129 



• Wastewater treatment operator certification treatment plant operators must be 

 State-certified, and documentation maintained 



• Spill containment program study the potential for spills, and design systems 

 for preventing and containing spills, evaluate the feasibility of recycling 

 treatment and non-wastewater disposal of spilled materials Containment of 

 spills will reduce the toxicity of Ketchikan Pulp Company Company's effluent 



• Water treatment plant discharge elimination define, describe and plan for the 

 steps which are necessary to prevent the direct discharge of filter backwash or 

 basin drawdowns to the filter plant outfall 



• Laboratory monitoring and improvement program: develop a standard 

 operating procedure for testing BOD, and describe in detail the steps for 

 laboratory analysis, identify a single seed source for conducting all BOD 

 analyses, develop a standard operating procedure for data entry review. 



• Ward Cove sediment project develop a technical studies work plan to 

 characterize sediments in Ward Cove, evaluate results, identify alternatives for 

 remediation, if necessary; and implement a remediation plan. This project is 

 not to exceed S6 million 



• Source test emissions from the recovery boilers: test for particulate matter and 

 sulfur dioxide and take all steps necessary to correct if violations of the Clean 

 Air Act are discovered by the testing 



• Mass balance study for sulfijr: conduct a facility wide mass balance study in 

 order to reduce the discharge and emission of sulfur 



• Environmental audit: retain an independent environmental audit firm to 

 develop and conduct an audit that will focus on both compliance and 

 effectiveness of compliance assurance systems and management structure. 



• Operations and maintenance program design a program of operations and 

 maintenance procedures that will minimize pollution at the mill. 



• Pollution prevention study identify areas where discharges or emissions of 

 pollutants, especially toxics, can be reduced including fijgitive emissions, 

 stormwater and plant processes. 



• Civil Penalty: $3,111 million 



The Company entered into a Compliance Agreement with EPA which achieves a 

 settlement of any potential suspension and debarment issues with respect to Federal 

 procurement and non-procurement activities which could have resulted from the entry of a 

 guilty plea to the felony and misdemeanor charges The agreement reflects EPA's 



