Management of Waste Streams The proposed Project will be based on a Kraft pulping process and will apply technologies and practices that are consistent with Good International Industry Practice (GIIP) to minimize the generation of waste streams (i.e. solid waste, effluents, air emissions (including odors), noise/vibration) and their discharges to the environment as described below. Solid Wastes - The Project will initially generate construction related solid wastes consisting primarily of wood and metal scrap, miscellaneous wastes from cafeterias and offices, and sanitary waste and sludge from portable toilets and onsite wastewater treatment facilities. During the operational phase, the proposed Project will generate significant quantities of solid wastes from the manufacturing process, including wastes from wood handling operations, dregs and grits from the causticizer, lime mud, biomass boiler ashes, empty chemical containers, and sludge from water and wastewater treatment processes. Non-process solid wastes will include packaging paper and cardboard, plastics, metallic scrap, fluorescent lamps and batteries, and miscellaneous wastes from mechanical maintenance shops and plant maintenance (including used oil, glass, tires etc.), cafeteria services, and medical services. Solid wastes will be managed according to the Sponsor?s corporate procedures and Brazilian requirements during both the construction and operational phases. Wastes will be segregated by classification into hazardous and non-hazardous / recyclable and non-recyclable, stored and disposed of where applicable. Klabin?s corporate environmental management programs include detailed procedures for the selection and monitoring of waste management contractors providing transport, treatment, and disposal services. Organic wastes from manufacturing processes, cafeterias, and sludge will be used to produce compost that will be sent back to forest planting locations. The Project site will include a 15 ha composting area built with surface drainage and a clay layer. Wood wastes will be burned into biomass boiler and ash, lime mud, and dregs/grits from the causticizer also will be sold as soil amendment (i.e. to reduce soil acidity and may also provide macronutrients such as phosphorus, potassium, calcium, and magnesium), under the authorization and supervision of Brazilian agricultural authorities. Paper, cardboard, plastic, metal scraps, glass, tires, and lubricant oil will be recycled by authorized contractors. The Project will include the construction of an on-site landfill dedicated to plant operations. The landfill will be constructed for the disposal of Class IIA (non-hazardous, non-inert solid wastes in accordance with Brazilian Technical Norm ABNT NBT 10.004). Only those wastes that cannot be recycled will be disposed at the landfill. These wastes may include the sludge from the water treatment plant and from the wastewater treatment plant (WWTP) tertiary treatment. The landfill design will include 50 cm compacted soil layer, overlain by a membrane of high-density polyethylene. It will include a leachate monitoring system to detect potential leaks to the environment, and a leachate collection system. Leachate will be collected and transported to the on-site WWTP for treatment. Wastewater ? The Project will include process measures to reduce organic loads in effluents during the pulping process which include: Washing of the brown stock before the delignification; Oxygen delignification before the bleaching; Use of elemental chlorine free (ECF) bleaching with chlorine dioxide; Collection and recycling of spent cooking liquors; and Stripping and reuse of evaporation and digester condensates. In addition, to prevent chemicals or untreated effluents from being discharged to the environment, the design of the Project include an emergency pond, which will store effluents that do not comply with the specified quality. The Project will have online monitoring of pH, temperature and conductivity. If the online monitoring detects values outside of the specifications, control valves will close and the effluent will be directed to the emergency pond. This pond will have a storage capacity of 100,000 m3 and would allow the pulp mill to operate for approximately 14 hours. The Project will include the construction and operation of a wastewater treatment plant (WWTP) that will operate continuously and will include primary, secondary and tertiary treatments prior to the discharge of treated effluents to the Tibagi River via three underwater pipes with diffusers. The various treatments aim at the removal of solids, organic load, phosphorus, nitrogen, chemical oxygen demand (COD) and color. The Project will generate approximately 7,000 m3/h of effluent. The WWTP is being designed to meet the following discharge limits: WWTP Design Levels Parameter Units Predicted Value IPPC BREF (2001) WBG EHS Guidelines Process water flow m3/ADt 29-32 30-50 50 pH 6 ? 8 6-9 TSS kg/ADt 0.706 1.5 COD kg/ADt 5.645 8-23 20 BOD5 kg/ADt 0.353 0.3-1.5 1 AOX kg/ADt 0.071 <0.25 0.25 Total N kg/ADt 0.106 0.1-0.25 0.2 Total P kg/ADt 0.007 0.01-0.03 0.03 Notes: m3/ADt ? cubic meters per 1,000 kg of air dry pulp; kg/ADt ? kilograms of pollutant per 1,000 kg of air dry pulp; TSS ? Total Suspended Solids; COD- chemical oxygen demand; BOD ? Biological oxygen demand; AOX ? Chlorinated organic substance; N ? nitrogen; and P ? phosphorous; IPPC BREF ? European Union Integrated Pollution Prevention and Control Best Available Technique Reference Document (2001); WBG EHS ? World Bank Group Environmental Health and Safety Guidelines. As part of the Project effluent quality monitoring program, untreated and treated effluents will be monitored to assess the efficiency of the WWTP and to ensure compliance with Brazilian standards. Effluent flow, pH, conductivity, and temperature will be monitored online. COD, suspended solids and settable solids and color will be measured on a daily basis. Biological oxygen demand (BOD) will be measured twice a week (at least). Total phosphorus and total nitrogen, oil and grease will be measured on a monthly basis. Heavy metals, sulfates, sulfides, chlorides, phenols, sodium, calcium and iron will be measured on a yearly basis. This monitoring program will begin at start of operations and will be conducted for the life of the Project. The Project proposes to use three underwater discharge pipes with 33 diffusers. Based on preliminary simulations for wastewater discharge scenarios considering the Tibagi River?s average and low-flow conditions, project discharges will not have a significant impact on the quality of the receiving water which is presently categorized as a Class 2 water body (water suitable for human consumption following treatment) per Brazilian regulations. The Sponsor has updated the dispersion modeling including simulations for Dissolved Oxygen, BOD, QOD, phosphorus and nitrogen, and in both scenarios of lowest river flow (Q7,10) and average flow was concluded that the the concentrations went back to same upstream level before reaching the water reservoir area and that river has self-depuration capacity to assimilate the wastewater discharge . Atmospheric Emissions - The Project will employ chemical recovery processes to reclaim spent cooking chemicals used in the pulping process. Black liquor will be concentrated in multi-effect evaporators to 80% by dry solids before it is incinerated in the plant?s recovery boiler, as a measure to reduce sulfur emissions. Stripper systems will be used to treat the condensates generated during the evaporation of the black liquor. Methanol from the strippers will be removed in the methanol column and incinerated in the recovery boiler. Diluted and concentrated non-condensable gases from cooking, evaporation, foul condensate tank and methanol handling will be collected and incinerated in the recovery boiler. Gases from the dissolving tanks will be washed and injected in the recovery boiler. Combustion gases will be treated with high-efficiency electrostatic precipitators to control PM emissions. The biomass boiler will use pinus and/or eucalyptus bark and will consist of fluidized bed technology. Combustion gases will be treated with electrostatic precipitator to control the emissions of PM. The two lime kilns will be feed by loading and transportation systems that include dust removal technology. The lime kilns will use predominantly oil as fuel, but will also be able to burn turpentine, methanol, tail oil and hydrogen as auxiliary fuels. Lime kilns will have electrostatic precipitators to control the emissions of particulates. Optimum operating conditions will be monitored online to guarantee best results in the air emissions released to the environment. The Project will have online monitoring of temperature, flow, pressure, humidity, excess oxygen, total reduced sulfur (TRS) and carbon monoxide. In addition, the heights of the stacks are being designed according to Good Engineering Practice (GEP) to ensure best air dispersion and stack heights are as follows: Recovery Boiler ? 160 meters; Biomass Boiler ? 100 meters; and Lime kilns ? two stacks 100 meters each. The combined emissions from these three sources are estimated to be as follows: Projected Stack Emissions Parameter Units Predicted Value IPPC BREF (2001) WBG EHS Guidelines TSP kg/ADt 0.409 0.2-0.5 0.5 SOx as SO2 kg/ADt 0.332 0.2-0.4 0.4 NOx as NO2 kg/ADt 2.188 1.0-1.5 1.5-2.0 TRS as SO2 kg/ADt 0.054 0.1-0.2 0.2 Notes: kg/ADt ? kilograms of pollutant per 1,000 kg of air dry pulp; TSP ? Total suspended particulate; SO2 ? sulfur dioxide; S ? sulfur; NO2 ? Nitrogen dioxide; TRS ? total reduced sulfur compounds; IPPC BREF ? European Union Integrated Pollution Prevention and Control Best Available Technique Reference Document (2001); WBG EHS ? World Bank Group Environmental Health and Safety Guidelines. Following licensing requirements, Klabin conducted preliminary air dispersion modeling using global weather models data (WRF ? Weather Research and Forecasting). Initial results suggest that the project atmospheric emissions will not have a negative impact on the regional airshed and that ambient air quality levels for the above parameters will remain well below applicable Brazilian ambient air quality standards. Klabin also conducted cumulative impact assessment considering emissions from existing plant in Telemaco Borba, and which concluded that emissions from Telemaco Borba site won?t intervene or overlap with Puma?s project emissions. Nonetheless, the Sponsor will deploy a meteorological station in the site and will collect data to update the dispersion modeling and confirm preliminary results . The air emission monitoring program has been defined in coordination with IAP. The Air emissions control program defines the air emission monitoring approach, via stack tests, of carbon monoxide (CO), oxygen (O2), particulate matter (PM), sulfur dioxide (SO2), TRS and nitrogen oxides (NOx) on a semi-annual basis, and specific control measures described above to achieve compliance with Federal (CONAMA 382/06) and Estate Level (SEMA 54/06) threshold requirements Noise Emissions ? The Project will generate significant levels of noise during construction and operations. The main sources will consist of transport related activities for daily transport of construction workers between the worker camps or the nearby cities and the construction site, and construction site civil works activities. During the operational phase, main sources of noise will consist of the transport of raw materials, mainly wood, from the plantations to the Project, wood harvesting operations, and pulp mill operations (i.e. log yard handling activities, power and process equipment noise, steam system purges, etc). Noise prevention and mitigation measures considered in the ESIA include such aspects as the project siting in a rural area away from major population centers; purchasing of sufficient land for the construction of the pulp mill in consideration of the need for a sizable buffer zone to provide additional setback to nearby residents; installation of vibration isolation for mechanical equipment and acoustic enclosures for large pieces of equipment with high noise levels; use mufflers and other suitable devises on engine exhausts and compressor components; use of mufflers for materials transport equipment (during construction and operation); limitations of forest harvesting and wood transport activities as required by local law. The Project proposes to monitor ambient noise levels at seven locations, which represent residential receptors. Noise monitoring will start at commencement of construction activities. Going forward, as described above in PS1 section, Klabin will also develop specific management program (programa de Monitoramento de impactos do Tr?fego de ve?culos durante a constru??o) to monitor dust and noise emissions from traffic during construction. Hazardous Materials Management During construction, the Sponsor and its contractors will be required to prepare and implement environmental management plans and procedures in accordance with the environmental license and Ministry of Labor and Employment?s Regulatory Norm (NR) 18, which establishes procedures and standards for construction sites. NR-18 requires the preparation of the Program of Conditions and Working Environment for the Construction Industry (Programa de Condi??es e Meio Ambiente de Trabalho na Ind?stria da Constru??o ? PCMAT). The PCMAT includes the preparation of an Environmental Risk Prevention Program (PPRA, Programa de Preven??o de Riscos Ambientais) and the implementation of hazardous materials storage and handling procedures and practices. These typically include dedicated fueling and chemical storage areas with secondary containment and the implementation of spill prevention and control measures. During operation, the Project will require the use of various hazardous materials that will be transported to the Project site via trucks and which will be stored on site in designated chemical storage areas. A risk analysis was conducted as part of the ESIA to identify risks associated with the following hazardous materials (and proposed storage volumes): Sulfuric Acid (98% by weight, 750 m3); Sodium Bisulfite ( 100 m3); Caustic soda (50% by weight, 2,000 m3); Caustic soda (20% by weight, 350 m3); Hydrogen Peroxide (450 m3); Methanol (200 m3); Solution of Sodium Chlorate (1,200 m3); Chlorine Dioxide (10 g/L, 2,500 m3); Diesel (100 m3); and Fuel oil (4000 m3). The above listed chemicals are used at other pulp mills operated by Klabin and the Company has standard plans and procedures that will be used at the proposed Project site. The design of the Project includes measures for proper storage of hazardous materials, secondary containment for potential spills, spills response planning, and specific health and safety procedures and training for worker?s protection. In the forestry management operations, Klabin currently uses three types of authorized herbicides for weed control based on field assessment of weed infestation and on a qualified agronomist prescription. Klabin also monitor ants? infestation and chemical control decisions are based on the economical level of control, consistent with IPM principles and IFC requirements. Klabin does not use pesticides within hazard class Ia or Ib according to WHO pesticides hazard classification system. Greenhouse Gases Because Klabin owns and operates many forest plantations of pinus and eucalyptus in Southern Brazil, the Company reports that its carbon sequestration capacity exceeds emission of GHG released at pulp and paper mill facilities and the project will also co-generate energy from biomass for own consumption and to be sold to the grid. Klabin has complement the GHG impact evaluation included in the ESIA with a project-specific analysis of potential GHG emissions for the Project, taking into consideration temporary direct and indirect emissions from the construction and operational phases (Scope 1,2 and 3 of the World Resources Institute (WRI) GHG emissions estimation methodology. Results show that emissions from construction phase are 3,804 ton of CO2 eq and annual emissions of 2,521,727 ton of CO2 eq during operations.