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Countermeasure Plans are maintained for each of the camps, the Thorne Bay Son Yard 

 and the Annette Hemlock Mill 



Resource Conservation and Recovery Act 



The Resource Conservation and Recovery Act (1970) mandates that hazardous waste will 

 be treated, stored, and disposed of so as to minimize the present and future threat to 

 human health and the environment RCR.A is a regulatory statute designed to provide 

 "cradle to grave" management of hazardous waste by imposing requirements on 

 generators and transporters of hazardous waste The Hazardous and Solid Waste 

 Amendments of 1984 (HSWA) mandated waste minimization and a national land disposal 

 ban program Congress has declared that the generation of hazardous waste is to be 

 reduced or eliminated as expeditiously as possible, and land disposal should be the least 

 favored method for managing hazardous waste For facilities operating in the State of 

 Alaska, this program is regulated by the Environmental Protection Agency There have 

 been no regulatory actions filed regarding hazardous waste management at KPC 



Ketchikan Pulp Company operates several facilities that have the potential for hazardous 

 waste generation at different generation rates and volumes The pulp mill complex 

 currently operates under a Large Quantity Generator (LQG) status, although actual waste 

 generation levels would often qualify it for Small Quantity Generator (SQG) status A 

 large quantity generator is one which generates over 1000 kilograms of waste in any 

 calendar month, or exceeds a storage volume of hazardous waste of 6000 kilograms at 

 any time KPC's camps, sawmills, and helicopter hanger currently operate under a 

 Conditionally Exempt Small Quantity Generator (CESQG) status This level of generation 

 specifies generation of up to but less than 100 kilograms of hazardous waste in a calendar 

 month 



As a large quantity generator of hazardous waste, KPC's pulp mill complex is actively 

 involved in waste minimization and source reduction programs Ail waste streams are 

 reviewed for source reduction and recycle possibilities Ketchikan Pulp Company currently 

 recycles a large number of waste streams, including but not limited to, antifreeze, crushed 

 oil filters, batteries, light ballasts, and paint solvents KPC has eliminated several waste 

 streams through the substitution of less toxic or non-toxic material 



Ketchikan Pulp Company Company's pulp mill complex generates a variety of 

 wastes that represent the following waste codes 



DOOl Unlisted Hazardous Wastes Characteristic of Ignitability 



D002 Unlisted Hazardous Wastes Characteristic of Corrosivity 



D003 Unlisted Hazardous Wastes Characteristic of Reactivity 



D004 Unlisted Hazardous Wastes Characteristic of Toxicity - Arsenic 



D005 Unlisted Hazardous Wastes Characteristic of Toxicity - Barium 



D006 Unlisted Hazardous Wastes Characteristic of Toxicity - Cadmium 



D007 Unlisted Hazardous Wastes Characteristic of Toxicity - Chromium 



D008 Unlisted Hazardous Wastes Characteristic of Toxicity - Lead 



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