125 



document current rates of formation of 2,3,7, 8-TCDD and TCDF, AOX, and to 

 characterize the final effluent in terms of TSS, and 2,3,7,8-TCDD and TCDF 



During this sampling, concurrent monitoring for both acute and chronic toxicity is also 

 required. Acute testing is performed using a specified protocol for a 96 hour static 

 renewal testing with inland silversides as the test species. This testing is performed for 

 KPC by Northwestern Aquatic Sciences (NAS) of Newport, Oregon 



Chronic testing is required to be performed using either an echinoderm sperm cell 

 fertilization test (Dinnel, 1987), or a bivalve embryo larval development test (ASTM E 

 724-89) KPC is actively pursuing measures to reduce the chronic toxicity of the mill 

 effluents. For this reason, KPC typically conducts both tests on all effluent samples. All 

 of this testing is performed for KPC by Telonicher Marine Laboratories of Trinidad 

 California To date for NPDES Permit No AK000092-2, KPC has spent approximately 

 $250,000 dollars for chronic toxicity testing 



In addition to permit specific monitoring and reporting, the National Pollutant Discharge 

 Elimination System (NPDES) Form 2C provides a listing of conventional pollutants, 

 metals, cyanide, phenols, volatiles, acid compounds, basic compounds, and other 

 substances present in KPC's waste streams The form is completed during the NPDES 

 permit application period and is a matter of public record 



Finally, KPC is required to implement several other programs to demonstrate compliance 

 with NPDES Permit No. AK-000092-2. 



The first of these is the Best Management Practices (BMP) Plan. This was a new 

 requirement for KPC and was made a requirement of the 1994 permit. The intended 

 purpose of the plan is to minimize the generation and potential for the release of pollutants 

 from the facility to the waters of the United States through normal operations and ancillary 

 activities. This plan is being implemented by KPC. Additional employees have been hired 

 to assure that BMP incident reporting, follow-up analysis and appropriate action occur 



The second of these is KPC's stormwater monitoring program. Since KPC applied for 

 federally required stormwater permits for all of its facilities, stormwater permits for both 

 the KPC facility and the KSM facility are incorporated into NPDES Permit No. AK- 

 000092-2. Under this program, KPC is required to monitor COD, TSS, pH, oil and 

 grease, PAH's, total hydrocarbons, benzene, ethylbenzene, toluene, and xylene three times 

 per year at each respective stormwater outfall. Also, during the summer months, KPC is 

 required to monitor the BOD and dissolved oxygen content of each outfall twice per 

 calendar month. Since the inception of NPDES Permit No. AK-000092-2 in 1994, KPC 

 has installed a comprehensive stormwater collection system designed to both reduce the 

 number of outfalls and to increase the quality of the discharge from the KPC facility. This 

 system is nearly complete and 1996 will be the first year in which monitoring of these new 

 outfalls is to occur. 



