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Northwest. Submission of Form R, the Toxic Chemical Release Inventory is required by 

 the Emergency Planning and Community Right-to-Know Act 



The reporting of hydrochloric acid on Form R is one of the best examples of data which 

 must be properly interpreted to be understood From 1989 to 1992 following Form R 

 instructions, KPC reported that they discharged 2 million pounds of hydrochloric acid 

 even though it is not used anywhere in the pulp process This figure was an anomaly of the 

 reporting process In late 1993 KPC installed an effluent neutralization system which 

 reduced the reported discharge of chloride ion as hydrochloric acid which is now more 

 properly reported at less than 1,000 pounds per year 



To my knowledge, EPA does not use Form R in the way it is abused by KPC's opponents. 

 The Form collects information for future use and is not a compliance measurement tool 

 Nonetheless, KPC's opponents continue to cite the old Form R data in a manner which 

 completely distorts the truth 



Health Effects of Air Pollutants 



Some have asserted that Ketchikan Pulp has not complied with Alaska laws protecting the 

 enjoyment of life and property 



In April 1995, KPC completed exactly such a study for the State of AJaska The purpose of the 

 study was to determine the risk that air pollutants might pose to human health and the 

 environment. 



The study looked at the impact of dozens of chemicals including dioxin and showed that only 

 chloroform merited further analysis KPC completed a health risk assessment of chloroform 

 which showed that the human health risk was within the State's regulatory risk level. 



Resource Conservation and Recovery Act 



Testimony has suggested that KPC is not properly regulated by the Resource Conservation and 

 Recovery Act (RCRA) because the State of Alaska lacks adequate funding to enforce the law 



Alaska does not enforce this very important environmental law EPA does KPC reports all 

 hazardous waste generation activities to EPA in the Biennial Hazardous Waste Report as 

 required by the Resource Conservation and Recovery Act In addition, KPC submits a 

 waste minimization questionnaire as a supplement to the State of Alaska's Annual 

 Hazardous Waste Report 



Ward Cove Sediments and Bioaccumulation of Toxics 



Testimony has been given citing KPC's evaluation of water and sediment quality in Ward 

 Cove KPC monitors for dioxin as well as metals, mfethyl mercury, toxicity and many organic 

 chemicals Some have been detected at some Ward Cove sampling stations, but at levels lower 

 than the action thresholds established in sediment standards Concentrations of dioxin are 20 



