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KPC is in the process of conducting a trial to bum secondary sludge (generated in the waste 

 water treatment facilities) in the recovery boilers Although it is dewatered using a device 

 called a screw press, it is nonetheless quite moist and can be difficult to bum Currently, 

 primary and secondary sludge is mixed with wood waste and bumed in the power boilers The 

 high moisture content of sludge has the potential to cause emissions problems KPC believes 

 that burning sludge in the recovery boilers will obviate the need to dispose of it in the power 

 boilers and allow for a better lliel mixture in the power boilers. It is believed that these changes 

 will improve the power boilers' emissions characteristics. 



KPC has extensive reporting requirements to ensure that governmental agencies and citizens 

 have comprehensive, up to date information on the facility's air emissions Under Federal law, 

 KPC is required to immediately report certain gas leaks to appropriate State, local, and national 

 authorities. KPC is also required to report sulfur dioxide and chlorine releases under its air 

 permit/consent decree ADEC also requires KPC to verbally report within 24 hours any 

 emission control equipment failure or emission control unit bypass, process upsets that may 

 cause exceedances of applicable air requirements, and opacity exceedances which last for more 

 than twenty minutes Under the proposed air operating permit, KPC will be required to report 

 any releases of mist or foam from the wastewater treatment systems which have the potential 

 to migrate oflf-site. KPC is implementing engineering measures which the Company believes 

 will eliminate the potential for off-site transport of foams and mists from the wastewater 

 treatment system 



KPC submits quarterly reports to both EPA and ADEC These reports contain comprehensive 

 data on operations and air quality processes including: 



• number of hours or operating days for emission sources, 



• tons ofair-dried pulp produced, 



• amount of steam produced by the boilers; 



• amount of No. 6 low sulfur fuel oil used; 



• amount of heavy red liquor solids bumed in the recovery boilers; 



• type and quantity of any paper, charcoal, and used oil spill absorbent material 

 bumed in the multi-fuel boilers; 



• sources test results for the power boilers and the package boilers; 



• percent of the time the ESP fields are energized; 



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