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For the first time, KPC reported the manufacture of formic acid as a by-product of the 

 pulping process under the Form R for the 1994 reporting year Once this material is 

 manufactured, it tends to adhere to the pulp fibers It remains with the product and human 

 exposure to the substance does not occur under normal conditions of use 



Ketchikan Pulp Company is a charter member and continuing participant in EPA's 

 voluntary 33/50 program which fosters industry's innovative efforts to pledge and meet 

 goals for reduction of TRJ chemical releases Ketchikan Pulp Company continues to 

 regularly review guidance documents and mill specific data in order to anticipate future 

 reporting responsibilities 



Alaska Hazard Ranking Model 



The Alaska Hazard Ranking Model was developed as a tool to allow ADEC to prioritize 

 contaminated sites for cleanup actions under Alaska's Oil and Hazardous Substances 

 Pollution Control Regulation. 18 AAC 75, and the state's Underground Storage Tank 

 Cleanup Regulation, 18 AAC 78. The model is designed to be used in the evaluation of 

 sites where contamination has occurred, and contaminating activity has ceased 



The Hazard Ranking Model has several limitations that are important to understand First, 

 the Ranking Score derived by the model does not consider the actual human health impact 

 of a site, only the potential for impact, therefore, a high score does not mean that human 

 health impacts such as cancer and chronic health conditions have been observed that can 

 be attributed to the site. Second, although the model does identify site specific conditions 

 such as the relative toxicity and volume of the contaminants present, and the proximity to 

 potentially affected plant, animal and human populations, the model is not a risk 

 assessment. A relatively high Ranking Score based on agency file data alone does not 

 demonstrate that a site poses any threat to human health or the environment, or that 

 immediate action is warranted. Third, the model has no way to incorporate the actual or 

 potential benefits of management practices or remediation programs which may have been 

 implemented to address potential exposure pathways 



The Ranking Score compiled by ADEC incorrectly combines contaminants, contaminated 

 media, and exposure and release pathways to develop a "composite" ranking score The 

 instructions which are part of the Model instruct the user not to score a site in this manner 

 in several different places. Multiple contaminants and multiple source sites are accounted 

 for using the Multiple Sources or Contaminants Value in the model The method used by 

 ADEC seriously overstates the resulting score. 



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