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Department of Environmental Conservation are notified immediately by phone with a 

 written follow-up report when KPC is responsible for a spill of any size to the water. 



Debris is not allowed to accumulate on, or beneath log transfer structures Thome Bay 

 and the Annette Hemlock Mill both have permitted annual dredge activities Thome Bay's 

 dredging is strictly monitored as required by State, Section 401 certification stipulations 



General Stormwater permits (NPDES) are held by either KPC or the United States Forest 

 Service for each Log Transfer Facility These stormwater permits have requirements for 

 monitoring which are implemented in a pollution prevention plan specifically for each Log 

 Transfer Facility 



Pollution Prevention 



Pollution prevention activities have been unofficially underway for many years at KPC. In 

 the past, these activities have been carried out informally due to the absence of a 

 requirement for specific pollution prevention activities in the State of Alaska These 

 activities include, but are not limited to, the use of non-toxic antifreeze, vegetable based 

 hydraulic oils, recycle of lead batteries, buming waste oils and substitution of non- 

 hazardous materials for hazardous materials Recently however, KPC has been required 

 to conduct a pollution prevention study by Consent Decree No A92-587-CV 



KPC is in the process of conducting this study at the present time The due date for 

 completion is March 27, 1997, at which time EPA Region 10 will make determinations for 

 implementation of any recommendations which appear in the final report Currently, KPC 

 has completed about 50% of this study, and has just completed the preliminary evaluation 

 of alternatives as specified in the following draft workplan 



The goal of pollution prevention is to identify manufacturing and management process 

 changes that will prevent the formation of pollutants, thus eliminating the need to remove 

 them through various treatment processes Pollution prevention focuses on all media, 

 therefore, the transfer of a pollutant from one medium (eg, water) to another (e g , air or 

 land) is not a preventive measure and is not considered an acceptable alternative for 

 purposes of this study The pollution prevention study is focused on KPC'^ key 

 production processes, such as pulping and bleaching, and other on-site areas that may be 

 responsible for the production and possible release of hazardous compounds (particularly 

 chlorinated organics) to the environment 



KPC's commitment to pollution prevention dates back to the mill's initial construction. 

 At that time, in the eariy 1950's the company decided to install a system for complete 

 recovery of pulping chemicals. This decision was made at a time when other similar mills 

 were achieving much less. Other accomplishments since the mill's startup include 

 installation of a log bundle crane to reduce debris loss in Ward Cove, conversion from 

 hydraulic to mechanical debarking to reduce water consumption, and expansion of 

 evaporation capacity, washing improvements, and boiler modifications to fijrther improve 

 spent sulfite liquor (SSL) recovery. 



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