166 



times lower than the standards and well below the threshold considered low risk for fish Some 

 compounds have been detected at levels which will be addressed in the Ward Cove remediation 

 plan 



Alaska Hazard Ranking Model 



KPC's score on the Alaska Hazard Ranking Model has been cited as evidence of threats to 

 public health from the mill The Hazard Ranking Model was developed as a tool to allow 

 the State to rank sites where contamination has occurred and contaminating activity has 

 ceased. It is inappropriate to apply to an ongoing operation. 



The model has no way to incorporate the benefits of management practices or remediation 

 programs which have been implemented by the site owner The State has acknowledged 

 that permits and review programs already in place properly manage the contaminants of 

 concern and are rescoring the facility accordingly. 



Conclusion 



KPC's environmental record contains evidence of serious problems which include the 

 enforcement action which I have already described. They have already been punished, and 

 have already paid a heavy price They deserve the same opportunity as other industrial 

 enterprise to accept responsibility for their mistakes and to move on with their future 



I have only been able to cover a few of the fabrications of KPC opponents The alarm 

 they have raised is unsupported and unwarranted State and Federal regulators charged 

 with enforcing environmental regulation and protecting public health are knowledgeable of 

 the most minute details of KPC operation They have available a fijll array of compliance 

 and enforcement measures 



KPC's compliance and enforcement history is already a matter of public record They 

 accept responsibility for their shortcomings and mistakes They have nothing to hide from 

 the regulators, this Committee, or their community Thank you for the opportunity to 



testifV today 



