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improvement of the discharge characteristics of the Company's wastewater 

 outfalls. 



• Implement an environmental policy that sets forth the individual responsibilities 

 of employees with respect to the environment 



Ketchikan Pulp Company has instituted employee training that will provide 

 employees at all levels with information about State and Federal environmental 

 laws. More specific training in the monitoring, reporting and control required 

 by law and permit will be provided for those with specific job responsibilities 

 which include environmental compliance. 



• Prevent unpennitted discharges and implement management practices to 

 prevent spills. 



KPC has developed an unpermitted discharge program to minimize the 

 potential for non routine discharges These issues are also addressed by several 

 of the elements of the civil Consent Decree described below 



• Implement components of the Consent Decree as it relates to wastewater 

 For a description of all Consent Decree components, see below. 



• Implement the Environmental Compliance Program described in the pre- 

 sentencing report. 



This document is titled "Corporate Responsibility Program" and is attached. 



• Fine: $3 million, $1.75 million to be offset by expenditures for the projects 

 described above. 



• Provide quarterly reports to the Court, Office of Probation, and the 

 Department of Justice on the status of the implementation of the 

 Environinental Compliance Program 



The Company and the Government entered into a Consent Decree in order to settle the 

 claims brought by the Government under the civil enforcement provisions of the Clean Air 

 and Clean Water Acts. The Consent Decree provides for a substantial penalty, as well as 

 the implementation of injunctive measures designed to remedy Ketchikan Pulp Company 

 Company's noncompliance with the two Acts and to improve its compliance with State 

 and Federal environmental laws 



Ketchikan Pulp Company obligations under the Consent Decree: 

 Develop and implement the following: 



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