119 



ATTACHMENT B 



Supplementary Testimony of Ralph D Lewis 



Environmental Compliance at Ketchikan Pulp Company 



Senate Energy Committee, July 10, 1996 



House Resources and Agriculture Committee, July 1 1, 1996 



This testimony is offered to inform the Committee of environmental protection and 

 compliance related programs, projects, activities and controls at the Ketchikan Pulp 

 Company While the testimony itself offers only a summary of each point raised, I am 

 providing for the Committee copies of many documents which detail the compliance 

 related activities at Ketchikan Pulp Company 



Ketchikan Pulp Company complies with Federal and State laws governing environmental 

 protection. These laws require the company to secure, from Federal and State agencies, a 

 number of operating permits. Each permit requires the company to submit periodic 

 reports, monitoring and measurement results and inspection reports to the issuing agency 

 AJl of these reports and data are pan of the environmental compliance record of 

 Ketchikan Pulp Company and are available for public review 



Testimony has been offered in this and related proceedings by groups and individuals 

 which is based on Ketchikan Pulp Company Company's reported information. Some of 

 that testimony presents the information out of the context in which it was originally 

 reported. Data have been interpreted without regard for scientific method, and 

 conclusions have been reached based on subjective values rather than objective measures 

 Data have been separated from regulatory reports and rearranged without regard to the 

 purpose for which they are collected KPC's opponents have often manipulated and 

 distorted data in order to illustrate theories which are designed to raise public alarm 

 Ketchikan Pulp Company and State and Federal regulators cannot similarly choose the 

 method of interpretation that best accomplishes their goals. I believe that the Committee 

 should have the opportunity to learn of the strict and comprehensive regulatory context in 

 which resource protection is actually achieved at Ketchikan Pulp Company 



My testimony today presents an overview of the full scope of regulatory control over 

 operations and waste management at Ketchikan Pulp Company You will see from 

 reading the entire testimony that all contaminants of concern to State and Federal 

 regulators are monitored, measured, and reported according to guidelines and schedules 

 set by the government. Reported quantities are regularly checked against the action levels 

 established by environmental law. Action is taken when appropriate These reports along 

 with inspections by regulatory staff provide the basis which demonstrates compliance, or, 

 alternatively, on which enforcement action may be taken. Enforcement actions, too , are a 

 matter of public record. 



I welcome the opportunity to offer this summary for the public record. The compliance 

 and enforcement history of the Ketchikan Pulp Company is already a matter of that 

 record. We are proud of our achievements, and accept responsibility for our shortcomings 



