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applicable Federal Clean Air Act requirements In the absence of applicable State standards, 

 certain Federal air requirements (eg. New Source Pertbrmance Standards) are enforced 

 directly by the Environmental Protection Agency (EPA) in the absence of comparable State 

 law 



KPC has seven boilers at its facility which are used to generate power and recover chemicals 

 from the pulping processes KPC's powerhouse produces steam for process heating and to 

 drive two 10,000 KWH turbine generators and one 18,000 KWH turbine generator These 

 boilers are the primary source of air emissions at the KPC facility Emissions also result from 

 the pulp production processes and the facility's wastewater conveyance system and treatment 

 facilities. 



Regulatory Authority 



KPC is currently operating under the authority of a consent decree entered into between it and 

 the State of Alaska in May 1995 



In April 1995, KPC completed a study to satisfy 18 AAC 50 1 10 This section of the Alaska 

 Administrative Code provides that "No person may permit any emission which is injurious to 

 human health or welfare, animal or plant life, or property, or which would unreasonably 

 interfere with the enjoyment of life or property " The purpose of the study was twofold: (1) 

 model ambient concentrations of pollutants (2) determine the risk that these pollutants pose to 

 human health and the environment The study was conducted using computer dispersion 

 modeling and the most current information regarding health risks It is common in the air 

 quality field to attempt to predict the ambient concentration of pollutants using computer 

 generated models. The modeled concentrations of pollutants can then be assessed to determine 

 potential compliance with the National Ambient Air Quality Standards (NAAQS) or 

 alternatively, can be used to predict the risk posed to human and ecological receptors at the 

 modeled locations. 



KPC's April 1995 study indicated that the facility had the potential, under certain worst case 

 operating and meteorological conditions, to exceed applicable ambient air standards for sulfur 

 dioxide and oxides of nitrogen. The study also indicated that the risk to human health posed by 

 chloroform emissions merited further analysis Based on these results, the State of Alaska was 

 unable to renew KPC's air operating permit upon its expiration in May 1995 A then existing 

 provision of State law required compliance with 1 8 AAC 50 1 10 as a condition for reissuance 

 of an existing air operating f)ermit 



In May 1995, KPC entered into a consent decree with the State of Alaska to resolve ambient 

 air and human health issues raised by the April 1995 study The consent decree required KPC 

 to undertake a comprehensive modeling analysis for fine particulate matter, sulfijr dioxide, 

 carbon monoxide, total reduced sulfijr, nitrogen dioxide, lead, and chloroform Based on the 

 April 1995 study, ADEC preliminarily determined that these pollutants had the potential to 

 cause noncompliance with the NAAQS or posed unacceptable risks to human health. The 



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