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W W W.V E R M O N TR E A LE S TAT E

352 PAPER MILL ROADEAST R

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W W W.VE R M O N T R E A L ES TAT E

352 PAPER MILL ROADEAST R

W W W.V E R M O N T R EA L E S TATE

352 PAPER MILL ROADEAST R

State of Vermont

LAND USE PERMIT

CASE # 7C1026 APPLICANT CPM Inc./Kimberly-Clark Corp. ADDRESS Main Street

PO Box 95 East Ryegate, VT 05042

LAWS/REGULATIONS INVOLVED

10 V.S.A., Chapter 151 (Act 250) and Vermont State Environmental Protection Rules: Chapter 61, Water Supply and Wastewater Disposal

District Environmental Commission #7 hereby issues Land Use Permit #7C1026 pursuant to the authority vested in it in 10 V. S .A., Chapter 151. This permit applies to the lands identified in Book 34, Pages 99-107 of the land records of Ryegate, Vermont, as subject of a deed to CPM Inc./K.imberly-Clark Corp. Main Street, PO Box 95, East Ryegate, VT 05042, the "permittee as grantee". This permit specifically authorizes the permittee to construct of a 75' X 269' bulk storage warehouse extending south from the existing mill buildings, a 32' X 48' infrared burner control building located between existing mill buildings, a 3 O' X 40' forklift truck maintenance garage, and a 20' X 100' covered railroad unloading dock located south of the warehouse building. The project also introduces latex saturating capability (paper coating process) to the paper manufacturing process. This project is located on 5. 5 acres of a 24. 5 acre tract on Town Highway 70 in East Ryegate, Vermont.

The permittee, its assigns and successors in interest, are obligated by this permit to complete and maintain the project only as approved by the District Commission in accordance with the following conditions:

1. The project as described above and authorized above shall be completed , maintained and operated as set forth in Findings of Fact and Conclusions of Law and Order #7C1026, in accordance with the plans and exhibits on file with the District, and in accordance with the conditions of this permit. No material changes shall be made in the project without the written approval of the District Commission.

2. By acceptance of the conditions of this permit without appeal, the permittee confirms and agrees for itself and all assigns and successors in interest that the conditions of this permit shall run with the land and the land uses herein permitted, and will be binding upon and enforceable against the permittee and all assigns and successors in interest.

Land Use Permit #7Cl026 CPM, Inc./Kimberly-Clark Corp. East Ryegate, VT Page2

3. The District Commission maintains continuing jurisdiction during the lifetime of the permit and may periodically require that the permit holder file an affidavit certifying that the project is being completed in accordance with the terms of the permit.

4. By acceptance of this permit the permittee agrees to allow representatives of the State of Vermont access to the property covered by the permit, at reasonable times, for the purpose of ascertaining compliance with Vermont environmental and health statutes and regulations and with this permit.

5. This permit hereby incorporates all of the conditions of Water Supply and Wastewater Disposal Permit #WW-7-0661 issued on August 13, 1997 by the Regional Engineer, Wastewater Management Division, Department of Environmental Conservation, Agency ofNatural Resources.

6. The permittee and all assigns and successors in interest shall install and maintain water­conserving non-process plumbing fixtures including but not limited to low-flush toilets, low-flow showerheads, and aerator-type or flow-restricted faucets.

7. The heated structures approved herein shall be constructed in accordance with the plans on file with the District Commission. The installation and use of uncontrolled electric resistance heating systems is prohibited without the review and approval of the District Commission.

8. The permittee shall continually maintain the landscaping substantially as approved in the exhibits by replacing dead or diseased plantings as soon as seasonably possible.

9. The permittee shall comply with the exhibits for erosion control. Hay bale dams and silt fences shall be installed as depicted on the plans prior to commencement of construction within 24 hours of grading of the slopes. From October I st to April 15th of any calendar year, all non-vegetated disturbed areas of the construction site shall be mulched until final vegetation is permanently established. All erosion control devices shall be periodically cleaned, replaced, and maintained until vegetation is permanently established on all slopes and disturbed areas.

I 0. The permittee shall apply to the District Commission for approval for any material change in the manufacturing processes which could cause noxious or unhealthy emissions into the air or injection of toxic wastes into the soils.

Land Use Permit #7C1026 CPM, Inc./Kimberly-Clark Corp. East Ryegate, VT Page3

11. Storage of any hazardous materials unless in an approved containment area and stored in accordance with appropriate recognized procedures shall not occur outside of buildings.

12. There shall be no floor drains installed at the facility without first acquiring the required Underground Injection Control Permit from the Water Quality Division of the Agency of Natural Resources.

14. Within six months following issuance of this permit and findings, the permittee shall prepare and submit to the Commission an overall site "Master Plan" for review and approval. The plan should address outstanding stormwater, shoreline, hazardous material handling, and bulk paper storage issues as per discussion presented in the findings of fact.

15. All conditions of the Insignificant Waste Disposal Event Determination (IWDED) permit are incorporated herein.

16. Permittee shall not erect additional signage without first obtaining approval from the District Commission. (Necessary traffic safety, property posting, internal plant signage, etc. is exempted from this condition.)

17. Any new outdoor lighting shall be installed or shielded in such a manner as to conceal light sources and reflector surfaces from view substantially beyond the perimeter of the area to be illuminated.

18. Permittee shall not proceed with construction of this project without the approval of the proposed structure from the Vermont Department of Labor and Industry.

19. The permittee will map the archeologically sensitive areas on the site plan and label them as not-to-be-disturbed buffer zones. Copies of this revised site plan will be submitted to the District Commission and to the Division for Historic Preservation (DHP).

20. Topsoil removal, grading, scraping, cutting, filling, stockpiling, logging or any other type of ground disturbance is prohibited within the buffer zones without written approval of the District Commission and the DHP. Snowfencing, flagging, or other appropriate physical barrier will be placed at the edge of the buffer zones, where necessary as determined by the DHP, to make sure that it is clearly marked. The project contractor, if different than the permittee, will be notified through contract conditions about the buffer zone restrictions.

Land Use Permit #7Cl026 CPM, lnc./Kimberly-Clark Corp. East Ryegate, VT Page4

21. All other conditions and requirements, regarding Archeological and Historic Preservation issues, as presented and outlined in the findings of fact, shall be strictly adhered to.

22. Prior to demolition of the Lower Stock House, the structure will be documented in accordance with the Division's draft Photographic Documentation Requirements for Historic Structures. Copies of the documentation will be submitted to the Division and the Ryegate Public Library.

23. Each prospective purchaser of this tract shall be shown a copy of the approved plot plan, the Water Supply and Wastewater Disposal Permit and the Land Use Permit before any written contract of sale is entered into.

24. No further subdivision of the tract approved herein shall be permitted without the written approval of the District Commission.

25. Pursuant to Environmental Board Rule 2(f) and IO V.S.A. § 6086(a) (8), the Commission has reviewed this project in the context of the entire tract of land upon which the project is sited, as that tract is located in the general area. Accordingly, no changes shall be made to the balance of the tract prior to review by the District Coordinator or Commission under applicable Environmental Board Rules.

26. This permit shall expire three years from the date of issuance if the permittee has not commenced substantial construction in accordance with IO V.S.A. § 609l(b) (amended June 21, 1994).

27. Pursuant to IO V.S.A. § 6090(b) (effective June 21, 1994), this permit is hereby issued for an indefinite term, as long as there is compliance with the conditions herein.

28. Failure to comply with the above conditions may be grounds for permit revocation pursuant to IO V.S.A., Section 6090(b).

Dated at St. Johnsbury, Vermont, thisl4thday of August,~

BY iltwL~~Q_Q_ Edward N~ Chair District #7 Environmental Commission

Land Use Permit #7Cl026 CPM, Inc./Kimberly-Clark Corp. East Ryegate, VT Page 5

(C:\ACT250\FILES\7CI026.LUP)

Other members participating in this decision:

William Johnson Leniy Zenonos

Any appeal of this decision must comply with all provisions of 10 V.S.A § 6089 and Environmental Board Rule 40 including the submission of the original and ten copies of the following: notice of appeal, a statement of why the appellant believes the commission was in error, a statement of the issues to be addressed in the appeal, a summary of the evidence that will be presented, a preliminary list of witnesses, decision and certificate of service. Decisions on minor applications may be appealed if a hearing was held by the district commission or timely requested by the appellant.

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STATE OF VERMONT DISTRICT ENVIRONMENTAL COMWSSION #7

I RE: CPM, Inc./Kimberly-Clark Corp. Application #7C 1026 Findings of Fact and Conclusions of Law

· Main Street PO Box 95 East Ryegate, VT 05042

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IO V.S.A., Chapter 151 (Act 250)

i I. INTRODUCTION:

On February 7, 1997 an application for an Act 250 Permit was filed by CPM, lnc./Kimberly-Clark Corp. for a project generally described as the construction of a 75' X 269' bulk storage warehouse

.. extending south from the existing mill buildings, a 32' X 48' infrared burner control building located l between existing mill buildings, a 30' X 40' forklift truck maintenance garage, and a 20' X I 00' covered ! . railroad unloading dock located south of the warehouse building. The project also introduces latex i saturating capability (paper coating process) to the paper manufacturing process. This project is located ! : on 5.5 acres ofa 24.5 acre tract on Town Highway 70 in East Ryegate, Vermont.

The tract of land consists of 24. 5 acres with 5. 5 acres involved in the project area. The applicant's legal interests are ownership in fee simple.

Under Act 250, projects are reviewed based on the ten criteria of 10 V. S.A., Section 6086( a) 1-10. Before granting a permit, the Board or District Commission must find that the

, · project complies with these criteria and is not detrimental to the public health, safety or general ' welfare.

Decisions must be stated in the form of Findings of Fact and Conclusions of Law. The facts we have relied upon are contained in the documents on file identified as Exhibits 1 through 3 2 and the evidence received at a site visit and a hearing held on March 3, 1997. At the end of the hearing, the proceeding was recessed pending submission of additional information and deliberation. The hearing was finally adjourned on July 7, 1997 upon receipt of all the additional information and review of the record.

Parties to this application who participated in the hearing are:

(A) The Applicants by Joe Lemanski, Lee Roberts, Larry Reeb, Geofiley Williams and others.

(B) Agency of Natural Resources by Andy Raubvogel, Carl Pagel, Randy Bean, Eric Palmer and others.

(C) No other petitions for party status were made.

Findings of Fact and Conclusions ofLaw #7Cl026 I

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II. COMMISSION'S OPENING COMMENTS AND FUTURE PROJECT SITE j ! MASTER PLAN REQUIREMENT: . I lj

kimberly-Clark as applicant has, through this Act 250 permit application, proposed to make ~ubstantial improvements to the old CPM Paper Mill in East Ryegate, Vermont. The mill itself pre-dates Act 250 (1970) and has, until now, been exempted from Act 250 review. While still tjnder the so-called "grandfathered status" in regard to Act 250 jurisdiction, improvements were Ih.ade to the water quality treatment facilities at the plant. The addition of aeration splashers, :~ludge conveyors and a new clarified resulted in dramatically reduced solids and biological oxygen !demand (BOD) levels in water discharge .

. The present construction plans represent a "substantial change" under the Environmental Board Rules and thus an Act 250 permit will, for the first time, cover plant operations. Immediate 'capital improvements discussed herein are aimed at improving efficiency and expanding the mill's product lines to become more competitive and, hopefully, more profitable. The primary i~provement planned involves a roughly 5-8 million dollar project to provide latex saturating capability (paper coating process) and improved warehousing.

The mill site visit conducted as part of the hearing process made apparent some of the challenges ;associated with bringing a mill, built in 1902, into compliance with the best environmental .management practices of 1997. While considerable good work is being done at the mill, ~dditional improvements in regard to stormwater management and treatment, bulk paper storage, ! '. ·hazardous material handling systems and shoreline management may be necessary.

!I !~t hearing it was apparent that the scope of the present application was limited by the applicant's ;desire to make additional progress toward improving the site this year. As with the past efforts ;bn improving water quality, the present planned improvements will move the facility in a positive ;direction toward compliance under the ten Act 250 criteria. We recognize that it is not iteasonable to expect all aspects and elements of the facility to experience improvement overnight. JtJowever, to insure that all required improvements (or mitigation of impacts) at the facility are i made, the Commission, by permit condition, will require that within a six month period following : issuance of this permit and findings, a five year Master Plan for the site be prepared and submitted 1for Commission review and approval. It is the Commission's view, having reviewed the project I plans and having inspected the mill site, that the proposed plant improvements permeate the entire I project site and thus these specific issues must be further reviewed and ruled upon by the f f:ommission. The plan shall detail: 1. existing on-site stormwater paths and discharge points, 2. I shoreline encroachment and buffer protection issues, 3. hazardous materials handling <storage, lhse, recycling, etc.) throughout the site operations and, 4. bulk paper storage and handling I activity. The plan shall also identify any proposed changes to existing practices, operations or 1 tnethods of handling in regard to any of these areas identified above. The plan is to be submitted if or Co~ssion review ~d ap~roval und~r the ten A~ 2_50 criteri~ n? later t~an six_( 6~ ~o~ths : f ollowmg issuance of this pernut and findings. The D1stnct Commission retams full 1unsd1ct1on over these areas of site operations pending approval of the plan. As discussed at hearing, the plan I

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II llis intended to identify outstanding compliance issues at the mill, if they exist, and propose an approach for achieving compliance with all relevant state and federal law and in particular,

I compliance under the ten Act 250 criteria. A five year time line to gain necessary conformance

1 with identified issues was discussed at hearing as a reasonable time frame for achieving overall site

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I i The Commission has employed this same five year plan approach in the past with other aged :facilities (the 100+ year old Ethan Allen furniture manufacturing plant in Beecher Falls) with good 1 success. The applicant, at hearing, expressed their support for this Master Plan approach and the /Commission has offered the assistance of Environmental Board and Agency ofNatural Resources ! staff to assist in defining the necessary scope and goals of this Master Plan effort.

i I j The acceptance of this site Master Planning requirement without appeal has allowed the ; Commission to make positive findings under all ten criteria. We note that the present proposed

1 ! improvements, independent of the older mill and associated site activities, meet the standards i ! required by the ten criteria. l i

;III. FINDINGS OF FACT: ! I

l! /Prior to taking evidence with regard to the ten Criteria of 10 V.S.A., Section 6086(a), all parties

Ii agreed that the applicant through submission of the application material has met the burden of , proof with respect to: I In making the following findings, we have summarized the statutory language of the I 0 Criteria of 10 V.S.A., Section 6086(a):

I SECTION 6086(a)(l) Am POLLUTION:

j The Commission finds that this project will not result in undue air pollution. I j

11. The expected air emissions and odors and measures proposed to control them are

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· described in the Construction Permit Application prepared by Joe Lemanski of CPM Incorporated. This project does not include any new sources of noise that would be transmitted off site.

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The bulk storage warehouse and infrared burner control building will be heated by gas fired, roof mounted, hot air heating units. The maintenance garage will be heated with gas fired hot air unit heaters. The gas supply is a propane-air mixture supplied from the existing 30,000 gallon storage tank and associated vaporized and air mixer equipment located south and west of the warehouse building.

3. A Construction Permit Application has been filed with the Air Pollution Control Division.

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Dust will be controlled during construction by application of water or hygroscopic chemicals such as calcium chloride to reduce the generation of dust due to traffic.

Dust will be controlled during operation by paving work areas as shown on the site plan. High traffic areas such as the truck maneuvering space west of the warehouse building will be paved with bituminous concrete to reduce dust generation. The pulp storage yard located on the site of existing septic field will be similarly paved to reduce dust generation and match existing storage areas.

The hours of construction will be restricted to daylight periods with minor amounts of evening construction to coordinate earthwork placement with normal mill operations.

: SECTION 6086(a)(l)(Al HEADWATERS:

i The Commission finds that this project is not located in a headwaters area as defined by this section because it is not situated in a drainage area of 20 miles or less. The Commission finds that the project will meet applicable health and water resources regulations regarding the reduction of .the quality of the ground or surface waters.

:SECTION 6086(a)(ll(B) WASTE DISPOSAL:

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; ;The Commission finds that this project will meet applicable Division of Protection Regulations : land will not result in the injection of waste materials or harmful or toxic substances into ! j

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The majority of stormwater runoff from the building roofs, pulp storage areas and truck maneuvering areas will be directed through the existing stormwater system to the wooded wetland south of the warehouse and pulp storage yard. Since the existing outlet culvert through the railroad embankment is approximately two (2) feet above grade at the lower end of the wetland, the majority of the stormwater infiltrates into the sandy subsoil leaving its contaminates in the wetland area.

The runoff from the parking area on the east side of the new warehouse flows onto the existing vegetated side slopes down to the river. This buffer varies in width from 75 feet to over I 00 feet and provides treatment by sedimentation and vegetative uptake.

Process wastewater generated by the modifications within this project are treated in mill's existing wastewater treatment plant.

Latex coating chemicals and aqueous ammonia will be unloaded at the chemical unloading station and stored in tanks located at the south end of the bulk storage warehouse.

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past Ryegate, Vt. Page 5

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The latex coating will be stored in five stainless steel tanks of 7,500 gallons capacity, located within a concrete containment located within the building. The ammonia will be stored in a plastic tank of 5,000 gallon capacity located in a concrete containment area outside the south end of the warehouse.

The unloading station will be sloped to drain towards a trench drain which is connected to the wastewater sump inside the warehouse.

Any spillage at the truck or from hoses will be flushed into the drain and collected in the wastewater sump.

All unloading and transfer pumps and filters are located in the Latex Tank Containment, which drains to the wastewater sump.

Wastewater from the sump is pumped to the mill's process wastewater treatment system for disposal.

The ammonia tank containment will have a sump to collect spillage and stormwater. This wastewater will be pumped into containers for transfer to the mill's wastewater treatment system on an as needed basis.

Construction debris generated by the project will be removed from the site for disposal by a licensed disposal facility. Due to the project's minimal impact on wooded area, the amount of woody plant debris generated will not be significant. This material will be hauled off site for disposal by a licensed facility.

Discharge Permit

The Discharge Permit review section of ANR has determined that there will be no significant increase in flow and BOD content of discharge.

Bulk latex storage will be in a contained area capable of holding a complete tank failure.

Under the proposed design there can be no discharge to the existing wastewater treatment facility without material first going through the pre-treatment system.

A Discharge Permit has not been required for the project.

Insignificant Waste Disposal Event Determination IWDED

Applicant has applied to dispose of septic field stone and associated soils, concrete and asphalt on site. These materials will be generated from the removal of the existing septic field system at the mill.

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. Findings of Fact and Conclusions of Law #7Cl026 '.CPM/Kimberly-Clark Corp.

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East Ryegate, Vt. 1Page 6 I i :23. I

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The mill originally planned to connect to the municipal sanitary sewer.

Revisions to the plan show that the septic wastes may not be generated as a municipal connection may not be immediate.

In the event such waste disposal on site occurs it will occur in accordance with the terms and conditions of the ANR issued IWDED dated June I 0, 1997.

The terms and conditions of the IWDED are incorporated here by reference and shall be binding and enforceable under the Act 250 permit.

;SECTION 6086(a}(ll(C) WATER CONSERVATION:

The Commission finds that the project utilizes the best available technology for water : conservation. 1,

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This project does not include replacement of plumbing fixtures in the existing bathrooms and showers throughout the mill .

The plumbing fixtures installed in the recently constructed temporary office building are low flow fixtures as specified.

Any future modifications to the mill's sanitary facilities will include low flow plumbing fixtures.

The water required for the latex saturating process is expected to be less than 50,000 gallons per day. For environmental safety and also based on the cost of the latex coating chemicals, great care will be taken to avoid unnecessary waste in storage, mixing and cleanup operations.

The excess material supplied to the "size press" for application to the paper will be recycled continuously through the system.

The majority of water used for cleanup and latex wastewater treatment will be recycled from the mill's existing treatment system to reduce water usage.

!SECTION 6086(a)(ll<Dl FLOODWAYS:

I The Commission finds that this project will not be located in any floodway or floodway fringe.

! 33. The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (Panel '1 500030-00ISB) for the site does not specifically designate the boundary of the floodway.

It is assumed to be at the east wall of the existing paper machine buildings and the existing

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·'Findings of Fact and Conclusions of Law #7C1026 :cPM/Kimberly-Clark Corp. I

!East Ryegate, Vt. I iPage 7

I riverbank, as defined by the high bank east of the temporary office and the treeline east of i the employee access driveway (former town road) as shown on the site plans. No ! construction or filling will take place within the assumed floodway as part of this project. I ! .34. I I

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The floodway fringe is taken to be the area between the floodway proper and the 100 year flood plain boundary. The 100 year flood elevation is designated as Elevation 430 for this site. The FEMA map depiction of the flood plain boundary (shown on the site plan) is inconsistent with the Elevation 430 feet contour which is depicted as "assumed flood plain" on the site plans. l

I ,35. Fill area for the temporary pulp storage area and the lower pulp storage yard infringe somewhat into the assumed flood plain as defined at Elevation 430. The volume of potential flood storage displaced by the proposed fill is 101,500 ft3 in the lower pulp storage area and 33,900 ft3 in the temporary pulp storage area for a total of 135,400 ft3 or 3. 11 acre-feet.

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The temporary pulp storage area will be raised above Elevation 430 and the lower pulp storage yard and covered rail platform will be raised above Elevation 438. This will effectively flood proof the material storage area and rail unloading function by raising them above the 100 year flood level, consistent with the requirements of the National Flood Insurance Program.

I SECTION 6086(a)(l)(E) STREAMS:

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The Commission finds that the project will, whenever feasible, maintain the natural condition of the streams.

137. The only named stream adjacent to the work area is the Connecticut River as shown on the site plans. A man-made drainageway extends from the existing culvert discharge through the wooded wetland south of the lower pulp storage yard.

!38. The drainage area of the man-made drainageway is significantly less than ten (10) acres and none of the proposed modifications require a Stream Alteration Permit. I

I I SECTION 6086(a)(l)(F) SHORELINES:

The Commission finds that this project will not be located on any shoreline.

39. The Connecticut River is located on the eastern border of the project site.

40. The existing wooded and vegetated slope adjacent to the river will be designed as an undisturbed buffer on the site plan.

; : Findings of Fact and Conclusions of Law #7Cl026

1 CPM/Kimberly-Clark Corp. East Ryegate, Vt. Page 8

41. There is no present shoreline access for boats and watercraft permitted from the mill property. Fishing is permitted from the riverbank below the mill. The mill does not intend to fence the riverbank or otherwise prevent access for fishing.

42. The existing trees and vegetation along the riverbank will be retained as shown on the drawings. The landscape plans specify new trees and shrubs to be planted on the top of bank and along the east face of the buildings to screen the parking areas, office buildings and warehouse building from the river.

43. The existing vegetation will be retained and augmented with landscape plantings as shown on the plans.

SECTION 6086(a)(l)(G) WETLANDS:

The Commission finds that the project will meet applicable Water Resource Board regulations regarding any impacts on designated significant wetlands.

44. The site wetlands were delineated by William D. Countryman in July of 1995. The boundaries were collected by survey for the previous project and are shown on the site grading plans.

45. The wetlands are Class Three Wetlands and are not protected under the Vermont Wetland Rules. The Temporary Pulp Storage Area encroaches into the small wetland south of the propane tank with an expected loss of 400 square feet. The lower pulp storage yard encroaches into the wooded wetland west of the railroad siding with an expected loss of 3,500 square feet. The total area of wetland impacts is 3,900 square feet. These encroachments have been minimized consistent with good engineering design and the material storage needs of the mill. The site plans specify one (1) or two (2) vegetated side slopes on the encroaching fill areas that will serve to buffer each of these wetland areas. Silt fence will be installed at the toe of embankment prior to construction to control siltation.

46. An Army Corps of Engineers permit is not required for this project as proposed (D.H. Killoy P.E. letter ofMarch 4, 1997)

4 7. Sloping edges of the temporary pulp storage and parking lot areas south of the large propane tank as well as the lower pulp storage yard shall be graded, seeded, mulched and planted with shrubs.

Criteria I Discussion

1 We refer the reader to our opening comment and Master Planning requirement which proceeds

. : these findings. ; !

:Findings of Fact and Conclusions of Law #7Cl026 '.CPM/Kimberly-Clark Corp. 1,

East Ryegate, Vt. I•

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lkECTION 6086(a)(2&3l WATER AVAILABILITY AND IMP ACT ON EXISTING :suPPLY: ii 11

iThe Commission finds that there is sufficient water available to meet the needs of this project and :¥at it will not place an unreasonable burden on an existing supply.

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The domestic or potable water for the mill is supplied by the Ryegate Fire District No. 2 as a municipal supply. The service line runs parallel to and east of the railroad siding, as shown, to a shutoff located south of the new town road.

This project does not add bathrooms, washrooms or kitchen facilities to the mill. It is expected to add a maximum often (10) new employees with an estimated maximum water usage of fifteen (15) gallons per day per employee for a 150 gallons per day increase.

The existing source is adequate to supply the existing needs of the mill. (See letter from the Ryegate Fire District No. 2)

The existing 1 1/4 inch diameter PVC water service will be relocated to clear the warehouse building foundations as shown on the site utilities plan.

The mill's process water supply is drawn from the Connecticut River at the dam and is filtered in their existing raw water treatment system. The expected increase in water usage for industrial processes such as dilution, mixing and clean up of latex coating materials is expected to be 50,000 gallons per day. The mill has deeded water rights to draw 3,230,000 gallons per day and is currently using 500,000 gallons per day in its process.

Project is within the primary recharge area of the wellhead protection area for East Ryegate Fire District No. 2.

Applicant will coordinate with the East Ryegate Fire District and obtain a final letter of project approval prior to actual construction.

An on-site pre-construction meeting with the District Coordinator will include Mr. Earl Ashcroft, Water Supply Operator for the District.

In case of domestic water supply, the usage is expected to increase by 150 gallons per day for a maximum of 2,250 gallons per day or a 7% increase over the day. The pattern of usage through a 24 hour period will be the same as currently exists due to addition of employees to all manufacturing shifts.

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The process water supply is drawn directly from the river and the increased demand is expected to be 10%.

The increase in domestic water usage is insignificant and will not impact the aquifer from which the Ryegate Fire District No. 2 draws its supply. The increase in process water usage is drawn entirely from the river and will not impact nearby aquifers.

!SECTION 6086(a)(4) SOIL EROSION AND THE CAPACITY OF THE LAND TO HOLD I 1WATER:

I :The Commission finds that the construction of the project, if completed as approved, will not :cause unreasonable soil erosion or a reduction in the capacity of the land to hold w.ater.

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The majority of the site is a moderately sloping terrace located below the high bluff of the Connecticut River bank and above the river itself. The fine sandy soils indicate that it was mostly deposited by the river during prehistoric times. The land slopes from an elevation of approximately 445 feet, north of the mill near the Connecticut River damn, to Elevation 425 feet in the field south of the mill. Approximately one half of the site is currently developed as a paper mill. The site is bordered on the west by a thirty(30) feet tall bluff defined by an existing railroad embankment. The east side of the site borders the Connecticut River. At the south end of the existing mill building the land falls 33 feet over an approximate distance of 100 feet to the river's edge. At the south end of the site near the relocated town road, the land falls 16 feet over an approximate distance of 40 feet to the river's edge. The riverbank is steep in some locations and is stabilized by existing vegetation. Based on the topography and proposed development, the areas of potential soil erosion during construction are limited to the south fill slopes of the temporary pulp storage area and the lower pulp storage yard. These slopes border existing wetlands.

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I I i 161.

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The wetland areas will be protected by silt fences at the toe of proposed fill sideslopes. the inlets of the existing storm drain system will be protected by suitable silt barriers during earthwork operation to prevent siltation of the pipes and discharge into the wooded wetland.

The site will be stabilized by paving the high traffic areas with bituminous concrete and the parking and lower storage areas will be paved with a rolled gravel surface. All fill sideslopes will be covered with a six ( 6) inch layer of topsoil and seeded with a suitable conservation seed mixture. These areas will also be planted with trees and shrubs that will act both as bank stabilization and screening. The existing culvert extending under the west access road will be connected to the existing drainage swale in the wooded wetland with a rip-rap lined swale. The discharge from the extended storm drain system will flow into a rip-rap plunge pool to control velocity and attendant erosion.

: Findings ofFact and Conclusions ofLaw #7Cl026 EPMIK.imberly-Clark Corp. past Ryegate, Vt. rage II

1

.62. The erosion control measures will be inspected on a weekly basis by the general contractor

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who will be accountable for their maintenance. The mill's environmental engineer will provide oversite inspection of the contractor's erosion control practices.

Approximately five ( 5) acres of the owner's 24. 5 acres or 20% of the site will be impacted by this project. Only 0.50 acres will be paved or otherwise rendered impervious that were not already paved or impervious in the existing condition.

All of the stormwater runoff from the additional impervious area is directed into the wooded wetland or the wetland south of the propane tank. Based on the elevations of the existing railroad and roadway culverts, the stormwater escapes from the site by infiltration into the sandy subsoil. The minimal increase in the site runoff will not overpower this existing stormwater disposal mechanism.

: SECTION 6086(a)(5) TRANSPORTATION:

· 1The Commission finds that this project will not cause unreasonable congestion or unsafe · 'conditions with respect to stransportation.

.65. I

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The traffic associated with the project is essentially the same as the traffic currently existing at the site. The number of employees will increase by ten (IO), resulting in twenty (20) or thirty (30) additional vehicle trips per day. The process improvements will not result in an increase in paper production at the mill. The impact on truck traffic is limited to delivery of latex coating materials which will occur at a maximum of one (I) per day.

The project involves relocating the rail car unloading platform on the existing private rail siding. Rail traffic into the mill is not expected to increase as a result of this project.

:SECTION 6086(a)(6&7lEDUCATIONAL AND MUNICIPAL SERVICES: I I

1The Commission finds that this project will not place an unreasonable burden on the ability of the !municipality to provide educational, municipal or governmental services. !

67. This project is expected to create ten (10) new jobs at the East Ryegate Facility. Since the existing employee population is drawn from at least eight (8) surrounding towns and the State of New Hampshire, it is unrealistic to expect that all new positions will result in an increase in student population for the school system serving Ryegate. We would estimate a maximum increase in school age children to be ten (IO), based on five (5) families of two (2) children each relocating into the school district. The Blue Mountain Union School serves the Town of Ryegate, Groton and Wells River.

The Ryegate Town Plan lists current enrollment at the Blue Mountain Union School as 534 students with a design capacity of 600 students based on 1994 enrollment figures.

, ' Findings of Fact and Conclusions of Law #7Cl026 CPM/Kimberly-Clark Corp. East Ryegate, Vt. Page 12

Considering the estimated school impact often (10) additional students, the impact would project a growth of 1. 7% in the student body distributed throughout all grades. In 1994, the school had a reserve capacity of sixty-six ( 66) students or 11 % of the design population. Based on the available capacity two (2) years ago, and the minor impact expected from the project, we conclude that the school can accommodate the additional students without undue hardship.

! 69. The local school impact is not significant enough to require mitigation measures.

70. The project is an expansion of the existing CPM facility which is currently protected by the local fire department. The building expansions will be protected by automatic sprinkler systems, and the fire protection access and hydrant facilities are improved by this project. The process additions do not result in increased fire hazards due to product or chemical storage.

: 71. The project is not expected to significantly increase the amount of solid waste generated by the CPM facility. All new materials are delivered in bulk tank trucks or recyclable bulk containers, and the incidental trash generated by the ten (10) additional employees is insignificant.

72. The project is an expansion of the existing CPM facility currently served by local rescue services. There are no additions or modifications to the facility that will increase the risk of employee injury or impede the rescue and transport of injured employees.

73. The impact on municipal services is not significant enough to require mitigation measures.

1 74. This project will not impact significantly the municipal services provided by adjacent

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towns.

SECTION 6086 (8) AESTHETICS, SCENIC BEAUTY, HISTORIC SITES AND NATURAL AREAS:

The Commission finds that the project will not have an undue adverse effect on the scenic or natural beauty of the area, aesthetics, historic sites, or rare and irreplaceable natural areas.

75. The northern end of the project site has the industrial appearance of a working paper mill. It is located on a sloping plateau above the Connecticut River. The site is essentially in a hole below the community of East Ryegate and is visible only from two (2) or three (3) residences located nearby. An existing two (2) story paper machine building and single story office are situated on a north-south axis along the riverbank. South of the existing office building a dilapidated wooden warehouse is located adjacent to an existing railroad siding. A recently constructed modular office building and a 30,000 gallon propane tank are located in the yard to the south and east of the wooden warehouse. The space

;Findings of Fact and Conclusions of Law #7C1026 CPM/Kimberly-Clark Corp. I 1

East Ryegate, Vt. Page 13 l

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between the structures is used as parking for mill employees. The land directly west and south of the warehouse, which slopes down to a wooded wetland, is covered with bales and rolls of waste paper that is used as feedstock for the mill. South of the propane tank is a small patch of trees and brush that marks the site of a sludge pile deposited by previous owners. The land south of the sludge pile is an open field extending to the end of the property and beyond.

The project site is zoned for industrial occupancy and is currently occupied as such. The project will generate only minor off-site noise after construction.

The most significant new feature is the warehouse building that will extend from the existing paper machine room and finishing room to the south along the same axis. The building is a large industrial warehouse building located essentially on the site of the existing wooden warehouse. Its form and use are consistent with the rest of the industrial buildings on the site. It will be screened from the riverbank with landscape plantings including white cedar and balsam fir to break up the massing of the building (see landscape plans). The south end which is visible from the town road is similarly landscaped and screened.

The new warehouse building will be a flat roofed concrete masonry building 7 5 feet wide and approximately 270 feet long with a roof height approximately 5 feet taller than the existing paper machine building. The concrete masonry cladding will be painted an earth tone brown color to match or harmonize with the brickwork of the existing machine room and office. The portion of new structure extended above the existing office will be face brick on concrete masonry back up, to match the existing materials and blend with the existing structures.

The parking area adjacent to the temporary office will be screened from the riverbank by landscape plantings as shown on the landscape plans.

The exterior lighting mounted on the warehouse building will be directed down to light the traffic area east and west of the building. The fixtures will be 400 watt high pressure sodium type fixtures as shown on the attached lighting plans. The temporary and lower pulp storage yards will not be illuminated. The pulp storage area west of the existing mill buildings including the area of the septic disposal field will be illuminated by similar fixtures placed on the existing building. Those areas are currently illuminated.

The propane tank located south of the proposed warehouse will be screened from the town road by the same landscape plantings that serve to screen the employee parking area. The majority of the new 34. 5 KV power line is located behind the existing mill and new warehouse building, which effectively screens it from the river. The feed to the transformer located on the east wall of the warehouse is routed underground from the last pole near the south end of the warehouse to minimize visual impact on the east facade of ·

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Findings of Fact and Conclusions of Law #7Cl026 CPM/Kimberly-Clark Corp. East Ryegate, Vt. Page 14

the warehouse and permit taller landscape plantings. The presence of the wooded wetland and the site topography screens both the propane tank and the power line from traffic on the upper part of the town road.

82. The general site landscaping is shown on the final landscape plans. It is intended to screen potentially objectionable features of the proposed development and provide a visually attractive workplace for the employees.

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84.

85.

86.

The entire riverbank east of the access road will be designated as an undisturbed buffer during the construction process and treated as such during operation as company policy.

There are no designated rare or irreplaceable natural or fragile areas on or near the project site.

The project will involve an expansion of the existing mill facility including the construction of a bulk storage warehouse, an infrared burner controlling building, and a railroad unloading dock, as well as improvements to the surrounding infrastructure such as roadways and parking lots.

An archeological field inspection of the project area was conducted by GEOARCH in March 1997 which resulted in the identification of two general zones of archeological sensitivity; the entire lower field encompassing the floodplain, and the southern portion of the mid-level terrace where the existing mill complex is located.

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Based on project plans dated 5/12/97 and submitted on June 16, 1997, the applicant has modified the project's area of potential effect to completely avoid the archeologically sensitive zones.

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Discussion and Conclusions

Regarding the rehabilitation plan for the existing building, the former CPM Mill Complex was constructed between 1903 and 1906 as the Ryegate Paper Company. The complex was determined eligible for the State Register of Historic Places by the Vermont Advisory Council on

1 Historic Preservation at their meeting on April 15, 1997. The complex is a good example of an

, early 20th century paper mill.

Proposed rehabilitation plans, dated 5/28/97, and clarified in Liz Pritchett's letter dated 6/25/97 for the main mill building and attached office building, meet the Secretary of the Interior's Standards for Rehabilitation. Plans also call for removal of the Lower Stock House, built in 1912

: and one of the contributing structures in the historic mill complex.

/Findings of Fact and Conclusions of Law #7Cl026 / CPM/Kimberly-Clark Corp. !East Ryegate, Vt. jPage 15 · I

! R~m~val. will. have an a~verse effect to t~s histori~ st~cture how~ver, reuse ~r moving of the. · buddmg 1s neither technically or economically feasible m order to mcorporate 1t to current project needs.

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j The adverse effect to the Stock House will be mitigated through documentation of the structure ! which meets the Division's draft Photographic Documentation Requirements for Historic I I Structures. ! i

The Commission, in order to insure compliance of the project under Criterion 8 will impose the following permit conditions:

a. The permittee will map the archeologically sensitive areas on the site plan and label them as not-to-be-disturbed buffer zones. Copies of this revised site plan will be submitted to the District Commission and to the Division for Historic Preservation (DHP).

b. Topsoil removal, grading, scraping, cutting, filling, stockpiling, logging or any other type of ground disturbance is prohibited within the buffer zones without written approval of the District Commission and the DHP. Snowfencing, flagging, or other appropriate physical barrier will be placed at the edge of the buffer zones, where necessary as determined by the DHP, to make sure that it is clearly marked. The project contractor, if different than the permittee, will be fully notified about the buffer zone restrictions.

c. In those areas in which a buffer zone is not possible, an archeological study to identify sites in the buffer zone will be carried out by a qualified consulting archeologist prior to construction. The study will be scheduled accordingly so that mitigation measures that may be necessary can be satisfactorily planned and accomplished.

d. Archeological sites within the project area will not be impacted until any necessary mitigation measures have been carried out. Mitigation may include but is not li~ted to further site evaluation, data recovery, design of one more proposed project components, or specific conditions that may be imposed during construction (i.e. installation of temporary snow fencing, etc.).

e. Proposed mitigation measures will be discussed with and approved by the DHP prior to implementation, and a copy of all mitigation proposals will be filed with the Commission. The archeological studies will result in one or more final reports, as appropriate, that meet the DHP' s Guidelines for Conducting Archeological Studies in Vermont. Copies will be submitted both to the DHP and to the Commission.

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Findings of Fact and Conclusions of Law #7Cl026 ;cPM/Kimberly-Clark Corp. fEast Ryegate, Vt. Page 16.

f. All archeological studies and assessments must be conducted by a qualified consulting archeologist and must follow the DHP' s Guidelines for Conducting Archeological Studies in Vermont. The permittee' s archeological consultant must submit any scope of work to the DHP for review and approval.

g. If the permit holder or the DHP cannot agree in the course of implementing the above conditions, either party can ask the District Commission to reconvene a hearing to resolve outstanding issues.

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If an archeological site(s) eligible for the State or National Register of Historic Places is discovered in the c_ourse of archeological studies that may be required under this permit, and if the permittee decides to avoid and protect it in-place perpetuity, the site(s) will be mapped on the official site plan. The updated site plan will be submitted to both DHP and the District Commission. In consultation with the DHP, the permittee will draw up and execute covenants to protect the site( s) in perpetuity and enter it into the deed. A copy of the covenants will be filed with the Commission and the DHP.

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1. Any new or revised project plans should be submitted to the Division for review as soon as they become available. Any future changes to existing buildings will meet the Secretary of the Interior's Standards for Rehabilitation and will be reviewed and approved by a consulting architectural historian with concurrence by the Division prior to construction.

Prior to demolition of the Lower Stock House, the structure will be documented in accordance with the Division's draft Photographic Documentation Requirements for Historic Structures. Copies of the documentation will be submitted to the Division and the Reygate Public Library.

!SECTION 8(a) WILDLIFE AND ENDANGERED SPECIES:

!The Commission finds that the project will not destroy or significantly imperil necessary wildlife i and endangered species habitat. I

188. There are no critical wildlife or endangered species habitat on or near the project site. I

II SECTION 6086(a)(9) CONFORMANCE WITH THE CAPABILITY AND DEVELOPMENT PLAN:

I

I The Commission finds that this project conforms to the capability and development plan. i

!SECTION 6086 (a)(9)(A) IMPACT OF GROWTH:

Findings of Fact and Conclusions of Law #7Cl026 CPM/Kimberly-Clark Corp.

; East Ryegate, Vt. : Page 17 ! ; The Commission finds that the municipality will be able to accommodate the total growth and rate 1 of growth that will result from this project.

89. The Commission finds that the small growth in population and related financial demands on the town associated with this project will not cause an undue burden on the town or region.

1 SECTION 6086(a)(9)(B) PRIMARY AGRICULTURAL SOILS:

; The Commissions finds that the soils on the parcel cannot be considered primary agricultural soils , and the development will not significantly reduce the potential of the primary agricultural soils.

! : 90. The project site does not contain any primary agricultural soils.

SECTION 6086(a)(9)(C) FOREST AND SECONDARY AGRICULTURAL SOILS:

The Commission finds that the soils on the site do not qualify as secondary agricultural soils but will not significantly reduce the potential of the soils.

! : 91. The project site does not contain any significant forest or secondary ag-soils.

SECTION 6086(a)(9lCD&El EARTH RESOURCES AND EXTRACTION OF EARTH RESOURCES:

i The Commission finds that earth resources have not been identified on this site and approved for ~ extraction under a previous land use permit. i

92. The project site does not contain known valuable mineral resources.

SECTION 6086(a)(9l<Fl ENERGY CONSERVATION:

The Commission finds that the planning and design of this project reflects the principles of energy : conservation and incorporates the best available technology for the efficient use or recovery of i 1 energy.

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93.

! 94.

Exterior 12" block walls will be insulated with perlite masonry fill insulation providing an overall "R" value of 5. 5. The roof will be insulated with 4" of isocyanurate with an overall "R" value of 23. All exterior doors will be metal with insulated cores with all overall "R" value of I. 7. There are no windows or skylights.

All cooling supply and return ductwork will be insulated with I 112" thick semi-rigid fiberglass with FSK facing. All ductwork transverse and longitudinal joints shall be sealed with hardcast resin impregnated tape.

findings of Fact and Conclusions of Law #7C1026 ,CPM/Kimberly-Clark Corp. ~ast Ryegate, Vt. Page 18 I I i95. The rooftop heating and cooling unit will be equipped with a dry bulb economizer to allow

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for free cooling when outside air temperature falls below room setpoint. The unit's EER is 9. O. The units indoor air casing will be completely insulated.

The heating and ventilation units will be direct fired gas. Controls will be provided to modulate the firing rate to maintain space setpoint temperature. The unit's blower and burner cabinets will be insulated in 1" thick fiberglass. Supply fan motors will be high efficiency type.

The use of electricity energy is limited to motorized mechanical drivers, lighting and control systems for which there is no suitable alternate energy source.

Green Mountain Power Corporation has indicated an ability to serve the proposed project.

Electrical supply for the project will be through a 2,500 kw transformer from GMP's 34.5 kw transmission system.

!;100. Total peak initial demand is roughly 600 kw. \ l

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It is anticipated that the three-phase motor proposed will produce a starting voltage flicker of less than 3% on the 34.5 kw system for one motor start per day.

j 102. None of the proposed 600 kw will be electric space heating. I

I 103. More than one start per day may be subject to more stringent flicker criteria.

I 1104. Peak demand requirement for 600 kw can be supplied from Green Mountain Power's I existing and planned generation sources.

I 105. Final design plans for lighting, heating, and energy efficiency will be submitted to Stuart I Slote, Department of Public Service, for review and approval.

1SECTION 6086(a)(9)(G) PRIVATE UTILITY SERVICES:

; The Commission finds that there are no private utilities proposed for this project. I

) 106. There are no "private utilities" associated with this project that pose any risk ofburden. i I

: SECTION 6086 (a)(9lffil COSTS OF SCATTERED DEVELOPMENT:

. The Commission finds that the project is not contiguous to an existing settlement.

i Findings of Fact and Conclusions of Law #7C 1026 : ~PM/Kimberly-Clark Corp. ;East Ryegate, Vt. page 19 I 1107. The project site is an expansion of an existing industrial facility and is contiguous to the

existing settlement of East Ryegate.

SECTION 6086(a)(9)(Jl PUBLIC UTILITY SERVICES:

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lfhe Commission finds that utility service is available to this project, that an excessive or uneconomic demand will not be placed on such facilities or services, and that the provision of such services has been planned on the basis of a projection of reasonable population increase and

: ~conomic growth. i I :108. i ;

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The governmental services and public utility services required for this project are water and electric power. Green Mountain Power Company has advised that their existing substation can handle the proposed new load.

The new PLC control system will be designed to limit demand during peak operating periods. Operator training will be provided to instruct personnel to limit energy demand during peak hours.

There are no utility lines in the proposed area of the new construction.

' SECTION 6086(a)(9)(K) DEVELOPMENT AFFECTING PUBLIC INVESTMENTS: I j

;The Commission finds that this project will not unnecessarily endanger any public investment.

1111. This project will not endanger any adjacent public investments.

SECTION 6086 (a)(9l(Ll RURAL GROWTH AREAS:

~he Commission finds that this project is located in a rural growth area as defined by the statute. I

!112. The project site is not located within a rural growth area.

I '.SECTION 6086(a)(l0) CONFORMANCE WITH THE LOCAL OR REGIONAL PLAN:

I 1The Commission finds that this project conforms to the local plan. I I 1113.

I I :114.

The Town ofRyegate has a town plan that was adopted September 26, 1994. The planned expansion of the existing CPM facility is supported by the town plan's objective.

The project is in conformance with the adopted Regional Plan.

i Findings of Fact and Conclusions of Law #7C1026 t CPM/Kimberly-Clark Corp. i East Ryegate, Vt. I 'Page 20

IV. CONCLUSIONS OF LAW:

Based upon the foregoing Findings of Fact, it is the conclusion of this District Environmental Commission that the project described in the application referred to above, if completed and maintained in conformance with all of the terms and conditions of that application, and of Land

, Use Permit 7Cl026 will not cause or result in a detriment to public health, safety or general I welfare under the criteria described in IO V.S.A., Section 6086(a). .

: V. COMMISSION ORDER: I l

: Based on the foregoing Findings of Fact and Conclusions of Law Land Use Permit #7C1026 is . ! hereby issued. Ii

, Dated at St. Johnsbury, Vermont, this 14th day of August, 19:0 . By: tibLt-'0.u.c~~Ul--

: 1

(C:\ACT250\FILES\ 7C 1026.FF)

Edward Newell, Chairperson District #7 Environmental Commission Environmental Board

Others participating in this decision:

William Johnson Leniy Zenonos

DATE

1. 2/7/97

2. 2/7/97

3. 2/7/97

4. 2/7/97

5. 2/7/97

6. 2/7/97

7. 2/7/97

8. 2/7/97

9. 2/7/97

10. 2/7/97

11. 2/7/97

12. 2/7/97

13. 2/7/97

14. 2/7/97

15. 2/7/97

16. 2/7/97

17. 2/7/97

EXHIBIT LIST FOR #7Cl026 CPM/KIMBERLY-CLARK

EAST RYEGATE, VT

SUBMITTED BY

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

APPLICANT

SUBJECT

COVER LETTER

PERMIT APPLICATION

SCHEDULE A ACT 250 FORM

SCHEDULE B ACT 250 FORM

CONST. PERMIT APPLICATION

LATEX EFFLUENT PRE­TREATMENT DIAGRAM #3540-C-701-C

BRUNO ASSOCIATES WETLANDS DELINEATION JULY 10, 1995

TOWN OF RYEGATE FIRE DIST. #2 LETTER RE: CAPACITY TO SERVE

RYEGATE TOWN PLAN REGIONAL PLAN

SCHEDULE E ACT 250 FORM

SCHEDULE F ACT 250 FORM

SCHEDULE G-2 ACT 250 FORM

LATEX SATURATION PROJECT SITE PLAN SHEETS 1 & 2 #3586-C-002-D

SITE UTILITIES PLAN #3586-C-003-C

GRADING AND DRAINAGE PLAN SHEETS 1 & 2 #3586-C-006-D

SITE LANDSCAPE PLAN #3586-C-008-D

WAREHOUSE ARCHITECTURAL PLANS #3586-C-202

EXHIBIT LIST #7Cl027,CPM/KIMBERLY-CLARK EAST RYEGATE, VT PAGE 2

18. 2/7/97 APPLICANT

19. 2/7/97 APPLICANT

20. 2/7/97 APPLICANT

LATEX EXHIBIT

21. 6/16/97 LEE ROBERTS

WAREHOUSE ELEVATIONS (4 SHEETS) #3586-C-204-A

lR BURNER BLDG. ARCHITECTURAL PLAN & ELEVATIONS #3586-C-215

WAREHOUSE LIGHTING PLAN #3586-C-510-2-A

LETTER RE: REVISED SITE PLAN DRAWINGS AND REVISED ARCHITECTURAL PLAN l)LATEX SATURATION PROJECT PROPOSED SITE PLAN SHEET 1 #3586-C-001 2)LATEX SATURATION PROJECT PROPOSED SITE PLAN SHEET 2 #3586-C-002 3)LATEX SATURATION PROJECT SITE UTILITIES PLAN #3586-C-003 4)LATEX SATURATION PROJECT GRADING AND DRAINAGE PLAN SHEET 1 #3586-C-005 5)LATEX SATURATION PROJECT GRADING AND DRAINAGE PLAN SHEET 2 #3586-C-006 6)LATEX SATURATION PROJECT SITE LANDSCAPE PLAN SHEET 1 #3586-C-007 ?)LATEX SATURATION PROJECT SITE LANDSCAPE PLAN SHEET 2 #3586-C-008 8)LATEX SATURATION PROJECT PLAN AND ELEVATION #SK-3586-002 9)LATEX SATURATION PROJECT H & V PLAN SHEET 1-WAREHOUSE #3586-C-450 lO)LATEX SATURATION PROJECT H & V PLAN SHEET 2-WAREHOUSE #3586-C-451

EXHIBIT LIST #7Cl027,CPM/KIMBERLY-CLARK EAST RYEGATE, VT PAGE 3

22. 6/19/97 APPLICANT

23. 6/19/97 APPLICANT

24. 6/19/97 NEIL & GUNTER

25. 2/28/97 AGENCY

26. 7/2/97 TOWNSEND ANDERSON

27. 6/17/97 AGENCY

ll)LATEX SATURATION PROJECT H & V PLAN SHEET 3-WAREHOUSE #3586-C-452 12)LATEX SATURATION PROJECT H & V SECTION & DETAILS-BURNER & LATEX MAKEDOWN AREA #3586-C-454 13)LATEX SATURATION PROJECT H & V PLAN, I.R. BURNER & LATEX MAKEDOWN AREA #3586-C-453 14)LATEX SATURATION PROJECT H & V DETAILS & SECTIONS #3586-C-455 15)LATEX SATURATION PROJECT H & V EQUIP. SPECIFICATIONS AND GENERAL NOTES #3586-C-456 16)LATEX SATURATION PROJECT H & V PLAN AND DETAIL-SIZE PRESS EXHAUST HOODS #3586-C-457

LIGHTING SYSTEM NARRATIVE

ENERGY EFFICIENCY CALCULATIONS

LETTER TO STUART SLOTE, DPS, RE: ENERGY EFFICIENCY CONSIDERATIONS

COMMENTS ON A. WASTE DISPOSAL B. WETLANDS C. WATER SUPPLY D. ENERGY EFFICIENCY

LETTER RE: HISTORIC/ ARCHEOLOGICAL REQUIREMENTS

I.S.W.D.E. LETTER AND CONDITIONS

28. 5/7/97 ROLAND G. GRENIER, LETTER RE: WW APPLICATION JR.

29. 5/20/97 GREEN MTN. POWER LETTER: ABILITY TO SERVE

EXHIBIT LIST #7C1027,CPM/KIMBERLY-CLARK EAST RYEGATE, VT PAGE 4

30. 3/14/97

31. 3/7/97

32. 2/7/97

AGENCY

ARMY CORPS OF ENGINEERS

TOWN OF RYEGATE

(C:\ACT250\FILES\7C1026.EXH)

DISCHARGE PERMIT LETTER

LETTER RE: SIGNOFF

LETTER RE: ABILITY TO SERVE