MEMORANDUM 

TO: Toni Jones, Charlene Spells, Ketan Patel, U.S. Environmental Protection Agency

FROM: Jason Huckaby, Eastern Research Group, Inc.

DATE: August 25, 2010

SUBJECT: Meeting Summary with ConocoPhillips Alaska 

INTRODUCTION 

A meeting and telephone conference between representatives of U.S. Environmental Protection 

Agency (EPA), ConocoPhillips Alaska and other interested parties was held so that stakeholders 

could present their comments and concerns on the proposed Commercial and Industrial Solid 

Waste Incineration (CISWI) emission guidelines and new source performance standards 

regarding remote incineration units in Alaska. 

ATTENDEES 

Brad Thomas, ConocoPhillips 

Clint Gill, ConocoPhillips 

Dave Newsad, SLR International representing Alaska Oil and Gas Association (by telephone) 

John Hellen, Pioneer Natural Resources, Alaska (by telephone) 

Toni Wyche Jones, EPA 

Ketan Patel, EPA 

Charlene Spells, EPA 

Susmita Dubey, EPA (by telephone) 

Jason Huckaby, ERG (by telephone) 

TIME and DATE 

2:00 to 3:00 PM EDT on August 24, 2010 

AGENDA 

See attached brief agenda prepared by ConocoPhillips Alaska and presentation slides. 

DISCUSSION SUMMARY 

The meeting discussion is presented below according to talking points, opening with an 

introduction of attendees. 
2

Toni:

Thanks for your voice mail this morning. I'll be in DC on the 23rd meeting with 

EPA about the GHG reporting rules so thought that a meeting with you on the 

24th would work best. I think 1 to 1.5 hours would be sufficient. With me will be 

Clint Gill who helps with our regulatory affairs.

Of course, the 24th is after the CISWI rule public comment period closes. I'll 

make sure our comments are submitted by the deadline and would like to use the 

meeting to ensure our issues are clearly understood. Sometimes letters don't do 

justice to matters as important as this - where the shutdown of our incinerators 

could create substantial health and safety issues as well as being very costly 

(annualized costs in excess of $100,000 per ton of emissions reduced).

Briefly, the issues I'd like to cover are:

 

 Shutting down our remote incinerators will force the periodic stockpiling of 

MSW-type waste and this could create problems with, particularly, rabid 

foxes and bears; 

 In our review of the rule, we cannot see where any Alaska incinerators can 

comply with the proposed emission standards making us face the 

possibility of removing most if not all of them all from service. It does not 

appear this was EPA's intent but the definition in the rule for "small remote 

incinerators" seems to make the conclusion inescapable; 

 In at least one case, the removal of incinerators from service may have to 

occur at or near the time of rule finalization (still working on this piece); 

and 

 We have two facilities not connected to the statewide road system and this 

will cause us, in one case, to have to fly waste to a landfill and, in another, 

to barge it all the way to the state of Washington.

We believe there are solutions consistent with EPA's intent in the rule and I want 

to propose those to you as well. I'll make sure you have our comment letter prior 

to the meeting and will develop a ppt for it.

I look forward to your response.

Brad Thomas

ConocoPhillips Alaska

ph: 907.263.4741

c: 907.947.1597
August 24, 2010
Incinerator Capacity 

(lbs/hr)

Annual Average 

Amount Burned 

(tons)

Daily Average

Amount Burned 

(tons)

NOx 

(tpy)

SO2 

(tpy)

PM-10 

(tpy)

CO 

(tpy)

KRU EU ID 35 1300 379 1.0 2.0 1.2 1.5 3.5

KRU EU ID 36 900 312 0.9 1.3 0.9 1.2 2.0

ALP EU ID 13 350 473 1.3 0.9 1.2 1.7 2.9

ALP EU ID 14 350 437 1.2 0.8 1.1 1.6 2.7

BRU Unit 150 3 <0.01 0.01 0.01 0.01 0.02

All exempt from 2000 CISWI because they burn >30% MSW
Alaska Federal Aid Highway System

Beluga River

Alpine Kuparuk Prudhoe Bay
6
Little to no spare space
30% MSW exemption removed an exemption

ubiquitously used in Alaska

CISWI (ERG memo) assumes all tested AK

incinerators in small remote incinerator category

Sets emission limits for these incinerators within

that category

Only Kuparuk complies with all limits

But small remote incinerator definition appears

to exclude Kuparuk (and most others)

Thus no small remote incinerator in Alaska can

achieve limits (see next slide)
ComparisonofProposed(6/ 4/ 2010) CISWI standards(ExistingSmall Remotesubcategory)to empirical data(3

runaverages)forthe5unitsincludedintheFloor analysisbypollutant

Propo

sdCISWI Smal Remote

Standard

Pione r Kuparuk(Noteunit

hisisabove

the

proposed1

tondaycapacity

limitfor ap licabilityforthe

smal remote

standard)

Hecla Gre

nsCre

k

Coeur ChugachElectricBeluga

Propo

sdCISWI Incinerator Standard

Cadmium (mg/dscm) 0.26 0.011 0.044 0.122 1.25 0.232 0.0013

Carbon Monoxide (ppmv) 78 11.8 40 169.1 0.45 205 2.2

Hydgrogen Chloride (ppmv) 150 81 77.7 76.4 117.9 45.4 29

Lead (mg/dscm) 1.4 0.61 1.16 0.45 0.63 2.15 0.0026

Mercury (mg/dscm) 0.0029 0.0011 0.0021 0.0018 0.0096 0.028 0.0028

Nitrogen Oxides (ppmv) 210 116.5 112.5 121.9 73.7 89.3 34

Particulate-filterable (mg/dscm) 240 189.2 181.1 118.3 83.5 106.9 13

Sulfur Dioxide (PPMV) 44 16.4 13.7 13 4.79 46.4 2.5

Dioxin Furan- Total (ng/dscm) 1600 3350 366.3 1611.7 421 632.8 0.031

Dioxin Furan - TEQ (ng/dscm) 130 0.0025

Empirical datafrom"MACTFloor Analysisfor theCommerical andIndustrial SolidWasteIncineratorsSourceCategory",April 26, 2010,ERGtoEPA

 proposed standard based on cement kiln ratio to total Dioxin Furan results

below proposed 

standard
Installation of stack controls may be technically infeasible:

Not certain serial controls can work

Not certain wet scrubber will function in Arctic

Even if it did, there d be an ice fog problem

Transportation of waste off-site is enormously expensive

but this, for now, is a secondary consideration

Transportation of waste off-site will not be a regular

occurrence

Grounded flights due to weather

Surface traffic interruptions due to white out conditions

Waste may have to be accumulated for extended

periods, this is the central problem
Without incineration, wastes can and have

become an animal attractant

Main concern is bears and foxes

Incineration part of solution to past issues

ADF&G and the USF&WS involvement

Refer to handouts

Incineration is a key tool in our human-animal

interaction management strategy

Losing this tool will force involvement of other

agencies (ADEC, ADF&G, USF&WS)
Remote Alaska incinerators, according to

proposed definitions, cannot comply with

proposed emission limits

Installation of stack controls may be technically

infeasible

Incinerator shutdown could pose health, safety,

and animal issues and regulatory problems

We therefore do not believe the proposed rule

took into adequate consideration our

circumstances
Exempt remote Alaska incinerators (i.e., those off

the FAHS and those north of the Brooks Range)

If that s not possible:

Remove from this rule-making remote Alaska

incinerators for further work

Develop specific subcategories that won t force the

shutdown of these units

A tertiary fallback but incomplete solution

would be to adjust small remote incinerator

definition to cover units that burn less than 2 tpd

We re not certain this would address the more

fundamental issues we raise, however