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In March 1995, KPC received a NOV from the State of Alaska alleging that it exceeded 

 applicable opacity and particulate standards and associated reporting requirements. The 

 exceedances were determined to have been caused by Bnnks Canisters (emission control ur^its) 

 that, due to age and design problems, were no longer effective in ensuring compliance with 

 particulate emission limits applicable to the recovery boilers This matter was settled with 

 ADEC and resulted in the payment of a penalty of S2 1,908 to the State as well as a schedule to 

 install an additional (seventh) Brinks Canister KPC believes that the additional Brinks Canister 

 will give it more flexibility to perform maintenance and related activities on existing Brinks 

 Canisters) without compromising the pollution control effectiveness of the system 



As discussed above, the existing consent decree was entered into by ADEC and KPC in May 

 1995. In addition to the projects, studies, and reporting requirements imposed upon KPC by 

 the decree, ADEC also has the authority to seek stipulated penalties for violations of consent 

 decree conditions ($5,000 per violation) and exceedances of opacity limits ($500 per violation) 

 ADEC has assessed stipulated penalties for opacity exceedances 



KPC has retained an outside consulting/engineering firm to study its powerhouse and 

 determine ways to improve boiler performance and minimize opacity exceedances. In the 

 context of permit negotiations with ADEC, KPC proposed to incorporate a number of the 

 consultant's recommendations into the consent decree and/or permit as enforceable conditions 

 When the draft permit is finalized, KPC will be required to implement a number of the 

 recommended measures ranging from enhanced powerhouse employee training to engineering 

 and equipment improvements. These are designed to improve the operating performance of 

 the boilers and reduce the potential for opacity exceedances 



Solid Waste Management 



KPC currently operates two contiguous solid waste landfills located adjacent to the pulp 

 mill at approximately Mile 9, North Tongass Highway These two landfills, the Ash 

 Landfill, and the Wood waste Disposal Site, are regulated by the ADEC Solid Waste 

 Program and are thus subject to regulation under 1 8 AAC 60 Landfill leachate, as well as 

 stormwater, are also regulated under the existing KPC NPDES permit. 



Both landfills are managed in a series of lifts, with impermeable membranes installed 

 between lifts. Both landfills also have a leachate collection system that routes landfill 

 leachate to the pulp mill secondary treatment system prior to discharge 



The Ash landfill is permitted to accept solid wastes under Solid Waste Permit Number 

 9 1 1 3-B A005, issued by ADEC on April 13,1 995 The permit expires on December 3 1 , 

 1998 The Ash Landfill permit restricts landfilled materials to boiler ash, flyash, calcium 

 filtrate, hogged fuel mixed with rock and dirt, and primary/secondary waste water 

 treatment sludge. Materials specifically restricted from the landfill by the permit include 

 waste oil, oily waste, domestic sewage sludge, material pumped from septic tanks, fish 

 processing waste, and hazardous and potentially hazardous materials. 



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