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In addition to this specific program for quarterly monitoring, KPC will continue to be 

 required to maintain the following additional programs which were implemented with the 

 present permit. 



• Best Management Practices (BMP) Plan This plan has been implemented by KPC and 

 will continue to be in force after final certification of the Tongass Narrows permit 



• Stonmwater Monitoring Program. Under this program, KPC will continue to monitor 

 COD, TSS, pH, Oil and Grease, PAH's, Total Petroleum Hydrocarbons, Benzene, 

 Ethylbenzene, Toluene, and Xylene three times per year at each respective stormwater 

 outfall. Also, during the summer months, KPC will continue to monitor the BOD and 

 dissolved oxygen content of each outfall twice per calendar month 



• Receiving Water Monitoring Program The original purpose of this program was to 

 monitor the water quality of Ward Cove, which is the direct receiving water of KPC's 

 discharge. This program will continue to monitor Ward Cove after the certification of 

 the Tongass Narrows Permit and after the relocation of the outfall 



• Annual Sediment Monitoring Studies. The annual sediment monitoring studies carried 

 out at the same specific twelve stations throughout Ward Cove and Tongass Narrows 

 Currently, KPC is required to analyze appropriate sediment samples from each of these 

 sites for all congeners of TCDD and TCDF, total organic carbon, PAH's, cadmium, 

 arsenic, zinc, phenol, 4-methylphenol, benzoic acid, acid volatile sulfides, EOX, methyl 

 mercury, and toxicity using marine amphipods, larval sanddollars and purple sea 

 urchins. KPC is anticipating that this requirement will continue after certification of 

 the Tongass Narrows permit. Procedures for this testing will continue to follow strict 

 USEPA guidance. Reports, which will include thorough discussions of sampling and 

 analytical methodologies and QA/QC procedures, will continue to be submitted to the 

 EPA on an annual basis, if required. 



• Annual Bioaccumulation Monitoring Program The annual bioaccumulation 

 monitoring program is conducted in the vicinity of the discharge KPC is anticipating 

 that this requirement will change with the certification of the Tongass Narrows permit 

 Current negotiations with ADEC have indicated that ongoing monitoring of the 

 Tongass Narrows outfall location will occur, possibly including bioaccumulation 

 monitoring. 



Air Emissions Control 



Overview 



Air quality issues at the KPC facility are governed primarily by the State of Alaska through the 

 Alaska Department of Environmental Conservation (ADEC). State statutes and regulations 

 are incorporated into the State Implementation Plan (SIP) Once approved by EPA, the SIP is 

 enforceable under Federal law The State does not yet have authorization to enforce all 



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