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Meeting Report: Alaska Department of Environmental Conservation (ADEC), 

Anchorage, AK. 

8/9/10 

9:30 – 11:00 AM 

Participants 

Lynn Kent Director, Division of Water, 

Alaska DEC 

Don Anderson U.E. EPA

Washington, DC 

Sharmon 

Stambaugh 

Manager, Water Quality 

Programs, ADEC 

Rick Cool U.S. EPA Region 10

Sharon Morgan ADEC, Juneau Betsy Bicknell ERG

Sean Stokes Manager, permits, nondomestic wastewater, ADEC 

(calling from Sitka) 

Kathleen Wu ERG, Chantilly, VA

Anne Jones ERG, Lexington, VA

Betsy Bicknell (ERG) provided Sharmon Stambaugh, ADEC with these notes for her review. No 

comments were received from ADEC and the notes were finalized as delivered on August 25, 

2010. 

Betsy Bicknell (ERG) met with Lynn Kent and Sharmon Stambaugh in person on Monday 

morning, August 9, 2010 at the ADEC offices in Anchorage. Other participants listed above 

joined the meeting by phone. 

Division Director Lynn Kent explained that her division is responsible for APDES permits, 

compliance, facilities grants and loans (state revolving fund), cruise ships, and water quality 

standards and monitoring. Sharman Stambaugh’s group is responsible for water quality, permits, 

and enforcement. Sharon Morgan also reports to Sharmon Stambaugh. 

Lynn Kent explained that the seafood industry is both vital to the Alaska economy and a vital, 

thriving industry. Because of the geographical differences between Alaska and the lower 48, 

Alaska seafood processors have unique issues. 

Not all seafood processors are direct discharges. Some in Anchorage discharge to the municipal 

sewer system. Some processors discharge to septic tanks and absorption fields. 

Don Anderson provided an update on EPA’s work on responding to the seafood processing 

industry petition. He noted that EPA extended the due date for the questionnaire to October 1. 

He also noted that changes to any of the limits are not part of the scope of the project. For 

example, reviewing the requirement for 0.5” grind (versus whole carcass disposal), is not part of 

the review1. 

 

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 Sharmon Stambaugh explained that some limited studies indicate that whole carcasses may degrade better 

in an underwater environment than waste ground to 0.5” dimensions. Further, there is cost to grinding, so 

some processors are interested in changing the 0.5” grinding requirement that applies to seafood processors 

in remote locations. 
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Betsy Bicknell explained that ERG has been tasked to support EPA’s evaluation of the cost to the 

industry to comply with the currently suspended limits for TSS and oil and grease. Compliance 

with these limits could be achieved via screening and offsite disposal. 

After discussion that landfill disposal of seafood wastes was not feasible in Alaska because it 

attracts bears, gulls, and eagles, Ms. Bicknell clarified that by “offsite” she meant off shore. 

Sharmon Stambaugh asked how offshore disposal would be permitted. Although it was “outfall 

003” in the EPA general permit, offshore disposal requires an ocean dumping permit (it is not 

part of NPDES). Lynn explained that EPA does not have a strong ocean dumping permitting 

system; it is typically done by letters. 

Processors want to maximize seasons 

Using raw material, e.g. chum after roe has been harvested 

Northwest communities have some very small seafood processing plants 

Fish hatcheries process their fish (for example, Macaulay salmon hatchery in Juneau) 

Sean Stokes asked if EPA would clarify the definition of “non-remote” processing centers in the 

regulation. It currently provides the list of centers, and says that “non-remote” is “not limited to” 

the centers listed. ADEC noted that other communities are processing a lot of fish: 

• Dutch Harbor 

• Kenai Peninsula 

• Petersburg and Wrangell are of similar size (in terms of seafood processing) 

• Excursion Inlet (near Juneau, across from Admiralty Island)

• Seward 

• Sitka 

Sharmon Stambaugh expressed a preference to waste management solutions that provided 

beneficial use of the seafood processing wastes. She noted that barging would require costly fuel 

and generate excess emissions. She mentioned one local byproducts plant, Arctic Paws, who 

produce Yummy Chummy dog treats. She also noted that fish-based fertilizer is available locally. 

We discussed access to capital for businesses to establish byproducts recovery plants. 

Lynn Kent mentioned that the clean water revolving loan fund could probably be used for such 

projects; however, municipalities need all the funds for their wastewater treatment plants and 

there isn’t any money available for other uses. 

Alaska Import Export Development Authority (AIEDA) provides financing to help start 

businesses. However, Sharmon related that they are gun shy of seafood products, they started a 

business that went bust, they got burned, and are not eager to work with the seafood industry. 

Native Alaska corporations may be interested in investing in seafood byproducts plants. There 

are xx corporations, including Sealaska (Tlingit, Haida and Tsimshian, in southeast Alaska) 

NANA (Inupiat, in northwest Alaska) and others. 

Alaska Division of Community Advocacy (ADCA) provides grants to small communities. This is 

another possible source of financing. 
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Lynn Kent asked how much EPA would be able to present to the public and other stakeholders 

the basis of its conclusions about economic achievability of the currently suspending regulations. 

ERG explained that the questionnaire requested company and facility financial information, much 

of which will be company confidential information. Don Anderson further explained that 

although EPA will have this information, they may not be able to present it, even in aggregated 

form. Even if aggregated, the CBI may be deducible by a knowledgeable reader, so even 

aggregated data would not be presented. However, the methodology and underlying assumptions 

EPA uses in its analysis will be thoroughly explained and available to the public in the docket 

supporting the EPA action. 

Sharmon noted cost factors that vary quite a bit: 

• Shipping costs, due to the variability in the price of fuel; 

• Production (catch) varies year-to-year; 

• Product and byproduct prices. 

Don Anderson explained that because of these varying factors, EPA would conduct a range-type 

of analysis. 

ADEC noted that there are risks when the processors hire vessels to haul waste, including spills 

and other unpermitted discharges. 

ADEC asked if EPA was including near-shore facilities (vessels that anchor close to shore and 

don’t move). Don Anderson explained that the questionnaire directed companies to report about 

their near-shore facilities, but EPA did not presently think they would be included in the petition 

response. 

Sean described a small town (Caltague?) that estimated the cost of a byproduct facility to handle 

waste from several hundred thousand pounds of processed fish was $1 million. He did not have 

cost details. Sean could provide contact information for the ADCA grant administrator. 

Lynn asked for an update of EPA’s timeline for the action. Don Anderson replied that companies 

would submit completed questionnaire by October 1. After January 1, 11, EPA would issue a 

Notice of Availability (and request for comment). This would be the main opportunity for public 

comment for EPA’s possible action on the petition. 

After reviewing the comments on the NODA, EPA would publish its final action for locations 

identified in the petition. If EPA determined it should add additional processing centers to the list 

of “non-remote” processing centers, Don believes this would require a separate action with a 

proposal and final rule. 

Lynn Kent expressed her concern about the notice and comment process. She was concerned that 

the industry might not recognize the NODA as their only opportunity to comment on EPA’s 

action on the petition (because the industry is used to a proposed rule and final rule process). 

We discussed the need to inform the industry of EPA’s process, so they will understand that 

commenting on the NODA is their opportunity to comment on EPA’s action. 

Betsy Bicknell mentioned that one of the seafood processors she and Lindsay Guzzo plan to visit 

in Juneau is Alaska Glacier. Sharmon explained that Alaska Glacier screens and barges its waste 
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to inland waters. They may transport some of the waste to landfills. They are not eligible for an 

ocean dumping permit. 

Betsy Bicknell 

After the meeting, Sharmon explained the electric power sources in Alaska 

Juneau, Ketchikan, Sitka: have hydroelectric plants, with diesel back-up. 

Most coastal communities rely on diesel powered generators. 

Anchorage uses natural gas, recovered from Cook Inlet. 

Other energy sources are being discussed, including wind and tidal. Geothermal areas are remote 

from population centers and so are not feasible.