1

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 offshore 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, 
2

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. 
3

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.”
4

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.”