2011 Environmental Statement 1.8 MB - Sappi

Environmental Statement
2011
Sappi Nijmegen BV
sappi
The art of adding value

t/a
Environmental targets
Results
Certification

Contents
Introduction ....................................................................................................................... 4
Summary ........................................................................................................................... 5
1 Description of business activities ............................................................................. 6
1.1 Sappi Nijmegen BV. .............................................................................................. 6
1.2 Description of business processes ........................................................................ 6
1.3 Supporting services .............................................................................................. 9
2 Environmental management activities, licenses and charters .............................11
2.1 Structure and status of the environmental management system ..........................11
2.2 Overview of key legislation, requirements and compliance ...................................16
2.3 Charters ...............................................................................................................19
3 Objectives of an environmental policy: measures and achievements ................ 21
3.1 Introduction ......................................................................................................... 21
3.2 Air ....................................................................................................................... 22
3.3 Water .................................................................................................................. 24
3.4 Waste material .................................................................................................... 25
3.5 Soil ...................................................................................................................... 28
3.6 Noise .................................................................................................................. 29
3.7 Fire prevention, external safety and emergencies ................................................ 29
3.8 Traffic and Transport ........................................................................................... 30
3.9 Indirect environmental impacts ............................................................................ 30
3.10 Effects on biodiversity ffecten op de biodiversiteit ............................................... 31
3.11 Education ............................................................................................................ 31
3.12 Comparison to BAT-Bref / IPPC / E-PRTR ........................................................... 32
3.13 European Pollutant Release Transfer Register (E-PRTR) ...................................... 32
4 Validator’s data .......................................................................................................... 33
5 Next environmental statement ................................................................................. 33
Appendices ...................................................................................................................... 34
1. Glossary ........................................................................................................................ 35
2. Facts and figures relating to EMAS Sappi Nijmegen BV ................................................. 36
3. Clarification of facts and figures (Appendix 2 and paragraph 3.12) ................................. 36
4. Overview and justification of presented data ................................................................. 37
5. Overview of complaints registered and reports submitted by Sappi Nijmegen BV ......... 38
6. Overview of key legislation, requirements and compliance ............................................ 39
Environmental Statement 2011 3

Introduction
Dear reader,
W. Thomas, Mill Director
This is Sappi Nijmegen BV‘s 2011 EMAS III
Environmental Statement.
With EMAS - ‘Eco Management and Audit
Scheme’ – the participating companies, who
do so on a voluntary basis, target the enhancement
of environmental performance by
way of continuous improvement.
In this sense, the yearly EMAS Statement is
much like an annual report on environmental
issues.
It describes the current state of affairs, new
developments and success or failure in achieving
targets with respect to all environmental
activities by Sappi Nijmegen BV in the calendar
year of 2011.
4 Environmental Statement 2011
Since 1997, the statement is annually prepared
by the Safety & Environment Department
of Sappi Nijmegen, in cooperation with other
local departments. The statement has been
verified by DNV.
The year 2010 marked the end of the plan
period associated with the Integral Environmental
Target Treaty, the Convenant Integrale
Milieu Taakstelling, the framework of a series
of agreements with Dutch authorities aimed
at reducing the environmental impact of the
paper and board industry. In general, for Sappi
Nijmegen BV, this plan period, running from
1995 to 2010, a time in which the company
achieved a small increase in production volume,
can be said to have resulted in a reduction
of energy consumption of approx. 25 %,
the virtually complete termination of ammonia
and formaldehyde emissions and a reduction of
water use and various waste streams by 50%.
This year, focus is on execution of Project Koala,
which, although primarily aimed at improvements
to the local paper machine, also
encompasses sub-projects aimed at further
reduction of energy consumption. For all relevant
aspects, new targets have been set for
a period until the end of 2015.
As was the case last year, the 2011 environmental
annual report will also be available
online, at www.sappi.com.
If you have questions or comments, or if you
would like to receive a hardcopy of this statement,
feel free to contact us. Contact information
can be found on the last page of this
report.
Nijmegen, March 2012
W. Thomas
Mill Director

Summary
Organization
Sappi Nijmegen is part of the South-African
Sappi Group. The mill, which has around 197
employees, produces some 200,000 –
250,000 tons of coated reel paper per year.
Business processes
Raw materials and additives are transported to
the mill mostly by ship, Raw materials and additives
are externally stored at an ISO 14001
certified company. The process of paper production
itself consists of several steps, including
stock preparation, the actual production
of coated reel paper on the paper machine
and reel finishing. Apart from this, there are
some non-process related activities, related to
the combined heat-power plant, technical services,
treatment of groundwater, internal transport,
fire protection and first aid. Finished products
leave the mill by road transport.
Environmental Management
System and official licenses
Sappi Nijmegen BV uses a certified system
for environmental management (ISO
14001:2004), which assures full compliance
with requirements in terms of licenses and regulations,
legislation and charters through
operational control of (major) environmental
issues. Every four years, new targets are set
for environmental performance. The instruments
for achieving these targets are supplied
by long-range plans and year programs, which
are then annually reported on in the validated
environmental statements (EMAS). Throughout
the year, measurements are made, in combination
with registrations, inspections and audits.
Deviations, inadequacies or complaints
are followed up by corrective and/or preventive
measures. Management reviews evaluate
the effective functioning of the environmental
management system.
Overview targets 2011
Item Energy Ammonia Water con- Pollution
consumption
sumption units
Achieving objectives
In 2010 the plan period of the Integral Environmental
Target Treaty came to an end,
coinciding with the final term of the third Bedrijfs
Milieu Plan (BMP-3), the Corporate Environmental
Plan. To follow up on the agreements
made in the Treaty, specific corporate
plans have been laid down, but as no new
treaties have been signed with the government,
Sappi Nijmegen has defined its own
targets for the period until 2015.
Targets of 0% signify the intention to maintain
the level of performance from the base year
- 2010 for all items, with the exception of energy
- because reductions have already been
achieved during the now expired IMT period
and/or because of the fact that emissions are
already below BAT/Bref limits. See paragraph
3.11.
The status with regard to these targets is reflected
in the diagram below.
Targets of 0% indicate the intention to
maintain the level of performance from the
base year. Percentages preceded by a minus
sign indicate intended reduction, percentages
preceded by a plus sign indicate intended increase.
The figures presented here, are explained
in greater detail in chapter 3.
Structure of this document
Chapter 1 describes Sappi Nijmegen BV and
its business processes. Chapter 2 presents
an overview of activities relating to management
of environmental issues, while Chapter
3 discusses measures taken and results
achieved.
This is followed by 5 appendices. Appendix 2
contains the actual facts and figures.
Purification
sludge
Industrial
waste
Re-usable
waste
Target -14% 0 % 0 % 0% 0% 0% 0% 0%
Hazardous
waste
Realized
in 2011 -2% -94% +4% +26% +31% 0% +7% -29%
Environmental Statement 2011 5

Description of business activities
The Nijmegen paper mill is part of the
Sappi Group, one of the leading producers
of coated fine paper used for a
broad range of print applications, such
as glossy magazines, catalogues, etc.
Customers who buy Sappi’s products
are paper merchants, printers and
publishers.
1.1 Sappi Nijmegen BV
Production of fine paper makes up two thirds
of the total turnover of the Sappi Group. Apart
from this, Sappi Fine Paper Europe produces
pulp, coated specialty paper grades, packaging
paper and uncoated papers.
The globally active Sappi Group started out
as a South-African company. Today, it employs
approx. 15,000 people on five continents,
with production facilities in South-Africa,
North-America and Europe.
Production detail
The mill in Nijmegen, part of Sappi Fine Paper
Europe S.A., is an exclusive producer of twosides
double coated fine paper. It employs
around 197 people, most of them working in
round-the-clock shifts. The mill has a maximum
production capacity of approximately
300,000 tons of paper per year. Nijmegen
produces well-known brands such as Royal
Roto Matt, Royal Roto Silk and Royal Roto
Brilliant Plus in grammages from 90 g/m 2 to
170 g/m 2 .
Its market is the entire world.
1.2 Description of business
processes
Incoming raw materials and additives
Most of the raw materials and additives are
delivered to the mill by ship. Some additives
are brought in by road or rail transport.
Production line Machine deckle Max. speed Capacity
PM7 4.950 mm 1068 m/min 300,000 tons/year
Products Grammages Type
Royal Roto Matt 90 - 170 g/m 2 Reels
Royal Roto Silk 90 - 170 g/m 2 Reels
Royal Roto Brilliant Plus 90 - 170 g/m 2 Reels
6 Environmental Statement 2011

1.2.1 Storage of raw materials and
additives
Raw materials and additives are stored in a
number of different locations. Storage of materials
classified as environmentally hazardous under
the WMS (Wet Milieugevaarlijke Stoffen, the
Dutch Environmentally Hazardous Substances
Act) or under GHS (the Globally Harmonized System)
is provided by an external company, certified
according to the ISO 14001:2004 standard,
from where supplies are delivered on call to the
different work locations (departments) of Sappi
Nijmegen BV. Internal storage at the mill itself fully
complies with all legal and regulatory requirements.
1.2.2 Description of paper production
processes
The process of paper production itself consists
of several steps, including stock preparation, the
actual production of coated reel paper on the
paper machine and reel finishing.
Stock preparation
In stock preparation, raw materials (cellulose,
broke, additives and chemicals) are suspended
in water in a so-called pulper. Broke is a pulp
mixture consisting of water and paper left over
from previous production runs.
Paper production
Sappi Nijmegen B.V. has one paper machine -
PM 7. From special tanks, the paper stock is
transferred to the headbox, from where it is
evenly distributed across the wire. The final properties
of the base paper, including its grammage,
are determined by the amount of fibres in
the suspension, the speed of the wire and the
speed at which the suspension leaves the headbox.
After the wire section, remaining water is
removed in the press section. This pressing has
a direct effect on the strength of the resulting
paper. After it has been pressed, the paper web
passes through a drying section. The final process
step involves the application of coating, in
two layers on each side of the paper. This coating
substance is prepared in a dedicated coating
kitchen. Finally, the paper web is reeled to
so-called mother reels.
Environmental Statement 2011 7

Finishing
In the finishing process, the mother reels
pass through a supercalender, which gives
the paper its gloss and smoothness. Gloss is
a factor of pressure applied and temperature.
Next, the slitter-rewinder cuts the mother
reels into smaller sections, fit for transport to
the customer. The weight of these final reels
varies from one to three tons, depending on
width and diameter specifications by the customer.
Finally, these reels are packaged in
the wrapping machine.
Transport of end products
End products are stored internally. From storage,
the end products are transported to the
customer by truck.
1.3 Supporting services
Apart from the process-driven activities described
above, a number of additional activities
take place at the mill’s premises which
are not directly related to production processes,
but do have their own potential impact
on the environment. We distinguish between
the following areas of supporting
activity.
Utilities
The Utilities Department is responsible for
supplying energy and water, two main ingredients
of the production process.
In 1987, Sappi Nijmegen BV installed its own
combined heat-power plant, consisting of a
gas turbine driving a generator. The combustion
gases from this turbine are fed through a
gas kettle which delivers high pressure steam
and in turn drives a counterpressure steam
turbine. The steam turbine generates electricity
and depressurizes the steam, which is then
fed to the internal distribution network. The
gas kettle also has its own additional heating
provisions and a ‘cold air’ system, so that it, by
itself, can provide the total amount of steam
needed if the gas turbine is not in use.
Additionally, two low pressure kettles are on
stand-by to take over the production of steam
in case of malfunctions in the primary kettle.
Depending on internal consumption, additio-
nal energy is purchased from public providers
or delivered to the public grid.
In 2005, the original gas turbine was replaced
by a water injected model, for future compliance
to ever more demanding requirements
with regard to NO x emission.
In 2008, as part of on-going maintenance,
the steam turbine was revised for added efficiency
in the future.
Water used to feed the kettle is first de-ironed
and softened, after which a small amount of
chemicals is added for protection of the installation.
Sappi Nijmegen BV also uses groundwater
for its production processes. This too is deironed
before use. Recycling water, along
with waste water from the production process,
is purified in the mill’s own water treatment
facilities.
Process water released during the production
of paper, is recycled in stock preparation,
where it is used as an ingredient for the pulp
suspension. All other process water is fed
through dirt and sand filters, a pH-regulator
and a buffer tank. Pumps then transfer the
water to the mill’s own water treatment installation
in nearby Weurt. After purification, the
water is discharged into the river Waal.
Environmental Statement 2011 9

Technical Department
In the Technical Department’s workshop,
small repairs are carried out for installations,
machines and buildings. Hazardous substances
are stored and removed according to
all legal requirements.
Offices, staff facilities and laboratories
The mill has offices for commercial and administrative
tasks.
There are also two laboratories, one for intake
and quality control, the other one dedicated
to process development. In both cases, the
work being done consists mainly of physical
measurements, wet chemical analysis being
only an occasional aspect of activities.
Materials Handling / Logistics
This department is responsible for all internal
transport and supply management of raw
materials and finished end products.
For internal transport, the mill has a number
of fork lift trucks, running on LPG or electricity.
LPG is stored in 33 litres gas containers
which are re-filled in a specially equipped facility.
Fire prevention / First aid
Fire extinguishers and fire-extinguishing installations
are present at strategically selected
locations throughout the buildings. There are
two redundant machine rooms for the sprink-
10 Environmental Statement 2011
ler system. Apart from this, Sappi Nijmegen
BV has its own emergency organization, consisting
of fire fighters and a first aid team.
Twice a year, trainings are held to maintain
the required level of skills and expertise. As to
specific content, these trainings are driven by
recent incidents and general emergency procedures
as defined in the internal emergency
plan.

Environmental management activities,
licenses and charters
2.1 Structure and status of the
environmental management
system
2.1.1 General
This chapter deals with the structure and status
of the environmental management system
in use at Sappi Nijmegen BV. Also, we will
describe the current situation with regard to
licenses and charters.
Some years ago, Sappi Nijmegen BV implemented
a dedicated environmental management
system, which, in March 1998, was certified
according to the NEN-EN-ISO
14001:2004 standard.
On December 1, 1998, the mill was also registered
by SCCM as a participant in the EMAS
program under member number NL-S-
0000024. In the following years, this registration
has steadily been renewed for the duration
of one year after verification and approval of
the annual environmental statement by DNV.
Elements of the NEN-EN-ISO 14001:2004 standard
Plan
Instruments
- Policy statement
- Charters
- Environment targets
- Consultation
Do
Instruments
- Training
- Structures
- Emergency plans
4.1 General requirements
4.2 Environmental policy
4.3 Planning
4.3.1 Environmental issues
4.3.2 Legal requirements and
regulations
4.3.3 Objectives, targets and programmes
4.4 Implementation and execution
4.4.1 Instruments, task assignment,
responsibilities and authorisations
4.4.2 Competence, training and
awareness
4.4.3 Communication
4.4.4 Documentation
4.4.5 Familiarity with documentation
4.4.6 Control over activities
4.4.7 Being prepared for, adequately
reacting to emergencies
As of 2004 Sappi Nijmegen BV has completely
integrated its management systems
for safety and health, environmental affairs
and quality, in particular with regard to documented
components. In 2012, energy management
will, according to plan, be added
to the list. In the spring of this year, the ISO
50001 audit will take place, evaluating the
mill’s energy management systems.
The environmental part of this management
system ensures, among other things, that
authorizations held or issued by the mill, are
translated into actual procedures and specific
work instructions. By linking requests, authorization
and environmental management, the
whole complex of licenses is also transparent
and verifiable to relevant authorities and
members of the internal organization.
The following paragraphs outline the main
structure and mode of operation of the environmental
component of the mill’s integrated
management system, according to the Plan-
Do-Check-Act principles of the Deming Circle.
Act
4.6 Board assessment
Check
4.5 Control
4.5.1 Monitoring and measurement
4.5.2 Compliance evaluation
4.5.3 Deviations, corrective and
preventive measures
4.5.4 Registration management
4.5.5 Internal audits
Environmental Statement 2011 11
Instruments
- Internal
audit reports
- Recommendations
Instruments
- Waste management
- Emission registration
- Reporting system
- Audit results
- Maintenance checks

Policy statement
It is the true conviction of Sappi Nijmegen
BV’s management team and Board of
Directors that responsible entrepreneurship
contributes greatly to sustainability,
continuity, profit, employment opportunities,
customer satisfaction, commitment to
environmental protection and the highest
possible degree of safety, health and
well-being of the work force. This also
entails an attitude of active open dialogue
towards authorities and customers,
employees and the communities in which
we are active. It means that we will continually
strive to improve our performance
with respect to safety, health, environment
and quality within the framework of
conditions as prescribed by business
economics.
Our company policy with regard to safety and
health, quality and the environment is a key
evaluation criterion for Sappi Nijmegen BV.
We comply to national and international standards,
national and international legislation
and regulations and endorse branch guidelines
and charters.
Management and employees of Sappi Nijmegen
BV will do all within their power to prevent
incidents.
To accomplish this, we see it as our mission to
continually focus on potential risks within our
working environment, eliminate risks where possible
and improve safety awareness among our
employees.
What this requires is an attitude of positive awareness
in an environment where adequate behaviour
is one of the deciding conditions for safety.
Our safety policy is based on:
- Attention to (un)safe behaviour; our goal is
0 lost time incidents.
- Trust, in oneself, in each other, in the working
environment.
Nijmegen, 17 october 2011
12 Environmental Statement 2011
- Responsibility and initiative, for the sake
of personal safety and the safety of others.
- Order and cleanliness: maintaining a clean
workplace and general environment prevents
accidents.
- A strict set of values: safe behaviour and
working safely is not just an obligation to
colleagues, it is a value in itself.
- Communication: we discuss incidents
within our own company and within our
branch of industry, in order to learn from
mistakes and further improve the safety of
our workplace.
Our environmental and energy
policies are based on:
- Prevention of inconvenience for the
surrounding community, prevention of
emission to air, soil and water and strict
conformance to environmental laws and
regulations and all agreements and
obligations from existing charters.
- Further reduction of water and energy
consumption, with the target of performance
above and beyond the level put
forward in BAT ( Best Available Techniques)
Reference Documents (BREF).
- Striving for continuous improvement of
energy efficiency by sourcing less energy
consuming products and services.
Our quality policy is based on:
- Controlled, repeatable production processes.
- Observing agreements with customers as
to quality, reliable delivery and service.
- Guaranteeing consistency of product
properties.
- Continuous improvement of products,
processes, systems and human skills.
The implementation of this policy is reflected
in our company objectives and long term
targets.

2.1.2 Plan
On a yearly basis, Sappi Nijmegen BV takes
complete stock of all effects on the environment
resulting from its business operations,
using a special analysis tool called EcoSig. The
tool enables us to prioritize effects, thus allowing
for informed choices. This environmental analysis
also provides for all planning requirements of the
ISO 14001:2004 standard, with regard to:
• environmental aspects
• compliance to legislation and regulations
• objectives, targets and programs
The analysis allows for a differentiation on the
following criteria:
• Non-adherence to legislation and regulations
• Failure to achieve general objectives in
terms of BBT (IPPC: BAT / BREF)
• Degree of harmfulness to the environment
• Increased emission as a result of special /
non-standard business operations
• Increased emission in case of incidents or
emergencies
• Concern from or interest by third parties
Reliability of numerical data
During the reporting period of 2011, there
has been one case of process modification.
Boiler 8 has been dismantled and scrapped.
The major changes with regard to the item
analysis scores are as follows:
• Air: ammonia emission scores higher, due
to the use, in the course of 2010, of a latex
containing slightly more ammonia.
• Water: suspended solids emission scores
lower, because in 2011 there has been no
bulking sludge from secondary settlement
to the waste water treatment plant.
• Soil: tank storage of chemicals scores higher,
because of additional requirements in
the new Environmental Management Act.
Monitoring of historical pollution scores lower,
due to a ruling issued by the City of
Nijmegen.
• Waste: as there has been no more coating
waste disposal during the past few years,
this item has been taken out of the analysis.
• For reasons of ISO 50001 compliance, this
item has been added to the analysis.
The measures are listed, per compartment, in
chapter 3, along with objectives and results.
Every year, budgets are allotted to projects,
including projects aimed at environmental
performance improvement.
2.1.3 Do
Management system agents and auditors
Within Sappi Nijmegen BV’s management system
(pertaining to health & safety, quality
and environment), management system
agents for the different departments and auditors
play an important part. The agents are
largely responsible for executive aspects of
the system, such as internal communication,
counselling and the implementation of corrective
measures. The specially trained auditors
take care of internal audits.
Thanks to the efforts and commitment of these
agents and auditors, Sappi Nijmegen BV
is able to maintain the current level of efficiency
of its management system and accomplish
its ambitious objectives.
Education and training
Where necessary, employees are specifically
educated on activities that have possible impact
on the environment. How exactly this
education takes place, can vary according to
function. All formal trainings are listed in the
Education Plan of the Human Resources Department.
Employee involvement
Weekly newsletters inform the mill’s employees
on a broad range of issues, including
safety and the environment.
Early in 2008, the mill started out on the road
toward Lean Transformation. The first phase
of this journey is dedicated to developing and
studying improvement ideas in special working
groups consisting of representatives
from the different departments. These can
cover many topics, from production related
suggestions to initiatives in the field of administration.
The primary concern in these efforts
is reduction of cost and time,
but this same process of Lean Transformation
also generates many improvement ideas
Environmental Statement 2011 13

elated to safety and the environment. In general,
Lean is a methodology aimed at continuous
improvement of work processes.
Document management
As mentioned above, all management systems
relating to quality and environment and
health & safety (ISO 9000, ISO 14000 and
OHSAS 18000, respectively) have been integrated
in 2004. All documents pertaining to
this integrated management system have
been published to the company intranet, so
that they are readily available throughout the
company.
The entire management system has been
certified since 2005.
Control
The degree of control over environmental issues
is determined and registered through
EcoSig, with all defining characteristics of the
process involved and the type of control observed.
Based on these findings, the overall
level of control is determined. Control over
major environmental issues (and impact on
the environment) is one of the key functions
of the environmental management system.
For all aspects of environmental performance,
assurances are in place to help achieve the
desired level of control, which is documented
in procedures, instructions and other specified
routines within the management system.
Emergencies
The management system also provides procedures
to ensure that the organization is
prepared for incidents and emergencies. These
have been aligned (based on drills and
practice) with the internal fire brigade and the
authorities in charge. Copies of the emergency
plan have been made available to the authorities.
Hazardous substances present at Sappi Nijmegen
BV are stored according to all relevant
legislation and regulations (Hazardous Substances
directives: PGS-15/NRB).
14 Environmental Statement 2011
2.1.4 Check
Registration, measurement and inspection
Emission levels at the mill are regularly measured
by Sappi Nijmegen BV itself or in commission
of the company. Measurements and
registrations to be carried out per department
are documented in a fixed program, listing all
measurements that are legally required and
those that take place on the initiative of a given
department or the mill as a whole. All
measurements and inspections are documented.
and this documentation is always
available at the mill.
Measurements and registrations are determined
on the basis of procedures and instructions
that are part of the environmental
management system. Registrations are stored
in several locations. The Safety and Environment
Department is responsible for coordination
of data availability.
According to procedures and instructions as
defined in the environmental management
system, periodical environment inspections
take place, the results of which (together with
a record of the corrective measures taken in
case of deviations) are available to the relevant
authorities.
Deviations
Observed deviations or shortcomings are documented
in writing, and procedures as prescribed
by the management system are adjusted
by way of documentation and
implementation of corrective measures, to
prevent repetition and to ensure restriction or
elimination of the effects of deviations.
Preventive measures are taken to preclude
potential defects in the future. Deviations observed
in checking the values provided by
inspection, measurement and registration are
carefully assessed and where necessary followed
up on by corrective and/or preventive
measures.

Complaints and reports
The environmental management system also
provides procedures and instructions for dealing
with registration, handling, documentation
and reporting – both internally and externally
– of complaints. Apart form this,
procedures have been defined for legally required
reporting of (temporary) process
changes to the authorities.
In 2011, Sappi Nijmegen BV received one complaint.
Due to miscommunication, no permit was
issued to a ship’s captain for unloading cellulose.
This has been reported by way of complaint to
the Province of Gelderland. The company has
been advised of the incident, after which the permit
was issued as a retroactive correction.
There have been five instances of legally required
or preventive reports to the authorities. All complaints
and reports are followed up by corrective
measures where necessary. Appendix 5 contains
an overview of complaints received and
reports submitted by Sappi Nijmegen BV.
Audits
Compliance to all elements of the environmental
management system according to the
ISO 14001:2004 standard is ensured by internal
and external audits, complemented by
management reviews. These audits – both
internal and external – periodically review all
elements, aspects and components of the
environmental management system to assess
whether the principal goal of the system
– control and reduction of impact of business
operations on the environment – is actually
being achieved and whether agreements
made are adhered to in daily practice. Based
on the results of this assessment, Non Conformity
Notes are drafted and adjustments
and/or corrections are made to the management
system and its application.
These documents are available for review by
the authorities, so that they can determine
how the company has followed up on both
internal and external audits and checks.
All measures taken are recorded in a progress
monitoring system, which is part of the
yearly audits and management reviews.
In 2012, Sappi Nijmegen BV will also perform
the annual environmental analysis and an
overall assessment as to progress in achieving
the self-imposed objectives. New targets
have been defined for the period 2011
through 2015.
Results of internal audits in 2011
In 2011, internal audits on working conditions
and environmental performance against the
background of the management system have
taken place in all departments of Sappi Nijmegen
BV. These audits were coordinated by
internal auditors, always in other departments
than the ones they are personally attached to,
as a safeguard for impartiality.
Around 17 improvement actions have been
defined in 2011, relating to quality, working
conditions and – in approximately 33% of all
cases - the environment.
Strong points were the following:
• All (legally required) inspections and tests
have been recorded in SAP, the maintenance
system.
• A carefully designed contingency plan is in
place.
Key areas for improvement related to:
The absence of clear agreements concerning
post-calamity assessment, reporting and correction.
Air-conditioning fills are recorded, but not added
to the logs for the installation concerned.
Results of external audits in 2011
There have been no external audits of the
management system in 2011. Sappi Fine Paper
Europe holds one ISO certification for all
its mills. These are audited in rotation. In December
2011, document assessment in preparation
for the ISO 50001 certification audit
took place.
2.1.5 Act
Management review
The aim of management reviews (assessment
by mill management) is to verify whether objectives
and targets have been met and to
judge the efficiency of the (environmental)
Environmental Statement 2011 15

management system. Based on this assessment,
it is then possible to make adjustments
to environmental policies in order to ensure
continuous improvement, both in environmental
performance and in the management
system.
Summary of the management review
There were two management reviews in
2011, in April and September. One of the
conclusions is that the management systems
are not sufficiently efficient when it comes to
realizing targets.
As a result, new constructions are now under
review, using the Lean Performance approach.
2.2 Overview of environmental
licenses and regulations
2.2.1 Wet Milieubeheer – Environmental
Management Act (WM License)
Sappi Nijmegen BV holds a WM License issued
by the Province of Gelderland. This
license has been renewed in 2010.
The Sappi waste water treatment plant in
Weurt holds a separate WM License from the
City of Beuningen. This license has been renewed
in 2007.
Reports and visits related to the Environmental
Management Act
In 2011, a modification in business practice
has been reported to the Province of Gelderland,
concerning the decommissioning of
Boiler 8.
On May 17 2011, representatives of the Province
of Gelderland visited the mill in the
context of project “Night Owl”, intended to
check compliance to environmental licenses
during evening hours and throughout the
night. No violations of the Environmental Management
Act were found during this visit. It
16 Environmental Statement 2011

has, however, been agreed that the procedures
on alerting provincial authorities in the
case of unforeseen incidents will be made
available for review by the Province. This has
been done.
On August 19 2011, representatives of the
Province of Gelderland visited Sappi Nijmegen
BV to learn how data reported in the
PRTR statement are assembled. (This is done
using EMAS procedures.) No irregularities
were found and it was concluded that “the
methods used provide reliable data.”
On December 7 2011, provincial representatives
visited Sappi Nijmegen BV to check on
license regulations. Five irregularities were
found, four of them of an “administrative” nature,
concerning documents which had not
(yet) been made available, and one violation
with regard to installations. The latter concerns
a wall in the gas container storage room,
where the presence of a window is in conflict
with the required 60 minutes fire resistance.
For all irregularities dates have been agreed
for the completion of corrective measures.
2.2 Water Act
On December 22 2009, the new Water Act
became effective, replacing, among other
provisions, the Surface Water Pollution Act.
Sappi Nijmegen BV holds a license issued by
the Province of Gelderland in May 2004, but
under the new Water Act the City of Beuningen
is now responsible for granting permissions
where indirect discharges of purified
waste water are concerned, as is the case at
Sappi Nijmegen BV. These discharges now
fall under the provisions of the Environmental
Management Act. This transition of control
from national (Rijkswaterstaat) to local authority
(the City of Beuningen) was formalized in
January 2011.
Each year, all required data as to waste water
discharged in this manner, are reported to the
authorities (see Appendix 2). A small amount
of domestic waste water from the offices is
discharged into the communal sewer system.
License for sewage discharge under
the Water Act
The license for emergency transfer into the
communal sewer system has been issued on
and been active as of December 30, 2003.
The emergency transfer installation is located
on the company premises at Ambachtsweg,
Nijmegen. As of December 2009, when the
new Water Act became effective, authority in
the area of sewerage discharge passed from
the Waterschap Rivierenland to the Province
of Gelderland, the governing body in charge
of licenses under the Environmental Management
Act.
2.2.3 Groundwater Act
As part of the Third Water Management Plan
Gelderland for 2005 – 2009, the Province of
Gelderland has update all existing licenses,
assessing groundwater extractions on effectiveness,
efficiency and durability and where
necessary modifying the allotted extraction
area to fit actual water consumption. In this
context, Sappi Nijmegen BV has been granted
an updated license in October 2008.
2.2.4 Kernenergiewet – Act on the Use
of Nuclear Energy (Kew)
Kew, the Act on the Use of Nuclear Energy,
regulates the use of ionizing radiation sources.
For the mass gauges (thickness gauges)
in use at the mill, Sappi Nijmegen BV has requested
a revision of the current equipment
permits in July of 2006. In August 2006, the
revision license was issued by the Ministry of
VROM according to the provisions of the Act
on the Use of Nuclear Energy. The license is
subject to certain requirements as to transport,
application, checking, calibration and
maintenance, this last task to be performed
by authorized personnel only. Sappi Nijmegen
BV meets all stipulated demands, including
those relating to maintenance.
Environmental Statement 2011 17

2.2.5 License NOx and CO2 emission
rights
On January 1, 2005, the system of emission trading,
or Cap and Trade, was introduced on an
international (European) level for CO 2. As of June
1, 2005, the same is true for emission of NO x.
Trade in NO x emission rights is an internal
Dutch affair.
Aim of the system is to allow for compliance to
the arrangements of the Kyoto protocol.
Sappi Nijmegen BV has been issued a license to
participate in this system of trading in NO x and
CO 2 emission rights. For the plan period of 2008
- 2012 Sappi Nijmegen BV has drawn up an
NO x and CO 2 emission monitoring plan,
which has been submitted to (and approved
by) NEA, the Dutch Emission Authority (Nederlandse
Emissieautoriteit).
NEA is the authority in charge of enforcing provisions
for trade in NO x and CO 2 emission rights.
To this purpose, NEA issues licenses, keeps record
of emission rights balances and acts as a
general supervisor.
Requirements as to the measuring of CO 2
emission have been standardized on a European
level.
On November 2011, a Nea audit took place to
check measuring, reporting, validation and quality
control procedures. Administrative aspect
and installations have been evaluated, but no
report has yet been received listing the conclusions.
18 Environmental Statement 2011
2.2.6 Requirements under standard law
and regulations
The legislative context in which Sappi Nijmegen
BV operates when it comes to environmental
issues, is made up of requirements
pertaining to licenses, obligations arising from
standard laws and regulations and signed agreements
and charters (see section 2.3 Charters).
The relevant standard laws and regulations
applicable to Sappi Nijmegen BV have been
recorded in a dedicated procedure within the
management system.
Appendix 6 contains an overview of the most
significant laws and regulations.
The procedural approach within the system is
intended to support management of tasks
and responsibilities based on the legislative
context as described above and to assess
whether and ensure that the organization
operates within the limits as prescribed by
law. Compliance to these laws and regulations
is specifically audited on a yearly basis.
During the 2011 theme audit, six deviations
were found, four concerning work conditions
and two with respect to the environment. The
latter are related to updating the air-conditioning
logs after maintenance and updating the
list of legal inspections. An improvement
measure has been defined to correct the situation.

2.3 Charters
Charters, also in the environmental sense, are
(voluntary) agreements between the authorities
(state, province, city council or district
water board) and a group of (branch related)
companies, as part of the Industrial Target
Group Policy. Their aim is to provide a coordinated,
structured approach to environmental
issues in which measures to be taken are
phased over time, so that individual companies
have certain assurances for the longer
term.
2.3.1 Convenant Integrale Milieutaakstelling
– Charter Overall Environmental
Targets (IMT)
As part of Overall Environmental Targets
charter, in which Sappi Nijmegen BV participates,
three plan periods have been defined
for which the individual companies have laid
down environmental measures in Corporate
Environmental Plans. Which of these measures
have been taken by Sappi Nijmegen BV
in the context of the most recent Corporate
Environmental Plan (BMP-3), is documented
in the EMAS Statement for 2010. The IMT
charter, which ended on December 31 2010,
has not been renewed.
2.3.2 Long-term Agreement on Energy
Efficiency for ETS companies
(MEE - Meerjarenafspraak Energie-efficiëntie)
On October 2 2009, the Long-term Agreement
on Energy Efficiency for ETS companies
(Meerjarenafspraak Energie-efficiëntie ETSondernemingen)
was signed. ETS stands for
Emission Trading System, the European system
for trade in emission rights. Companies
participating in the Charter for Benchmarking
and obliged to participate in the European
system for trade in emission rights - and both
conditions apply to Sappi Nijmegen BV - are
automatically carried over to participation in
MEE. The charter provides agreements toward
significant contributions in improving
energy efficiency in a period of ten years ending
in 2020 by:
• Taking profitable measures to improve energy
efficiency within the companies’ own
facilities and throughout their supply and
delivery chains;
• Strategically investigating options to save
energy in the long term.
Under these long-term agreements Sappi Nijmegen
BV has created an Energy Efficiency
Plan and will participate in various projects in
the context of the charter.
2.3.3 Resolution for Packaging, Paper
and Board Management
Sappi Nijmegen BV is registered with VRN
(Verpakkingen Recycling Nederland – the
Dutch foundation for recycling of packaging
materials) in order to comply with the regulations
based on the Resolution for Packaging
Management, which makes it obligatory for
producers to report on the volumes of packaging
material they use. These reports are
submitted through branch organization VNP,
the Royal Society of Dutch Paper and Board
Producers.
Environmental Statement 2011 19

Objectives of the environmental policy:
measures and achievements (targets)
3.1 Introduction
Achieving targets
General targets based on the overall policy
(policy statement) are translated to specific
targets in environmental performance, see
the targets table under Summary, page 4,
and the separate objectives in this chapter.
Targets for realization of environmental objectives
are listed in this chapter according to
subject matter and paragraph as specific
measures in the section ‘Measures implemented
/ measures planned / status’. Considering
the modest size of the organization,
targets (actual measures to be taken) are set
by one department (in most cases Manufacturing)
and managed by one project leader.
The targets are not necessarily defined in
terms of specific figures. The department /
project leader reports on progress in achieving
the targets and on the effects of the
measures implemented, thus facilitating yearly
assessments of the extent to which efforts
on a specific issue contribute to general targets
in the field of environmental performance.
In 2011, new targets have been defined for
the period through 2015. The base year is
2010, except for energy, where 2009 is the
base year, due to choices made in energy
management according to ISO 50001.
Targets of 0% signify the ambition to maintain
the level of performance from the base year,
because reductions have already been achieved
during the now expired IMT period and/
or because of the fact that emissions are already
below BAT/Bref limits. See paragraph
3.11.
Key indicators
The paragraphs below list targets (key indicators)
and details per type of emission,
The figures (‘R’) in this chapter’s tables represent
the (indexed) ratio of total year consumption
and effect on the relevant area (‘A’),
divided by total year production (‘B’).
A (year consumption/effect on the relevant
area) : B (total year production) = R (result)
Also listed are measures (targets) implemented
so far and those with a certainty of being
carried out in the future to further reduce impact
on the environment, along with the status
concerning actual and expected achievement
of objectives.
Facts and figures
The year totals in consumption and effect (the
company loads) in the relevant area (emissions)
and the total year production figures can
be found in Appendix 2, Facts and figures.
Specific action: annual planning with regard
to working conditions, safety and the environment
The annual planning as recorded in the management
report (for the Sappi year, which
runs from October through September) reflects
the operational translation of measures
in the field of working conditions, safety and
the environment (prompted by the results of
internal or external audits, for instance, or based
on suggestions by employees). Progress
on these operational plans is monitored by
mill management on a monthly basis.
Comparison to BAT-Bref / IPPC (Paper &
Pulp) and E-PRTR
The final paragraph of this chapter compares
the levels of actual emission for a number of
the categories in the previous paragraphs to
the theoretical level of emission if Best Available
Techniques (BAT) as defined for the paper
and pulp industry, had been used.
Modifications
Based on the annual environmental analysis
for 2011 and the environmental management
system there is no cause for modifications or
additions to facts and figures or (key) indicators,
nor have there been changes in the organization
that would make such modifications
necessary. See paragraph 2.1.2.
New targets, however, have been set due to
expiration of the BMP-3 period.
Environmental Statement 2011 21

3.2 Air
Major aerial emissions are emissions of NO x,
CO 2 and CO by the combined heat-powerplant
and, to a lesser degree, the infrared jets
and mixed-air heaters of the local paper machine,
PM 7. Apart from this, there is some
emission of ammonia and dust.
There is no emission of gasses generally assumed
to contribute to global warming, such
as N2O, HFC’s, PFC’s and SF6, nor is there
any emission of SO2 since the source of energy
is natural gas. Emissions of CH4 (methane)
at Sappi Nijmegen BV, expressed in tons
CO 2 equivalent (reference substance) are related
to the amount of natural gas consumption
and automatically calculated by using a
fixed factor in the e-MJV. Emissions are reported
according to this calculation.
CO 2 and NO x emissions are the result of the
use of natural gas, the primary source of energy
for the production process. The volumes
of these emissions, see Appendix 2, are directly
related to the amount of energy necessary
to produce one ton of paper. There is no
SO2 emission.
3.2.1 Energy
Target (related to climate change)
The target for 2015 is 5435 MJ/gross tons
In 2011, an energy management system has
been established according to ISO 50001
standards. The certification audit is planned
for January 2012. For this management system,
based on ISO 50001 considerations,
2009 has been chosen as the base year.
Another deliberate choice concerns progress
reporting, which will be done in the environmental
statement. Energy consumption is
calculated on a daily basis, with gas con-
22 Environmental Statement 2011
sumption, sourced electricity and gross production
as the determining factors. The diagram
above shows the average year volumes.
At this time, Sappi Nijmegen BV does not
(yet) use energy from renewable sources.
Measures implemented / measures planned
/ status in this plan period
In 2005 VNP, the association of Dutch paper
and board producers, published a ‘vision document’
concerning the future of paper production
in The Netherlands. One important
aspect of the vision presented in this paper, is
the so-called Energy Transition Paper Chain,
a concept aimed at 50% reduction of the energy
used for the production of paper and
board by 2020. To help achieve this ambitious
objective, a Strategic Innovation Agenda
has been drafted by way of an Innovation
Roadmap outlining the 5 different stages or
components of an overall innovation program:
energy management, energy neutral
paper, the paper chain of the future, biological
refinement and water free paper production.
These programs are coordinated by the
branch association Royal VNP and the Knowledge
Centre for Paper and Board. Meanwhile,
several research projects (see below) have
been initiated within the framework of this initiative.
More information is available at www.
vnp-online.nl
Sappi Nijmegen BV is also one of the participants
in the CapWa project - Capture of evaporated
Water with novel membranes - aimed
at recapturing (demi)water from vapour
using selected separation membranes. For
the paper industry this could prove to be an
interesting technology, preserving not only
water, but energy as well. Water which has
been reclaimed in this way, could then be
channelled back into the production process,
as kettle water, for instance. On a modest
scale, the membrane technology has already
proven its viability, so the current project is
primarily aimed at up scaling its usability to an
industrial level. Pilots are underway at a power
station and in a paper mill. The total bud-

get for the project is 4.7 M€. Dutch partners
in the project, apart from Sappi Nijmegen BV,
include The University of Twente and the
Knowledge Centre for Paper and Board. In
2011, KEMA performed a practical test at
Sappi Nijmegen. More information is available
at: www.kcpk.nl
In 2011, a decision model has been defined
for the combined heat/power plant, which
enables operators to shut down certain parts
of the plant during production stops. This will
allow for savings of approx. 100 MJ/tons of
energy.
In 2011, the pressure in the compressed air
system has been reduced. Compressing air
requires a lot of energy. Reducing the operational
pressure in the system, saves energy.
In August 2011, research was done on energy
efficiency. A number of energy saving modifications
will take place as part of the rebuild,
planned for 2012. All other measures
are listed in the opportunity register for energy
savings which is part of the ISO 50001
management system established in 2011.
Document assessment took place in December
2011. The certification audit will take
place in January 2012.
For 2012, a rebuild of the paper machine is
planned. During this rebuild, adjustments will
be made allowing for the exclusive use of
hardwood cellulose as raw material. Other
adjustments will be aimed at increasing (cost)
efficiency. As far as energy is concerned, this
will primarily be accomplished by projects aimed
at energy recovery.
3.2.2 Ammonia (NH3)
Target (related to acidification)
Maintaining the performance level of 2010
(one fourth of the allowed quantity)
Status of measures in this plan period
• Emission of ammonia is a result of small
rest percentages of ammonia in the raw
materials used for coating.
• Emission levels have been calculated since
2004 based on the so-called mass balance:
the proportion of ammonia in the ammonia
containing latices used. This method
is in accordance with the provisions of the
WM license.
• The decrease in 2011, as compared to
2010, is caused by a choice made in the
latter year, driven by quality considerations,
for a type of latex with a slightly higher ammonia
content. The intention remains to
use only latex types with no ammonia content.
3.2.3 CFC
Target (related to ozone layer depletion)
No more re-filling with newly produced
HCFK’s as of 2010
Status of measures in this plan period
The air-conditioning equipment used by Sappi
Nijmegen B.V. contains some 230 kilograms
of R22 (HCFK: freons). Maintenance of
this equipment is restricted to a qualified con-
Environmental Statement 2011 23

tractor (STEK). No newly produced HCFK
has been added in 2011. Therefore, no additional
measures are necessary.
3.2.4 Odour
Target (related to inconvenience)
No odour emission
Status of measures in this plan period
Emissions at Sappi Nijmegen BV do not lead
to detectable odour pollution outside of the
premises. No additional measures are necessary.
3.2.5 Dust
Target (related to dissemination)
No dust pollution
Status of measures in this plan period
Dust emission is the result of periodical filling
of the starch containers. Total emission per
year, based on a single measurement, is approx.
40 kg. There have been no changes in
installation or process circumstances since.
3.3 Water
Intaken groundwater is used in the production
process.
Sluice and regeneration water from the heatpowerplant
is transferred, along with process
waste water, to the Sappi Nijmegen owned
purification installation in Weurt. The same is
true for part of the waste water from the laboratories,
the other part of which is drained to
communal sewage - exact percentages are
impossible to specify. Approx. 1% of the mill’s
total water consumption concerns domestic
water used in the offices. Waste water resulting
from domestic use is drained to communal
sewage.
24 Environmental Statement 2011
3.3.1 Groundwater used in production
processes
Target (related to dehydration)
Maintaining performance level of 2010
Status of measures in this plan period
During the last plan period of 2003-2010, water
consumption has been reduced from approx.
15 m 3 /tons to approx. 8 m 3 /tons.
According to the IPPC reference documents,
the production of one ton of graphic paper
requires 10 – 15 m 3 of water, see paragraph
3.11.
Further reductions are not expected for this
plan period.
3.3.2 Pollution units (PU’s)
Target (related to dissemination)
Maintaining performance level of 2010
Measures implemented / measures planned
/ status in this plan period
The increase in 2011 as compared to 2010 is
caused by higher load in the waste water
treatment plant. This higher load, in turn, was
caused by the extensive use of broke as a result
of poor runability on the paper machine.
Sappi Nijmegen BV is one of the participants
in project Waterwaarde – The Value of Water
- aimed at filtering green fatty acids from the
process water used in paper and board production.
As part of the biological refining pro-

gram of project Energy Transition Paper
Chain, researchers are investigating practicable
innovations that add value to the raw materials
currently in use by the paper industry.
Today, production of fatty acids is countered
by adding biocides. This slows acid formation
down to a point where those acids that are
still being produced can be broken down in
the waste water purification process. In the
context of project Waterwaarde a pilot installation
has been built to isolate fatty acids from
paper industry process water and locate the
best suited point in the process to do so.
In 2011, research was conducted on possibilities
to isolate fatty acids at an early stage of
the production process, during stock preparation.
Sappi Nijmegen has participated in
this research. More information is available at
www.kcpk.nl
In 2012, additional research will be conducted
on reducing the loss of fatty acids in
the coating kitchen and other components of
the production chain.
3.3.3 Nitrogen (N) and Phosphor (P) in
waste water
Target (related to composting)
Use of waste nutrients as of 2012
Measures implemented / measures planned
/ status in this plan period
Sappi Nijmegen BV’s water purification plant
and the sewage water purification installation
owned by Waterschap Rivierenland are both
located in the industrial area of the city of
Weurt, Jonkerstraat, Industrial Zone West Kanaaldijk.
The two plants are on adjacent lots.
As the waste water from paper production is
not rich enough in nitrogen (N) and phosphate
(P) to ensure proper natural purification,
both elements are added in the waste
water treatment process, in a mix of nutrients
purchased for this purpose and added in prescribed
dosages.
The adjacent, municipal waste water treatment
plant, with a capacity of 400,000 pollution
units, processes domestic waste water
from the city of Nijmegen and the surrounding
villages, which, as is generally true for domestic
waste water, contains a relatively high
proportion of N and P, released in different
phases of the purification process and ending
up in a mixed stream.
An idea has been worked out to use this nitrogen
and phosphor containing mixture in
the waste water treatment plant at Sappi Nijmegen.
In 2011, requests for a license and
financial support have been submitted and a
first agreement has been reached. It is expected
that technical realization will start in
the spring of 2012.
3.4 Waste material
Waste material is collected separately, according
to procedures in the environmental management
system. Every month, data on
waste material, both quantitative and qualitative,
are reported internally.
3.4.1 Purification sludge
Target (related to disposal)
Maintaining performance level of 2010
Status of measures in this plan period
During the last plan period, 2003-2010, purification
sludge volume has been reduced
from 42 kg/tons to 20 kg/tons. Further reductions
are not expected for this plan period.
The increase in 2011, as compared to 2010,
is caused by poor runability on the paper machine,
leading to high losses of material in the
months of May and June.
Environmental Statement 2011 25

3.4.2. Industrial waste
Target (related to disposal)
Maintaining performance level of 2010
Industrial waste consists of general waste
from the production process, waste wood
and sewage sludge. The volumes for each
component are listed in Appendix 2.
Status of measures in this plan period
The volumes of industrial waste have been
more or less consistent in recent years. Research
on possible reductions in 2011 did not
yield significant results, so that for now,
maintaining current performance levels remains
the most practicable target.
3.4.3 Re-usable waste
Target (related to disposal)
Maintaining performance level of 2007-2009
Re-usable waste consists of metal, wood
(pallets) and paper waste (paper/board/
cores). The volumes for each component are
listed in Appendix 2.
Status of measures in this plan period
The volumes of re-usable waste have been
more or less consistent in recent years. The
target is to maintain the performance levels of
2007 – 2009. In 2010 and 2011, a once-only
volume of broke has been disposed of, causing
a result slightly above the set target.
Sappi Nijmegen BV produces only reels,
which means that all packaging at the mill
consists of reel packaging. The material used
is paper and the process of packaging is always
closely monitored, because of strict demands
for both quality and safety, especially
during handling. What this means, is that there
is little or no margin for manipulation of nature
or volume. Amount and type of packaging
material are, however, constant
issues of consideration and regular assessment.
The high volume in 2010 is caused by onceonly
disposal of rejected paper reels.
3.4.4 Hazardous waste
Target (related to disposal)
Maintaining performance level of 2010
Hazardous waste consists of used oil, oil and
water mixtures, solid oil containing waste,
miscellaneous and small hazardous waste.
The volumes for each component are listed in
Appendix 2.
Status of measures in this plan period
The volumes of hazardous waste have been
more or less consistent in recent years. The decrease
as compared to 2010 is caused by the
absence of disposals of small hazardous waste
in 2011. This type of waste, in contrast to used
oil, can be collected and constitutes a more or
less regular stream of waste. The target is
maintaining the performance level of 2010.
3.4.5 Material efficiency
Material efficiency for the production of paper
at Sappi Nijmegen BV refers to the yearly bulk
stream of used raw materials and additives,
expressed in tons (with the exception of energy
carriers and water).
Environmental Statement 2011 27

Material efficiency is based on the relation of
produced paper (net saleable paper, NSP) to
production loss. Production loss is the
amount of purification sludge (external) and
paper produced but disposed of (rejected
product, unsuited for internal re-use). To facilitate
objective comparisons, the bulk streams
are first converted to 100% adro (100% dry
substance share).
Below is an overview of material efficiency,
one of the key indicators in the EMAS III provisions,
for paper production at Sappi Nijmegen
BV.
3.5 Soil
3.5.1 Soil preservation
The presence of certain potential sources for
soil pollution within Sappi Nijmegen B.V. is
inherently linked to the production process.
On locations where this is the case, floors
have been protected with liquid-proof layers,
resistant to the chemicals used in the mill.
This applies to:
• work place floors
• floors in storage areas for chemicals and
oils
• floor of the boiler house
Target (related to disposal)
No soil emissions
All storage locations within Sappi Nijmegen
B.V. have been equipped with adequate pro-
Net Paper production Sales (NPS)
95 % adro, in tons
Purification sludge
45 % adro, in tons
Dirty white
95 % adro, in tons
Material efficiency (key indicator)
Relation: NSP (purification sludge
+ dirty white)
28 Environmental Statement 2011
Material efficiency
visions to minimize the chance of soil pollution.
This has been assessed in compiling the
BRD (BodemRisicoDocument – Soil Risk Document),
according to the NRB methodology.
All measures proposed in this document have
been implemented. In 2006, the document
has been updated and new measures have
been planned and implemented based on the
new findings.
3.5.2 Soil sanitation
Target (related to disposal)
Prevention of further spreading of present
pollution
Current status
In the context of BSB, an exploratory investigation
was conducted on the premises of
Sappi Nijmegen BV in 1996, followed up by
additional studies on specific locations. External
consultants then suggested recommendations
in a monitoring plan, which has
been approved by BSB. The plan lists locations
eligible for monitoring, also indicating
frequency and phasing. The monitoring plan
has been carried out by Sappi Nijmegen BV
until January 1, 2008, when BSB Gelderland
suspended its activities and the file was taken
over by the City of Nijmegen.
In consultation with the City of Nijmegen, a
start has been made to update the previous
soil surveys, to be followed by risk assessment
as to severity and urgency of the existing
situation. In 2008, the authorities in
1985 2009 2010 2011
100% adro 100% adro 100% adro 100% adro
120,600 114,570 197,184 187,325 217,923 207,027 194,633 184,901
13,600 6,120 4,168 1,876 4,327 1,947 5,056 2,275
97 92 219 208 326 310 279 265
94.6 % 98.9 98.9 98.6

charge, in this case the City of Nijmegen,
have been requested to rule on this assessment.
Currently, at the City’s request, additional
soil tests are being carried out on various
locations. In October 2010 the City of Nijmegen
concluded that “a situation of serious soil
pollution exists” but that “as there are no immediate
unacceptable risks, sanitation can
wait until there are naturally suited circumstances,
as in the case of new construction.”
3.6 Noise
Target (related to inconvenience)
Meeting the standards of the ‘Zone Model’ of
the City of Nijmegen
The industrial area in which Sappi Nijmegen
BV is located, has been divided into a number
of ‘zones’ according to the Wet Geluidhinder,
the Noise Pollution Act. These zones are managed
by the City of Nijmegen.
Sappi Nijmegen B.V. complies to all regulations
pertaining to noise in the current license
granted under the Environmental Management
Act.
3.7 Fire prevention, external
safety and emergencies
3.7.1 BHV organization
Sappi Nijmegen BV has its own BHV organization
(BedrijfsHulpVerlening – Emergency
Assistance Team), which is on call 24/7, 365
days in the year. The team consists of fire
fighters and first-aid specialists, supervised
by a BHV Coordinator. End responsibility lies
with the Production Shift Leader. Apart from
this BHV organization, Sappi Nijmegen BV
also has an emergency team, made up of
members of the management team. Depending
on type and severity of the situation at
hand, the emergency team can assume full
control.
In 2011, fire fighters and first-aid personnel
have practiced their knowledge and skills in
adhering to procedures as stipulated in the
BNP, the company emergency plan.
Environmental Statement 2011 29

3.7.2 BHV resources
Fire extinguishers are available at many, strategically
selected locations on the mill’s premises
and part of the mill is protected by a
sprinkler installation.
All fire extinguishers are checked on a yearly
basis, the sprinkler installation is inspected
once a year. For several areas housing electrical
equipment, such as the computer room,
extinguishing gas installations have been provided.
The internal fire department has a dedicated
own station and a fully equipped fire engine.
3.7.3 Storage of hazardous substances
Internal storage of hazardous substances
(less than 10 tons, packaged) is organized
according to the level of protection as stipulated
in PGS. In 2005, a new storage regime
was implemented for small dangerous waste
(KGA), by way of response to relevant
changes in PGS 15.
An external firm provides storage of raw materials
and additives (more than 10 tons, packaged)
according to the PGS. The firm is
certified according to the ISO-14001:2004
standard.
3.8 Traffic and Transport
Logistics continue to play a vital role within
Sappi Fine Paper Europe. On a yearly basis,
Sappi Logistics Wesel, Sappi’s logistic headquarters
in Germany from where finished products
are shipped to their final destinations,
reviews all transport options from a strategic,
economical and environmental perspective.
Regularly, Sappi reviews planning and actual
execution of transport to make sure that the
most efficient options are chosen for supply
of raw materials and additives to its production
sites and delivery of finished end products
to its customers.
In 2011, 94% of all raw materials used was
brought in by ship, the remaining 6% by road
transport, Finished reels are predominantly
transported by road, a relatively small proportion
being shipped by waterways.
30 Environmental Statement 2011
The load factor of road transport is constantly
monitored by Sappi Logistics Wesel and
where necessary, measures are taken in consultation
with hauliers, customers and internal
planning. Reliability of delivery is also closely
monitored in order to detect traffic problems
for specific areas in an early stage.
In the context of traffic and employees, a bicycle
plan was developed and initiated in the
first quarter of 2001 as a way to stimulate the
use of bicycles, as an alternative to cars, in
commuter traffic. Many employees have enthusiastically
participated in this programme.
3.9 Indirect environmental
impacts
3.9.1 Raw materials and additives
Since 1998, procurement of raw materials
and additives is to a large extent centralized
on corporate level in Sappi Europe’s Central
Purchasing function in Brussels. Goods that
are used throughout the Sappi Europe organization
are purchased by means of direct
contracts with Sappi Europe. On call, these
goods are supplied to the mills. Environmental
considerations play an important part in
this approach, as is testified by the Sappi Sustainability
Report, the latest version of which
is available at www.sappi.com.
To verify if and to what degree our suppliers
meet the demands set by Sappi Fine Paper
Europe, regular audits take place, performed
by specialized audit teams. Goods that, in
utilization, are unique to Nijmegen mill, are
ordered separately by Sappi Nijmegen BV.
(see paragraph 3.9.3 Services).
3.9.2 Products (utilization and waste
phases) and content of product
range
Sappi Nijmegen BV has drawn up a complete
inventory of all environmental aspects of its
products in the utilization and waste phases.
These environmental aspects mainly pertain
to transport in the utilization phase and recycling
of paper in the waste phase.

Transport is assessed and, where possible,
guided through planning of transport and logistics.
In the waste phase, waste paper is by far the
most important raw material for the production
of new paper in the Netherlands: 75%
consisting of waste paper, 25% consisting of
wood fibres (source: Informatiecentrum Papier
en Karton, the Information Centre for Paper
and Board, papier.pagina.nl). Based on
this factual situation, Sappi Nijmegen BV
sees no grounds for further action on this issue.
3.9.3 Services
The Procurement department of Sappi Nijmegen
BV is responsible for sourcing of services
and (temporary) labour. The environmental
impact of procured services is controlled by
express conditions in all contracts, with regard
to rules dictated by the (environmental)
management system. Companies supplying
the services are responsible for meeting these
conditions. Periodically, Sappi Nijmegen
BV evaluates its suppliers in order to further
optimize the sourcing of services.
3.9.4 External safety
External safety is ensured by adequate training.
Process operators, engineers, lab technicians
and members of other departments
dealing with (environmentally) hazardous substances
have all been thoroughly trained in
handling these materials. The internal fire brigade
also trains regularly in dealing with environmentally
dangerous situations. Special
procedures have been developed to prevent
mistakes in the unloading of chemicals. Control
measures have been taken to prevent
incidents with possible impact on the environment
and energy procedures are in place
for the unlikely event of environment related
incidents.
All incidents and reports are documented,
thus providing input for the management review
as well as the EcoSig environmental
analysis procedures.
3.9.5 Design, development and capital
investments
Following procedures laid down in the management
system, potential environmental
impact is considered in an early stage of process
and product design and development
by way of projects and capital investments.
This way, safety and environment are vital
factors in the process of decision making. All
planned projects must be authorized by the
Safety & Environment Department before actual
start-up. When a project is finished, the
same department again assesses compliance
to safety aspects and environmental
requirements.
3.10 Effects on biodiversity
In 2005, as part of the outlines of BMP-3,
Sappi Nijmegen B.V. investigated the applicability
of the Habitat and Bird Wildlife directive.
There is a protected nature reserve within a
range of 10 kilometres from the mill’s premises,
the Ooijpolder, east of Nijmegen. As
the mill, however, is situated on the opposite
side of the city, west of Nijmegen, it has been
concluded in consultation with the authorities
that the Habitat and Bird Wildlife directive
does not apply and that, as a result of minimal
impact on the protected area, there are
no consequences for Sappi Nijmegen BV.
The total surface area of the mill premises covers
60,000 m 2 , approximately 40,000 m 2 of
which is built-on. For the waste water purification
plant, the numbers are 7,000 m 2 total
surface area, 2,000 m 2 built-on.
3.11 Education
Dedicated budgets for education are available
every year. These are used for professional
training, but also for classes in safety and
environmental issues.
Environmental Statement 2011 31

3.12 Comparison to BAT-Bref /
IPPC / E-PRTR
The table below lists the results of a comparison
of procedures used by Sappi Nijmegen
BV with Best Available Techniques in the pulp
and paper industry. The assessment is based
on IPPC reference documents, describing
best available techniques in the industry on
the basis of information exchange within the
European Community according to directive
96/61/EG.
On March 1, 2006, the Province of Gelderland
performed a test to determine whether
the provisions of the European IPPC guidelines
and the relating Brefs have been implemented
in the business operations of Sappi
Nijmegen. Evaluated Brefs included Pulp and
Paper, Storage and Transfer of Bulk Material,
Large Burner Installations and Monitoring.
The conclusion was that “Sappi Nijmegen BV
has shown to have invested and continues to
invest sufficient effort to ensure that its environmental
performance meets all principles of
Parameter Unit Emission level in
case of BAT
application
IPPC in terms of the application of BBT. Under
the provisions of the IPPC guidelines, therefore,
no changes to the current environmental
licenses are called for.”
Explanation of higher values (in relation
to BAT Bref)
None. There is a slight increase in parameter
values as compared to 2010, particularly in
the cases of process heat and gas supply.
This is caused by poor web behaviour on the
paper machine in the months of May and
June.
3.13 European Pollutant Release
Transfer Register (E-PRTR)
In 2006, the E-PRTR directive, European Pollutant
Release Transfer Register, became effective,
This directive makes it obligatory for
businesses to yearly measure and record
emission levels and report findings to the authorities.
The authorities are obliged to publish
these data, making them publicly available.
The report supplied by Sappi Nijmegen BV
will be part of the electronic Environmental
Year Report.
Comparison to BAT-Bref / IPPC / E-PRTR
Emission level
Sappi Nijmegen
2010
Emission level
Sappi Nijmegen
2011
BZV 5 kg/t paper 0.15 - 0.25 0.05 0.06
CZV kg/t paper 0.5 - 1.5 0.4 0.5
TSS (total
suspended
solids)
kg/t paper
0.2 -0.4 0.07 0.09
total P kg/t paper 0.003 – 0.01 0.001 0.001
total N kg/t paper 0.05 – 0.2 0.02 0.02
debit m3/t paper 10.0 - 15.0 7.9 8.1
elektricity MWh/t paper 0.7 -0.9 0.5 0.5
process heat GJ/t paper 7.0 - 8.0 6.0 6.6
gas supply mg NOx/MJ 30.0 - 60.0 45 50
* taken from Bref Pulp and Paper
See Appendix 3 for explanation of the figures
32 Environmental Statement 2011

Validator’s data
This environmental statement, dealing with environmental effects for the year 2011, has been
subjected to validation by DNV.
DNV’s accreditation number is NL-V-002.
Based on documents, data and information released during the validation process as a result
of investigations into the internal procedures of Sappi Nijmegen BV, Mr J.C. Stans, on behalf
of DNV, declares that the environmental management system in use by Sappi Nijmegen B.V.,
including its environmental policy, programme and statement, meets all requirements of the
EMAS III Directive (November 29 2009, nr. 1221)
Next environmental statement
Sappi Nijmegen B.V. intends to publish the next EMAS statement, pertaining to 2011, before
July 1, 2013.
Environmental Statement 2011 33

Appendix 1
Glossary
Term Explanation
Arbo Arbeidsomstandigheden - Working conditions
AWZ Afvalwaterzuivering – Waste water purification
BAT/Bref EC reference document listing best available
techniques in the pulp and paper industry
BEES Besluit Emissie Eisen Stookinstallaties – ruling on emission limits for boiler installations
BHV Short for “Bedrijfshulpverlening” – company assistance unit
BMP Bedrijfs Milieu Plan - Corporate Environmental Plan
BSB
Bodemrisicodocument
“Commissie Bodemsanering in gebruik zijnde Bedrijfsterreinen” – commission for soil sanitation
of operational business areas
Soil risk document - analysis of the risks of soil pollution presented by different installations on
the premises
BOD Biological Oxygen Demand, a measure for biodegradable pollution of waste water
CFC
CO en CO2 Chlorofluorocarbons, compounds used, among other things, as refrigerants in air-conditioning
installations
Carbon monoxide and carbon dioxide, by-products of full or partial combustion of fossil fuels.
CO2 is one of the causes of global warming.
COD Chemical Oxigen Demand, measure for the pollution of waste water
dB(A) Decibel, measure for the volume of sound
EHBO Short for “Eerste Hulp Bij Ongelukken” – first aid
EMAS Eco Management and Audit Scheme, EC regulatory system for environmental management and
auditing
E-PRTR European Pollutant Release Transfer Register.
International Organization for Standardisation, a committee setting standards for different
ISO
aspects of business operations, such as quality (ISO-9001:2008) and environment (ISO
14000:2004)
IMT Short for “Integrale Milieu Taakstelling” – overall environmental objectives
IPPC Integrated Pollution Prevention and Control, EC guideline on integrated prevention and control
of pollution
KGA Short for “Klein Gevaarlijk Afval” – small hazardous waste
LPG Liquid propane gas
MTR Short for “Maximaal Toelaatbaar Risico” – maximum allowable risk
NEa Nederlandse Emissieautoriteit – Dutch emission authorities
NeR Nederlandse Emissie Richtlijnen – Dutch emission guidelines
NMP Nationaal Milieubeleidsplan – National environmental policy plan
NOx Nitrogen oxide, by-product of the combustion of fossil fuels. NOx is a factor in climate change.
NPV Short for “Netto product(ie) verkoopbaar” – net saleable product
NRB Nederlandse Richtlijn Bodembescherming – Dutch guideline for soil protection. Guidelines for
optimal choice of soil protecting measures and provisions.
OHSAS Occupational Health and Safety assessment series, international standard for management of
working conditions
PGS15 Publicatie gevaarlijke stoffen – hazardous substances publication.
Guideline for storage of packaged hazardous substances
in terms of fire safety, safe working conditions and environmental safety.
Pulper Stock preparation tank
Precoating First layer of coating applied to the paper, serving to smooth out coarse irregularities in the base
paper. Followed by an additional coating layer, referred to as topcoating.
PQM Proces Quality Management
SCCM Stichting Coördinatie Certificatie Milieu- en Arbo managementsysteem, Dutch organization
responsible for enforcing compliance to EMAS regulations
STEK Stichting Erkenningsregeling voor de uitvoering van het koeltechnische installatie bedrijf, Dutch
organization responsible for compliance to cooling regulations
SVW
Short for “Samen Veilig Werken” – working safely together, programme aimed at detection and
elimination of unsafe behaviour
Reel drum Metal axis the paper is spooled onto
VNP
Vereniging van Nederlandse Papier- en kartonfabrieken, association of Dutch paper and board
producers
VROM Ministerie van Veiligheid, Ruimtelijke ordening en Milieu, Dutch ministry of safety, town and
country planning and the environment
WKC Short for “Warmte Kracht Centrale” – combined heat-power plant
34 Environmental Statement 2011

Appendix 2
Facts and figures relating to Sappi Nijmegen B.V.
Description Unit 2009 2010 2011
Endproduct reel paper (NSP) ** Tons 197,184 217,923 194,633
Natural gas, purchased 1.000m3 40,427 41,418 40,838
Electricity, total consumption
(including waste water purification)
MWh 103,311 105,380 102,848
Energy consumption (ISO 50.001)
MJ/gross
tons
6,344 6,091 6,202
Exhaust PM7 - Ammonia Tons 2.0 5.0 0.3
NOx total Tons 66.2 58.9 64.9
CO2 total Tons 72,549 74,205 73,158
Groundwater m3 1,796,023 1,784,453 1,661,545
Waste water purification plant
(drainage to river after cleaning)
m3 1,704,394 1,726,465 1,573,718
Nitrogen (N) Tons 6.7 3.3 3.3
Phosphorus (P) Tons 1.7 0.2 0.2
Chloride (Cl-) Tons 373 345 365
Suspended solids Tons 29 16 18
BZV Tons 19 10 11
CZV Tons 115 98 101
pollution (based on BZV and nitrogen, including v.e. 1,835 890 1,125
transfer)
Industrial waste Tons 129 125 125
Re-usable waste Tons 671 799 730
Purification sludge (wet) Tons 4,168 4,311 5,056
Hazardous waste Tons 20 14 10
* Data reliability 99,9%
** Equals B for key indicator calculation
Environmental Statement 2011 35

Appendix 3
Clarification of facts and figures (Appendix 2 and paragraph 3.12)
Production
End product reel paper based on Sappi annual
figures for 2011.
Energy
Total internal use of electricity based on invoices.
Air
NO (total)
gas turbine and boiler 6
steam boilers 5 and 7
infrared jets
mixed-air heaters
Water
As of 2008, groundwater consumption is recorded
on the basis of calibrated measurements.
Pollution units for 2011 are based on internal
calculations.
As of 2007, chloride volumes are analysed by
accredited laboratories.
Phosphate recorded while measured, according
to measurement deposition.
Waste (non-hazardous)
Industrial waste consists of general waste
from the production process, waste wood
and sewage sludge.
Re-usable waste consists of metal, wood
(pallets, based on 15 kg per pallet) and paper
waste (paper/board/cylinders).
Not included are packaging materials such as
barrels, big-bags and pallets (as these are returnable).
Volumes of used oil are indicated in kilograms,
based on conversion using the following
formula: used oil (litres) x specific mass
(0.9 kg/l).
36 Environmental Statement 2011
Comparison to BAT-Bref / IPPC /
E-PRTR (paragraph 3.12)
Emission levels for BOD5, COD, Total Suspended
Solids, Total P and Total N have
been calculated by dividing year load by
net production (Net Saleable Product).
Emission levels are listed in Appendix 2.
Debit emission level has been calculated by
dividing the purification plant waste water
totals from Appendix 2 by Net Saleable
Product.
The emission level for electricity has been
calculated by dividing Electricity, total consumption
from Appendix 2 by Net Saleable
Product.
The emission level for process heat has
been calculated by multiplying gas consumption
from Appendix 2 by the calorific
value of gas (0.03165 GJ/m 3 ) and dividing
the outcome by Net Saleable Product.
Gas supply emission level has been calculated
by dividing the NO emission (in mg)
from Appendix 2 by the calorific value of
total gas consumption (gas consumption
multiplied by calorific value of gas (31.65
MJ/m 3 ).

Appendix 4
Overview and justification of presented data
Description
Air
Justified by
Ammonia
Measurement reports and registration of ammonia-containing
raw materials consumption
NOx, CO2 ,CO
Water
Measurement reports, calculations, registrations, gauging
reports and registration of gas consumption
Groundwater
Waste water purification
Registrations, gauging reports, reports
plant (drainage to river
after cleaning)
Effluent emissions
Registrations, gauging reports, reports
Phosphorus (P) Analysis data from accredited laboratory, calculation
Chloride (Cl-) Analysis data from accredited laboratory, calculation
Suspended solids Analysis data, calculation
Nitrogen (N) Analysis data from accredited laboratory, calculation
COD Analysis data from accredited laboratory, calculation
BOD Analysis data from accredited laboratory, calculation
Registrations, analysis data from accredited laboratory, counter-
Pollution units (PU’s)
Waste material
sampling, calculations
Industrial waste Registrations, weighing tickets, internal reports
Re-usable waste Registrations, weighing tickets, internal reports
Purification sludge
(approx. 40% ds1)
Registrations, weighing tickets, internal reports
Hazardous waste
End products
Registrations, weighing tickets, internal reports
PM 7 (reel paper)
Energy
Registration, weighing, gauging reports (weighing)
Natural gas, purchased Registrations, gauging reports, reports
Electricity Registrations, gauging reports, reports, third party invoices
Environmental Statement 2011 37

Appendix 5
Overview of complaints registered and reports submitted
by Sappi Nijmegen BV (2011)
Complaints registered by Sappi Nijmegen BV in 2011
07-10-2011 Due to miscommunication, no permit was issued to a ship’s captain for
unloading cellulose. This has been reported by way of complaint to the
Province of Gelderland. The company has been advised of the incident, after
which the permit was issued as a retroactive correction.
Reports submitted by Sappi Nijmegen BV in 2011 to the authorities in matters pertaining to
the environment
11-04-2011 Water: Approximately 600 m3 of water has been transferred to communal
sewage.
15-06-2011 Water: As a result of broke disposal, approximately 200 m3 of water has been
transferred to communal sewage.
13-08-2011 Water: As a result of pressure fluctuations during broke disposal, a conduit to
the waste water treatment plant burst, causing waste water and paper pulp to
flood streets, ending up in ditches. At the same time, approximately 2,050 m3
of water was transferred to communal sewage. An extensive report has been
made, with suggestions to prevent similar incidents in the future.
04-10-2012 Water: As a result of new pump settings after a conduit burst, approximately
104 m3 of waste water was transferred to communal sewage.
27-10-2011 Water: At the request of Waterschap Rivierenland, water was transferred to
communal sewage. This was done in connection with maintenance to the
effluent mill, which also processes effluent from Sappi Nijmegen’s waste water
treatment plant.
Four out of five reports concern discharges of waste water into communal sewage. These
discharges of waste water into communal sewage have no negative impact on the environment.
38 Environmental Statement 2011

Appendix 6
Overview of key legislation, requirements and compliance
Source document Requirement description
Soil Protection Act Legislation concerning soil protection
Soil Quality Decree Ruling with regard to existing, historical pollution
Soil Sanitation Circular
2006
Elaboration on sanitation standards and objectives
Groundwater Act, as of Guidelines for the extraction of groundwater
22-11-2009 Water Act
CLP (EU-GHS)
regulation (EG nr
1272/2008)
Provincial Environment
Provision
Implementation Act EC
guideline for trade in
emission rights
Provincial Environment
Agreement
Regulation for arrangement, labelling and packaging of substances
and mixtures
provincial policy and guidelines concerning the environment
regulations on monitoring, reporting and trade in CO 2 and NO x
charter with Province of Gelderland concerning waste
Soil preservation Soil sanitation premises in industrial use (mandatory soil check)
BEES-A
Inspection and
maintenance boiler
installations
decree on emission requirements boiler installations
Policy statement parent company specific policy
Eural European list of waste material
CE-mark
Conformité Européene, European safety hallmark, testing
requirements for installations using natural gas
GIVEG Dutch centre for gas technology, supervisor for gas installations under
GIVEG testing requirements
EMAS III European standard
IPPC directive European guideline on the prevention of environmental pollution
PRTR protocol
Disclosure and transparency of emissions and transport of polluting
substances
EC directive transport
of waste material
Regulations on transport of waste material within the EC
REACH Registration, Evaluation and Authorization of Chemical Substances
PGS Publicatiereeks Gevaarlijke Stoffen – Hazardous Substances
Publication Series
ADR guideline/ Guideline on transport, loading and unloading of hazardous
Transport of Hazardous substances
Substances Act
Environmental Statement 2011 39

Sappi Nijmegen BV
Ambachtsweg 2
6541 DB Nijmegen
Nederland
Tel + 31 (0) 24 371 09 11
Fax + 31 (0) 24 371 07 46
www.sappi.com
sappi
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