drainage.

3. Treatment: where contact of stormwater with significant materials is unavoidable, use treatment devices to reduce the concentration and amount of contaminants in stormwater discharges. This may include oil/water separators, stormwater detention ponds, and vegetated swales.

The NPDES Permit, SWPPP, and erosion and sedimentation control measures will minimize significant impacts from the proposed Project. Significant impacts to the St. Louis River and other water bodies are not anticipated.

17. Water Quality – Surface-water Runoff. a. Compare the quantity and quality of site runoff before and after the project. Describe

permanent controls to manage or treat runoff. Describe any storm-water pollution prevention plans. An SWPPP was developed to manage stormwater at the Existing Mill. The SWPPP is routinely updated as new conditions arise that may affect stormwater management. The most recent update to the SWPPP was in May 2006. Stormwater management practices at the Existing Mill described in the SWPPP including the following: • Treatment of on-site stormwater by means of stormwater detention ponds and vegetated swales. • Use of catch basins with sediment settling systems in the wood yard to collect sediment, bark,

wood chips or other organic debris prior to discharge to the St. Louis River.


• Use of oil/water separators in catch basins near where fuel tanks are located and vehicle fueling takes place.

• Regular house keeping activities at several areas around the Existing Mill. House keeping activities include items such as cleaning the wood yard of bark and debris, maintaining berms and swales, conducting inspections after storm events and keeping the Existing Mill ground free of trash and debris.

• Inspection of stormwater outfalls between storm events for the presence of non-stormwater discharges.

As part of the proposed Project, the SWPPP will be updated to include planned stormwater management practices for the new paper machine building, new finishing complex, and associated parking areas. New stormwater infrastructure will be installed to collect and transport runoff from the new buildings and parking areas including catch basins, storm sewers, vegetated swales, berms, and detention basins as needed. The city of Cloquet recently adopted an erosion control and stormwater management ordinance. The ordinance states that all SWPPPs for development sites must be submitted to the City for review. The proposed Project’s revised SWPPP will be submitted by the Sappi to the City. After addressing comments from the City, the SWPPP will then be submitted to the MPCA as part of the application for the NPDES Stormwater Construction Permit. An NPDES Stormwater Construction Permit is required by the MPCA for all project sites that disturb greater than one acre of land. The proposed Project will disturb approximately 36.9 acres. There are special NPDES requirements for proposed Project sites that disturb more than 10 acres. Construction sites of this size are required to maintain temporary sediment basins to manage stormwater during construction. The sediment basins must be sized to provide storage for a two year, 24-hour storm event. The two-year, 24-hour storm event for Minnesota is 2.75 inches of precipitation. The proposed facility expansion will take place within the existing wood storage yard, which is essentially an impervious surface. A conservative runoff coefficient for this area is 0.95. The total of the existing wood storage yard that will be disturbed to construct the new paper machine is 20.1 acres. Using the above inputs, the 2-year, 24-hour storm event for the project construction area can be calculated as: 2.75 inches rain fall x 0.95 runoff coefficient x 20.1 acre site x 1 ft / 12 inches = 4.38 ac-ft This would be equivalent to a one-acre pond that is approximately 4.5 feet deep. The exact location of the stormwater pond(s) will be determined during the final detailed engineering phase of the Project. This detailed engineering will be submitted with the NPDES Stormwater Construction Permit Application. At a minimum, the stormwater pond will conform to the parameters shown above, and will entail BMPs to minimize any impact on the environment. Permanent stormwater controls for the site are being discussed with the city of Cloquet as they are in the process of becoming a Small Municipal Separate Storm Sewer System (MS4) Permit holder. The temporary sediment basins are required to be constructed in conjunction with the start of soil disturbance for the Project.


b. Identify routes and receiving water bodies for runoff from the site; include major downstream

water bodies as well as the immediate receiving waters. Estimate impact runoff on the quality of receiving waters. The Existing Mill is located along the banks of the St. Louis River. The terrain of the proposed Project site generally slopes from the south and west to the north and east towards the river. Stormwater at the Existing Mill drains towards the St. Louis River under existing operating conditions. Upon completion of the proposed Project, stormwater will continue to drain to the St. Louis River. Stormwater runoff from the proposed Project will be managed following the procedures described above in section 17.a. Based on the relative volume of stormwater produced at the site and the implementation of the controls described in the site SWPPP, impacts to the water quality of the St. Louis River are not anticipated as a result of the proposed Project.

18. Water Quality – Wastewater. a. Describe sources, composition and quantities of all sanitary, municipal and industrial

wastewater produced or treated at the site.

Upon installation of the new paper machine, the wastewater generated by the Existing Mill plus proposed Project will increase from 15.1 mgd to 16.4 mgd (Table 3a below). The sources of wastewater include wastewater from employees and process wastewater from pulp and paper making. Both sanitary and process wastewaters are conveyed to the WLSSD for final wastewater treatment. Upon completion of the proposed Project, an additional 100 to 200 people may be added, thus generating an additional 1,300 to 2,600 gallons per day of sanitary wastewater. Sanitary wastewater is collected separately from the process wastewater system and joins with the city of Cloquet municipal wastewater line upstream of the WLSSD pumping station located on Existing Mill property. The pulp manufacturing operation is not affected by the proposed Project as no additional pulp will be produced. Wastewater generated from the pulp and paper making process receives primary treatment on site in accordance with the WLSSD Pretreatment Ordinance and Permit 007 (Attachment 4).

b. Describe waste treatment methods or pollution prevention efforts and give estimates of composition after treatment. Identify receiving waters, including major downstream water bodies, and estimate the discharge impact on the quality of receiving waters. If the project involves on-site sewage systems, discuss the suitability of site conditions for such systems. The proposed Project will result in an increase in water usage that will in turn lead to an increase in wastewater generated at the Existing Mill plus proposed Project. Wastewater generated at from the Existing Mill plus proposed Project twill average 16.4 mgd. Values presented in the following tables are daily values based on the annual daily averages during typical operating conditions.


Table 3a – Daily Wastewater Values Based on the Annual Daily Averages During Typical Existing Mill plus proposed Project Conditions

Wastewater Parameter Existing Mill Conditions

Existing Mill plus proposed Project

Conditions Effluent Flow 15.1 mgd 16.4 mgd Effluent TSS(1) 23,642 lb/day 33,600 lb/day Effluent BOD5

(2) 51,112 lb/day 52,300 lb/day On-site Wastewater Treatment Residuals

38 tons/day 60 tons/day

(1)TSS = total suspended solids (2)BOD5 = biochemical oxygen demand

Table 3b – Wastewater Treatment Capacity and Treatment Capacity Allocations

Wastewater Parameter

WLSSD Total Treatment Capacity

WLSSD Total Treatment Allocations

Existing Mill

Projected WLSSD Total Treatment

Allocations Existing Mill plus proposed Project

Effluent Flow 48.4 mgd 40.7 42.0 Effluent TSS 112,000 lb/day 52,557 62,557 Effluent BOD5 121,000 lb/day 118,059 118,059

Pre-Treatment As required by permit, wastewater is pretreated at the Existing Mill and then treated again at the WLSSD before discharge. The wastewater at the Existing Mill is monitored throughout the day for pH, flow, temperature, BOD and COD before being directed to the WLSSD sewer system. Corrective action measures are in place at the Existing Mill’s pretreatment system to prevent and contain spills, leaks, excessive BOD and COD, and other pollutants from entering the WLSSD system (see section 18c for more detail). The proposed Project will not require modifications to the existing pretreatment process. The existing pretreatment permit (Permit No. 007) is valid until September 2011. The increase treatment volume of water from the pre-treatment process will result in an increase in residual sludge. The sludge will be burned on site to the maximum extent allowable, up to the permitted amount of 38,200 tons per year. The remaining sludge will be placed in Sappi’s permitted landfill. The goal is to burn all of the residual sludge (or preferably find some other beneficial use), with no sludge sent to the landfill. WLSSD Treatment After pre-treatment at the Existing Mill, wastewater is sent to WLSSD where the wastewater is further treated to meet all regulatory standards, before being discharged into the St. Louis Bay. WLSSD provides solid waste management and wastewater services for an approximately 500-square mile region around Duluth, Minnesota that includes the cities of Duluth, Cloquet, Hermantown, Proctor, Carlton, Scanlon, Thomson, and Wrenshall and the surrounding townships. Approximately half of the wastewater treated at WLSSD comes from industrial users with the remaining water from homes and businesses. Wastewater is transported through an approximately 73-mile network of interceptors and forcemain sanitary sewers to the wastewater treatment plant in Duluth. The WLSSD


wastewater treatment plant consists of bar screen and grit removal, oxygen generation, activated sludge process, mixed media filters, disinfection and sludge processing by anaerobic digestion to produce biosolids that are land-applied as fertilizer on agricultural fields and mine-land reclamation areas. The change in the effluent discharge from the Existing Mill plus proposed Project to WLSSD will be in terms of an increase in volume only. The total discharge to WLSSD from the Existing Mill plus proposed Project will be approximately 40 percent of the total volume of wastewater treated by WLSSD on a daily average basis. The WLSSD plant has the capacity to accommodate the increase in wastewater effluent as well as the increased TSS and BOD5 loads that will be produced by the proposed Project (Figure 18).

c. If wastes will be discharged into a publicly owned treatment facility, identify the facility, describe any pretreatment provisions and discuss the facility’s ability to handle the volume and composition of wastes, identifying any improvements necessary. The Existing Mill operates under an Industrial Waste Discharge Permit from the WLSSD, valid from October 1, 2006 to September 30, 2011. The WLSSD has an Industrial Pretreatment Ordinance in place that regulates major industrial wastewater contributors in order to prevent certain pollutants from entering the receiving waters of the St. Louis Bay. The Industrial Pre-Treatment Permit 007 covers two separate discharges from the Existing Mill: 1) the categorical discharge from the Existing Mill Kraft Paper operations, and 2) the Sappi Industrial Solid Waste Landfill Leachate and Seeps. The Landfill and Leachate Seep portion of the permit is not relevant to the proposed Project because the use of the landfill is not changing. The following sections describe WLSSD wastewater treatment capacity for average daily flow, peak flow, BOD5, and TSS. The Existing Mill has a Capacity Allocation Agreement with the WLSSD that sets daily and monthly limits on the wastewater effluent flow (average and peak), BOD5 and TSS. The proposed Project will require that the existing Allocation Agreement be modified to account for the small increases in daily average flow, BOD5 and TSS. The WLSSD plant has over 50 percent of its treatment capacity available for TSS.

Daily Average and Peak Flow Total wastewater effluent flow to WLSSD averages approximately 40 mgd from all of its contributors. Peak wastewater effluent flow is not expected to change as result of the proposed Project. The industrial pretreatment permit (Permit No. 007) issued to Sappi by WLSSD limits peak flow to 24 mgd. The proposed Project will increase Sappi’s daily average flow to WLSSD from 15.1 to 16.4 mgd and the total wastewater flow from the entire WLSSD service area to approximately 41.3 mgd, which is within the daily average wastewater treatment capacity of the collection system and wastewater treatment plant. WLSSD expects that daily average wastewater treatment flow to the plant from the balance of the WLSSD service area will remain relatively stable in future years. From 2004 to the present, the Existing Mill has implemented several projects to reduce the inflow of stormwater into the WLSSD collection and treatment system. These projects have included: • To direct stormwater from parking lots away from wastewater treatment inlets and into

stormwater conveyances, additional sloping and regrading was done.


• New stormwater collection systems for roof drains, which directs stormwater away from

wastewater treatment inlets and into stormwater conveyances. • Emergency shutdown procedure to reduce the volume of wastewater flow during significant rain

events. Stormwater collected from the rest of the Existing Mill area will be sent to WLSSD for treatment, along with other wastewater generated from the Existing Mill.

Due to the implementation of these inflow reduction projects, Sappi has significantly reduced its peak flow discharge during significant rain events. Because the building roof drains associated with the proposed Project will be directed to the river and the Existing Mill emergency shutdown procedure is in place, the proposed Project will not increase the Existing Mill plus proposed Project’s peak wastewater flow to WLSSD. BOD5 A BOD5 capacity evaluation was completed in 2006 as part of the Existing Mill BMP Plan. The following information was provided by the BMP Plan: The WLSSD capacity to treat wastewater BOD5 is approximately 120,000 pounds per day. The total influent of BOD5 to WLSSD typically averages 105,000 pounds which is about 87 percent of design capacity. On average, the wastewater from the Existing Mill contains 51,000 pounds of BOD5 from all sources per day The Existing Mill has established a procedure to avoid WLSSD treatment plant upsets resulting from spills or leaks of black liquor, soap, or turpentine. The procedure includes the measurement of chemical oxygen demand (COD) at 4-hour intervals at the influent to the Existing Mill wastewater treatment plant clarifier and the final wastewater effluent prior to discharge to WLSSD. Final wastewater effluent grab samples are collected hourly. Every four hours, the grab samples are composited and analyzed for COD and then converted to an estimate of BOD using a correlation factor. If the estimated BOD5 for a four-hour period exceeds 13,000 pounds due to a release of black liquor, soap, or turpentine, a BOD5 investigation is initiated to determine root cause and corrective actions. The investigation also includes communicating with the WLSSD to determine whether the WLSSD can accept the estimated BOD loading. If the WLSSD cannot accept the loading, wastewater effluent is diverted to the WLSSD diversion basin. Total Suspended Solids The discharge of to WLSSD will increase as a result of proposed Project; however, WLSSD has sufficient excess capacity to treat the additional solids both in the activated sludge and biosolids processing areas. Phosphorus The total phosphorus discharge from the WLSSD treatment plant to the St. Louis Bay is regulated by an existing discharge permit issued to WLSSD by the MPCA. This permit limits the total phosphorus concentration in the plant effluent. Past monitoring of the WLSSD effluent has indicated that the plant has met the requirements of the discharge permit in terms of total phosphorus concentrations. Total phosphorus is not a parameter of concern in the effluent sent form the Existing Mill to the WLSSD treatment plant (Figure 19). Based on discussions with the WLSSD, the


proposed increase in wastewater flows sent to the WLSSD treatment plant as a result of the Existing Mill plus proposed Project will not hinder WLSSD’s ability to meet total phosphorus effluent concentrations required under their existing discharge permit. In summary, the WLSSD capacity has been evaluated for the proposed Project’s estimated increases for wastewater discharge. The WLSSD wastewater treatment plant has enough collection system and wastewater treatment plant capacity to handle the additional wastewater flow, BOD5 and TSS.

d. If the project requires disposal of liquid animal manure, describe disposal technique and location and discuss capacity to handle the volume and composition of manure. Identify any improvements necessary. Describe any required setbacks for land disposal systems.

The proposed Project does not require disposal of any liquid animal manure.

19. Geologic hazards and soil conditions. a. Approximate depth (in feet) to Groundwater: 20 minimum; 20 average. Bedrock: 0 - 2 minimum; 5 - 10 average.

Describe any of the following geologic site hazards to groundwater and also identify them on the site map: sinkholes, shallow limestone formations or karst conditions. Describe measures to avoid or minimize environmental problems due to any of these hazards. Geologic site hazards, such as sinkholes, limestone formations, or karst conditions do not occur at the proposed Project site. The geology at the Existing Mill consists of underlying bedrock from the Thomson Formation, which is a moderately metamorphosed rock consisting of greenish-grey to black slate, siltstone and greywacke. Soil layers are generally thin to nonexistent at the north end of the proposed Project site, with bedrock outcroppings common along the St. Louis River.

b. Describe the soils on the site, giving Natural Resources Conservation Service classifications, if known. Discuss soil granularity and potential for groundwater contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination. Review of the Carlton County Soil Survey revealed that there are four soil types found on and around the proposed Project site. Soils of the Cloquet series are found on the majority of the proposed Project site. Cloquet fine sandy loam soils cover the majority of the Existing Mill and proposed wood yard at the former tree nursery. These soils are somewhat excessively drained soils consisting of one to two feet of loamy material overlaying stratified sand and gravel. The Cloquet series soils are often associated with areas of river terraces and outwash plains. The other major soil series found on the proposed Project area is Borofolist. These very shallow soils are nearly level to undulating and are excessively drained. Borofolist soils consist of only two to eight inches of organic material that often overlies greywacke rock and may contain bedrock ridges. The two other soil groups found in lesser amounts at the proposed Project site include soils of the Duluth series and Fluvaquents. Soils in the Duluth series consist of level, well drained soils formed in loam or clay loam till, while Fluvaquents soils are hydric soils, which can be frequently flooded and consist of loamy alluvial material that may have thin layers of sandy or clayey material.


The Existing Mill has been in operation for over 100 years. In that time, the Existing Mill has produced pulp and paper, which have used a variety of chemicals in the process. The Existing Mill products have been transported by truck and rail, which use various types of petroleum. Given the age and nature of the Existing Mill, contaminated soils may be encountered during excavation and construction of the proposed Project. Sappi has an Excavation Contingency Plan in place. This plan provides safety and environmental guidance to site personnel in the event that contamination of soil or groundwater is encountered during site excavation activities, including construction of buildings. Soil contaminants most likely to be encountered at the site include turpentine, petroleum substances (i.e., gasoline, fuel oil, or other hydrocarbons), various liquors, and lime mud. Proper handling procedures for contaminants are detailed in the Excavation Contingency Plan.

20. Solid Wastes, Hazardous Wastes, Storage Tanks. a. Describe types, amounts and compositions of solid or hazardous wastes, including solid animal

manure, sludge and ash, produced during construction and operation. Identify method and location of disposal. For projects generating municipal solid waste, indicate if there is a source separation plan; describe how the project will be modified for recycling. If hazardous waste is generated, indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments. Sappi Cloquet owns and operates an industrial solid waste landfill that is located to the southeast of the main Existing Mill production facilities. The landfill consists of clay and synthetically lined cells with leachate collection. Leachate from the landfill is routed to the WLSSD collection system. The Existing Mill is permitted to dispose of or stage several byproducts of the pulp and paper making process at the landfill. These materials include: wood ash, wastewater treatment plant residuals, knotter rejects, lime mud and recausticizing process solids. By implementing proposed Projects to reduce, reuse and recycle these materials over the past four years, Sappi has reduced the amount of material landfilled from 120,000 tpy in 2002 to less than 50,000 tpy in 2007. As result, the landfill life has been extended from less than 6 to an expected 20 years. Proposed projects to reduce landfill quantities and thus extend the life of the landfill included: • reducing the quantity of knotter/screen rejects produced during pulp production • reusing knotter/screen rejects during pulp production • burning wastewater treatment plant residuals in Existing Mill power boilers • land applying boiler ash, lime mud and woodroom dirt through the MPCA’s beneficial use

program

Solid waste generated at the Existing Mill will increase as a result of the proposed Project. The increase in paper production at the Existing Mill plus proposed Project will result in an increase of approximately 16,000 tons per year of wastewater treatment plant residuals. However, Sappi plans to continue burning wastewater treatment plant residuals in its power boilers for energy recovery and volume reduction. The resultant wood ash from the power boilers will continue to be land applied in accordance with Minnesota Rules. Therefore, the proposed Project is not expected to change the life expectancy of the landfill which will remain at 20 years while efforts continue to further reduce landfill quantities and thus further extend its life.


b. Identify any toxic or hazardous materials to be used or present at the site and identify measures

to be used to prevent them from contaminating groundwater. If the use of toxic or hazardous materials will lead to a regulated waste, discharge or emission, discuss any alternatives considered to minimize or eliminate the waste, discharge or emission. The proposed Project is the construction of a new paper machine and the associated infrastructure required to operate the paper machine. The paper making process uses small quantities of several potentially toxic or hazardous chemicals and additives. This includes coatings, titanium dioxide, calcium carbonate, retention aids, biocides, felt washes, cleaners/boilout chemicals, defoamers, flocculants, anti-scaling chemical, dyes, sizing chemicals, and sodium hypochlorite. These chemicals will be stored on site in steel or concrete/tile storage tanks or plastic totes which will be housed within concrete containment areas within the new paper machine complex. These substances are used in the paper making process. Toxic or hazardous chemicals or wastes are not generated as a result of the proposed Project.

c. Indicate the number, location, size and use of any above or below ground tanks to store petroleum products or other materials, except water. Describe any emergency response containment plans. The Existing Mill operates under a permit for Storage of Liquid Substances at a Major Aboveground Storage Tank Facility permit issued by the MPCA. The permit applies to outdoor aboveground storage tanks (ASTs) located at the Existing Mill as defined in Minnesota Rules. The Existing Mill ASTs store substances grouped into the following categories: power and recovery, pulp manufacturing, petroleum, fiberline, bleach plant, lime kiln, and market pulp. The tanks at the Existing Mill range in size from 4,000 gallons to over 2 million gallons, depending on the substances. The MPCA permit provides a detailed list of the ASTs, substance, capacity, and inspection records. The MPCA permit requires regular visual inspections, external inspections, internal inspections, secondary containment for each tank, an overfill prevention system, and an operation and maintenance procedure. The secondary containment for each tank is approved by the MPCA, so that waters of the state are reasonably protected from pollution. The permit outlines the procedures that must be followed for maintaining secondary containment for each AST. The permit also includes a list with the secondary containment requirements for each AST at the Existing Mill and any specific requirement for an individual tank, as far as monitoring, maintenance, or improvements needed. The proposed Project includes the installation of up to 15 new outdoor ASTs associated with the new paper machine. The tanks contain uncoated broke, coated broke, clear filtrate, white water, fresh water, hardwood pulp, softwood pulp and/or recycle pulp, depending on the specific needs of the new paper machine. The AST permit from MPCA will be amended to include the new tanks. These tanks will be located outside of the new paper machine building. The new tanks will be located within the secondary containment structure consisting of a concrete containment wall that will surround the entire tank farm. There will be U-drains connected to the wastewater treatment system where leaks or spills would be conveyed for pretreatment before being discharged to WLSSD. There are no below ground tanks at this Existing Mill. No below ground tanks will be added with the proposed Project.


21. Traffic. Parking spaces added: 100 Existing spaces (if project involves expansion): 300 Estimated total average daily traffic generated: Estimated maximum peak hour traffic generated (if known) and its timing:

Provide an estimate of the impact on traffic congestion affected roads and describe any traffic improvements necessary. If the project is within the Twin Cities metropolitan area, discuss its impact on the regional transportation system.

There are 300 parking spaces at the Existing Mill to serve the 760 employees and daily visitors. A new employee parking lot will be constructed to serve the new paper machine complex to accommodate the 100 – 200 new employees associated with the proposed Project. Approximately 100 parking spaces will be added.

The existing main gate entrance from Avenue B is currently used by employees, commercial deliveries

and vendors, tanker truck deliveries, and visitors to access the Existing Mill. Trucks delivering round wood enter across the scales through the 18th Street entrance. Construction workers and contractors use the West Gate access to Industrial Avenue to access the Existing Mill. Traffic flow patterns at the Existing Mill will be altered as a result of the proposed Project. A new main gate entrance will be constructed approximately 500 feet south of the current main gate entrance. A third stop sign will be added to the intersection of Avenue B and 18th Street North to reduce vehicle speeds entering the plant at this intersection.

A traffic impact study has been completed for the proposed Project that will be used by the city of Cloquet to complete the traffic forecasts and traffic analyses that will be the basis for the traffic impact study. The study includes information on traffic volumes (existing and potential future), current development plans at the site and nearby the proposed Project site, projected employee and truck volumes, and any planned roadway improvements.

22. Vehicle-related Air Emissions. Estimate the effect of the project’s traffic generation on air quality, including CO levels. Discuss the effect of traffic improvements or other mitigation measures on air quality impacts. Note: If the project involves 500 or more parking spaces, consult EAW Guidelines about whether a detailed air quality analysis is needed. As a part of this proposed Project, Sappi is proposing to annex portions of Avenue B. Trucks will travel on 18th Street between the existing scale road and Highway 45. As a result of the proposed Project, truck traffic is expected to increase from 114,452 trips per year to 136,508 trips per year and employee traffic is expected to increase from 146,000 trips per year to 184,225 trips per year, or a total vehicle increase of 260,452 trips per year to 320,733 trips per year. The increase in truck traffic is expected to come from additional chemical delivery trucks and shipping trucks taking out more paper product. The increase in employee traffic will come from the additional workers needed for the new paper machine. Following the proposed Project, finished product will be loaded onto shipping trucks at two different loading docks. Products from paper machines #4 and #12 will be shipped from the existing loading docks. Products from the new paper machine will be shipped from loading docks that will be located at the west end of the converting plant. The new paper machine shipping trucks will travel from the new main gate to the new loading docks and leave by the new main gate.


Employees will park at two different parking lots following the completion of the proposed Project. Two-thirds of employees will park in a lot north of the converting plant. The remaining one-third of employees will park in a lot north of the new paper machine building. The proposed Project will only affect unpaved traffic patterns of the roundwood trucks. Additional unpaved roundwood truck distances as a result of this proposed Project are estimated to be approximately 1.7 miles per trip. This total represents the individual contributions from the various roundwood truck travel routes at the site. The vehicle related air emissions calculations were completed using the formulas, default values, and methodology provided in AP-42 Section 13.2.1, Introduction to Fugitive Dust Sources - Paved Roads, AP-42 Section 13.2.2, Introduction to Fugitive Dust Sources - Unpaved Roads, and on-site measurements of silt loading taken in 2005. Sappi completed emission calculations for fugitive dust generated by vehicle traffic on paved and unpaved roads. PM10 and PM2.5 were assessed in the calculations. The Existing Mill plus proposed Project is assumed to have a silt loading content on most paved roads of 1.02 grams per square meter (g/m2). This silt loading was chosen to reflect a measured silt loading of 1.02 g/m2, sampled by Wenck Associates in August 2005. Silt loading values as high as 10 g/m2 were assumed for paved road segments that experience track-out from unpaved areas. The Existing Mill plus Proposed Project is assumed to have a silt content on unpaved roads of 4.81 percent, as sampled by Wenck Associates in August 2005. Table 4 summarizes the total vehicle related fugitive dust emission changes resulting from the proposed Project.

Table 4 – Total Vehicle-Related Fugitive Dust Emissions Following proposed Project Total Fugitive Dust

Emissions Projected Post-

Proposed-Project Emissions

(facility-wide) (Ton/Yr)

Existing Mill Actual Emissions

(facility-wide) (Ton/Yr)

Projected Emissions Change (facility-wide, from Existing Mill to

Post-Proposed Project conditions)

(Ton/Yr) PM 94.71 141.17 -46.46 PM10 18.87 32.14 -13.27 PM2.5 2.67 3.81 -1.14

Impacts from CO levels generated by vehicle traffic are not expected to be significant with respect to the total proposed Project impact. For more information regarding the vehicle traffic fugitive dust emissions, see the Sappi Major Air Permit Amendment Application supplement submitted in October 2008 and supplemented/finalized in March 2009.

23. Stationary Source Air Emissions. Describe the type, sources, quantities and compositions of any emissions from stationary sources of air emissions such as boilers, exhaust stacks or fugitive dust sources. Include any HAPs (consult EAW Guidelines for a listing), any greenhouse gases (GHGs) (such as carbon dioxide, methane, and nitrous oxides), and ozone-depleting chemicals (chlorofluorocarbons, hydrofluorocarbons, perfluorocarbons or sulfur hexafluoride). Also describe any proposed pollution prevention techniques and proposed air pollution control devices. Describe the impacts on air quality.


The Existing Mill is a major source under the PSD Program of the Clean Air Act. The proposed Project involves the following proposed actions:

• Install a new 671,000 ton per year (net) paper machine capable of producing both web and sheet

papers. o New paper machine with full on-machine coating o New stock preparation and coating preparation facility o New sheeting, finishing and shipping facility o New 132.3 MMBtu/hr natural gas dryer

• Install a new 350 MMBtu/hr (250,000 lbs steam/hr) package boiler firing natural gas (with low NOx burners).

• Install a new cooling tower • Install SNCR on Power Boiler #9 for NOx reduction and an overfire air system to reduce carbon

content in the boiler ash. • Build a new wood yard at a former tree nursery area and subsequent rerouting of Avenue B.

Sappi performed an applicability analysis to determine if PSD rules apply to the proposed Project. A hybrid approach (under 40 CFR § 52.21.a (2) (f)) was applied for this proposed Project to determine the emissions increase, since the proposed Project includes both changes to existing emission sources and the addition of new emission sources. This analysis showed projected increases in PM, PM10, NOX, and CO in excess of the significant emissions increase threshold described in 40 CFR § 52.21(b)(40) , therefore source-wide netting is required. Sappi has prepared a source-wide netting analysis for PM, PM10, NOx, and CO. PSD would apply to the proposed Project only if it were to result in a significant net increase in emissions of a regulated pollutant. The proposed Project’s net emissions increases, based on the difference between the projected increases due to the proposed Project and the increases and decreases in actual emissions of all changes made during the past five years (contemporaneous period) are below the PSD significant emissions increase thresholds as shown in the Table 5 below.

Table 5 – Net Emissions Changes Associated with the Proposed Project

Pollutant Sum of Increases(1)

Netting Required?

Sum of Netting Projects(2)

Sum of Increases +

Netting Projects (3)

PSD Significant Emissions

Increase Threshold(4)

(tpy) (tpy) (tpy) (tpy)PM 33.5 Yes -47.92 -14.4 25

PM10 29.3 Yes -15.00 14.3 15SO2 1.2 No --- --- 40NOx 161.8 Yes -122.61 39.2 40CO 109.5 Yes -15.15 94.3 100

VOC 38.1 No --- --- 40Lead 0.092 No --- --- 0.6

Fluorides 0.00132 No --- --- 3H2SO4 0 No --- --- 7

H2S 0 No --- --- 10TRS 0 No --- --- 10


(1) Projected emissions associated with the new and modified equipment, for the proposed Project only. (2) Sum of increases and decreases in actual emissions associated with all changes that are contemporaneous with this Project, as described in 40 CFR § 52.21(b)(3). (3) Net emissions increase, as defined in 40 CFR § 52.21(b)(3) (4) As defined in 40 CFR § 52.21(b)(4)

The proposed Project requires a major amendment under Minn. R. 7007.1500, subp. 1(C) and Title V of the Clean Air Act. This is based on emission limitations taken in conjunction with source-wide netting, to avoid being subject to PSD. An initial air permit application was submitted for the proposed Project prior to the July 15, 2008, effective date for inclusion of PM2.5 in PSD analyses. Therefore, PM2.5 is not included in the analysis for PSD applicability. PM2.5 was assessed as part of the analysis to address Cumulative Potential Effects in Question 29 of this document. An air dispersion modeling analysis demonstrated that existing and proposed PM2.5 emission sources will comply with the National Ambient Air Quality Standards (NAAQS) for PM2.5 following the proposed Project. PM2.5 emissions were calculated based on AP-42 emission factors, National Council for Air and Stream Improvement (NCASI) emission factors, permitted and proposed emission and operating limits, stack test data, or a combination of these sources. Documentation of these calculations can be found in the PM2.5 modeling report submitted to MPCA on September 16, 2008, and the ensuing memorandums submitted to MPCA dated January 2009. Table 6 shows the change in facility-wide potential emissions associated with the proposed Project.

Table 6 – Change in Potential Emissions

Pollutant Future Potential Emissions

Current Potential Emissions

Difference EAW/AERA Threshold

(tons/yr) (tons/yr) (tons/yr) (tons/yr) CO 24,331.4 24,658.7 -327.3 250/100

Lead 0.15 0.14 1.0E-02 250/100 NOx 1391.7 1301.1 90.7 250/100 PM 259.4 291.1 -32.5 250/100

PM10 274.3 261.7 12.5 250/100 SO2 5262.0 5260.8 1.2 250/100

VOC 111.1 66.7 44.4 250/100

For a more detailed and in-depth review of the completed emission calculations, reference the Sappi Major Air Permit Amendment Application submitted in June 2008 with subsequent updates on July 11, July 18, July 30, and October 8, 2008; a revised application incorporating all updates was submitted in March 2009. For a discussion regarding GHG emissions associated with the proposed Project, see EAW question 29 – Cumulative Impacts.

Sappi was required to perform air dispersion modeling of all Existing Mill plus proposed Project sources for PM10 and PM2.5. Note that this proposed Project is not subject to PSD permitting requirements and, therefore, modeling was not required for permitting purposes, but rather was completed to satisfy environmental review requirements. The purpose of the modeling was to demonstrate compliance with the applicable Minnesota National Ambient Air Quality Standards (MAAQS) and NAAQS for PM2.5 and PM10 and the PSD Class II Increment Standards for PM10 in support of the environmental review.


The air dispersion modeling analysis used the AMS/EPA Regulatory Modeling with Plume Rise Model Enhancements (AERMOD), version 07026 to estimate concentrations at and around Sappi. The dispersion modeling was completed using surface meteorological data from the Duluth, Minnesota National Weather Service Station (NWS) with upper air data from the St. Cloud, Minnesota NWS station for the years 1986 through 1990. Building downwash was assessed in the modeling analysis using the U.S. Environmental Protection Agency Building Profile Input Program – Plume Rise Model Enhancements (BPIP-PRIME), version 04274. Receptor locations were developed using MPCA guidance. Receptor elevations were determined using the AERMOD Terrain preprocessor (AERMAP), version 06341, and U.S. Geological Survey 7.5-minute resolution digital elevation model (DEM) files. The results of the air dispersion modeling analysis for Sappi sources demonstrate compliance with NAAQS and MAAQS for PM2.5 and PM10. Modeling for Sappi sources also demonstrates compliance with the PSD Class II Increment Standards for PM10. Sappi’s maximum impacts computed by AERMOD for all of Sappi’s sources are presented in Table 7, along with the applicable air quality standards. Results represent Existing Mill plus proposed Project wide impacts. Note also that truck idling is not anticipated to be a significant issue. Tailpipe emissions have been included in the analyses.

Table 7 - Maximum Predicted Sappi Impacts

PM2.5 PM10

Impact 24-Hour Average (μg/m3)

Annual Average (μg/m3)

24-Hour Average (μg/m3)


Sappi Increment-consuming sources - all --- --- 22.65a 1.85b

PSD Class II Increment Standard --- --- 30g 17h

Sappi NAAQS sources - all 13.93c 3.65d 58.31e 10.70f

National Ambient Air Quality Standard 35i 15j 150k 50h Minnesota Ambient Air Quality Standard --- --- 150k 50h

a Concentration represents the maximum high-2nd high from the five one-year model runs b Concentration represents the maximum high-1st high from the five one-year model runs c Concentration represents the maximum high-8th high (98th percentile of 365 days) from the five-year

model run d Concentration represents the maximum high-1st high three-year average from the one five-year model

run e Concentration represents the high-6th high from the one five-year model run f Concentration represents the maximum high-1st high from the one five-year model run g Not to be exceeded more than once per year h Never to be exceeded i Not to be exceeded more than the three-year average of the 98th percentile of 24-hour concentrations j Not to be exceeded more than a three-year annual average k Not to be exceeded more than five times during a five-year period


Greenhouse Gases (GHGs) Introduction This GHG inventory has been developed to provide general information for inclusion in the EAW regarding GHG emissions at the Existing Mill plus proposed Project. Reference Documents There is no mandatory tool required for use in developing a GHG emissions inventory. The most relevant emission calculation tool for the Existing Mill is a series of spreadsheets developed by the NCASI for the American Forest and Paper Association for use by the forest products industry. An additional resource includes The Climate Registry General Reporting Protocol (Version 1.1, May 2008). Both of these resources are based on protocols developed by the World Resources Institute (WRI) and World Business Council on Sustainable Development (WBCSD). The U.S. Department of Energy report, Voluntary Reporting of Greenhouse Gases (Form EIA-1605, October 15, 2007), is also referenced within the NCASI calculation tool for some emission factors. The MPCA has developed the General Guidance for Carbon Footprint Development in Environmental Review (publication p-ear1-07, July 2008). In general, the MPCA Guidance Document follows The Climate Registry methodology. This GHG emissions inventory was prepared using the NCASI calculation tool as the primary resource. The MPCA General Guidance document was also referenced as the inventory was developed to assure that the inventory met the general requirements of the MPCA Guidance. Methodology There are six internationally recognized GHGs. The GHG inventory for Sappi includes estimated emissions of carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O). The other three GHGs (hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride) are not applicable to the Existing Mill as they are not emitted. CO2, CH4 and N2O emissions were converted to Carbon Dioxide Equivalents (CO2e) to account for the global warming potential for each chemical. Emissions were estimated for the Existing Mill plus proposed Project using 2007 as a baseline, as this is the most recent year of compiled and verified operational data. A future projected scenario for the Existing Mill plus proposed Project, was also completed. A comparison can then be made as to the impact of the proposed Project. For additional comparison purposes, the past emissions from 2002 were also estimated for the Existing Mill. The Existing Mill must define its operational boundary for the GHG inventory. The operational boundary is the Existing Mill located at 2201 Avenue B in Cloquet, Minnesota. Within that operational boundary, “Scopes” are typically defined: • Scope 1 – Direct GHG emissions • Scope 2 – Indirect GHG emissions (from the consumption of purchased energy) • Scope 3 – Optional. All other indirect emissions not covered in Scope 2 (e.g., upstream/downstream

emissions from purchased and saleable goods, employee business travel or commuting, etc.)

The relationship of these Scopes is shown in the following figure:

Source: WRI/WBCSD GHG Protocol Corporate Accounting and Reporting Standard (Revised Edition), Chapter 4.

Biogenic sources of CO2 can be included in GHG inventories for biomass combustion in direct sources (either stationary or mobile sources). However, they are required to be kept separate from Scopes 1-3. As stated in The Climate Registry Protocol, “CO2 emissions from biomass combustion are reported separately because the carbon in biomass is of a biogenic origin – meaning that is was recently contained in living organic matter – while the carbon in fossil fuels has been trapped in geologic formations for millennia. Because of this biogenic origin, the Intergovernmental Panel on Climate Change (IPCC) Guidelines for National Greenhouse Gas Inventories requires that CO2 emissions from biomass combustion be reported separately.” It is important to demonstrate the biogenic sources at the Existing Mill, as they are considered carbon neutral. The MPCA General Guidance further supports this, stating “…emissions of CO2 from wood fuel combustion are often treated as zero and are not inventoried.” The Existing Mill has stationary combustion of biomass material (wood/bark chips); therefore, the CO2 emissions were evaluated as biogenic sources. This is provided to acknowledge that energy needs at wood processing facilities utilize biomass fuels recovered from the industry’s waste and process streams, rather than utilizing additional fossil fuels. CH4 and N2O emissions from the combustion of biomass are not considered biogenic, and therefore are accounted for under the Scope 1 direct sources.



Table 8 summarizes the Existing Mill and Existing Mill plus proposed Project sources included in this GHG inventory.

Table 8 –Summary of Sources Included in the GHG Inventory

Scope Sources 2002, 2007 Baseline

(Existing Mill) Future Scenario (Existing

Mill plus proposed Project) Stationary Combustion

On-Site Boilers 7, 8, 9 and 10, Lime Kiln, IQS and Dryers (natural gas, distillate fuel, wood/wood waste, pulping liquids)1

2007 baseline + Boiler 11

Mobile Combustion

On-Site Vehicles (diesel, propane, gasoline)

On-Site Vehicles (diesel, propane, gasoline)

1 – Direct

Waste Management

On-Site Landfill (knots/sludge)

On-Site Landfill (knots/sludge)

2 – Indirect Purchased Electricity

Purchased Electricity from MN Power

Purchased Electricity from MN Power

Biogenic Stationary Combustion

On-Site Boilers – biomass (wood/wood waste, pulping liquids)

On-Site Boilers – biomass (wood/wood waste, pulping liquids)

1 Biomass (wood/wood waste, pulping liquids) is included in Scope 1 for CH4 and N2O emissions. CO2 emissions from biomass are included in the Biogenic Scope.

Estimated GHG Emissions Table 9 presents the Existing Mill’s estimated GHG emissions inventory for historic operations in 2002, the 2007 baseline, and for the future scenario with the proposed Project. Results are presented in metric tonnes (Mtons) of CO2e.

Table 9 – Estimated GHG Emissions Inventory

Scope Sources

2002 Historic

CO2e (Mtons/yr)

2007 Baseline

CO2e (Mtons/yr)

Future w/project

CO2e (Mtons/yr)

2007 Baseline to

Future Difference

CO2e (Mtons/yr)

Stationary Combustion 194,000 104,200 304,400 Mobile Combustion 1,800 1,800 3,600

1 – Direct

Waste Management 3,100 11,600 11,600 Total Direct Scope 1 198,900 117,600 319,600 202,000

2 – Indirect Purchased electricity 6,000 8,700 366,000 Total Indirect Scope 2 6,000 8,700 366,000 357,300

Total Scope 1 and 2 204,900 126,300 685,600 559,300 Biogenic Stationary Combustion 283,700 329,500 388,400

Total Biogenic 283,700 329,500 388,400 58,900

The GHG emission inventory for the Exiting Mill plus proposed Project was calculated to compare the Existing Mill conditions (2007 baseline) to the future conditions with the proposed Project. Overall, the proposed Project is estimated to increase GHG emissions by approximately 559,000 metric tonnes of CO2e. The increase is a worst-case estimate primarily due to operation of a new natural gas-fired package


boiler and an increase in purchased electricity. To counteract these emissions from fossil-fuel derived sources, biogenic CO2 is estimated to increase by approximately 59,000 metric tonnes due to the Existing Mill and proposed Project’s goal to increase biomass combustion. Biogenic emissions demonstrate the importance that combustion of biomass materials has versus the burning of fossil fuels, as they are considered carbon neutral.

Table 10 shows the GHG emissions on a production unit basis (ton of finished product, or TFP), which provides a normalized ratio for comparison purposes. This is presented to demonstrate that the Existing Mill has and will continue to make improvements in its operations to become more efficient with time, thus decreasing the overall footprint of GHG emissions per TFP.

Table 10 –Estimated GHG Emissions per Unit of Finished Product

Total Scope 1 and 2 Estimated GHG Emissions

CO2e Mtons per year 1

CO2e Mtons / ton of finished

product (TFP)

% Reduction on TFP Basis

Compared to 2002

2002 204,900 1.05 ----- 2007 126,300 0.47 55%

Future w/proposed Project 685,600 0.68 35% 1 As shown, the Existing Mill has decreased its ratio of CO2e per TFP by 55 percent between 2002 and 2007. Although the future scenario with the proposed Project increases GHG emissions, the overall reduction of CO2e per TFP from 2002 to the future scenario is 35 percent.

Historical GHG Reductions 2002 – 2007 From 2002 to 2007, the Existing Mill reduced its GHG emissions by 80,000 metric tons of CO2e by using warm water streams to heat cold water streams in the pulp and paper making process, minimizing steam system losses, improving boiler combustion efficiency, increasing biomass combustion, and reducing the combustion of natural gas. Prior to 2002, the Existing Mill gave up its ability to burn coal as part of a pollution control project to reduce emissions of sulfur dioxide. The GHG emission reductions associated with that change are not presented here but are mentioned to provide additional context to projected future emissions. Sources of Energy Biomass-Derived Fuels Sixty-three percent of the fuel used by the wood products industry and 49 percent of the fuel used by the pulp and paper industry is biomass-derived (WBCSD 2005). This is far more than any other major industry. In comparison, the Existing Mill meets 85 percent of its energy demand through the use of renewable fuels. When these biomass fuels are burned, they return carbon to the atmosphere that was only recently (decades) removed from the atmosphere. Fossil fuels put carbon into the atmosphere that has not resided there for millions of years, causing increases in atmospheric CO2 levels. If the forest products industry used fossil fuels to satisfy the energy needs now satisfied by biomass fuels, its emissions would be significantly larger. The approximate magnitude of these avoided emissions can be estimated as follows. On an energy-in-fuel basis, about one-half of the fuel used by the forest products industry is biomass derived. If the energy derived from biomass was obtained instead from fossil fuel, less total fuel in terms of energy content would be required because fossil fuels generally burn more efficiently than biomass fuels (Special Report No. 07-02 19 National Council for Air and Stream Improvement). Assuming that one megajoule (MJ) of fossil fuel produces as much usable energy as 1.25 MJ of biomass fuel, one can


calculate that the industry’s fossil fuel requirements would increase by 80 percent if fossil fuel was used to displace the biomass fuel now used by the industry. It is reasonable to assume that this 80 percent increase in fossil fuel use would result in an 80 percent increase in the industry’s direct emissions. Therefore, the avoided emissions associated with the industry’s use of biomass fuels is approximately 175 million tonnes of CO2 per year. Natural Gas-Fired Package Boiler Natural gas has the lowest carbon intensity of all fossil fuels. The carbon intensity of natural gas is 62 grams of CO2 per megajoule versus 112 for coal (data from www.dft.gov.uk). As has historically been the case, the Existing Mill will continue working to reduce its energy demand through energy conservation and efficiency projects. For example, if after startup and stable operation, it can be shown that the Existing Mill plus proposed Project can operate without the package boiler during all or certain periods of the year based on the facilities steam demand, the GHG footprint for the Existing Mill plus proposed Project will be lower than the estimates shown in Table 8. Purchased Electricity With regard to purchased electricity, Minnesota’s Renewable Energy standard requires Minnesota’s electric utilities to provide 25 percent renewable electricity by 2025 (referred to as 25x’25). Forest Products Industry Carbon Profile (source: NCASI Special Report 07-02) The forest products industry has more complex connections to the climate change issue than any other industry. The industry’s carbon and GHG profile is composed of emissions, sequestration, and avoided emissions. Emissions from the global forest products industry value chain are comprised of direct emissions (~260 million metric tonnes CO2 per year), indirect emissions associated with electricity purchases (~190 million metric tonnes CO2 per year), harvest- and transport-related emissions (~70 million metric tonnes CO2 per year), and methane from discarded forest products in landfills (~250 million metric tonnes CO2 equivalents per year). Carbon is sequestered in managed forests (net increases equivalent to at least 60 million tonnes CO2 per year) and forest products (~540 million tonnes CO2

equivalents per year). Avoided emissions, which further enhance the industry’s global profile, are associated with the industry’s use of biomass fuels (~175 million metric tonnes CO2 avoided per year), combined heat and power (~95 million metric tonnes CO2 avoided per year), recycling (~150 million tonnes CO2 equivalents per year), and product substitution effects (not possible to estimate). The available data demonstrate that the GHG emissions, along the forest products industry value chain, are largely offset by the sequestration accomplished in forest products. The Existing Mill procures wood from sustainably managed forests with Forest Stewardship Council (FSC) and/or Sustainable Forestry Initiative (SFI) certification, which results in carbon sequestration. Conclusions The GHG emission inventory for the Existing Mill plus proposed Project was calculated to compare the Existing Mill conditions (2007 baseline) to the future conditions with the proposed Project. Overall, the proposed Project is estimated to have increased GHG emissions by approximately 559,000 metric tonnes of CO2e. The increase is a worst-case estimate primarily due to operation of a new natural gas-fired package boiler and an increase in purchased electricity. Off-setting these emissions from fossil-fuel derived sources, biogenic CO2 is estimated to increase by approximately 59,000 metric tonnes due to the facilities goals to increase biomass combustion. Biogenic emissions demonstrate the importance that combustion of biomass materials have verses the burning of fossil fuels, as they are considered carbon neutral.


Sappi has taken measures over that past several years to reduce its overall energy consumption and become more efficient in its operations. This is demonstrated by evaluating the metric tons of CO2e on a per TFP basis. In comparing 2002 historic operations to the 2007 baseline, this ratio decreased by 55 percent. And although the future scenario with the proposed Project is estimated to increase GHG emissions, the overall reduction of CO2e on TFP basis from 2002 to the future scenario is still a reduction of 35 percent. The Existing Mill procures wood from sustainably managed forests with FSC and/or SFI certification, which results in carbon sequestration. In addition, carbon is sequestered in the paper products produced. This ongoing carbon sequestration, along with ongoing fossil fuel minimization efforts in combination with the electric utilities efforts to meet the 25x’25 renewable electricity standard is consistent with activities required to meet Minnesota’s statewide GHG emissions reductions goals. Air Emissions Risk Assessment The MPCA has developed an Air Emissions Risk Analysis (AERA) process to provide for: (1) a streamlined health review of facility air emissions; and (2) a consistent format for presenting the quantitative risk estimates, along with qualitative information to provide context to these risk estimates. An AERA estimates cancer and non-cancer risks to human health from a proposed project and/or an existing facility. In general, facility risk guidelines have been developed by the MPCA, in consultation with the Minnesota Department of Health (MDH) that are consistent with U.S. Environmental Protection Agency (EPA) guidance. The guidelines were established such that the chance of a person getting cancer over the course of their lifetime from exposure to the carcinogenic chemicals emitted from a given facility should be less than 1 in 100,000 (1E-05). The facility guideline for non-carcinogenic chemicals is that the sum of the risks (hazard indices) should be less than 1. If emissions from a facility result in estimated risks in excess of these levels, MPCA staff evaluates whether further refinement, future investigation or modifications are warranted. Interested readers can find more detailed information on the air risk analysis process at http://www.pca.state.mn.us/air/aera.html. Sappi used components of the AERA process as well as an EPA risk assessment model to estimate potential cancer risks and non-cancer risks (termed hazard indices) to people in its surrounding community. The analysis assessed risks from pollutants emitted from the proposed Project and from the Existing Mill. Proposed Project A preliminary Risk Analysis Screening Spreadsheet (RASS) was submitted by Sappi to estimate potential health impacts to the surrounding community from the proposed Project. The RASS is a screening tool developed by the MPCA as part of the AERA process. Sappi later conducted a more refined inhalation risk analysis of air emissions from the Existing Mill and an inhalation risk analysis of estimated mill emissions after the proposed project to understand the potential incremental change in risks posed by the proposed project. Multi-pathway risks were not computed for the proposed modification because the associated pollutants are primarily volatile and, therefore, do not deposit to a great degree in the vicinity immediately around the Existing Mill, nor do they persist in the environment long enough for a significant portion to bioaccumulate in the food chain (multi-pathway risks from the total mill before and after the modification are presented in the next section). Potential contributions to the Existing Mill from the proposed Project are summarized in Table 11 below. The incremental risks from the proposed Project will not significantly change the magnitude of the existing risks; in fact, no difference will be seen in risk values from the Existing Mill when the risks from the proposed Project are added.

http://www.pca.state.mn.us/air/aera.html


Table 11

Acute Hazard

Index

Chronic Non-Cancer Hazard

Index Cancer Risk

Change in risk value due to proposed project +0.04 -0.04 + 0.04 in 100,000

The only increases in emissions on an annualized basis are associated with natural gas firing in the new power boiler, and natural gas firing at the new paper machine. Existing boiler 9 is proposed to be equipped with SNCR to decrease NOx emissions. On a short term (hourly) basis there is an increase in paper making capacity (i.e. all 3 paper machines and the market pulp machine could run simultaneously on a short term basis). This could result in a short-term hourly increase in some paper machine pollutant emissions. That potential increase is addressed in the total mill risk analysis. Total Mill Risks: Before and After Proposed Project Modeling for the multi-pathway risk assessment followed recommendations from EPA’s Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities as implemented in the Industrial Risk Assessment Program software developed by Lakes Environmental Software. The information provided in this section represents risks from the Existing Mill. As discussed in the proposed Project section above, risks associated with the proposed Project do not change risk results from the Existing Mill. Risks from several potential exposure pathways were estimated for people living in Cloquet/Scanlon who might be exposed to pollutants in the air and in vegetables grown in their gardens. Risks from eating fish from nearby fishable water bodies were also evaluated, as were potential risks to farmers in the vicinity from exposure to pollutants through ingestion of home-grown meat and dairy products. Refined air dispersion modeling was performed for the risk assessment based on potential air emissions associated with the proposed Project and with the Existing Mill. Modeled risks are presented in Table 12 below.

Table 12

Total Inhalation Hazard Indices and Cancer Risks

Total Indirect Pathway Hazard Indices and Cancer

Risks

Total Multipathway Hazard Indices and

Cancer Risks

Acute Chronic Noncancer Cancer Noncancer Cancer Noncancer Cancer

Farmer (maximum risks in area zoned for agricultural use (2) ) Not

Avail (1) 0.8 5E-07 0.004 8E-06 (2) 0.8 9E-06

Resident (max risks in locations zoned for residential use)

1 1 9E-07 0.0007 3E-07 1 1E-06

Fisher (max resident risks plus risk from eating significant amounts of fish from St. Louis River and Thomson Reservoir)

1 1 9E-07 0.4 2E-05 1 (inh) (3)

0.4 (ing) 2E-05


(1) The maximum hourly hazard index was not computed at the farmer location; it will, however, be less than the hazard index estimated for the residential scenario, which is approximately one.

(2) Farmer ingestion risk does not include milk consumption from dairy cows (see Farmer Risk discussion below).

(3) The inhalation and ingestion hazard indices (HI) are not additive in this case since the toxic endpoints differ with the exposure pathways. The inhalation HI is 1 for respiratory effects and the ingestion HI is 0.4 for developmental neuropsychological impairment (methylmercury).

Farmer The farming scenario was evaluated in areas north of the Existing Mill where farming currently occurs and where it could potentially occur in the future. This scenario assumes than an individual gets some fraction of their food supply from the impacted area. The maximum farmer cancer risks fall in a location just north of the Sappi northeast boundary. There is not currently a farmstead at that location. The maximum excess lifetime cancer risk at that location is estimated to be approximately 3E-05, which is above the MDH/MPCA facility risk guideline of 1E-05. A closer analysis of the area north of the Existing Mill shows that several farms would fall in an area where estimated cancer risks would be above the 1E-05 guideline. Home-bred beef and consumption of milk from home-bred cows are the primary exposure pathways that would result in risks at this level; approximately 75 percent of the estimated cancer risk is attributable to milk consumption. According to the University of Minnesota Extension Service, there are two beef operations that house their cattle in this general geographic area. There are currently no pigs, dairy cows, or sheep housed routinely as a farm business in the area, although it is possible this type of business could occur in the future since it is not prohibited by zoning laws. Subtracting the milk consumption pathway from the maximum cancer risk because there are currently no dairies in the area yields a maximum farmer cancer risk of approximately 8E-06, which is below the facility risk guideline of 1E-05. Estimated noncancer risks to farmers are less than the guideline of 1. Town Residents Potential risks to people living in the Cloquet/Scanlon residential areas associated with exposure to air pollutants from the Existing Mill by way of inhalation and home-grown vegetable consumption were also estimated using risk and air dispersion modeling tools. Based on modeling results, the approximate location of maximum residential risk in areas where development has and could occur in Cloquet and Scanlon would be a point on the Sappi boundary. The inhalation non-cancer chronic hazard index is estimated at 2.5 at that location. This area is zoned for commercial and industrial use. Closer analysis showed that the Cloquet/Scanlon areas with a potential hazard index greater than 1 are for the most part zoned for commercial/industrial land use. The maximum hazard index in residentially-zoned locations is approximately at 1. Acute and sub-chronic residential hazard indices and estimated cancer risks in the residential areas of Cloquet/Scanlon are also estimated to be less than risk guidelines from inhalation and home-grown vegetable consumption. Fishers If Cloquet/Scanlon residents routinely consumed fish caught in the St. Louis River and Thomson Reservoir, the estimated excess lifetime cancer risk would be approximately 2 in 100,000 (2E-05). The assumption underlying this risk level was that the fishers would eat about a half-pound of fish four to five times per week. The MDH/MPCA lifetime cancer risk guideline is for facility emissions to result in risks no greater than one in 100,000 (1E-05). The non-cancer hazard index associated with consuming fish (at the same rate) from the St. Louis River and Thomson Reservoir is estimated to be about 0.4, which is less than the MDH/MPCA guideline of 1 for facilities.


24. Odors, noise and dust. Will the project generate odors, noise or dust during construction or during

operation? Yes No

If yes, describe sources, characteristics, duration, quantities or intensity and any proposed measures to mitigate adverse impacts. Also identify locations of nearby sensitive receptors and estimate impacts on them. Discuss potential impacts on human health or quality of life. (Note: fugitive dust generated by operations may be discussed at item 23 instead of here.) Odors Odor impacts from the Existing Mill are predominantly related to the pulping operations. The Existing Mill is not affected by the proposed Project and, therefore, odors from the Existing Mill plus proposed Project will not change from current conditions. Noise Noise will be generated by the proposed Project during construction and operation. Noise during construction will be temporary. This noise will include clearing equipment and construction equipment, including haul trucks. The construction of the proposed Project is anticipated to take approximately 18 to 24 months to complete. The noise generated by the proposed Project during operation will be similar to the Existing Mill noise with the addition of potential noise impacts generated by operations of the wood yard in a new location. The wood yard will be moved south of the Existing Mill across Avenue B in a primarily residential area. This will create the potential for noise impacts to nearby residences. Possible mitigation measures being considered include the following: • When feasible, maintain a pile of wood on the west side of the yard to provide sound barrier for

residents across the street. • Limiting typical operating hours to daylight hours. Noise levels from the Existing Mill plus proposed Project will comply with Minnesota rules and standards. Current noise standards provided for the state of Minnesota are described in Minn. R. 7030.0040, subp. 2. The rules describe permissible noise levels according to noise area classification, such as residential areas compared to industrial areas. The rules also distinguish between nighttime and daytime noise. For example, the most restrictive noise levels are in residential areas during the nighttime, whereas the least restrictive noise levels are in industrial areas. Noise standards are measured in decibels (dB(A)) and sound levels exceeded for 10 and 50 percent of the time in a one-hour survey (L10 and L50) for each noise area classification. The proposed Project will take place within the footprint of the Existing Mill and as a result overall noise related impacts beyond the noise associated with the current operations at the Existing Mill plus proposed Project are not anticipated. Dust Dust will be generated during construction. Dust emissions from operations will be evaluated as part of the Air Permitting process (described in response to Question 23). A preliminary list of potential sources and measures that can be taken to mitigate adverse impacts include:


Construction of the proposed Project will include removal of existing railroad spurs, construction of local buildings, paving of roadways, and utility upgrades as necessary (Table 13). This will generate dust typical of large construction projects for an 18 to 24-month period. Construction-related dust impacts are not expected to be significant or sustained.

Table 13 – Potential Dust Sources and Measures to Mitigate Adverse Impacts

Potential Dust Source Measures to Mitigate Adverse Impacts Earth moving for preparation proposed Project site

Compaction, water spraying of haul roads, minimizing of open areas, rapid revegetation of disturbed areas

Construction traffic Dust suppressant application (water or chemical) Truck loading and haul truck traffic associated with transfer of process materials

Roads will be paved/impervious as part of construction of the proposed Project

Existing Mill plus proposed Project operation

Discussed previously under Question 23

On-site traffic Paving of \roadways, use of dust suppressants as needed

Roadways at the Existing Mill will be paved as part of the proposed Project. This is expected to result in less overall impact from fugitive dust at the Exiting Mill plus proposed Project. Due to the proximity to residential areas, dust control will also be implemented at the new wood storage yard. Section 23 provides additional detail about stationary source air emissions, including fugitive dust and potential dust during operations.

25. Nearby resources. Are any of the following resources on or in proximity to the site? a. Archaeological, historical, or architectural resources? Yes No b. Prime or unique farmlands or land within an agricultural preserve? Yes No c. Designated parks, recreation areas, or trails? Yes No d. Scenic views and vistas? Yes No e. Other unique resources? Yes No If yes, describe the resource and identify any project-related impacts on the resources. Describe any

measures to minimize or avoid adverse impacts.

The Minnesota State Historic Preservation Office searched their Minnesota Archaeological Inventory and Historic Structures Inventory databases for the proposed Project site vicinity. The database search returned no records of known archaeological sites within the proposed Project vicinity (Attachment 2). The database search returned a total of 15 historical properties located within one mile of the proposed Project. The listed historical properties include several residential buildings, fire shacks, and two saw mill sites. The proposed Project will take place within the foot print of the Existing Mill and none of the 15 historical properties are located within the Existing Mill plus proposed Project footprint. No impacts to the existing conditions of historic structures or properties are anticipated as a result of the proposed Project. Jay Cooke State Park is located approximately five miles to the southeast of the city of Cloquet and the proposed Project site. Facilities and activities at the park include campgrounds, picnic areas, trails for hiking, biking, horseback riding, and cross country skiing, as well as access points to the St. Louis River for trout fishing and canoeing. The Willard Munger State Trail stretches for 70 miles from Hinckley to Duluth, passing


through Jay Cooke State Park. The entire 70-mile stretch of trail is paved, making it the longest paved trail in the world. The trail provides hiking, biking, horseback riding, and snowmobiling opportunities. The proposed Project will take place within the footprint of the existing industrial pulping and paper processing operation. No impacts to the existing conditions of Jay Cooke State Park or the Willard Munger State Trail are anticipated as a result of the proposed Project.

The St. Louis River borders the proposed Project site to the north and east. The DNR has designated approximately 78 miles of the St. Louis River as a state canoe and kayak route. However, the proposed Project site lies along the banks of the St. Louis River between the Knife Falls dam at river mile 35.5 and the Cloquet dam at river mile 34.5. Along this stretch of river, there are no public access points to the river and there are no portage trails at either dam. This stretch of river adjacent to the proposed Project site is not influenced by the activities at the Existing Mill plus proposed Project and will not change the existing conditions in terms of public access to the canoe route. Therefore, impacts to the state canoe route as a result of the proposed Project are not anticipated.

26. Visual impacts. Will the project create adverse visual impacts during construction or operation? Such as glare from intense lights, lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks? Yes No If yes, explain. The construction of the new paper machine complex will take place within the Existing Mill site and will cover approximately 620,000 square feet with a maximum building height of approximately 93 feet. The construction of the new package boiler and the new paper machine will include the addition of emission stacks. The new package boiler emission stack is proposed to be 125 feet in height. The proposed Project will be similar in appearance to the Existing Mill. As a result, significant visual impacts as a result of the proposed Project are not anticipated. The wood storage yard will be relocated from the Existing Mill site across Avenue B to the former tree nursery site. Round wood is stored at the existing wood yard with wood stack heights averaging 20 feet. The Existing Mill plus proposed Project will operate with less round wood stored on site. The total quantity of round wood stored at the site is anticipated to decrease from the existing 100,000 to 16,000 cords. The new wood storage yard is located along Scanlon Way (SR 45), which serves as the south eastern entrance to the city of Cloquet. Sappi will coordinate with the city of Cloquet to determine an acceptable solution for mitigating visual impacts from the new wood storage area on the adjacent neighborhoods and roadways. Considerations in the design of the new wood storage yard to lessen visual impacts include the following: • Limit round wood pile heights to a maximum of 25 feet • For wood storage piles, maintain a 25-foot setback from sidewalks and roadways • Use of vegetative screening around perimeter of wood yard • Use of perimeter berms to provide visual screening as well as increase height of vegetative screen • Install perimeter fencing to provide screening and prevent public access The final design of the new wood storage yard will include a combination of the above mentioned mitigation measures to lessen visual impacts as a result of the proposed Project.


27. Compatibility with plans and land use regulations. Is the project subject to an adopted local

comprehensive plan, land use plan or regulation, or other applicable land use, water, or resource management plan of a local, regional, state or federal agency? Yes No

If yes, describe the plan, discuss its compatibility with the project and explain how any conflicts will be resolved. If no, explain. The proposed Project site is located within the limits of the city of Cloquet, and as such the proposed Project is subject to the zoning and planning requirements of the City. The proposed construction of the new paper machine complex and the new paper finishing, converting and shipping complex will take place on the Existing Mill, which is zoned heavy industrial (zoning district I-2). The former tree nursery site currently exists as a vacant grassy area immediately to the south of the Existing Mill site. The proposed Project will convert the former nursery area to a new wood storage yard. The former tree nursery area also lies within the I-2, heavy industrial district. The proposed Project activities are compatible with the current zoned uses of the city of Cloquet, and the proposed Project will not require zoning or land use variances or exemptions be granted from the City.

28. Impact on infrastructure and public services. Will new or expanded utilities, roads, other infrastructure or public services be required to serve the project? Yes No If yes, describe the new or additional infrastructure or services needed. (Note: any infrastructure that is a connected action with respect to the project must be assessed in the EAW; see EAW Guidelines for details.) There are existing natural gas, electricity, water, and wastewater utility lines present at the Existing Mill. An additional 41 MW hours of electricity will need to be purchased from Minnesota Power to operate the Existing Mill plus proposed Project. Minnesota Power has indicated that they have sufficient capacity available for Sappi to purchase in order to supply the additional electricity needed by the proposed Project. There is an existing electrical substation regulating electricity at the Existing Mill. The additional electricity necessary to operate the proposed Project will require the installation of a second substation on site adjacent to the new paper machine complex. The city of Cloquet has a 54-inch stormwater pipe located at the proposed Project site. The stormwater pipe is constructed under the existing wood storage and rail yard, and runs the width of the proposed Project site, before discharging into the St. Louis River. The new papermaking building will be constructed in the area that is currently wood storage and rail yard. The City’s stormwater pipe will need to be relocated in order to accommodate potential future maintenance or other activities that would require the ability to access the pipe. The stormwater pipe route will be west of the proposed Project area away from the area directly impacted by construction. The stormwater pipe will continue to discharge into the St. Louis River. There will be impacts to local roads from additional haul truck and other traffic traveling to and from the Existing Mill plus proposed Project. Impacts associated with transportation and traffic are discussed in Section 21 – Traffic.


29. Cumulative impacts. Minn. R. 4410.1700, subp. 7, item B requires that the RGU consider the

“cumulative potential effects of related or anticipated future projects” when determining the need for an environmental impact statement. Identify any past, present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative impacts. Describe the nature of the cumulative impacts and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to cumulative impacts (or discuss each cumulative impact under appropriate item(s) elsewhere on this form). Cumulative impacts include those caused by the addition of the proposed Project to past, present, and reasonably foreseeable future activities. Sappi is not currently planning any actions in connection with the proposed Project that have not been addressed in this evaluation. Discussions were held by Sappi with the city of Cloquet and Carlton County to determine if any new industries were planned in the area. City and county staff indicated that they did not know of any industries planned for the area. The following is a summary of the issues included in the overall cumulative effect analysis. Air Quality Cumulative potential effects to air quality from this proposed Project and from nearby current and known future projects were evaluated in the air dispersion modeling analysis. Emissions from the Existing Mill and from nearby PM10 sources were included in the modeling analysis. The MPCA provided refined nearby source information for nearby sources - Jarden Home Brands and USG, Inc., which are both located in Cloquet. The MPCA also indicated which of the sources at Jarden Home Brands and USG, Inc. consume PM10 increment. In addition to refined sources, the MPCA also provided First-Approximation Regional nearby sources for the Facility-Wide Emission (FWE) sources and the County-Wide Emission (CWE) sources. FWE sources are included to address potential impacts from facilities outside of Cloquet. CWE sources are non-facility emissions in the Cloquet area such as mobile sources, residential heating, etc. Nearby PM2.5 sources were not included in the modeling analysis because PM2.5 emission rates for Jarden Home Brands, USG, Inc., FWE sources, and CWE sources are not available. Instead, a conservative PM2.5 background concentration was developed with MPCA assistance to account for the lack of information regarding specific nearby sources. The results of the air dispersion modeling analysis for all sources demonstrate compliance with NAAQS and MAAQS for PM2.5 and PM10. Modeling for all increment-consuming sources also demonstrates compliance with the PSD Class II Increment Standards for PM10. The maximum impacts computed by AERMOD for all sources are presented in Table 14, along with the applicable air quality standards. Table 14 also includes background concentrations developed according to MPCA guidance and monitoring data. This addresses any remaining impacts not included in the nearby source and FWE and CWE analyses. Based on the air quality modeling analysis for the proposed Project, the Existing Mill plus proposed Project will comply with the applicable air quality standards and is not expected to contribute to an adverse cumulative potential air quality effect.


Table 14 – Maximum Predicted Total Impacts PM2.5 PM10

Impact 24-Hour Average (μg/m3)


24-Hour Average (μg/m3)


Total Increment-consuming sources --- --- 23.66a 1.26b

PSD Class II Increment Standard --- --- 30g 17h

Total NAAQS sourcesl 13.93c 3.65d 99.55e 22.63f

Background Concentration 20.70 6.36 10 5 Total Predicted Impact 34.63 10.01 109.55 27.63 National Ambient Air Quality Standard 35i 15j 150k 50h Minnesota Ambient Air Quality Standard --- --- 150k 50h

a Concentration represents the maximum high-2nd high from the five one-year model runs b Concentration represents the maximum high-1st high from the five one-year model runs c Concentration represents the maximum high-8th high (98th percentile of 365 days) from the five-year model

run d Concentration represents the maximum high-1st high three-year average from the one five-year model run e Concentration represents the high-6th high from the one five-year model run f Concentration represents the maximum high-1st high from the one five-year model run g Not to be exceeded more than once per year h Never to be exceeded i Not to be exceeded more than the three-year average of the 98th percentile of 24-hour concentrations j Not to be exceeded more than a three-year annual average k Not to be exceeded more than five times during a five-year period l Includes nearby and FWE and CWE sources for PM10 – not available for PM2.5. See prior discussion.

Air Toxics or Non-Criteria Pollutants To form a more complete picture of risks from exposure to outside air pollution to people in the vicinity of the Sappi Mill, additional air emissions sources should be considered. Other sources might include industrial facilities, traffic, gas stations, wood-burning stoves, etc. Information on ‘background’ levels of air pollutants can be obtained from air monitoring data collected in a community with a similar population density, mix of residential and commercial land use and roadways. Monitoring data from Duluth are presented in Table 15 below in terms of risk. This data also reflects more distant emissions sources that contribute to a regional level of pollutants that have been detected at similar levels across the northern part of Minnesota. Potential risks to nearby residents and farmers from the existing Sappi mill and the proposed project are again presented in Table 15. For details on the assumed Sappi mill exposure scenarios, see the Air Emissions Risk Assessment discussion in Section 23. The noncancer hazard indices reported in Table 15 associated with air monitoring data reflect only the respiratory portions of the total background hazard index values since the inhalation noncancer hazard indices related to potential Sappi emissions are based on respiratory system effects. It is standard risk assessment practice that only those pollutant-specific non-carcinogenic hazard quotients be added together that would impact the same human systems or organs, e.g., liver or respiratory system. For potentially carcinogenic pollutants, it is standard risk assessment practice for estimated cancer risks to be added together regardless of tumor location or type.


Table 15 - Sappi Mill and ‘Background’ Risk Results

Cancer Risk Chronic Non-cancer Hazard Index

Acute Hazard Index

Sappi – Existing mill plus proposed project (1)

Farmer 8E-06 0.8 < 1 (3)

Resident 1E-06 1

(inhalation, respiratory effects)

1 (respiratory)

Fisher 2E-05 1 (inhalation) 0.4 (fish ingestion)

1 (respiratory)

Ambient Monitoring (2)

Pop. density 500-2000 per sq. mi. (Duluth)

4E-05 0.8 (respiratory)

0.6 (respiratory)

(1) Reported risks are from existing mill. As noted in question 23, existing mill risks do not change significantly with the proposed Project. Chronic risks are at point of maximum predicted air concentrations in areas zoned for indicated land use. Acute risk is at maximum hourly concentration predicted in residentially zoned area in Cloquet. (2) Monitored background values are the estimated risks based on historical measured concentrations of pollutants in ambient air. These values are calculated using representative data from the MPCA’s ambient monitoring network. (3) The maximum hourly hazard index was not computed at the farmer location; it will, however, be less than the hazard index estimated for the residential scenario, which is approximately 1. Mercury fish tissue data are also available with which ‘background’ non-cancer hazard quotients can be estimated for people who might eat a significant amount of fish caught from the three lakes evaluated in the risk assessment. Similar fish tissue data are not available to estimate background levels of cancer risk. Background methyl-mercury (the form of mercury found in fish) hazard quotients as well as methyl-mercury hazard quotients that could be related to future Sappi mill mercury emissions are provided in Table 16. The existing facility as currently permitted is allowed to emit approximately 43 lbs/year mercury. The proposed Project will add approximately 0.3 pounds per year of mercury. However, in conjunction with the proposed Project, additional mercury limits are being imposed on three existing sources, reducing allowed mercury emissions from those three sources by approximately 19 pounds per year. Thus, the allowed facility-wide mercury emissions after the proposed Project is completed will be approximately 23.4 pounds per year.


Table 16 - Fish Ingestion Hazard Quotients Sappi Mill and ‘Background’ Thomson

Reservoir/St Louis River

Chub Lake Pat Martin Lake

Sappi Mill 0.4 0.02 0.2 Background 10 5 14

Total 10 5 14

Approximate % contribution to background from Sappi mill

4% 0.4% 1%

Water Quality Surface Water/Stormwater Stormwater at the Existing Mill is currently directed to the St. Louis River. There is an existing SWPPP in place to oversee stormwater management at the Existing Mill plus proposed Project. As described under item 17a, the SWPPP will be updated to manage stormwater at the proposed Project. Additional impervious surfaces will be generated from the construction of the proposed Project. The stormwater detention ponds will provide treatment and control of stormwater discharges. The stormwater ponds have been designed to ensure that post-construction peak flows are less than or equal to pre-construction peak flows. The city of Cloquet is currently in the process of being designated as an MS4, under which it will be required to follow the guidelines detailed in the NPDES General Stormwater Permit. Upon implementation of the City MS4 Permit, additional stormwater BMPs and monitoring of stormwater quality may be required at the Existing Mill plus proposed Project. With the addition of the proposed stormwater detention ponds, the BMPs in the updated SWPPP for the proposed Project and Sappi’s coordination with city of Cloquet on potential stormwater management requirements outlined in the MS4 plan, the overall stormwater quality and quantity at the proposed Project will be equal to or improved compared to existing conditions. No significant cumulative impacts to local stormwater management or downstream receiving waters are expected as a result of the proposed Project. Wastewater Wastewater from the Existing Mill is currently sent to the WLSSD wastewater treatment plant located in the city of Duluth. The WLSSD treatment plant treats wastewater effluent from an approximately 500-square mile region around Duluth, Minnesota that includes the cities of Duluth, Cloquet, Hermantown, Proctor, Carlton, Scanlon, Thomson, and Wrenshall and the surrounding townships. Approximately half of the wastewater treated at WLSSD comes from industrial users with the remaining water from homes and businesses. Wastewater is transported through a 73-mile network of interceptors and forcemain sanitary sewers to the wastewater treatment plant in Duluth.


The discharge of wastewater effluent from the Existing Mill to the WLSSD wastewater treatment plant is governed by an Industrial Wastewater Treatment Permit (Permit No. 007) that requires Sappi to pre-treat and monitor their wastewater before discharging to WLSSD. Further detail on wastewater is provided under Item 18 – Water Quality-Wastewater. Wastewater flows will increase as a result of the proposed Project. However, the existing pre-treatment process of wastewater at the Existing Mill has the capacity to treat the increase and the process will not be altered as a result of the proposed Project. The only change will be an increase in the total volume of water pre-treated by Sappi and discharged to the WLSSD plant. The WLSSD plant has the capacity to treat the additional wastewater effluent, in terms of BOD, TSS, and total flow volume, which would be created by the proposed Project without altering their existing wastewater process or their existing discharge permit. The increase in treatment volume of water from the pre-treatment process will result in an increase of residual sludge. Sappi will continue to burn the sludge on site to the maximum extent allowable, up to the permitted amount of 38,200 tons per year. The remaining sludge will be placed in Sappi’s permitted landfill. The goal is to burn all of the residual sludge (or preferably find some other beneficial use), with no sludge sent to the landfill. As a result of the absence of changes to Sappi’s pre-treatment of wastewater on site, disposal of residual sludge or of WLSSD treatment plant operations or permitted capacity, no cumulative impacts due to wastewater flows are anticipated as a result of the proposed Project. Water Appropriation The Existing Mill uses two sources of water for pulp and papermaking: the St. Louis River and Lake Superior. Further detail on water use is provided in Item 13 – Water Use. The water used for the proposed Project will be purchased from the city of Cloquet, which pumps water primarily from Lake Superior with some water pumped from several city groundwater wells. Water for the proposed Project will also come from the St. Louis River. The water for the proposed Project will be used as process water for papermaking, cooling, and eventually wastewater. Water used in the papermaking process ends up as wastewater that is pretreated at Sappi and then piped to WLSSD. Once further treatment is complete at WLSSD, the water is put back into the St. Louis Bay, which eventually flows into Lake Superior. There is little water lost between the papermaking process and the final end result of treated water going back into Lake Superior. Further detail on wastewater treatment is described in Item 18 – Water Quality-Wastewater.

Lake Superior is the primary source of water for not only the city of Cloquet, but also the Duluth Metropolitan Area and the city of Superior, Wisconsin. The city of Cloquet has a DNR Water Appropriation Permit to pump up to 3,900 million gallons (MG) per year from Lake Superior. In 2007, it pumped 3,950 MG from the Lake. The city of Duluth has a DNR Water Appropriation Permit to pump up to 9,000 MG per year from the Lake. In 2007, the Duluth pumped about 6,300 MG from Lake Superior, and like Cloquet, also has several city groundwater wells. The city of Superior is permitted to pump up to 3,000 MG per year from the Lake. In 2007, Superior pumped 1,205 MG (see the table below for a summary of this information).


Table 17 - Minnesota DNR Water Appropriation Permits Water Permittee Permitted

(MG/Yr) Pumped in 2007 (MG)

Source

Sappi Cloquet, LLC 3,829 1,547 St. Louis River City of Cloquet 3,900 3,950 Lake Superior City of Duluth 9,000 6,334 Lake Superior Superior Water, Light, and Power (City of Superior, Wisconsin)

3,000 1,205 Lake Superior

Source: Minnesota DNR Water Appropriation Index – August 26, 2008 The proposed Project would increase Sappi’s water from 16.22 MG per day to 17.90 MG per day, but will also increase Sappi’s water use efficiency by 59 percent on gallons of water used per ton of paper basis. The Proposed Project will require the city of Cloquet to amend its DNR Water Appropriation Permit for an additional 2 MG per day, or 730 MG per year. The additional water from Lake Superior that would be requested for the proposed Project is 0.01 percent of the current major appropriations within the proposed Project vicinity. Given that the majority of the water used in the papermaking process is eventually returned to the source water Lake Superior via the St. Louis Bay, this increase in water appropriation from Lake Superior for the proposed Project does not pose a significant impact to the water volume of the either water body. Traffic Traffic within the city of Cloquet will increase as a result of the proposed Project. The proposed Project will result in an increase of 484 weekday daily trips, with the majority of these trips occurring between 5:30 a.m. and 5:30 p.m. The majority of the volume increase associated with the proposed Project will be a shift of traffic from Avenue B to 18th Street. A traffic impacts analysis was conducted for the proposed Project. The analysis determined that all of the intersections in the proposed Project area have adequate capacity with their existing alignments to adequately accommodate the increased traffic resulting from the proposed Project. However, due to the new traffic pattern generated at the intersection of Avenue B and 18th Street, it was recommended that this intersection be controlled by an all-way stop. Sappi is working with the city of Cloquet to add all-way stop control to this intersection. No significant cumulative impacts to regarding local or regional traffic patterns are expected as a result of the proposed Project. Timber Harvesting Timber used in the pulp and paper making process at the Existing Mill is purchased from a variety of sources, including those based in Minnesota, Wisconsin, Michigan, and Canada. Harvested round wood timber is directed to the pulp making process at the Existing Mill. Sappi has undergone significant efforts over the last several years to ensure that the timber purchased for producing pulp is from sustainable sources. Sappi has undergone chain-of-custody audits for sustainable wood certification from three separate organizations: the Forest Stewardship Council, the Sustainable Forestry Initiative, and the Program for the Endorsement of Forest Certification. Sappi has passed audits and received certification from all three organizations. By procuring wood for responsibly managed, sustainable forest sources, Sappi has ensured that its environmental impacts on the forests in Minnesota and other states is minimized to the maximum extent possible.

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