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done by the permittee and reported to the regulatory agency. For all monitoring required 

 by the NPDES permit, Ketchikan Pulp Company has developed Standard Operating 

 Procedures (SOPs) which are in use and on file with EPA Region 10 The SOP's are 

 developed from EPA approved testing and sampling protocols EPA Region 10 conducts 

 an annual inspection of the KPC facility, and adherence to these SOP's is evaluated by 

 EPA at this time. The mill produces a chlorinated organics report on a quarterly basis as 

 required by the NPDES permit The first report was produced during the fourth quarter 

 of 1994. The report provides test results for a specific list of chlorinated organics for 

 eight sample locations. Sample locations include the combined outfall (001), chlorination 

 stage effluent, caustic soak stage effluent, hot caustic extract effluent, combined 

 hypochlorite stage effluent, sulfijr dioxide stage effluent, bleached pulp from the bleach 

 plant, and sludge from the rotary screen thickeners which are directly ahead of the sludge 

 screw presses. 



Annual stormwater reports are required by the mill NPDES permit Samples from three 

 stormwater events are collected and tested for polycyclic aromatic hydrocarbons (PAHs) 

 and benzene, toluene, ethylbenzene, and xylene (BTEX) in addition to conventional 

 pollutants. The results for all sampling locations are averaged and presented in a summary 

 table. 



The mill's NPDES permit. No. AK-000092-2, requires routine monitoring and monthly 

 reporting for federally established standards on biochemical oxygen demand (BOD), total 

 suspended solids (TSS), temperature, and pH. Many of the wastewater constituents, such 

 as chronic and acute toxicity, AOX, chlorinated organics, metals, color, residual chlorine, 

 sulfide, and total petroleum hydrocarbons, are routinely tested for and reported according 

 to established frequencies. Other information such as production, effluent flow rate, and 

 stormwater runoff information are also submitted 



For those parameters for which KPC is required to monitor continuously, appropriate 

 monitoring equipment is installed and is operated according to the manufacturers' 

 specifications with appropriate calibration Backup apparatus are also installed to ensure 

 continuous monitoring should the primary equipment fail. 



For those parameters for which KPC is required to monitor daily, appropriate sampling is 

 performed using a one time "grab" or 24 hour composites, and these samples are analyzed 

 daily at KPC and/or contract laboratories for the required parameters Some parameters 

 are analyzed by KPC in-house following the approved Standard Procedures For the 

 majority of parameters, however, the analyses are performed by Columbia Analytical 

 Services of Kelso, WA. These samples are collected on Monday mornings, and shipped 

 for analysis to CAS under proper chain-of-custody control . The results are provided to 

 KPC monthly for regulatory reporting purposes 



All quarterly required parameters are monitored during intensive quarterly sampling events 

 as required by the NPDES permit. This includes sampling of various bleach plant waste 

 streams, outfall 001, sludge, and fully bleached pulp. The purpose of this program is to 



