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Ketchikan Pulp Company Company's transportation and storage of petroleum products at 

 its pulp mill complex, camps, sawmills, and helicopter hanger have resulted in several 

 plans to address these recent regulations 



Applicable regulations include: 



• ISAAC 75 



• 40CFR110 



• 40CFR112 



• 40CFR114 



• 33CFR153 



• 33CFR154 



• 33CFR156 



These regulations establish guidelines for procedures, methods and equipment, and other 

 requirements necessary to prevent the discharge of oil from transportation and non- 

 transportation-related on-shore and offshore facilities into or upon the navigable waters of 

 the United States or adjoining shorelines 



Programs developed to meet the regulations include Operation Procedures, Product 

 Transfer Procedures, Storage and Containment Programs, Notification Procedures, 

 Equipment Lists and Inspections, Line Testing, Health and Safety Response Training, 

 Identification of Environmentally Sensitive .\reas, and Emergency Wildlife Management 

 Procedures. 



KPC is required to develop several spill scenarios for its operations and to regularly 

 conduct response drills for those scenarios in order to be ready if a spill actually occurs A 

 quarterly notification exercise must be conducted by all EPA and USCG regulated 

 facilities as well as aboard manned vessels and unmanned barges The quarterly biannual 

 Emergency Procedures Exercise must be conducted by manned vessels and unmanned 

 barges. The Equipment Deployment Exercise must be conducted by all EPA and USCG 

 regulated facilities and vessels. The annual Tabietop exercise must be conducted by all 

 EPA and USCG regulated facilities and all vessels One Tabietop exercise over the 

 triennial cycle must evaluate the worst case discharge scenario .^n annual Unannounced 

 Exercise requirement must also be met 



KPC utilizes the following plans to fulfill planning requirements 



• EPA Facility Response Plan 



• KPC Oil Discharge Prevention and Contingency Plan 



• USCG Facility Response Plan 



• KPC Facility Operations Manual 



• KPC Spill Prevention Control and Countermeasure Plan 



• KPC Emergency Response Plan 



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