Meeting Report:  Alaska Fisheries Development Foundation, Anchorage, AK.


8//10/2010 

11:00 AM to 12:20 PM

Participants

James Browning, Executive Director 	Alaska Fisheries Development
Foundation

Don Anderson	U.E. EPA

Washington, DC

Zaya Ponomareva	AFDF

Betsy Bicknell	ERG

Glenn E. Reed, President	Pacific Seafood Processors Association, Seattle

Kathleen Wu	ERG, Chantilly, VA

Doug Donagan	Environmental Consultant, representing several processors

Anne Jones	ERG, Lexington, VA

Mark Sheer	Attorney, representing several processors

Mike Clutter	Icicle Seafoods

Chris LaCroix	Copper River Seafoods

Chris Norris	Icicle Seafoods

Slim Jorgen	Yard Arm Knoll (?)



	

Betsy Bicknell (ERG) provided Jim Browning, AFDF, with these notes for
his review. No comments were received from AFDF and the notes were
finalized as delivered on October 25, 2010. 

Betsy Bicknell (ERG) met with Mr. Browning, Ms. Zaya, Mr. Reed, and Mr.
Donagan in person on Tuesday morning, August 10 2010.  Other
participants listed above joined the meeting by phone.  Prior to the
meeting ERG had provided a list of potential discussion topics
(attached).  

Don Anderson (EPA/OW/EAD) began the meeting by providing a retrospective
of the national regulations that apply to seafood processing facilities
in Alaska.  In 1974-5, EPA established regulations for seafood
processing in the U.S., including regulations that were specifically
crafted for Alaska.  For certain parts of the Alaska seafood processing
industry, EPA set two levels of limits.  Less stringent limits required
that waste be ground to less than 0.5” prior to discharge.  For
seafood processing centers, called “non-remote” areas in the
regulations, EPA set limits for TSS and oil and grease, based on
screening solids from the wastewater and their off-shore disposal.  

Mr. Anderson explained that Alaskan seafood processing industry
representatives challenged the regulations in court.  The court upheld
EPA. In 1980, exercising its right to petition, industry petitioned EPA
to change the regulations because they were too costly. EPA suspended
the regulations in 1980, while considering the petition, and has never
lifted the suspension. In January 1981, EPA published a proposed a
response to the petition.  In the proposal, EPA found that Juneau should
be reclassified as “remote,” while Ketchikan, Petersburg, and
Cordova should retain the classification of non-remote and the more
stringent regulations.  While evaluating the petition, EPA evaluated two
alternatives for managing the seafood processing wastes: 1)screening and
barging for ocean disposal and 2) byproduct recovery.  

EPA Region 10 developed a General Permit for seafood processing industry
in 2001.  Comments on the proposed permit encouraged EPA to respond to
the 1980 petition and encourage waste recovery through byproduct
recovery. EPA has started the re-evaluation process, beginning with
collecting information reflecting the current state of the industry.  In
April 2010, EPA sent a questionnaire to nine seafood processing
companies with operations in Ketchikan, Petersburg, Cordova, and Juneau.
 EPA requested information about costs, revenues, technologies, and
related issues.  EPA will use this information to evaluate the economic
impacts of reinstating the suspended regulations.  EPA will evaluate
primary economic impacts, such as loss of profit, line closures, plant
closures, and job losses.  EPA will also evaluate secondary economic
impacts on the communities in which the processors are located and
foreign trade. Responses to the questionnaire are due October 1. 

To supplement the information collected by the questionnaire, EPA is
conducting a series of meetings and site visits in Alaska, August 9 –
19.  Betsy Bicknell, from ERG an EPA contractor, and Lindsay Guzzo, EPA
Region 10, will visit seafood processing and byproduct recovery plants
in Ketchikan, Petersburg, Juneau, Cordova, and Kodiak  They will meet
with other stakeholders (industry, Alaska government, academic). 

Mr. Anderson explained the timeline for the response to the petition. 
EPA plans to publish a Notice of Data Availability (NODA) in the Federal
Register in January 2011.  In addition to describing the data that EPA
has collected, Mr. Anderson that the NODA will describe EPA’s
anticipated response to the 1980 industry petition.  The NODA will be
open for comment.  Mr. Anderson hopes that EPA will be able to publish a
response (including implementing regulation) to the 1980 petition by
August 2011.

Mr. Browning asked about the timing of the EPA information collection
activities, May – October, the busiest time in the seafood processing
industry.  Mr. Anderson responded that he understands the industry cycle
and appreciates that the industry will provide the good data that EPA
needs to make good decisions. 

Mr. Clutter, from Icicle Seafoods (which operates three seafood
byproduct recovery facilities integrated with seafood processing)
commented that he appreciated the opportunity to provide industry
perspective.  He appreciates that EPA will give weight to comments from
folks who have been in the business over the years.  He noted that there
is not a one-size-fits-all approach to managing seafood processing
waste. 

Ms. Bicknell noted that prior to the meeting, Mr. Reed asked if
locations to which the regulations for “remote” areas apply might be
re-classified to “non-remote.”  Don Anderson explained that Kenai
and Dutch Harbor could be reclassified as non-remote.  EPA would need to
publish its intent and take comment on the proposed change, before any
change would take affect.  Although this would be a separate action from
the petition response, it would likely be done at the same time.  

Ms. Bicknell explained that the existing regulations are effluent
guidelines for total suspended solids (TSS) and oil and grease (O&G). 
These guidelines are used by the permitting authority (in this case,
ADEC) to develop permit discharge limits.  Ms. Bicknell noted that
permit limits may be more stringent than the guidelines (and include
limits for additional pollutants) as needed to protect water quality. 
She also noted that although the limits are based on technologies that
EPA has determined are technically feasible and economically achievable,
facilities may use any approach they can devise to meet their permit
discharge limits. 

Mr. Donagan asked if EPA was considering changing the effluent
guidelines for remote areas.  Mr. Anderson responded that it is
possible, but not likely.  The focus of the current effort is response
to the 1980 industry petition, that is, the guidelines for land-based
non-remote facilities. 

Mr. Reed asked if the criteria for what is remote or non-remote are
included in the Clean Water Act.  Mr. Anderson explained that the CWA
requires EPA to consider factors such as the age and location of
facilities as it develops guidelines.  The criteria EPA used to classify
Alaska seafood processing centers as “remote” or “non-remote”
are discussed in the 1975 Development Document.  They are also discussed
in the 1980 Industry Petition and the Agency’s proposed response. 
These documents are on the seafood processing questionnaire website.
EPA’s response to the industry petition will not change the criteria. 


Mr. Reed commented that most of the questions on EPA’s list of
discussion topics seem focused on the economics of the byproducts
production. He encouraged EPA to get specific information from the few
stand-alone by-products plants about their economics.  He asked if EPA
would account for price fluctuations in its analysis of the economic
achievability.  

Ms. Jones explained that EPA will conduct numerous analyses of the
sensitivity of the analysis outcome to price fluctuations and other
factors.   

Mr. Anderson discussed the current planned visits to secondary
by-products plants.  The visits could be followed with tailored
information requests, similar to the questionnaire sent to seafood
processors.  He noted that information provided by the industry may be
claimed as Confidential Business Information (CBI).  The industry needs
to protect its information, but other stakeholders want to know how EPA
made its decision about the petition.  Sometimes, when there are limited
numbers of facilities, EPA must screen the information it releases even
more.  

Mr. Reed expressed a concern that during the plant visits the production
people will tell EPA that they can do anything, without considering if
it is economical.  

Mr. Browning asked if the economic analysis would include energy and
transportation costs. Mr. Anderson confirmed that it would. 

Mr. Reed noted the impact of increased energy demand might be different
in small Alaska communities than elsewhere.  This is because the
electric power in coastal towns is generated by diesel powered
generators.  Increased energy demands would require burning more diesel
(to generate steam or to generate electricity).  

Meeting participants discussed additional permitting requirements of
changing current disposal practices.  Ocean disposal of screened wastes
will probably require an ocean dumping permit.  By-products production
is not zero discharge and will require a modified NPDES permit (with
limits developed from the byproducts subcategory).  Air permits may also
be required.  All participants noted that rendering processes generate
obnoxious odors, so odor control must be taken into account in the
development of byproduct recovery facilities. 

Mr. Reed noted that the scale of facilities for southeast Alaska will be
quite different than Kodiak, where they have 54,000 tons input He also
mentioned that production information is publicly available at
seafood.com

Doug Donogan agreed that investments would be required for odor control.
 He also suggested that EPA account for the impact of additional
byproducts (oil and meal) into the word markets. Would adding Alaska
production increase the supply enough that prices would be depressed. 

Mr. Reed suggested that EPA research Omega Protein. It considered
starting a meal production plant 10 years ago, but did not do so because
it didn’t “pencil out.”

Mr. Browning recalled a panel discussion that took place at the February
2009 conference in Portland, OR, focused on fish processing byproducts. 
He recalled some of the panelists (Joel Cougor, Aleutan Protein; Tony
Bimbo, seafood economist) declared that the Alaskan seafood processing
industry was “sitting on a goldmine.”  The industry participants in
the meeting scoffed at this characterization of seafood processing
wastes.  They noted that there is a resource, but the size of the waste
stream is critical in determining if byproducts can be recovered
economically.  They noted Dutch Harbor has 350 million pounds per year
in a 10 month season (white fish and salmon), vastly different than the
amount of fish processed in the non-remote processing centers in
southeast.  

Mr. Anderson mentioned that EPA will compare the cost of screening and
barging for ocean disposal to the cost of byproduct recovery.  Because
byproduct recovery has some payback, it may be a lower cost waste
management alternative, even if it doesn’t pay for itself.  Mr. Reed
stressed that if the seafood processing facility doesn’t operate in
the black it will not be operating.  

Ms. Bicknell asked if the meeting participants were aware of other uses
of fish processing waste. Mr. Browning mentioned that someone in Sitka
had used fish waste to produce biodiesel.  They found that this
biodiesel production required more energy than it produced.  None of the
meeting attendees was aware of the anaerobic digestion of fish
processing waste to generate methane. 

Ms. Jones asked what critical factors determined if seafood processors
produce byproducts from their processing waste.  Mr. Clutter explained
that the volume of waste and the length of the season are critical
factors.  In terms of location, he noted that in the non-remote
locations that are the focus of EPA’s study, when they are processing
salmon it overshadows any other species.  Icicle operates three
byproduct plants.  They produce both meal and oil.  They have found it
is not economically feasible to produce meal without oil.  

Mr. Reed suggested that most processors think about producing byproducts
every year, but if they can’t do it profitably, they won’t do it. 

Location:  tidal flow moves effluent away versus a sheltered bay, like
Sitka, where the wastes accumulate. 

 Mr. Clutter noted that EPA’s discussion points asked about a
processor sending its waste to another facility or take waste from
someone else.  He felt both approaches had elements that were outside
the processors control and for this reason were not likely to be
pursued.  What would a producer do if the other facility had an
equipment breakdown or other event and refused to take their waste?   If
they were taking waste from another facility, they would have little
control of its quality (e.g., freshness, whether it had metal
contaminants that could harm the processing equipment),  

The group discussed other impediments to by product recovery:  odor
issues, possible need for an air permit (because of burning more
diesel).  

After the meeting broke up, Mr. Browning mentioned a byproduct recovery
project planned for Sitka, called Mountlake Mining Process (Pete
Nicklason’s project).  He said that Alaska Import Export Development
Authority (AIEDA) was close to committing funds to finance the project
and that AIEDA was doing its “due diligence.” 

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