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• Oil Discharge Prevention and Contingency Plan tor KPC's oil and supply delivery 

 barge. 



• USCG Response Plan for the barge. 



TSCA 



The Toxic Substances Control Act (TSCA) enacted in 1976 provides EPA with the 

 authority to require testing of chemical substances entering the environment and to 

 regulate them where necessary Programs under TSCA gather mformation about the 

 toxicity of chemicals and the extent to which people and the environment are exposed to 

 them Polychlorinated Biphenyls (PCBs) are regulated under TSCA The EPA regulations 

 that accompany the law set specific standards regarding PCB manufactunng and use. 



Ketchikan Pulp Company does not manufacture PCBs, but is considered a generator of 

 PCB waste Prior to the mid seventies, PCBs were commonly used in transformers and 

 capacitors because of their excellent heat transfer characteristics PCBs were also 

 commonly found in some petroleum products 



Processing, distribution and the use of PCBs are prohibited except in a totally enclosed 

 manner A transformer or capacitor is an example of an allowed totally enclosed system. 

 Over the course of several years, Ketchikan Pulp Company has replaced PCB containing 

 transformers and capacitors with more updated systems The PCB fluid inside the units as 

 well as the "carcass" of the units are disposed of in permitted disposal facilities. Ketchikan 

 Pulp Company ships them off-site accompanied by a manifest similar to the manifest used 

 for hazardous wastes in the RCRA program 



Several shipments of PCB contaminated material have been made off-site in recent years 

 As of Spring of 1996, all PCB enhanced transformers and capacitors have been 

 successftjlly removed from operations and from locations at Ketchikan Pulp Company An 

 annual report to EPA early in 1997 will successfijlly close this program for KPC. 



CERCLA 



Section 302 of the Emergency Planning and Community Right-to-Know Act (EPCRA, or 

 Title III of the Superfund Amendments and Reauthorization Act (SARA) of 1986), Public 

 Law 99-499 requires reporting of a release of a regulated substance above the Federally 

 mandated 24 hour Reportable Quantity (RQ) that is not "federally permitted" or 

 "continuous in nature" This reporting requirement is for releases expected to travel 

 beyond the plant boundaries. 



In the 1986 legislation. Congress specified an initial one pound RQ for all SARA 

 "Extremely Hazardous Substances (EHS)"except for those substances which were already 

 CERCLA hazardous substances with established RQs In May, 1996 an EPA final rule 

 was published which increased the reportable quantities for over 200 substances 



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