EPA 910/9-76-017
EPA- IO-AK-NORTH POLE-FNSB-NPDES-76
ENERGY COMPANY OF ALASKA
TOPPING PLANT
NORTH POLE, ALASKA
FINAL ENVIRONMENTAL IMPACT STATEMENT
PREPARED BY
ENVIRONMENTAL PROTECTION AOE
L SEATTLE, WASHINGTON
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
on
Proposed Issuance of New Source National Pollutant
Discharge Elimination System Permit AK-002546-1 to
ENERGY COMPANY OF ALASKA TOPPING PLANT
for Discharge of Wastewaters to the Tanana River at
North Pole, Alaska
Prepared by:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X, SEATTLE, WASHINGTON 98101
Approved by:
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ERRATA
Page 35 - Replace the second paragraph with the following
paragraph:
A dye dilution study conducted in the larger (140 cfs)
channel found that mixing at 200 feet below the mid-stream
release point was about 41 percent of the complete mixing value,
this would correspond to a dilution ratio of between 500 to 1
and 600 to 1 for a waste discharge of 0.1 cfs. (See Appendix,
Exhibit 6 for dye study methods and analysis of mixing charac-
teristics. )
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PREFACE
On October 23, 1975 the U.S. Environmental Protection Agency
released for public review a draft environmental impact statement
on the proposed issuance of new source NPDES Permit #AK-002546-l
to Energy Company of Alaska (ECA) for discharge into the Tanana
River. In compliance with the provisions of the Federal Water
Pollution Control Act, as amended, (33 U.S.C. 1251 et seq), the
permit would authorize ECA to discharge process and non-process
effluent from their facility in accordance with the effluent
limitations, monitoring requirements and other conditions set
forth in the permit. To complete the environmental impact evalua-
tion of the proposed action (the issuance of the permit), EPA has
prepared this final EIS which is the result of the Agency's considera-
tion of the comments received on the draft EIS, testimony presented
at the public meeting, and additional evaluation of the discharge
and treatment alternatives.
New additions to the text of this final EIS are the inclusion
of Chapter 11 entitled "Comments and Responses to the Draft EIS"
and Chapter 12 entitled "Comments Received On the Desirability of
the Project." In Chapter 11, EPA has reproduced letters commenting
specifically on the draft statement and has attempted to respond
to all questions and requests for explanation, additional information,
corrections or revisions. Where necessary, appropriate changes have
been made in the text.
Chapter 12 is a collection of letters voicing opinions on whether
or not the topping plant is desirable. While these letters do not
specifically address concerns with the EIS, EPA considers these
expressions of values and feelings an important part of the decision-
making process. All of the comments received, whether by letter,
petition, or testimony, will be considered in the final decision.
Additional studies of the receiving water and public comment on
the draft EIS and draft permit prompted significant changes in the
requirements and conditions delineated in the proposed permit. As
proposed in the NPDES permit (Exhibit 5), the dilution required for
the effluent to meet Alaska Water Quality Standards has been reduced
from 590 to 1 to 200 to 1. In order to achieve these levels the
Energy Company of Alaska has agreed to install tertiary treatment
units. This additional treatment will result in substantial reductions
in the allowable pollutant load to be discharged into the Tanana River.
These strict limitations will ensure that the impacts on the water quality
of the river will be minimal.
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Under the proposed NPDES permit the permittee cannot discharge
domestic waste without ensuring that this waste will be treated to
secondary levels (or better). The permit offers three alternatives:
(1) The permittee may discharge sanitary wastes to a treatment
facility (other than their own) which provides adequate
secondary treatment as specified in 40 CFR 133;
(2) the permittee may contain sanitary wastes totally, thus
requiring no discharge, or
(3) the permittee may treat its own waste to secondary levels
and discharge directly to the Tanana or through another
existing treatment system.
EPA will also require a specific study which will ensure that
water quality is met at the defined mixing zone boundaries. At least
once during each of the months of December, January, February, and
March the permittee shall conduct a dye study. This will involve
injecting dye into his effluent at a constant rate and collecting
samples at specific points downstream. If the specified level of
dilution is not achieved, the permittee is required to notify EPA
and the State and must curtail or eliminate discharge to ensure that
proper dilution is achieved. Remedial measures include relocation of
discharge location with the concurrence of EPA and the State.
As a result of recommendations made during the comment period,
ECA will (1) utilize the Soil Conservation Service "Vegetative Guide for
Alaska" to revegetate cleared areas and (2) further investigate a
joint (or better coordinated) air monitoring program with the Environ-
mental Services Department of the Fairbanks North Star Borough for
the City of North Pole. Energy Company of Alaska will monitor for
N(L and SC»2 one year prior to startup and will continue to monitor
ana provide data to the State and Borough following startup. The Environ-
mental Services Department will monitor for carbon monoxide and parti-
culates. This program should provide the Borough and State with a
substantial amount of data on ambient air quality which is presently
lacking and will prevent duplication of effort and the expenditure
of unnecessary funds and resources.
With these changes, the Environmental Protection Agency submits
this final EIS to the public for a review period of thirty days. Follow-
ing this review period the Regional Administrator of EPA, Region X, will
make his final determination concerning the issuance of new source NPDES
permit #AK-002546-l to Energy Company of Alaska.
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TABLE OF OONlEflS
Page
CHAPTER 1
Introduction 18
History of Energy Company 18
Relationship with GVEA and Alyeska 18
Required Permits 19
CHAPTER 2
Description of Existing Environment 20
Project Site 21
Location 21
General Description 21
Leased Area 21
Existing Site Facilities 25
Geology 25
Topography . ..... 26
Soils 26
Permafrost ..... 27
Seismic Activity 28
Existing Hydrologic Conditions 30
Surface Drainage 30
Groundwater 35
Existing Air Quality 39
Climatology 43
Climatological Overview 43
Temperature 43
Precipitation 43
Storms 45
Wind 45
Stability 46
Mixing Depths 50
Ice Fog. 50
Flora and Fauna 52
Flora 52
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Fauna 56
Aquatic (Tanana River Fisheries) 56
Benthic Organisms 58
Terrestrial 58
Existing Land Use and Zoning 62
Existing Socio-Economic Environment 64
North Pole 64
Fairbanks North Star Borough 68
CHAPTER 3
Description of Proposed Action 70
CHAPTER 4
Description of Proposed Project 72
Market Area 73
Site Selection 73
Plant Type and Mode of Operation 77
General Description 77
Supply and Return Pipelines 79
Steam Supply 85
Electrical Power Supply 85
Water Supply 85
Wastewater Treatment 87
Water Quality Monitoring 91
Air Coolers 92
Stack and Flare 92
Schedule for Construction 93
Future Facility Expansion 93
CHAPTER 5
Environmental Impacts of Proposed Project 95
Water Quality Impacts 96
Tanana River Impacts 97
Groundwater Impacts. 100
Air Quality Impacts 100a
Air Pollution Conditions 100a
Primary Impacts - Stationary Source 101
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Combined Air Quality Effects of
the ECA-GVEA Facilities 129a
State Evaluation of Air Impacts 129a
Noise Impacts 129b
Secondary Impacts - Mobile Sources 130
Socio-Economic Impacts. 135
Demographics 135
Employment 137
Economic Base 137
Services and Facilities 138
Water Supply and Sewage Treatment 138
Fire Protection 140
Police Protection 140
Schools 141
Medical Services 141
Housing 141
Recreational Facilities 142
Other Facilities 143
Potential for Future Development 143a
Summary 144
Land Use Impacts 147
Historic and Archaeological Sites 147a
Flora and Fauna Impacts 148
Wildlife Impacts 148
Fisheries Impacts 149
Vegetation Impacts 149a
Aesthetic Impacts 150
Construction Impacts 150a
Permafrost 150a
Erosion 150a
Water 150b
Air. . . . 150b
Solid Waste 150b
Noise 151
Mitigative Measures 151
Site Utilization 151
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Modular Construction 151
Seismic Activity 152
Storage Facilities 152
Air Coolers 152
Odor 152
Oil Spill Prevention 153
Emission/Effluent Controls 154
CHAPTER 6
Unavoidable Adverse Environmental Effects 155
Adverse Impacts which Cannot be Avoided Should
the Proposed Action be Implemented 156
CHAPTER 7
Relationship Between Local Short-Term Use and
Maintenance of Long-Term Productivity 158
CHAPTER 8
Irreversible and Irretrievable Commitment of Resources ... 161
CHAPTER 9
Alternatives to Proposed Action 163
Alternatives 164
Issue Permit (Action) 164
Mixing Zone Considerations 164
Major Permit Issuance Alternatives 165
Deny Permit (No Action) 172
CHAPTER 10
Consultation and Coordination with Others 175
CHAPTER 11
Comments and Responses to the Draft EIS 178
CHAPTER 12
Comments Received on the Desirability of the Project .... 33
REFERENCES 381
APPENDIX
GLOSSARY
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LIST OF FIGURES
Figure No. Title Page
1. Location of North Pole with the
Borough 22
2. Topography Surrounding the North
Pole Site 23
3. North Pole and Vicinity 24
4. Site Location 31
5. Seasonal Changes of Water Table Depth . . 33
6. North Pole and Vicinity Water Table
Depths 37
7. Total Suspended Particulate (TSP)
Levels for North Pole 41
8. Schematic Diagrams of Typical Stack
Plume Patterns 48
9. Annual Variation of Wind Speeds and
Mixing Depths 51
10. Recommended Land Uses for North Pole Area 63
11. North Pole Topping Plant - Market Area. . 74
12. Block Flow Diagram 78
13. Overall Plot Plan - Original Orientation. 80
14. Revised Plot Plan 81
15. Process Area 82
16. Tank Farm Layout 83
17. Wastewater Treatment Facilities 84
17a. Detailed Wastewater Treatment Facilities. 84a
18. Water Flow Schematic Diagram 86
19. Wastewater Treatment System ....... 90
20. Coincident Winds with Hours of Ice Fog. . 108
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Figure No. Title Page
21. Typical Patterns of Light Surface Air 114
Flow During Extended Ice Fog Periods
22. North Pole Annual Wind Rose 117
23. 3-Minute Average Ground Level Concentration. 120
24. Plot of Fog/No Fog vs. Downwind Distance.... 127
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LIST OF TABLES
Table No. Title Page
1. Earthquakes in the Fairbanks Area 29
2. Flow of the Tanana River at Fairbanks ... 32
3. Meteorological Data for 1973, Fairbanks . . 44
4. Stability Categories 47
5. Plant Species Common to the North Pole
Area 53
6. Fish Use of the Main Tanana River 57
7. Manuals Common to the Fairbanks -
North Pole Area 59
8. Birds Common to the Fairbanks -
North Pole Area 60
9. North Pole Sewage Charges . . 66
10. Relative Acceptability of Potential Sites . 76
11. Constituents of Treated Process and Oily
Waste Water 89
12. Effect of Proposed Maximum Allowable
Discharge on the Tanana River at 3100 cfs . 99
13. Alaska Industrial Processes and Fuel
Burning Equipment Emissions Regulations . . 102
14. Frequencies of Wind Speed Ranges at Surface
and 600 meters above the Surface 110
15. Quadrant of Wind Directions at 1200z. ... Ill
16. Quadrant fo Wind Direction at OOOOz .... 112
17. Percentage Frequency of Wind Direction in
Velocity Classes by Stability Categories. . 116
18. Emission Burden - Mobile Sources 133
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Table No.
Title
P£fl£
19.
20.
21.
22.
23.
24.
25.
26.
27.
Number of Idling Cars Necessary to
Produce Emissions Equivalent to
Expected Emission Increase ....
Refinery and Marketing Personnel . .
Civilian Market - Demand Levels and
Potential Savings
Maximum Allowable Concentrations in
the Tanana River
Major Permit Issuance Alternatives for
Process Effluent Limitations ....
New Source Performance Standards for
Storm Runoff
Tertiary Treatment Processes and
Estimated Effluent Concentrations. .
Comments Received on the Draft EIS .
Comments Received on the Desirability
of the Project
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APPENDIX
EXHIBIT TITLE
1 Alaska State Water Quality Standards Summary
2 Water Quality Data
3 Fairbanks International Airport Wind Roses
4 Eielsen Air Force Base Wind Roses
5 Draft of New Source NPDES Permit
6 Miscellaneous Water-Related Information
7 Noise Data - North Pole Refinery Site
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SUMMARY SHEET FOR ENVIRONMENTAL
IMPACT STATEMENT
ENERGY COMPANY OF ALASKA TOPPING PLANT
NORTH POLE, ALASKA
(Check One)
( ) Draft
(X) Final
ENVIRONMENTAL PROTECTION AGENCY
Region X
Office of Federal Affairs
1. Name of action: (Check One)
(X) Administrative Action
( ) Legislative Action
2. Brief description of action indicating what states (and counties)
are particularly affected:
The U.S. Environmental Protection Agency is considering the issuance
of a new source NPDES permit for discharge of process waters from ECA's
proposed topping plant into the Tanana River. Pursuant to the National
Environmental Policy Act of 1969 (PL 91-190), EPA has prepared this
environmental impact statement to evaluate the probable impact of this
action on the City of North Pole, the Tanana River, and the surround-
ing area. North Pole is located within the Fairbanks North Star Borough
and lies about about 14 miles southeast of the City of Fairbanks.
The proposed topping plant will be capable of processing up to
25,000 barrels per day of crude oil from the Trans-Alaska Pipeline.
The plant, which is scheduled to begin operation in mid-1977, will
manufacture heating oils, diesel fuel, industrial turbine fuel, military
jet fuel, and asphalt.
The project is significant as the first of the "pipeline industries"
and as the first oil refinery to be located on fresh water in Alaska.
The initial cost of the project is estimated at $25 to $30 million.
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3. Summary of environmental impact and adverse environment effects:
(a) ECA anticipates that the location of the topping plant at North
Pole will eliminate the need for the Alaska Interior to import certain
petroleum products from Anchorage, Seward or Valdez. A 5-9
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Air Quality Impact
(does not include background)
SO?
T^g/m3)
Suspended Particulate
Matter (ug/m3-)
Topping Plant
Short-term Long-Term
28.0
(3-minute)
0.7
(seasonal)
.3 .005
(3-minute) (seasonal)
Regulation
Short-Term Long-Term
1300.
(3-hour)
150.
(24-hour)
80.
(annual)
60.
(annual)
NO?
Tug/m3)
23.0 0.4
(3-minute) (seasonal)
100.
(annual)
It should be noted that if the longer averaging times provided for
in the regulations (compared to the time periods assumed in the impact
estimates) were used for estimating pollutant concentrations resulting
from the plant, the results would be lower than tabulated.
The most frequent and persistent pattern of plumaflow is expected
to be in an east to west direction. Indications are that the topping
plant effective stack height would be in the range of 200-300 meters.
No ground level ice fog is expected from the topping plant stack
except under extremely cold atmospheric conditions {less than -30°F).
Some ice fog is expected in the elevated plume(several hundred feet
above the surface).
Increased automobile and truck traffic and increased traffic due
to the availability of cheaper fuels may aggravate ground level ice fog
conditions in Fairbanks, along the Old and New Richardson Highways, and
in North Pole.
(e) The construction of the topping plant within the North Pole
city limits will add substantially to the city's tax base. At the
present time, there is no industry within the city and very few commer-
cail establishments. The refinery will be one of the largest and most
significant economic factors in the community.
(f) Direct economic "benefits" to the city of North Pole include
increased levels of employment, payrolls and real estate property tax.
The plant will provide employment for approximately 100 persons
during construction and 60 persons for plant operation. The 60 perma-
nent employees alone will require an annual payroll of approximately $1.5
million.
Secondary effects are also expected in the form of additional retail
sales, home purchases, and the related creation of supportive employment.
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(g) In terms of land use trends that will be set by the presence
of the topping plant in North Pole, the possibility exists that much
of the land within the city will be used for more intensive purposes.
As much of the land surrounding the proposed site is still vacant,
expansion of an industrial complex is possible if the Borough and City
planners determine that adjacent lands are suited for that use. EPA
recommends that before zoning variances are granted, the residents and
planners of North Pole and the Borough determine whether or not such
growth will be in the interest of the North Pole residents.
4. List of Alternatives Considered.
1. No Action - Deny New Source NPDES Permit Application
2. Action - Issue Permit to Energy Company of Alaska
a. Require that ECA meet New Source Performance Standards (NSPS)
and achieve Alaska Water Quality Standards (AWQS) within a
defined mixing zone sized according to the allowed discharge.
b. Require that ECA achieve AWQS within a smaller mixing zone at
smaller dilution flows through stricter limitations than NSPS
necessitating consideration also of:
(1) Tertiary treatment
(2) Substantial recycle of treated effluent within the plant
c. Require that ECA achieve AWQS in the effluent.
5. The following Federal, State and local agencies and interested groups
and individuals were invited to comment on the environmental impact
statement:
Federal, State and Local Agencies
The Council on Environmental Quality
U. S. Department of Agriculture
U. S. Department of Interior
U. S. Department of Transportation
U. S. Department of Health, Education and Welfare
U. S. Department of Defense
U. S. Department of Housing and Urban Development
U. S. Army Corps of Engineers
National Marine Fisheries Service, Juneau
U. S. Department of Commerce
Advisory Council on Historic Preservation, Washington, D. C.
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Alaska State Clearinghouse
Department of Environmental Conservation
Department of Law
Department of Fish and Game
Department of Regional and Community Affairs
Department of Health and Social Services
Department of Natural Resources
State Historic Preservation Officer
Department of Economic Development
Department of Highways
Joint State-Federal Land Use Planning Commission
City of North Pole- Mayor and City Council
Governor of Alaska
Fairbanks North Star Borough
Planning Office
Pipe]fne Impact Information Center
Pollution Control Officer
Organizations
Alaska Sportuian's Council, Juneau
Sierra Club, Juneau and San Francisco
Alaska Conservation Society, College and Kenai
Alaska Wilderness Council, Anchorage
National Audubon Society
Alaska Center for the Environment, Anchorage
Fairbanks Environmental Center, Fairbanks
Golden Valley Electric Association
Friends of the Earth
Defenders of Wildlife
League of Women Voters of Alaska
Trout Unlimited
Individuals
Dr. Carl Benson
Dr. William Wood
Jack E. Wright
Con Miller
Helen Atkinson
Sue Ann Bowling
Glenn Shavj
Floyd Estes
Leo Schlotfeldt
C. William Snedden
Tom Miklautsch
Clarence Holt
6. This final environmental impact statement was made available to the
CouncfJ on Environmental Quality on:
Members of Congress
Ted Stevens - U.S. Senate
Mike Gravel - U.S. Senate
Don Young - U.S. House of
Representatives
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CHAPTER 1
INTRODUCTION
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INTRODUCTION
History of Energy Company
Energy Company of Alaska (ECA) was organized for the express
purpose of constructing and operating the proposed topping plant near
Fairbanks. ECA, a subsidiary of Earth Resources Company, was incor-
porated on August 27, 1969 under the laws of the State of Alaska. The
company's main office is presently located in Dallas, Texas (One Energy
Square, Suite 1200); however, it will be relocated in North Pole as soon
as construction of the topping plant is underway.
The majority of the company's stock is held by Earth Resources
Company, although thirty resident Alaskans are among the shareholders.
The Board of Directors of ECA is composed of six members, 3 of
whom are Alaskans: Dr. William Wood and Ray Kohler of Fairbanks, and
Larry Carr of Anchorage. Also serving on the board are Lloyd Burgess
of Seattle, Dan M. Krausse, President of Earth Resources Company, and
Robert J. Donachie, Executive Vice-President of Earth Resources.
Mr. E. R. Bouchard, Vice-President of ECA and former deputy manager
of the British Petroleum refinery in Ontario, is director and manager
of the proposed topping plant project.
In October of 1973, ECA acquired the business of Rogers and
Babler, Incorporated. Established in Alaska in 1949, Rogers and
Babler, Incorporated has been actively engaged in road building and
paving and the manufacture and sale of coumerclal aggregates and hot-
mix asphalt in the Anchorage area.
Relationship with GVEA and Alyeska
Golden Valley Electric Association has obtained a Partial Assign-
ment of Lease of 8 acres of Section 16, Township 2 South, Range 2 East,
Fairbanks Meridian, from Energy Company of Alaska with the approval of
the Alaska Department of Natural Resources. GVEA has begun construc-
tion of an electrical power generating plant which will house two 60
megawatt combustion turbine generators. Each regenerative gas turbine
unit will have a base load rating of 60,500 KW and a peak load rating
of 66,000 KW at site elevation and 35°F ambient temperature. The gas
turbines will serve as "peaking" and "firming" units with the existing
coal fired Healy plant providing base load capacity.
Because the turbines will use distillate oil for fuel, ECA intends
to enter into contractual agreement with GVEA to provide special turbine
fuel, and for GVEA to provide ECA with waste heat from the combustion
18
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turbines for process requirements. If the topping facility is not
constructed, G.V.E.A. intends to use Tesoro Arctic Diesel fuel imported
from the Kenai Peninsula. The generating facility is not wholly dependent
on the topping plant for its operation. Because each project can operate
without the other, they are not considered interdependent. If each is
constructed, however, they will be considered mutually beneficial.
To finance the design and construction if its new facility, GVEA
has applied for financing from the Rural Electrification Administration
(U.S.D.A.) and from the National Rural Utilities Cooperative Finance
Corporation (CFC). REA is currently preparing a draft environmental
impact statement on the GVEA facility and expects to publish the docu-
ment in late February or early March.
To date, GVEA has obtained a building permit from the City of
North Pole, a zoning permit from the Fairbanks North Star Borough,
two separate Air Quality Control Permits to Operate from the Alaska
Department of Environmental Conservation and a Conditional Use Permit
from the Planning Commission of the Fairbanks North Star Borough. In
approving GVEA's request for a land use permit, the Planning Commission
stated that it ".... recognized the benefits to the community of
locating a power plant on (the) proposed site, with regards to air
quality, reducing costs to the consumer, reducing ice fog generation
in an urban area and yet providing the power needs of the community
during a period of rapid growth." 1/
ECA has consumated a contract to secure crude oil for the topping
plant from a North Slope producer. The oil will come directly from
the Alyeska pipeline which will run 5 miles east of Fairbanks and 3
miles east of North Pole. ECA expects to draw 25,000 barrels of crude
per day from the pipeline and return about 10,000 barrels per day of
residual materials. ECA has also registered an interest with the
State of Alaska to secure state royalty oil.
ECA has submitted a bid to Alyeska to provide pre-startup turbine
fuel and operating fuel for Alyeska1s pump station 8. However, no
final decision on the bid will be made until ECA is granted a discharge
permit and begins operation. Alyeska has begun construction of its own
topping plant to produce fuel for pump station 8 but will consider pro-
curement of fuel in the future from ECA if it proves more economical.
Required Permits
In accordance with 18 AAC 50.120, ECA has submitted an application
to the Alaska State Department of Environmental Conservation for an
Air Quality Control Permit to Operate. The application to DEC addres-
sed bulk materials storage and handling capacity, estimated emissions
from stack and storage facilities, and fuel burning, sludge inciner-
ation, and process equipment. The permit will include pre- and post-
operational monitoring requirements.
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The State DEC is also reviewing ECA's application for a Waste
Disposal Permit (or Certification of Reasonable Assurance) in
accordance with 18 AAC 70.081-.090. The review will involve review
of waste treatment plans, and the permit will include monitoring
requirements.
Pursuant to AS 46.15.040 and 11 AAC 72.050, a permit from the
State Department of Natural Resources is required to appropriate the
process water pumped from on-site wells. ECA must also secure a
permit from the Alaska Department of Fish and Game for work affecting
the Tanana River and Chena Slough in accordance with Alaska Statute
16.05.870. ECA will schedule construction accordinq to their recommenda-
tions.
In order to construct the waste water discharge outfall in the
Tanana River, ECA must obtain a Corps of Engineers permit under the
Rivers and Harbors Act of 1899. Since the effluent line must cross
the Tanana-Chena levee, the crossing will be reviewed by the Corps
to assure minimal impacts on this flood control structure.
In order to discharge effluent waters from its proposed facility
ECA must obtain a new source National Pollutant Discharge Elimination
System (NPDES) permit from EPA. The decision to grant or deny ECA
the permit will be made by the Administrator of EPA, Region X, thirty
days after the publication of this final EIS and not until a minimum
of ninety days after the publication of the draft EIS.
ECA has indicated that future expansion plans include the addition
of a Hydrotreater and Reformer to manufacture gasoline and commercial
jet fuel. If this expansion involves other processes covered by EPA's
New Source Performance Standards (including petroleum storage vessels),
environmental acceptability of the action will be reviewed. EPA will
require that the best available system of air emission control tech-
nology be employed and that specific emission levels be met.
The facility as proposed is not subject to review under the EPA
Prevention of Significant Deterioration regulation. This determination
was made by EPA after review of materials concerning contractual obli-
gations for the project.
19a
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CHAPTER z
DESCRIPTION OF
EXISTING
ENVIRONMENT
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PROJECT SITE
Location
ECA's proposed topping plant site is located in the Tanana Valley,
in Interior Alaska, as shown in Figure 1. Located within the Fairbanks
North Star Borough, the site is approximately 1/4 mile south of North
Pole - a small city approximately 14 miles southeast of the City of
Fairbanks. Figure 2 shows the plant location in relation to the
surrounding area. The site is bordered by the Alaska Railroad and Old
Richardson Highway on the northeast and by the Tanana River on the
southwest. The U.S. Army Corps of Engineers flood control levee runs
through ECA's site. The Trans Alaska Pipeline route is approximately
3 miles to the east of the site (see Figure 3).
General Description
The topping plant site is located on the east side of the Tanana
River. It is a relatively level plain, characterized by a few shallow
slough meanders and local depressions. The U.S. Army Corps of Engineer's
flood control levee, which transects the site on the southwest, has
rendered the sloughs inactive, and combined with the Chena Lakes flood
control project, should prevent major flooding of the site and the
North Pole area.
Like much of the surrounding area, the site is covered with rela-
tively dense stands of black spruce (Picea mariana (Mill QB.S.P.)
with scattered clumps of birch (Betul^gTandulosa) and willows
(Salix spp.). Scars from past fires, which account for much of the
open grass areas on the site, are still visible.
Leased Area
The site, which covers 421 acres, was leased from the State of
Alaska, through the Director of the Division of Lands, Department of
Natural Resources. It is located in Section 16, Township 2 South,
Range 2 East, Fairbanks Meridian, ECA's lease term of 55 years com-
menced on October 22, 1970 and will end on October 21, 2025.
Golden Valley Electric Association holds a lease for 8 acres of the
site for ar? electrical power generating plant which will house two 60-MW
combustion turbine generators. This portion of Section 16 was cleared
in June, 1975 and GVEA has begun construction of the facility.
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ALASKA MAI' A
i 1 ~~£'':
/>*v
3^sm.
^-r-vSf L-r^.
.wtu,<
_.T
'_' ' c Hi— .
O NORTH POLE
NORTH STAR BOROUGH BOUNDARIES
ALASKA
FIGURE I
ALASKA M/VP \N ITH LOCATION OF NORTH POLE WITHIN THE NORTH STAR BOROUGH INDICATED
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ECA SITE FIGURE 2
TOPOGRAPHY SURROUNDING THE NORTH POLE SITE
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PAGE NOT
AVAILABLE
DIGITALLY
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Existing Site Facilities
Existing facilities on the site include the U. S. Army Corps of
Engineers Flood Control levee which runs through the southwest comer
of the leased area (see Figure 3) and three 10,000 barrel fuel tanks
belonging to GVEA. GVEA is continuing construction of its power
generating facility as planned.
GEOLOGY
The ECA topping plant site is located in the physiographic pro-
vince referred to as the Alaska Intermontane Plateau. This geographi-
cal area is bounded by the Brooks Range to the north and the Alaska
Range to the south, and is characterized by low mountains, plateaus,
and highlands of generally rolling topography. It is dominated by
the Tanana, a glacially fed river surrounded by relatively flat ter-
ra i n.2 ».3'
Within this province the site is located in the Tanana lowland
which lies within the Tanana River basin. The Tanana lowland is a
wide flood plain composed of thick beds of stratified gravels between
the upland on the north and the Alaska Range on the south. Coalescing
alluvial fans which extend north from the Alaska Range to the Tanana
flood plain were formed by sediments from the south deposited by north-
flowing rivers. These alluvial fans have forced the Tanana River to
flow along the northerly edge of the Tanana lowland. Aggradation of
the Tanana River and its tributaries is largely controlled by the
deposition of sediment from glacial streams and by the uplift of the
Alaska Range during the Pleistocene.
Although the Tanana River is heavily laden with outwash materials
from glaciers in the Alaska Range to the south, the Fairbanks-North
Pole area has never been glaciated. When glaciation was at its maximum,
several hundred feet of gravel and sand were deposited in the Tanana
lowland. These deposits were later covered by layers of fine alluvial
sand and silt, ranging from a few inches to many feet thick.
25
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Topography
The broad, level flood plain which borders the Tanana River and
its main tributary in this area, the Chena River, is still heavily
vegetated and, for the most part, lacks the ground relief necessary
for adequate surface drainage. Elevations within this flood plain
average less than 450 feet above sea level, however adjacent hills and
bluffs rise to 1,000-1,800 feet above sea level.1/
In the alluvial flood plain there are four major soil types:
(1) the wel 1-drained, sandy Salchaket soils, which border the princi-
pal rivers and are the most extensive soils of the alluvial plains,
(2) the poorly-drained, sandy Bradway soils, which occupy old stream
channels and low areas near principal rivers, (3) the silty, imperfect-
ly drained Tanana soils, and (4) the very poorly-drained Lemeta peat,
which is fairly extensive on the alluvial plains, occupying broad,
shallow depressions.2/
The primary soil type of the topping plant site is the well-drained
Salchaket soil. The soil is predominantly sandy but contains layers
of silty material and is underlain by thick deposits of gravel and
coarse sand. This Salchaket very fine sandy loam soil is generally
more than 36 inches deep over the underlying gravel. On the site
there are also strips of the poorly-drained Bradway very fine sandy
loam which occupy old sloughs and small areas of Tanana silt loam.
Interpretations of the engineering properties of the Salchaket soil
series done by the U.S.D.A. Soil Conservation Service (September, 1963)
indicate that the site is suitable to build on.
Coils
INTERPRETATIONS OF THE ENGINEERING PROPERTIES
OF THE SALCHAKET SOIL SERIES?/
Soil Series
Salchaket
Susceptibility to Frost Action
Moderate to Low
Suitability as a Source of -
Road Subgrade (Undisturbed Material)
Road Fill (Disturbed Material) . . .
Top Soil
Sand and Gravel
Good to Fair
Good
Fair
Good to Fair;
Depth to gravel
substratum
variable
26
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Soil Features Affecting Engineering Practices
Vertical Alignment of Highways
Material
Drainage
No adverse features
No adverse features
Dikes and Levees
Rapid Permeability
Farm Ponds
Reservoir Area
Embankment
Rapid Permeability
Good Stability,
Rapid Permeability
Agricultural Drainage
Irrigation
Low to Moderate
water holding
capacity; rapid
permeability
Not needed
Terraces and Diversions
Not needed
Waterways
Not needed
Remarks: Silty Lenses in Subsoil May Impede Drainage.
Permafrost
The Fairbanks-North Pole area is located within a discontinuous
permafrost zone. Permafrost is permanently frozen ground, defined
exclusively on the basis of its temperature being at or below freezing
(32°F) throughout the year.iUz/
In this discontinuous zone, permafrost does not exist throughout
the land mass, but it does underlie the greater part of the region.
There are thawed zones within the flood plain along the Tanana and
Chena Rivers. Permafrost is also absent on the moderate to steep
south facing slopes of the foothills of the Yukon-Tanana upland near
Fairbanks and is generally absent below large bodies of water.
Permafrost ranges in depth from about two feet below the surface,
in portions of the flood plain where natural vegetation is intact, to
the maximum observed depth of 265 feet near Fairbanks. The distribu-
tion of permafrost with respect to depth is dependent upon sediment
texture, groundwater circulation, geothermal gradient, and surface
topography.
27
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The depth of the "active layer", or that portion of the ground
which undergoes an annual freeze-thaw cycle, is determined by the type
of ground cover and snow depth. Frost penetration beneath roads or
parking areas which are kept snow-free during winter often exceeds
10 feet. In areas covered by thick mats of moss or other vegetation,
however, the thickness of the active zone is commonly 2 feet or less.
When natural vegetation is removed melting will occur.1/
Soil exploration studies on the proposed site by Arctic Alaska
Testing Laboratories (AATL) revealed the existence of permafrost in
only three of the eleven test holes drilled. In those holes where
permafrost did appear, the moisture content (8.9% to 9.6%) was not
high enough for the investigators to suspect free ice. AATL suspects
that the permafrost holes were located in areas where sloughs may
have once existed.
Further subsurface investigations by Shannon and Wilson Geo-
technical Consultants for Golden Valley Electric Association showed
that portions of the site were underlain by permafrost. In these
areas the depth of permafrost ranged from 11 feet to as much as 27
feet. Based on their boring results Shannon and Wilson recommended
that the facility be relocated to a site not underlain by near surface
permafrost. Upon their recommendation, ECA's and GVEA's facilities
will be relocated in an area where the possibility of differential
ground settlement resulting from the eventual thawing of the frozen
ground is expected to be minimal. The permafrost in the area will not
only affect plant location but also pipeline (oil and sewage) location.
(For further discussion on the relocation, see Description of Proposed
Project.)
Seismic Activity
The topping plant site is designated by the Corps of Engineers to be
in Seismic Probability Zone 3. This zone is characterized as experiencing
earthquakes with Richter magnitudes from 6.0 to 8.8 causing major struc-
tural damage. Table 1, derived from the U. S. Department of Commerce
"Earthquake History of the United States,"^/shows the location, time and
intensity of a number of earthquakes which have occurred in the Fairbanks
area.
28
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TABLE I
EARTHQUAKES IN THE FAIRBANKS AREA
Year
Date
Time(AST)
Locality
N. Lat.
W. Long.
Intens
1911
Jan 7
4:43
Near Fairbanks
65
148
V2
1929
Jan 21
:31
South of Fairbanks
64
148
-
1939
Feb 13
21:52
Fairbanks
65
148
V
1939
Oct 16
11:47
S.E. of Fairbanks
1940
Jan 6
Big Delta & Fairbanks
V
1940
Aug 29
21:32
Fairbanks
65
148
V ,
1947
Oct 15
16:10
Fairbanks Area
64.5
148.8
VIII3
1956
May 17
18:19
Fairbanks
65
148
V
1957
Mar 9
4:07
Fairbanks Area
65
149
V
1963
Dec 7
18:78
Fairbanks-Col lege
65
148
V
1- Intensities in Modified Mercalli Intensity Scale
2- Felt by nearly everyone; many awakened. Some dishes, windows, etc,
broken; a few instances of cracked plaster; unstable objects over-
turned.
3- Damage "slight" in specially designed structures; "considerable" in
ordinary substantial buildings, with partial collapse; "great" in
poorly built structures.
In June 1967, four separate earthquakes were felt by Fairbanks
area residents within a 30-minute period. The largest of these
registered 6.1 on the Richter scale. 2'
The U. S. Geological Survey Tectonic map of Alaska illustrates
that there are no major faults in the immediate vicinity of the project
site. The Denali Fault System in the Alaska Range lies about a hundred
miles south of the site, and the Tintina Faults have been mapped in
the Eagle Trough upland 70 to 100 miles northwest of the site. Linea-
ments have been mapped in the Little Chena River and Chena River areas,
and earthquake associated deformations have been reported in the Badger
Road area within a few miles of the site.
Mr. Larry Gedney of the Geophysical Institute in Fairbanks**!/
indicates that there exists strong evidence which suggests that there
is a fault which extends from the town of Nenana up to Fairbanks, ex-
tending to the headwaters of the Chena. He confirms, however, that
there is no active fault in North Pole.
29
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EXISTING HYDROLDGIC CONDITIONS
Surface Drainage
Rising in the mountainous regions near the Canadian border, the
Tanana River, one of the major rivers draining the interior of
Alaska, flows several hundred miles generally north and west to its
confluence with the Yukon River which enters the Bering Sea. Most
of the larger tributaries entering from the south carry silt-laden
glacial meltwaters from the Alaska range. Streams entering from the
unglaciated north are generally clearer.!./ As it curves past Fair-
banks, the Tanana is a wide, heavily braided stream flowing in a
perched channel through a broad, flat floodplain.°/ (See Figure 4.)
Other rivers in the area tend to be contained in narrow, meandering
channels with existing and relic oxbows. Abandoned stream channels
mark the former course of meanders.
Major tributaries of the Tanana are the Chisana, Nebesna, Salcha,
Chena, Nenana, and Kantishna. East of the City of North Pole, Chena
Slough (also called Badger Slough) once allowed part of the Tanana to
join the Chena River, but the slough has been artificially cut off from
the Tanana River.
Tanana. HiveA Hydnology: The annual streamflow pattern of the
Tanana Kiver Basin consists of high flows during May through September
and minimum flows during the winter months when frozen conditions
diminish inflows. With the spring thaw, flows increase rapidly.
Groundwater, rains, and glacial melt maintain high summer flows in
the Tanana.
At Fairbanks, the annual average flow of the Tanana based on the
twelve month period between October 1973 and September 1974 was
16,770 cfs. Minimum daily flows were estimated to be 3,100 cfs from
February 14 through March 31. The maximum flow for the water year,
59,400 cfs, occurred on August 24, 1973. Mean monthly flow rates are
shown in Table 2 for this recently established USGS flow recording
station on the Tanana River about 2.9 miles southeast of Fairbanks
International Airport. The drainage area for this station is unde-
fined because part of the river flows through the Salchaket Slough,
but data are important for estimating effects of waste discharged at
North Pole and in the Fairbanks area. However, because the river is
wide, heavily braided and subject to icing conditions and channel
changes, only a portion of this measured flow is likely to be available
for dilution at any point of discharge and complete mixing would prob-
ably not occur for many miles downstream. (The Corps of Engineers has
estimated the drainage area of the Tanana at the Chena confluence to
be 20,644 square miles compared to 2,115 square miles for the Chena
River, its first major tributary below Fairbanks.)1'
30
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IN MILES
-------
TABLE 2
Flow of the Tanana River at Fairbanks
Discharge
Discharge
Month
Rate (cfs)
Month
(Rate cfs)
June 1973
36,690
February
3,210
July
46,830
March
3,100
August
40,660
April
4,230
September
19,300
May
IB,250
October
9,000
June
27,600
November
6,790
July
45,360
December
5,230
August
47,100
January 1974
4,020
September
27,300
Although the short period of record at Fairbanks precludes estima-
tion of the 7-day, 10-year low flow, records at Nenana were compared
to see whether the available low-flow data at Fairbanks represent an
exceptionally wet or dry year. The average annual flow at Nenana was
higher than at Fairbanks (20,010 cfs compared to 16,770 cfs) but the
streamflow patterns for water year 1974 were similar. During
February-March, low flows at Nenana were lower than usual and greater
flows would be expected during 75 percent of the years based on 11
years of record. Thus, 3100 cfs at Fairbanks probably represents a
lower minimum flow than would be expected on the average. Based on
provisional USGS data, the minimum flow for the 1975 water year was
4,010 cfs on January 14, 1975.
Flood hazards, as evidenced by the record August 1967 floods which
followed extensive rains,£/ have necessitated flood control measures.
Flood flows of the Tanana River in the vicinity of North Pole are now
controlled by the Tanana-Chena Levee, part of a Corps of Engineers
project. Flood hazard boundary maps issued for the town of North Pole
were rescinded by the Flood Insurance Administration in June 1975
because adequate protection from the 100-year flood (215,000 cfs) now
exists.iy/ Because the levee design flow rate (292,000 cfs)
has a recurrence probability of less than 0.5%, floods over-
flowing onto the topping plant site can be expected approximately once
every 200 years. Additional work planned by the Corps to provide flood
protection for Fairbanks includes diverting flood flows from the Chena
to the Tanana River near Moose Creek. Interior drainage is also planned
because the levee system will impound runoff resulting from rainfall,
snowmelt, and seepage.
Uses of the Tanana include navigation, propagation of fish and
aquatic life, recreation, and water supply. The river is probably a source of
32
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water supply for adjacent wells. According to the October 1973 State
Water Quality Standards,JV the Tanana River is considered suitable
to serve all classifications of uses established under these standards
(see Appendix, Exhibit 1). These uses include water supply, drinking,
culinary and food processing, water contact recreation, growth and
propagation of fish and other aquatic life, shellfish growth and prop-
agation, agricultural water supply and industrial water supply. Al-
though no municipality uses the Tanana downstream from the refinery
for water supply directly, the Tanana appears to be a source of ground-
water in the vicinity of the river.
Fish populations in the Tanana vary with the season, but burbot,
humpback whitefish, sheefish and suckers are present throughout the
year. Arctic grayling, round white fish, and northern pike are winter
residents. King, chum and silver salmon and arctic lamprey migrate
through the Tanana and three other species, the least cisco, lake chub,
and slimy sculpin are present at various times.I^/ The Alaska
Department of Fish and Game indicates that chum and coho salmon
migrate and spawn in the Tanana River (see Fisheries section).
Subsistence fishing in the Tanana is done primarily with nets.
There is also a significant commercial salmon fishery on the
Tanana. In the summer, high turbidity interferes with sports fishing
which relies on fish sighting lures or bait.
Historically, the Tanana River has been used for navigation, al-
though ice prohibits winter use. Barge traffic up the Yukon, and into
the Tanana as far as Fairbanks is possible. There is some commercial
navigation downstream from Fairbanks.
Tanana Water Quality: Glacial meltwaters exert a major season-
al influence on the quality of the Tanana River. During the summer,
the Tanana carries a heavy silt load, but clears up in the fall and
remains clear throughout the winter. The Chena River, which receives
waste discharges from the Eairbanks area, is the major source of pollu-
tion in the Tanana River.il/
Water temperature is also an important water quality consideration.
Biological processes proceed at reduced rates at low temperatures. Ice
cover can completely freeze small channels and in others aeration is
reduced, which contributes to the phenomenon of extremely low dissolved
oxygen concentrations in some arctic and sub-arctic streams. During
about six months of the year, water temperature is about 0°C with nearly
total or total ice cover during most of this time.
During winter, dissolved oxygen of the Tanana decreases progres-
sively downstream, reaching about 6 mg/1 near its mouth in February
and March 1970 and was probably lower earlier in the winter.W
However, above the confluence of the Chena, several miles below the
proposed discharge, the dissolved oxygen concentration was about 10
to 11 mg/1.
Fecal indicator bacteria can persist during winter conditions for
many miles downstream in the Tanana. During February-March 1970,
33
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significant numbers of fecal indicator bacteria survived after seven days
flow downstream during total ice cover and 0°C water temperature.'2'
Above the Chena confluence (several miles below ECA's site), total
coliform bacteria were 740 organisms per 100 ml compared to 12,000 per
100 ml below the Chena confluence. Fecal coliform concentrations and
enterococci concentrations were 230* 120 and 11+ 1.6 organisms/100 ml,
respectively, at the station above the Chena, indicating effects of
fecal wastes.
Chemical characteristics of the Tanana River were measured upstream
and downstream from the ECA site during February-March 1975 by EPA-AERL
and the applicant (separate surveys). A survey by the applicant, of the
immediate vicinity of the proposed discharge location, was conducted on
February 6, 1976, with flow measurements performed by the USGS and par-
ticipation and observation by EPA Region X; chemical analyses were
performed on split samples by EPA and the applicant. Analytical data
appear in the Appendix, Exhibit 2.
The winter conditions in 1975 during the EPA survey reflected low
turbidity and low suspended solids, as expected. Most of the total
solids and essentially all of the volatile solids were in tne dissolved
state. Chemical oxygen demand and total organic carbon (another indi-
cator of oxygen demand) were similar at both upstream and downstream
stations. The pH was generally slightly alkaline. Concentrations of
nutrients (nitrogen and phosphorus) were below levels considered critical
for algal bloom potential. Total nitrogen and ammonia nitrogen concen-
trations were slightly higher at the downstream station. Other measured
concentrations were essentially the same at the upstream and downstream
stations (about three miles above and about fifteen miles below the ECA
site), indicating no significant pollution sources entering this reach
during the survey. Silver, copper and mercury were undetectable. Flows
during this survey were about 5,700 cubic feet per second on February 15
at Fairbanks.
During February 1975, points about 1-1/2 miles upstream and about
12 miles downstream of the proposed waste discharge were sampled by the
applicant for five days. Analyses of these two five-day composite
samples appear in Table 1-B in Appendix, Exhibit 2. Hexavalent chromium,
phosphate, alkalinity and dissolved solids were slightly higher at the
upstream station, and fluoride and lead concentrations were slightly
lower. The source or sources of hexavalent chromium and lead concen-
trations (which were somewhat higher than in other streams) is unknown.
Silver, barium, cadmium and total chromium were below their detection
limits (0.01, 0.1, 0.01, and 0.1, respectively). Phenol and oil and
grease concentrations were not measured.
Because ice can block river channels in the winter and reduce or
eliminate flow, the three channels nearest the east bank of the Tanana
at the south boundary of the ECA site were examined during February 1976.
From the bank westward, flows were 0.1 cfs., 17.9 cfs,and 140 cfs with
an island dividing the largest two flows. This island lies slightly
north of an imaginary westward extension of the east/west airstrip on
34
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on the Clarence Holt property south of ECA's site. Flow measurements
on February 6, 1976, when the channels were mostly ice-covered with
few open leads and heavy shore ice, are shown below. Air temperature
was about 22°F. On February 8, inspection found total ice cover in
the same area when the air temperature had dropped to -40°F. River
flow at Fairbanks was not measured but was estimated to be about 5,000
to 6,000 cfs for February 6, 1976, based on mid-January measurements
of the Tanana River at Nenana.
Flow in Three Channelsa of the Tanana River - February 6, 1976
Maximum Channel
Channel Location Flow, cfs Depth, ft Width, ft
1 Nearest ECA site 0.1
2 East side of island 17.9 1.1 42
3 West side of island 140^ 1.8 83
aFlow in other channels was not measured; only the channels
nearest the ECA site were inspected. Thus values do not
represent the total river flow at this point.
bAverage velocity was 1.32 feet per second.
A dye dilution study conducted in the larger (140 cfs) channel
found that mixing at 200 feet below the mid-stream release point was
41 percent of the complete mixing value. This would correspond to
an average dilution ratio of between 500 to 1 and 600 to 1 for a
waste discharge of 0.1 cfs. The minimum dilution ratio would be
smaller due to non-uniform lateral dispersion across the plume.
Water quality analyses by EPA demonstrated that sulfide, phenols,
and oil and grease were at or below detectable levels as expected for
an unpolluted river. Other characteristics measured in the larger
channel (140 cfs) were also at levels consistent with a clean water
environment. According to measurements by the applicant,6°/ dissolved
oxygen was near saturation (14 mg/1 at 0°C). Other data appear in
the Appendix, Exhibit 2.
Groundwater
In the Tanana subregion of Alaska, groundwater occurs at lower
elevations, although at some places in the higher elevations small
35
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amounts are available.Z/ Where permafrost occurs, the availability
of groundwater is reduced and drainage patterns may be altered. Sub-
stantial quantities of water (1,500 to 3,400 gpm) have been obtained
from properly constructed wells in the sands and gravels of the Tanana
Valley. For smaller wells, yields of 50 gpm have been obtained from
2 inch wells by suction lift.!U
The Tanana River appears to be a source of groundwater for the
areas adjacent to the river. Groundwater flow just southeast of
Fairbanks generally tends northwest.1°/ The depth of wells ranges
from 30 to more than 300 feet.
Quality of the groundwater varies from good to extremely bad.
Much of the water in the lowlands is higher in iron than the Public
Health Service Standard (0.3 mg/1). This excessive iron, and in some
cases manganese, and to some degree, hardness are the principal prob-
lems. Hard water, high in iron, is thought to result from the reaction
of sulfate with organic matter producing free carbon dioxide, which
then brings iron, calcium, and magnesium from sediments into solution.il/
Temperatures are generally low (e.g., 38°F for the Fairbanks municipal
supply). In some densely populated areas near Fairbanks, served by
individual wells, contamination from septic tanks or cesspools has
created health hazards.IZ./
Groundwater, from a 160 foot well, is used for the municipal supply
of the town of North Pole. The groundwater is moderately hard and
high in manganese as well as total iron. Excessive iron (0.6 mg/1),
which is not adequately removed by the pressure filter due to lack
of chemical pretreatment,is thought to contribute to problems exper-
ienced at the wastewater treatment plant.12/ (See Appendix, Exhibit
2 for data).
A single sample of water from an auxiliary well that is sometimes
used by the city of North Pole had excessive concentrations of several
elements on April 21, 1975 according to data submitted by the appli-
cant. (See Appendix, Exhibit 2 for data). Hexavalent chromium,
cadmium, lead, and barium concentrations were 0.1, 0.03, 0.1, and 2
milligrams per liter. For comparison, the 1952 U. S. Public Health
Service standards are 0.05, 0.01, 0.05, and 1 mg/1, respectively.
Arsenic was higher than recommended (0.03 compared to 0.01 mg/1), but
did not exceed the mandatory limit. No cause for these higher con-
centrations has been determined.
On the topping plant site, the groundwater table is thought to
be influenced by the nearby Tanana River. High groundwater levels
at the site are expected just after spring breakup of the Tanana and
again in late summer or early fall when rains come to the upper water-
sheds. y Data from three USGS wells near the site (see Figure 6)
indicate highest water tables during July and lowest water tables during
October-November (see Figure 5). Original investigations of the site
35a
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AUGUST DECEMBER APRIL AUGUST DECEMBER
1972 1972 1973 1973 1973
FIGURE 5
SEASONAL CHANGES OF WATER TABLE DEPTH
(DATA BASED ON U.S. GEOLOGICAL SURVEY TEST WELLS)
-------
FIGURE 6
-------
in April 1970 found water at depths of approximately 7 to 8 feet
below ground level (Figure 6); however, subsequent borings conducted
for the 6VEA turbine facility in April 1975 found the water table
at depths of 5 to 6 feet in the area selected for the generator
building. Borings along the east side of the proposed topping plant
process area found water at about 5 to 10 feet depths.2/
Higher water tables may exist on portions of the ECA land which
contain Bradway soils3J According to the Soil Conservation Service,
Bradway soils occupy lower areas in old stream channels in the alluvial
plains and may have water at 18 inches depth or less, above perma-
frost..?/
The quality of water from a shallow on-site well (20 feet) in the
vicinity of the GVEA turbine generator site was examined (see Appendix,
Exhibit 2 for data) in April 1975. Iron concentrations were low (less
than 0.05 mg/1) and the water was clear.
38
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EXISTING AIR QUALITY
Air quality is evaluated by measuring the ambient levels of var-
ious pollutants and comparing them to the applicable ambient air qual-
ity standards. There are two levels of ambient air standards. The
primary standards have been set at a level required for the protection
of public health. Secondary standards are set at levels to protect the
public welfare. The current National Air Quality Standards (NAAQS) are
summarized below.
Pollutant
Particulate Matter
- Annual geometric Matter
- Maximum 24 hour concentration*
Sulfur Oxides
- Annual arithmetic mean
- Maximum 24 hour concentration*
- Maximum 3 hour concentration*
Carbon Monoxide
- Maximum 8 hour concentration
- Maximum 1 hour concentration*
Photochemical Oxidants
- Maximum 1 hour concentration*
Hydrocarbons
- Maximum 3 hour (6-9am)
concentration*
Nitrogen Oxides
- Annual arithmetic mean
Primary
75 ug/m3
260 ug/m3
Secondary
60 ug/m3
150 ug/m3
80 ug/m3 (0.03 ppm)
365 ug/m3 (0.14 ppm)
1300 ug/m3 (0.5 ppm)
10,000 ug/m3 (9 ppm)
40,000 ug/m3 (35 ppm)
same as primary
160 ug/m3 (0.08) same as primary
160 ug/m3 (0.24 ppm) same as primary
100 ug/m3 (0.05 ppm) same as primary
* Not to be exceeded more than once per year.
39
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Before the impact of the proposed ECA topping plant on the am-
bient air at North Pole can be evaluated, the existing air quality
must be examined. Ambient air quality data have only been collected
for particulate matter in North Pole and that only for the period of
time from the third quarter of 1972. A summary of this data is given
below:
24 hour concentration greater than
Year Annual Geometric Mean 150 ug/m3 260 uq/m3
1972* 13 ug/m3 0 0
1973 55 ug/m3 5 1
1974 33 ug/m3 2 0
* Data not for entire year
Figure 7, which was taken from the report "Air Quality Profile
for Fairbanks Borough Primary Abatement Area" summarizes the trends in
Total Suspended Particulate (TSP) levels for the North Pole data.20/
Data for particulate matter and carbon monoxide has been gathered
for up to six years in Fairbanks, however, because of the unique sit-
uation concerning the generation and accumulation of carbon monoxide
in the Fairbanks central business district, that data cannot be extra-
polated to North Pole. The particulate matter measurements taken in
Fairbanks, on the other hand can be used to confirm the above data
for North Pole. The following data was taken at the National Air
Surveillance Network (NASN) site in downtown Fairbanks.
24 hour concentrations greater than
Year Annual Geometric Mean 150 ug/m3 260 ug/m3
1969
1970
1971
1972
1973
1974
175
16
8
152
11
6
100
2
0
137
12
5
102
6
2
74
0
1
40
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"T1
5
a
ZD
m
--j
-------
Because of the scarcity of data on ambient air quality in North
Pole, R. W. Beck and Associates conducted a background data study
during April, 1975. Using monitoring equipment purchased by ECA,
housed in an instrument trailer borrowed from the Environmental
Services Office of the Fairbanks North Star Borough, the parameters
measured included continuous NO concentration, continuous and daily-
average S0„ concentration, daily-average suspended particulate matter
and CO concentrations. In order to correlate site meteorological
conditions with corresponding information from Fairbanks International
Airport and Eielson Air Force Base, ECA's equipment was utilized to
continuously monitor temperature, relative humidity, wind speed and
direction, pressure and precipitation.
Ten days of continuous data-taking showed the following levels
of pollutants for that period of time:
NO - 8-hour average (.004 - .033 ppm / 5-41 ug/m3)
NO2- below threshold of instrument (.001 ppm / 2ug/m3)
SO^- below threshold of instrument (.005 ppm / 13ug/m3)
3
Particulate Matter - daily average 10-37 ug/m
CO - below threshold of instrument (1 ppm / 1160 ug/m )
H,,S - assumed negligible
These background levels of air pollutant concentrations are low enough
that the addition of air quality impacts from the topping plant are not
likely to cause violations of ambient air quality standards in the area
of North Pole.
ECA will continue to investigate the ambient air quality of the
North Pole area after the topping plant becomes operational. ECA
will also monitor SO2 and N0x at the plant at least one year before
the plant begins operation.
Review of meteorological data collected at the proposed topping
plant site indicates that wind conditions are similar to those recorded
at Eielson Air Force Base and that temperature, relative humidity and
precipitation patterns are representative of Fairbanks International
Airport, corrected to the rural North Pole situation.
42
-------
CLIiWOLDGV
Climatological Overview
Fairbanks is in the climatological division referred to as the
interior basin of Alaska. The weather in the Fairbanks area is
influenced by mountain ranges on three sides which form an effec-
barrier to the flow of warm moist air from the Bering Sea, except
during periods of persistent precipitation. Because of the lack
of moderating influence of maritime air, greater temperature
extremes occur here than along the coast. The extreme low tempera-
tures in the winter are normally caused by the polar air masses
that flow in from the north.
During the early summer, the sun is above the horizon from 18
to 21 hours each day. Conversely, through the winter months, periods
of sunshine range from 10 to less than 4 hours per day. The major
factor contributing to the development of extremely cold temperatures
during the winter is the persistent snow cover which prevents absorp-
tion of the available solar radiation. The surrounding upland areas
tend to aid drainage or settling of cold air into the Tanana Valley
lowland.
A tabulation of Fairbanks weather data is given in Table 3.
Although records were obtained from the U. S. Weather Bureau Airport
Station, it is assumed that weather conditions at North Pole are
similar to those at Fairbanks International Airport. However,
temperatures at North Pole are expected to be lower due to the rural
(vs. urban) situation and wind conditions should be influenced more
by the Tanana River drainage than by the topographic bowl surrounding
Fairbanks.
Temperature
The average monthly temperature ranges from a low of -11.1 °F
in January to a high of 59.7°F in July. The average annual tem-
perature is 25.7°F. In Fairbanks, the all time low temperature
recorded by the National Weather Service was -66°F in January, 1934,
and the highest temperature on record of 99°F occurred in July, 1919.
The growing season, which is defined as the number of days between
the last freeze of spring and the first freeze of fall, averages 97
days—from May 24 to August 29.
Precipitation
Most of the yearly precipitation occurs during the summer and
early fall, with considerably smaller amounts in the winter and spring.
The average annual amount is 11.3 inches. Two-thirds of the annual
43
-------
SUlien: FAIRBANKS' ALASKA
Month
Temperature
Degree days
(Bese 65*)
Precipitation
Relative humidity
Vi
d *
*
3
1
® *
\\
£L *
fc «•
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JAN
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14.2
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64
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641
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60
SI
97
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20
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7,2
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42
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6
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41
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JUL
70.6,
SS.4
62.0
14
25
«
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111
24
1.92
0.69
28*29
0,0
0.0
ao
72
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3.6
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62.8
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79
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29
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6.1
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20
8.7
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57.1
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19
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923
0
o.n
0.07
29
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78
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46
69
03
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7 • 6
OCT
91. 2|
18,4
23.1
49
24
2
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1231
0
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0.31
9
8.2
2.4
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66
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6.1
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1961
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0.80
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kite.
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34
2)
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-91
16
13814
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9.12
0.76
10-11
35.1
7.7
10-U
66
64
92
98
1.0
5.2
22
20*
7,2
Number of days
Temperatures
"3
t
2 ?
Minimum
S e
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117
NORMALS, MEANS, AND EXTREMES
ti
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-2.2
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1965
-61
1969
2364
0.60
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1957
0*01
1966
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1968
10.*
26.1
1957
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1948
67
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1954
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1970
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1966
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1966
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1966
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1966
69
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1970
-46
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1720
0*46
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1969
T
1968
0.92
1969
7.6
29.6
1969
12.6
1963
69
69
52
61
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40
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1970
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7
15
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9
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1966
1083
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1967
T
1969*
0.31
1969
3.9
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1967
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69
60
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94
6.9
N
31
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1965
6.9
7
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0
7
28
2
N
98.1
95.7
47.9
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1964
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1964
549
0.69
1.67
1959
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1997
0.66
1999
0.6
4.7
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4.5
1964
66
99
98
45
7.6
H
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19704
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1955
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1966
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1999
T
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1953*
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to
30
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1971
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71.6
49.6
60.7
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1964
146
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1962
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1997
1.63
1962
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69
90
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29
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1957
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69.1
44«9
99.4
83
1966
30
1969
304
2.19
6.|0
1967
0.40
1997
3.41
1967
T
T
19694
T
19694
82
77
94
67
6.0
N
34
27
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7
22
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S
94.4
34.4
44.4
SO
1*69
11
1972
618
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I960
0.19
1968*
1.21
1994
1.2
7.6
1972
7.0
1972
77
75
90
66
6.0
N
29
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1971
7.5
6
19
9
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a
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a
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14.9
29.2
69
1969
• 19
1945
1234
0,73
1.64
1970
0.04
1994
0.68
1970
9.4
24.2
1961
7.6
1970
77
77
66
74
5.9
N
40
25
I9»i
0.0
9
22
10
4
0
2
0
11
29
4
N
11.7
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2.6
46
1970
-43
1964
1666
0.66
3.32
1970
T
1939
0.64
1970
13.2
94.0
1970
14.6
1970
73
73
72
73
3.9
N
95
25
1970
6.9
5
18
9
4
0
1
0
26
90
19
0
•l.S
-19.3
-10.4
42
1969*
-96
1964
2337
0.69
2*29
1970
T
1969
1*29
1968
12.7
93.5
1969
14.7
1968
68
68
67
66
3*1
N
97
24
1970
6.9
6
18
1
4
0
4
0
30
91
26
4UH.
JAN.
AU0,
DEC.
ADO.
NOV.
M«.
HA ft.
V*
96.3
15.0
29.7
96
1969
-61
196%
14344
11.22
6.20
19*7
T
19694
3.42
1967
69,1
94,0
1970
20.1
1966
71
67
53
62
3.9
H
40
22
19704
7.1
67
13
215
102
22
9
20
51
162
226
122
$ For period September 1963 through the current yesr.
Heana end extreme* above are frrm existing end comparable exposures. Annual extremes have been exceeds at other aites tn the locality as follows;
Highest temperature In July 1919; lowest temperature -66 In January 1934; maximise monthly precipitation 6.86 In Augunt 1930; minimis monthly
precipitation 0.00 in February 19X9; taaximw monthly snowfall 65.6 in January 1937.
Length a4 record. mri, based cm Jaaoary lua.
Other «miKi mif w far more or {mw It
there have keen break a hi the record.
CUautotogtc*! annul* (19*1-1970).
Lm« rfcas one half.
Alto qa earlier dale* month*. or years.
Tnci an inoM too mall to mcaa«ra.
Below xero tetnper* tares arc practdat to amlaussigB.
$T9* at Akakas aliHiai
71s prmlHag dlreettos tar vtad la the Normals,
Mesas, as* Baxawwa tails to Irani records thn#
m
UnJene ortmrvtss Indicated, Omeneloml unite ssed Is tfcta bulletin am temperature In degree* F.j
Mtclph'Hwv tachtdJac aimwtaH, ts laetiea; wind mwuM In wife* per hoar; and relative htnr.ldlty
Is percent. Heating degree Ay totals are the euma off negative depsrtares of average d*IIy »wnj»er*-
tares from 69* P. Coolfst degree day totals sre the mas of aoelttv* departures or a\era«e dally
temperatures from 65* f. fleet vss he hided fn awvfall totals beginning
-------
snowfall amount—66.0 inches—occurs during winter and early spring.
Average snow density is less than 0.1 inch water equivalent for 1.0
inch of snow. The record seasonal snowfall of 168 inches occurred
during the winter of 1970-71.
Twenty-four hour precipitation, exceeding .01 inch water equi-
valent, either as rain or snow, occurs,some 103 days per year. Snow-
fall amounting to more than 1.0 inch occurs approximately 22 days
each year.
Storms
Severe storms are very infrequent. The mean thunderstorm fre-
quency is 5 days per year.
Wind
According to :he U.S. Weather Bureau Airport Station, the pre-
vailing wind direction at Fairbanks International Airport is from the
north with a mean annual speed of 5.0 miles per hour. Average wind
speeds are approximately two-thirds this value in winter and early
summer. The Weather Bureau indicates that winds are 5.0 mph or
less approximately 60% ot the time. The monthly prevailing wind di-
rection is from the north except for the months of June and July when
the prevailing wind direction is from the southwest. The maximum ob-
served wind speed was recorded in October, 1958, at 40 miles per hour
from the west - southwest.
Exhibit 3 in the Appendix shows the annual and seasonal wind
speeds and directions as recorded at Fairbanks International Airport
Exhibit 4 shows the same wind rose information for Eielson Air Force"
Base which is located southeast of the North Pole site. The length
of each line in these wind roses is proportional to the frequency of
wind from each of sixteen directions and the frequency of calms is
entered in the center. Therefore, the prevailing wind direction is
indicatedby the longest line. It is significant to note that wind
characteristics at each site are decidedly different. The complex
wind patterns have caused serious concern among some low-temperature
air pollution researchers who contend that the air quality and meteor-
ological information available is yet inadequate to fully assess the
impact of the incremental expansion of the refining facilities at
North Pole.
45
-------
Wind speed is one of the most important factors in the disper-
sion of air pollutants. Wind may cleanse a polluted atmosphere at a
given location by moving masses of stagnant air away from the sources
of pollution, preventing an accumulation of pollutants. It dilutes
the concentration of a contaminant directly and as it moves over rough
terrain, the resultant turbulent flow mixes any contaminant into a
larger volume of air, further diluting it.
Vertical mixing and the transport of pollutants away from pollu-
tion sources are oftentimes severely inhibited in the Fairbanks area
because of low wind speeds. Low wind speeds is only one of several
conditions that contribute to the susceptibility of the Fairbanks area
to critical air pollution problems. As indicated in Table 3, the mean
wind speed at Fairbanks is below 4.5 miles per hour for the months of
November through February. Horizontal wind speeds below 4.5 mph are
generally considered conducive to pollution potential.
Stability
In the simplest terms, the stability of the atmosphere is its
tendency to resist or enhance vertical motion, or alternatively to
suppress or augment existing turbulence. While stability is related
to both wind shear and vertical temperature structure, it is usually
the latter which is used as an indicator of stable conditions.^i/
The classification of stability, according to Pasquill^/ is
broken down into categories A through F, which are described with
typical plume behavior in Table 4. Due to the exceptionally strong
inversion conditions such as those found in Fairbanks during the win-
ter, the National Climatic Center recognizes an additional stability
class G. This extremely stable category occurs under severe inversion
conditions when wind conditions are calm. Under these conditions the
plume assumes a pencil - like appearance. See Figure 8 for schematic
diagrams.
46
-------
TABLE 4
STABILITY CATEGORIES
Stability Class
A - Extremely Unstable
B - Moderately Unstable
C - Slightly Unstable
D - Neutral
E - Slightly Stable
F - Moderately Stable
Transition
Description
This classification is associated with con-
ditions of lovj surface wind speeds and
strong solar radiation.
This stability class is most common when
the wind speeds are slightly higher (4 to 6
mph) and tlic solar radiation is still strong.
This category is typified by wind speeds
from 7 to 10 mph with moderate to strong
radiation or lower wind speeds coupled
with slight radiation.
Conditions which produce this type of sta-
bility are fairly high wind speeds during a
period of slight solar radiation or at night.
This classification is associated with wind
speeds from 4 to 6 mph at night.
This level of stability is found at night when
wind speed is even lower than in Class E.
Conditions which change in a relatively
short period of time from stable to neutral
or unstable.
Plume Behavior
There are rapid changes in wind direction with
time. Surface heating has eliminated all tem-
peinturc inversions near the ground. Wind
speeds are generally loss than 11 miles per
hour. Rapidly rising parcels of warm air from
near tl.-. earth's stirface are replaced by equal
amounts of air moving downward nearby. A
plume is carried with this "looping" motion.
It is typical that cumulus clouds will be seen
above terrain. Highly transitory maxima in
ground-level concentration relatively near the
source occur with this category.
This category includes most cases with winds
stronger than 12 miles per hour. Duration is
Z hours or more. The vertical temperature
profile is near the adiabatic lapse rate, A
plume is dispersed rapidly with a "coning"
motion.
Coolest air is located at the earth's surface
and stack plumes move horizontally at effec-
tive stack height. Almost no pollution can be
measured at the ground.
A portion of the plume will experier.ee lim-
ited mixing prior to complete linkage of sur-
face airflow to synoptic airflow, which is
controlled by pressure pattern winds.
-------
FIGURE 8
SCHEMATIC DIAGRAMS OF TYPICAL STACK PLUME PATTERNS
UNDER FOUR IDENTIFIABLE STABILITY CATEGORIES
-------
The following table summarizes stability conditions as tabulated
by the National Climatic Center on a seasonal and annual basis for
Fairbanks International Airport and for Eielson Air Force Base.
FREQUENCY OF OCCURENCE (%)
Fairbanks International Airport Class
Season
Months
A
B
C
D
E
F
G
Winter
Dec, Jan, Feb
_
0.2
7.2
29.8
11.9
29.8
21.1
Spring
Mar, Apr, May
0.3
6.9
15.8
48.8
11.5
12.0
4.7
Summer
Jun, July, Aug
0.3
10.0
18.6
51.5
9.8
7.9
2.0
Fall
Sept, Oct, Nov
-
1.7
9.6
47.4
14.1
17.9
9.4
Annual
All Months
0.1
4.7
12.8
44.4
11.8
16.8
9.3
Eielson
Air Force Base
Class
Season
Months
A
B
C
D
E
F
G
Winter
Dec, Jan, Feb
-
0.2
10.0
24.5
2.9
29.5
32.9
Spring
Mar, Apr, May
0.4
9.5
20.0
36.2
6.0
16.3
11.6
Summer
Jun, July, Aug
1.3
14.3
22.7
39.3
4.1
13.2
5.0
Fall
Sept, Oct, Nov
-
3.1
13.3
39.0
4.9
20.6
19.1
Annual
All Months
0.4
6.8
16.5
34.8
4.5
19.9
17.1
Nighttime temperature inversions, formed by radiational cooling
of the land's surface, are common in Fairbanks during the summer, but
are usually dissipated by the warming of the afternoon sun. During the
winter, however, the short days with low sun angle, clear skies, and
light winds often create conditions under which surface based inversions
can last for days or weeks. During these periods, the potential for
trapping pollutants in the lowest layers of the atmosphere is extremely
high. C.S. Benson of the Geophysical Institute, University of Alaska,
indicates that in Fairbanks inversions based at or near the surface
are present both day and night over 50% of the time from November through
February and about 80% of the time from December through January.
49
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Mixing Depths
Simultaneous occurrence of limited horizontal and vertical mixing
is commonly observed before and during high levels of air pollution.
Since it is the combination of low wind speeds and limited vertical
mixing that favors high levels of air pollution, the air pollution
potential of an area requires that wind speeds and mixing depths be
considered together. The graphs in Figure 9 compare the monthly mean
mixing depths and mean wind speeds expected at the North Pole site.
The mixing depths shown in Figure 9 were calculated from the sur-
face-based inversion data in Benson's^!/ study of low-level winds in
the Fairbanks area. Common criteria for the determination of high air
pollution potential is the simultaneous occurrence of wind speeds less
than 4.5 miles per hour and mixing depths less than 1600 feet. There-
fore, referring again to Figure 9, the only months of reasonable air
pollutant dispersion in Fairbanks are May through September. When
conditions of low wind speeds and limited mixing depths are forecast
to occur, and advisory is issued by the National Oceanic and Atmospheric
Administration, National Weather Service Forecast Office, Fairbanks,
Alaska. These "air stagnation advisories" are issued when poor disper-
sion is expected to persist over an area approximately 250 miles on a
side, with no appreciable precipitation anticipated, for a period of
at least 36 hours.
Ice Fog
Ice fog occurs as a result of introducing water vaDor into a
stagnant atmosphere sufficiently cold (lower than -10°F) to cause
extremely rapid condensation, cooling and freezing. This phenomenon
is common during the months of December and January in the Fairbanks
area and is the direct result of urbanization in cold regions. The
major sources of water vapor are stationary combustion processes (home
heating, power plant stack effluent), open water surfaces, and vehi-
cular exhaust. In Fairbanks, the depth of the ice fog layer is
usually less than 300 feet but has been observed as deep as 600 feet
during prolonged cold periods. The exhaust plumes from power plants
normally provide an example of minimal surface ice fog.
One of the best means of reducing ice fog is to eliminate low
altitude sources of water vapor. During strong inversions which pre-
vail during ice fog events, it is especially important to discharge
water vapor at the highest possible altitude. The exhaust plumes
from power plants provide an excellent example. Photographs taken
from the high terrain to the northeast of Fairbanks show that power
plant plumes sometimes join the main mass of ice fog before they
dissipate, or create a separate visible layer higher up. When this
mixing of plumes with the ice fog layer does occur, the ground level
concentrations of pollutants (e.g., sulfur dioxide and particulates)
may increase. Once the ice fog condition is well developed, the base
of the inversion shifts upward. The bottom of the inversion and the
top of the ice fog coincide, and normal lapse rates occur in the ice
fog layer.
50
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Ill
o
<
u.
AC
=>
CO
tli
>
o
CO
<
H
X
<£
UJ
X
(S>
z
><
z
2400
2100
1800
1500
1200
900
600
2 300
/AFTERN
/ MIXIN
/ rxroTL
OON
G
JC
1 1
;tr i r
1 J
Xmc
>RNIN
DE
G Ml>
3THS
CING
M A M J J A
FIGURE 3-9a
N
ANNUAL VARIATION OF MIXING DEPTHS
(MONTHLY MEAN VALUES)
D J F M A M J
FIGURE 9
ANNUAL VARIATION OF WIND SPEEDS
(MONTHLY MEAN VALUES)
READINGS TAKEN AT FAIRBANKS INTERNATIONAL AIRPORT
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FLORA and FAUNA
FLORA
General: The type of forest which covers the landscape in the
Fairbanks -North Pole area is termed "taiga." The taiga is a spruce-
dominated coniferous forest, characteristic of subarctic climates, which
covers vast areas of northern America and Eurasia.
Although the forests in the area are largely dominated by spruce
and birch, specific microenvironmental differences and historical fac-
tors have produced a complex mosaic of vegetation types. Influential
factors include (1) proximity of permafrost to the soil surface, (2)
frequency and extent of fires, (3) fluvial processes (4) topography
and (5) exposure.
The U.S. Army Corps of Engineers^/ has compiled a list of plants
which are characteristic of the area surrounding the North Pole site.
Table 5 provides both common and taxonomic names of species commonly
found in the Fairbanks - North Pole area.
On-site Vegetation: The proposed topping plant site is located
in a wetland ecosystem which is oftentimes referred to as a lowbrush
bog or muskeg. The characteristic vegetation is dominated by the black
spruce - tamarack (Picea mariana - Larix laricina) and the dwarf or
resin birch -ericaceous shrub type. This ecosystem type usually occurs
on old river terraces and outwash, in filling ponds and old sloughs,
and throughout the lowlands.
The black spruce - tamarack (Picea mariana - Larix laricina)
stand-type is prevalent on fairly well-drained shoals and bars of an-
cient river channel deposits which are usually covered with a conspic-
uous, thick moss mat. When mature, the black spruce - tamarack stand-
type often attains heights of 10 - 25 feet depending on nutrient avail-
ability. This type represents the climax stand-type for this habitat.
Less well-drained channel beds are characterized by open stands
of dwarf birch (Betula glandulosa) and a nearly continuous ericaceous
shrub layer composed of labrador tea (Ledum qroenlandicum) and lea-
therleaf (Chamaedaphne calyculata). Conmon throughout are occasional
willows (Salix spp.), thinleaf alders (Alnus incana tenuifolia), and
poplars (Populus spp.) growing in a substrate of grasses, lichens
and mosses of various species.
52
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TABLE 5
PLANT SPECIES COMMON TO THE
FAIRBANKS - NORTH POLE AREA
Coniferous Trees
Deciduous Trees
Ericaceous Shrubs
Other Shrubs
Larch (tamarack)
White Spruce
Black Spruce
Paper Birch
Balsam Poplar
Quaking Aspen
Bog-rosemary
Red-fruit Bearberry
Bearberry
Kinni kinnick
Leatherleaf
Labrador Tea
Bog Blueberry
Mountain Cranberry
Thinleaf Alder
Resin Birch
Prickly Rose
Feltleaf Willow
Larix laricina (Du Roi) K. Koch
Picea glauca (moench) Voss
Picea mariana (Mill.) B.S.P.
Betula papyrifera Marsh.
Populas baIsamifera L.
Populus tremuloides Michx.
Andromeda poll folia L.
Arctostaphylos rubra (Rehdo &
Wilson) Fern.
Arcotostaphylos uva-ursi (L.)
Spreng.
Arctostaphylos uva-ursi (L.)
Spreng.
Chamaedaphne calyculata (L.)
Moench
Ledum groenlandicum Oerder
Vaccinium uliginosum L.
Vaccinium vitis-idaea L.
Alnus incana (L.) Moench ssp.
tenuifolia (Nutt.) Breitung
Betula glandulosa Michx.
Rosa acicularis Lindl.
Salix alaxensis (Anderss.) Cov.
53
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Herbaceous Plants
Diamondleaf Willow
Buffaloberry
Hi ghbush Cranberry
Bluejoint Reedgrass
Beaked Sedge
Horsetails
Pasque Flower
Salix pulchra (Cham.)
Shepherdia canadensis (L.) Nutt.
Viburnum edule (Michx.) Raf.
Calamaqrostis canadensis
(Michx.) Beauv.
Carex rostrata Stokes
Equiseturc spp.
Pulsatilla patens (L.) Mill.
Source: Chena River Lakes Flood Control Project, Environmental Resource
Inventory, U.S. Arrny Corps of Engineers, Alaska District,
March 1975
54
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Rave and Endangered Plants: Pursuant to the Endangered Species
Act of 1973, EPA has consulted the most recent listing of threatened
or endangered flora to determine whether or not the existence or habitat
of any species, so classified, will be seriously affected by the proposed
project (Federal Register 40 (127) : July 1 , 1975). It was determined
that none of the species identified in Table 5 is classified by the
U.S. Fish and Wildlife Service as threatened or endangered.
The species found on the topping plant site are common throughout
much of the lowland areas in the Alaskan Interior and are not yet considered
threatened. The rarity of some species of plants in Alaska is largely
a function of specific habitat requirements. Due to specific adaptations
and environmental tolerances some species occur in widely separated
populations. These populations are oftentimes restricted to distinct
habitats which are themselves limited in occurrence, productivity, and
area. Species that occupy these areas, therefore, are much more susceptible
to perturbations caused by man's disturbances. None of these unique
areas have been identified on the site, nor in the surrounding North
Pole area.
Although much of the Fairbanks - North Pole area is still heav-
ily vegetated and the probability is low that the species now existing
in the area will be eradicated by major habitat changes, there exists
every possibility that the forested character of the area will be
lost by the expansion of suburban and industrial areas.
55
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FAUNA
Aquatic (Tanana RIvqa ¥heJiiz&}: The Tariana River, like other
glacially fed rivers in Alaska, is typically high and heavily laden
with silt during the summer and low, clear and ice-covered during
the winter. The drastic seasonal changes in the character of the
Tanana River bring about corresponding seasonal variations in fish
populations.
The State of Alaska Department of Fish and Game, Sport Fish
Division, reports that at least eleven (11) species of fish inhabit
or frequent the Tanana River; four of these species are present year
round, three use the main Tanana for overwintering, and four species
migrate through the river during spring and summer.'£/ See Table 6.
As Table 6 indicates, the year-round residents include the burbot
(Lota lota leptura), humpback whitefish (Coregonus pidschian), inconnu
or sheefish (Steriodus leucichthys), and suckers (Catostomus spp.).
Fish that reside in the Tanana River only during winter include the
arctic grayling (Thymallus arcticus), round whitefish (Prosopium
cyl indraceum), and Northern pike (Esox lucius). King salmon (OlTcor-
hynchus tshawytscha), chum salmon (0. keta), and silver salmon (0.
kisutch), and arctic lamprey (LampeTra japonica) use the Tanana tfiver
primarily as a migration route.
Three other species, the least cisco (Coregonus sardine!la), lake
chub (Couesius plumbeus), and slimy sculpin~TCottus cognatus) are
known to reside in the river at various times; however, information
on these is limited. The broad whitefish (Coregonus nasus) is known
to reside in the Minto Flats area.
Chum salmon are known to spawn in a number of tributaries of
the Tanana RiverM Silver and king salmon spawn and rear in the
Salcha and Chatanika Rivers and Clearwater Creek. King salmon are
also known to spawn in the Goodpaster, Delta, and Chena Rivers.-?-'
During the spring there are several intense but short sport
fisheries for arctic grayling or round whitefish in the Tanana River.
These usually occur in the vicinity of the mouths of tributaries.
During the winter the burbot is fished all along the Tanana.
Badger (Chena) Slough is important for arctic grayling production
and sport fishery. In 1973, approximately 10,000 grayling were har-
vested from Badger Slough by sport fishermen. The grayling receives
more pressure from sport fishing in the Tanana drainage than any other
species.
56
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TABLE 6
FISH USE OF THE MAIN TANANA RIVER
YEAR ROUND
RESIDENTS
WINTER
RESIDENTS ONLY
MIGRATION ONLY
PERIOD OF MIGRATION
SPECIES
ADULTS
SMOLTS
Burbot
Humpback whitefish
Sheefi sh
Suckers
Arctic Grayling
Round Whitefish
Northern pike
King salmon
Chum salmon
Silver salmon
Arctic lamprey
June 20 - July 30
July 1 - Oct 1
Aug 20 - Oct 15
Unknown
May 1 - July 30
April 1 - June 15
May 1 - July 30
Unknown
The above information was obtained from Mr. Stephen L. Tack, Fishery Biologist, Sport Fish Division,
Department of Fish and Game, Fairbanks, July 1, 1975
-------
Btntklc Oiga.ni&m* •• Contrary to popular belief, glacial streams
in Alaska do support significant populations of benthic organisms
which may most easily be found in habitats such as protruding stumps
and rocks. Studies of the Tanana downstream from the Delta River
confluence (about 40 miles above the proposed discharge site) indi-
cate low densities during high summer flows when the river carries
a heavy bed load of silt from glacial meltwaters. §/ Midges pre-
dominate at that time, although stone flies, may flies, and caddis-
flies are present.
During lower winter flows, higher densities of organisms and
greater species diversity appear. Winter populations are developed
in part from downstream drift of Clearwater biological communities.
With reduced turbidity, basic productivity is enhanced, especially
in the ice-free reaches. Greater light penetration is possible
although snow and ice cover, as well as the shorter daytime, compli-
cate determination of potentially available sunlight. Food production
which would appear to be greatest in the open reaches, would support
the winter fish population. It should be noted that lower temperatures
reduce feeding activity.
TeJiAeAVital.: Outlying areas of Fairbanks and North Pole are
heavily forested and wildlife is relatively plentiful. Tables 7
and 8 list the common species of wildlife found in the North Pole-
Fairbanks area. Snowshoe hare, red squirrel, beaver, wolf, red fox,
mink, lynx, moose and black bear are the more common large mammals
in the area of the proposed refinery. Many species of small mammals -
shrews, lemming, voles, muskrat, rat and porcupine - are also found
at the site.
Numerous species of birds use the Tanana Valley as residents
(either year round or in the summer) or for resting and foraging
sites during migration. The Tanana River and its floodplain provide
approximate habitat for a variety of waterfowl and shorebirds in-
cluding mallards, pintails, green-winged teal, bufflehead, lesser
yell owlegs, snipe and sandpipers. Various raptors, gamebird and
passerine birds are also found in the general area. Peregrine falcons,
ospreys and bald eagles are known to nest in the Tanana Valley. Other
raptors known to inhabit the valley include: goshawks and sharp-
shinned hawks; great horned, great gray and boreal owls (generally
observed in forested areas); and red-tailed, Harlan's, Swainson's,
rough-legged, marsh, pigeon and sparrow hawks^ Gyr falcons are
observed usually above 2,500 feel elevations.—'
No threatened or endangered species are known to inhabit the
project site.
58
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TABLE 7 3/
MAMMALS COMMONLY FOUND IN THE
FAIRBANKS - NORTH POLE AREA
Masked shrew
Sorex cinereus
Dusky shrew
Sorex obscurus
Arctic shrew
Sorex articus
Snowshoe hare
Lepus americanus
Red squirrel
Famiasciurus hudsonicus
Northern flying squirrel
Glaucornys sabrinus
Red-backed vole
Clethriomys rutilus
Meadow vole
Microtus pennsylvanicus
Tundra vole
Microtus oeconomus
Muskrat
Ondatra sibethicus
Norway rat
Rattus norvegicus
Porcupine
Erethizon dorsatum
Coyote
Canis latrans
Wolf
Canis lupus
Red Fox
Vulpes vulpes
Black bear
Ursus americanus
Marten
Martes americana
Ermine
Mustela erminea
Mink
Mustela vison
Lynx
Lynx lynx
Moose
Alces alces
Canadian beaver
Castor canadensis
Northern bog lemming
Synaptomys boreal is
59
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TABLE &2/
BIRDS COMMONLY FOUND IN THE
FAIRBANKS - NORTH POLE AREA
Mallard
Anas platyrhynchos
Pintail
Anas acuta
Green-winged teal
Anas carolinensis
American widgeon
Mareca americana
Bufflehead
Bucephala albeola
Goshawk
Accipter gentilis
Sparrow hawk
Falco sparverius
Spruce grouse
Canachites canadensis
Ruffed grouse
Bonasa umbel 1 us
Common snipe
Capella gallinago
Solitary sandpiper
Tringa solitaria
Lesser yell owlegs
Totanus falvipes
Great Horned owl
Bubo Virginianus
Yellow-shafted flicker
Colaptes auratus
Traill's flycatcher
Empidonax traillii
Common raven
Corvus corax
American robin
Turdus migratorius
Varied thrush
Ixoreus naevius
Swainson's thrush
Hylocichla ustulata
Ruby-crowned kinglet
Regulus calendula
Yellow warbler
Dendroica petechia
60
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Northern waterthrush
Rusty blackbird
Common redpoll
Slate-Colored junco
White-crowned sparrow
Fox sparrow
Seiurus noveboracensis
Euphagus carolinus
Acanthi's flairmea
Junco oreqanus
Zonotrichia leucophrys
Passeralla iliaca
61
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EXISTING LAND USE AND ZONING
As part of the Fairbanks North Star Borough Comprehensive Plan,
the refinery site is located in a sub-planning area referred to as the
North Pole Planning Area which covers approximately 67 square miles
east of Fairbanks and Fort Wainwright, extending along Badger Road and
the New Richardson Highway. The land use recommendations for the North
Pole area made by the Planning Department of the Borough are shown in
Figure 10.
The comprehensive plan, which was officially adopted this year,
recommends (1) concentrated commercial and urban and suburban residential
development in the North Pole city center, within the realm of the
existing water and sewer systems, (2) low suburban-rural densities on
land suitable for development but outside the limits of sewer and water
services, (3) the retention of lands along Chena Slough as part of a
proposed open-space trail system, and (4) heavy industrial use south of
the city center, between the Old Richardson Highway and the Tanana River,
and east along the railroad tracks.
At the present time the zoning plan for the North Pole area is
consistent with the Borough's comprehensive plan. The ECA site is
zoned Heavy Industrial; the State-owned property north of the site is
zoned General Agriculture; property to the east and on the opposite
side of the Old Richardson Highway is zoned General Agriculture and
Rural Residential respectively; and privately owned property south of
the ECA site is zoned for unrestricted use.
In June, 1975, under the authority of Ch. 8, SLA 1974 SSS, Governor
Jay Hammond authorized the State to grant the City of North Pole $20,000
in emergency financial assistance, contingent upon $10,000 from the Fairbanks
North Star Borough, to develop a comprehensive master plan for the North
Pole area. FNSB contracted with R. W. Pavitt and Associates, Incorporated
to develop the resource inventory and to provide the technical assistance
for the plan, which is expected to be completed by March, 1976. The
preliminary plan was presented to the North Pole Comprehensive Planning
Committee and other City and Borough officials on February 24, 1976.—'
The planning area for the new Dlan covers approximately 26 square miles,
extending from the southern intersection of the Old and New Richardson
Highways to approximately 3 miles north on Badger Road (about 1 mile north
of Plack Road). The final plan will deal with anticipated growth rates as
determined by numerous future developments of which the ECA refinery is
only one. The overall plan will (1) present a land use plan for the North
Pole area, (2) outline a capital improvements program, offering a housing
element and communities facilities plan, (3) delineate zoning and
transportation plans and (4) present a summary of the community's goals and
objecti ves.b9/
62
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With the adoption of this new plan the City of North Pole will be
the first self governing city in the Borough to have its own comprehensive
plan. This opportunity to plan for growth arises at an appropriate time
as the need for planning in North Pole is obvious. The City is subject
to numerous external forces, and it is clear that it will not remain static
The City greatly needs a comprehensive plan which will not only outline
alternative futures for the community or recommend prudent uses of the
City's resources but also delineate effective implementation measures.
The importance of the effectiveness of a comprehensive plan for a small
community like North Pole cannot be too greatly stressed. Unrestrained
private and public development, while providing the City with substantial
revenue, can collectively contribute to undesirable development patterns and
an eventual decline in that quality of life that is commonly associated
with living in a small community.
The planning environment of North Pole is such that there exists a
small number of decision makers who can be easily reached and who are
informed and responsive to the interests affected. In light of the
controversial nature of the proposed GVEA and ECA facilities, the residents
of the community are aware of the probable impacts of these facilities and
they are taking an active role in the community's decision making process
by making their views known.
A citizens committee was formed to assist Borough planners and the
planning consultant in making policy recommendations in such areas as
housing, annexation, transportation, community facilities, capital
assistance and land use.lZ/ This committee, known as the North Pole
Comprehensive Advisory Planning Committee and composed of five North Pole
residents, serves as liaison between the community and Borough planners.
It provides comment on the desirability of various growth and development
patterns and expresses the community's view of recommended zoning and
planning guidelines. The Borough continues to be administratively responsi-
ble for the appropriation of funds and for the adoption of the final plan.
62a
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-n
a
c
JO
m
O
POOR SOIL, OPEN SPACE,
STEEP SLOPES ft RIVER BANKS
FLOOD PLAINS, LIMITED USE
(AGRICULTURE, PARK)
COMMERCIAL SERVICES
0-1/10 UNIT PER ACRE
:
LAND-USE RECOMMENDATIONS FOR THE NORTH POLE AREA
2-4 UNITS PER ACRE
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EXISTING SOCIO - ECONOMIC
enviiweut
North Pole
Prior to the approval of recent annexation proposals the City of
North Pole occupied about a third of a square mile, or 210 acres. The
approval of the proposed annexations increased the City's jurisdictional
boundaries by 1300 acres, or roughly six times its original size. As
indicated in Figure 3, the topping plant site is now located within the
city limits.
In July of 1975 a door-to-dog§/Census in the City revealed a population
of 470. More recent information —- indicates that there are 562 people
living within the City boundaries and 3,036 living outside the City but
within the North Pole Planning Area. The residents of the North Pole
area are largely employed in Fairbanks, at Fort Wainwright or Eielson
Air Force Base, or by Alyeska.
North Pole is, at the present time, regarded as a residential "bedroom"
community dependent on outside employement centers. Residents of North
Pole are largely dependent on commercial and professional institutions
available in Fairbanks since there is no industry in the City and very
few commercial establishments. Despite its small tax base, North Pole
is classified as a first-class home rule city, and provides its residents
with fire and police protection, administrative services, and public
services, including community buildings, streets, street lighting, water
and sewer.
The City has a mayor-council form of government and currently employs
only 3 persons full time: a city clerk, chief-of-polic? (partially funded
by the Federal Government), and a public utilities supervisor (supported
by water and sewer receipts). The Mayor and City Council members are
unpaid public servants. Fire protection is provided by a volunteer fire
department, which also assists the Police Chief in providing emergency
ambulance services.
In November of 1974 the City of North Pole voted to impose a tax
limitation on the Home Rule Charter which eliminated sales and property
tax and reduced the improvement tax rate to 2 mills. This tax limitation
resulted in a tremendous loss of incoming revenue to the City. The loss
of revenue amounted to approximately $37,500 in property and sales tax
and about $167,000 in State discretionary funds. This substantial re-
duction in funds caused a significant reduction in the City's work force
and placed heavy constraints on the City's ability to provide adequate
services and facilities. In the past the City's tax rate for Land and
Improvements ranged from a low of 5.8 mills to a high of 13 mills.
64
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On July 18, 1975 North Pole residents passed a proposition which
repealed the temporary charter tax limitation amendment. The City
now hopes that an increase in the tax rate on property, improvements,
and sales tax will provide them with the revenue necessary to re-estab-
lish vital fire and police services and to better serve the needs of the
community. The lifting of the tax limitation should allow a large
increase in the total assessed value of the North Pole community.
North Pole presently obtains the majority of its operating reve-
nues from water and sewer receipts, and from State and Federal revenue
sharing. In 1974 North Pole received $152,000 from state pipeline im-
pact funds, however, it did not receive any in 1975 although approximately
$300,000 was requested.
North Pole's waste water treatment facility, which was completed
in December, 1972, is a typical package plant utilizing the extended
aeration mode of the activated sludge process. The plant was designed
to treat 227 cu. m./day (.06 mgd), or 600 population equivalents, of
domestic waste. The current population equivalent served is approxi-
mately 300; about 200 residents plus a school population of 400.
Since its completion, however, the extended aeration treatment
plant has failed to properly treat wastes from the present population
equivalent. Despite numerous attempts to identify the cause, the treat-
ment facility fails to perform properly. Problems with the sewage col-
lection system (infiltration/inflow and solids deposition) have also
been experienced and have contributed to treatment problems. Some pro-
blems may be related to the high iron content of the potable water supply.
Installation of equipment necessary for iron removal in the water treat-
ment system has been recommended, but has not yet been accomplished.
The City's potable water supply and distribution system was in-
stalled during the same time frame as the construction of the waste
water treatment facilities. The system consists of a deep well, 378.5
cu.m. (0. lmg) storage tank, chlorination, a green sand pressure filter
and both constant pressure and circulating pumps. The system is pre-
sently designed to serve a population of 4000 people.
Water and sewage rates now finance the operation and maintenance
of these utilities. The present rates for water and sewage are shown
in Table 9. Minimum monthly service charges have also been estab-
lished: unmetered water and sewer $32.50; unmetered sewer $14.00;
less than 3000 gallons, water and sewer $20.45; less than 3000 gallons,
sewer $8.50.
65
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TABLE 9
NORTH POLE SEWAGE CHARGES3
Cost per 1000 gallons
$2.80
$2.50
$2.00
Flow (gallons)
0 to 5,000
5,000 to 25,000
Above 25,000
a
Charges for water are the same.
The existing solid waste collection and disposal service for the
City of North Pole and adjacent areas is provided by Drake Sanitation,
a private operator.
The solid waste is disposed of at the City of Fairbanks disposal
site south of the city, adjacent to the Tanana River. The Fairbanks
North Star Borough Comprehensive Plan indicated that fill material
on the site was inadequate and that solid waste is frequently dumped
into groundwater. A recent Fairbanks North Star Borough Environmental
Services Department study (1974) of the S. Cushman site showed, however,
that contamination of groundwater does not occur. The average solid
waste disposal at the City site is 6.1 pounds per capita per day.IZ/
There is an elementary school with an enrollment of about 800
students. A new Junior-Senior High School with an anticipated capacity
of 1000-1200 students is now under construction at a site which is 600
feet northeast of ECA's leased parcel. The new high school accommodates
students for the city as well as outlying areas, including Moose Creek,
Half Mile, and Badger Road. A recently constructed Borough Public Library
is located near the city center. Part of the North Pole Elementary School
was reconstructed due to considerable damage ($363,000) caused by arson
fire in May of 1975.24./
Many of the streets in North Pole are yet unpaved, and many residential
streets are not equipped with street lighting. Although the City recognizes
the need for street improvement and maintenance, action by the City has been
greatly constrained by the lack of funds.
66
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The New Richardson Highway, which was completed in 1971 and runs
east of North Pole, has sufficiently accommodated an increase in
Fairbanks-Eielson Air Force Base traffic. The average daily traffic
flow through the North Pole area on the new highway exceeds 4000
vehicles. The State Department of Highways proposes to limit the
number of on-off access points in the North Pole area and plans to
construct an underpass connecting subdivisions east of the highway
to the city. Proposed completion date of this project is 1980 when
the average daily traffic volume is expected to be 5300 vehicles per
day. The capacity of the highway with the proposed interchanges is
over 20,000 vehicles per day
Construction of a road joining the Chena Hot Springs and Badger
Roads was completed in late 1975. This road connects the Chena Hot
Springs area, northeast of Fairbanks, to North Pole. The Department
of Highways reports that average daily trips (ADT's) on this new road
approximated 450 in September of 1975. This road has facilitated
access to the city.
Housing in both Fairbanks and North Pole is a scarce commodity;
vacancy rate is persistently low and turnover is slow. This acute
shortage of housing is caused not only by the large in-migration of
workers seeking jobs in pipeline construction work but also by such
factors as the rising cost of building materials, a labor-intensive
construction industry, severe climatic and topographic constraints,
and an isolated, fluctuating market.
The availability of housing in North Pole, however, is expected
to increase in the near future. One residential subdivision, con-
taining 60 lots was recently annexed to the city; construction of
2 four-plexes located within the city limits has been completed and
2 more are under construction; substantial residential construction
is underway in the Beaver Subdivision which is located adjacent to
the city limits; and Columbia Mobile Sales is finalizing plans and
beginning construction of a 500-unit mobile home park which will
accommodate over 1000 residents. City officials expected that
residential construction would have doubled the number of living units
within the city limits by the end of 1974, however, several develop-
ment plans were either cancelled or postponed.
Several projects were postponed or cancelled because of the city's
financial inability to provide the customary municipal services, in-
cluding the extension of sewer and water feeder lines, street main-
tenance and lighting, and police and fire protection. (For further
discussion on the impacts on municipal services, refer to Socio-
Economic Impact section.)
67
-------
Fairbanks North Star Borough
The Fairbanks North Star Borough encompasses a land area of
7361 square miles. In 1970, the U. S. Census Bureau estimated the
population of the Borough to be 31,364 persons, of which the Eielson
Reservation was estimated to have contributed 6149 and Fort Wain-
wright, 9097. The City of Fairbanks had an estimated population of
14,771, and the University of Alaska at College, 3434. In July, 1975,
the Borough Assembly certified the Borough population as 63,350.
The larger Fairbanks Census Division had an estimated peculation
of 48,700 in 1973; 14,500 people, or 29% of the total population, were
military personnel and their dependents. In 1960, 47" of the Borough
population was military personnel and dependents. The economy of the
Borough is dominated by government and military activities. However,
non-military business activities are beginning to have a greater
effect on the local economy.
During the time lapse between the initial North Slope petroleum
discovery and the actual commencement of pipeline construction, the
unemployment rates in the Fairbanks area were high (over 10% of the
labor force in 1973). During this period, the number of people seek-
ing work in oil-related businesses exceeded the availability of jobs.
The substantial cutbacks in personnel at Fort Wainwright also added
to the unemployment figures.
The State Department of Labor reports that the unemployment rate
in the Fairbanks area in March, 1975 was at about 10% of the labor
force. The total number of persons employed was 19,500 and the total
unemployed was 1,950. These figures reflect a little more than a 33%
increase in employment over 1974 figures. §/
In March of 1974, when pipeline construction was just beginning,
the unemployment rate was at 13.8%. There were 2,300 persons unem-
ployed, and 14,500 persons employed. It's significant to note that with-
in one year there was an increase of about 4,000 persons in the total
working force in the Fairbanks area.28/
Historically, there has been no appreciable non-governmental indus-
try in the Fairbanks North Star Borough to provide economic support
for the area. Construction has primarily occurred on public or military
projects rather than private developments. Therefore, there has been
minimal local control of economic activity. The lack of manufacturing
in Fairbanks has resulted in the need to import most manufactured goods
and creating an "outflow" of monies from the local economy, thereby
reducing internal development potential.
68
-------
The severe flood of August, 1967, which occurred in the Fairbanks
area, also had the effect of slowing new development. A housing
shortage resulted which is still a problem. Housing costs are
extremely high in the area due in part to this shortage. Scarcity of
local development capital has perpetuated the problem. Low and
moderate income housing is difficult to obtain. Permafrost conditions
create problems in providing utilities, sewer and water to new housing.
Poor building soils and the high water table in the Fairbanks area
also cause problems in building and in the construction of wells and
septic systems. The short building season adds to the housing construc-
tion problem, and in addition to the importation of all necessary
materials, raised the cost of housing.1Z/
According to figures published by Larry Smith and Company, median
incomes in the Fairbanks area are 20-25% higher than in the lower 48
states ($12,443 per family in 1970 vs $9,590 per familyjlZ/.
More recent information provided by the Pipeline Impact Information
Center indicates that the cost of living in Anchorage is approximately
28-48% above the U.S. urban average (depending on the budgetary level)
and that the cost of living in Fairbanks is higher than in Anchorage. The
report cites a study entitled "Consumer Prices, Personal Income and
Earnings in Alaska" prepared by the University of Alaska's Institute
of Social, Economic, and Government Research and published in 1974. This
study shows that while wages may be about 15% higher in Fairbanks than
in Anchorage (for classified University employees and general government
employees working for the State), the cost of housing is 9-18% higher
and food is 7-8% more in Fairbanks than in Anchorage. Although the
study is largely based on pre-pipeline data, it can be safely said
that the cost of living in Fairbanks is over 10% greater than in
Anchorage and more than 30% higher than the cost of living in cities
in the lower 48.
69
-------
CHAPTER 3
DESCRIPTION OF
PROPOSED ACTION
-------
DESCRIPTION OF PROPOSED ACTION
The U.S. Environmental Protection Agency (EPA) is considering
the issuance of permit No. AK-002546-1, a new source NPDES permit,
for discharge of process and non-process waters from Energy Company
of Alaska's proposed topping plant into the Tanana River. The permit
proposed to be issued by EPA to Energy Company of Alaska (ECA) will
authorize ECA to discharge effluent from their facility to receiving
waters only in accordance with effluent limitations set forth in the
pe rmi t.
The permit, a draft of which is included in this document, is based
on Alaska Water Quality Standards and effluent levels achievable with the
use of tertiary treatment, Alternative 2A in the Alternatives Sections.
A special allowance based on New Source Performance Standards published
in the Federal Register of May 9, 1975 and amended May 20, 1975 for the
Petroleum Refining Point Source Category will be provided for storm
runoff waters. The draft permit specifies a maximum limitation for
flow from process area runoff. Impoundment areas to store excess runoff
will be designed based on this maximum flow. Non-process area runoff is
not limited as this flow should normally not be contaminated. If
contaminated, this flow must also be treated and discharged at a
controlled rate. The method by which the permittee must monitor these
values will include two alternatives due to the treatment flow scheme
that may occur. Monitoring of storm runoff will be separate unless all
wastes are combined for treatment.
No administrative action shall be taken by EPA, Region X, until
thirty (30) days after the publication of the final EIS.
The Regional Administrator wil1 approve or deny the new source
NPDES application for a permit following a complete evaluation of the
significant beneficial and adverse environmental impacts of this action
on the human environment consistent with EPA's legal authority including,
but not limited to, the Federal Water Pollution Control Act (33 U.S.C.
1151 et. seq.), the National Environmental Policy Act of 1969 (42 U.S.C.
4321 et. seq.), the Clean Air Act of 1970 (42 U.S.C. 1857 et. seq.), and
the Safe Drinking Water Act of 1974 (42 U.S.C. 300 f).
71
-------
CHAPTER 4
DESCRIPTION OF
PROPOSED PROJECT
-------
DESCRIPTION OF PROPOSED PROJECT
Market Area
The approximate marketing area for the Energy Company of Alaska's
products (see Figure 11) encompasses 200,000 square miles, extending
600 miles west from the Canadian border and 350 miles south from
Prudhoe Bay.
ECA has estimated the mid-1970's petroleum products consumption
in Interior Alaska as 10,000 barrels per day. The current demand is
wholly fulfilled by petroleum products transported by rail or truck
from Anchorage, Seward, or Valdez at a cost of 7
-------
A
c t i c
Bering
Sea
o
PRI9IL0F ISLANDS
O
O 0
SCALE IN MILES
FIGURE 11
NORTH POLE TOPPING PLANT
MARKET AREA
-------
These included two sites to the northwest of Fairbanks along Sheep
Creek and on Murphy Dome, a site along the Tanana River between Fort
Wainwright and North Pole, and a site outside the Fairbanks area such
as Delta Junction. These sites were evaluated in terms of the afore-
mentioned criteria and were deemed to be less suitable than the pro-
posed North Pole site.
An approximate numerical rating of the potential sites with
respect to suitability for a topping plant is shown in Table 10. No
attempt was made to assess the relative importance of the various sit-
ing criteria.
The favorable air dispersion characteristics of an elevated loca-
tion such as the Murphy Dome site were offset by a number of factors.
The site is relatively distant from the source of crude oil, construc-
tion of both the topping plant and transfer pipelines would be difficult,
and problems were anticipated with water supply and waste water disposal.
A study of the airflow within the Sheep Creek area has indicated
that under normal conditions, drainage is into the Goldstream Valley,
which can in turn drain in a westerly direction or to the southeast
into the Fairbanks basin. This phenomenon was recognized by Benson
and Weller in 1970.23/ Consequently, a potential site for the topping
plant was abandoned for environmental reasons.
A site adjacent to the Richardson Highway and to the southeast of
Fort Wainwright was considered. The area is, however, heavily under-
laid with permafrost which would have made construction extremely
difficult.
Delta Junction was also suggested as a possible site due to its
relatively good air dispersion characteristics and the possibility of
improving the local economy. However, this site would be located approx-
imately 90 miles from the major potential marketing area. ECA has in-
dicated that the distance from the refinery to the major marketing areas
alone would make this location unfeasible from an economic standpoint.
In addition, rail facilities do not exist in this area and certain of
the local resources required for construction and operation of the
topping plant are not available.
If a refinery were to be located at Delta, it would be necessary
for ECA to ship all products by truck. Well over 90% of the products
would move to consumers in the Fairbanks area, 90 miles away, at an
estimated shipping cost of 2 to 2.8^/gal. This increase in truck
traffic between Delta and Fairbanks could be significant in terms of
air quality degradation, depending on the frequency of trips and the
distance travelled.
75
-------
TABLE 10
RELATIVE ACCEPTABILITY OF POTENTIAL TOPPING PLANT SITES
RATING
SITING CRITERIA
1 - Positive
2 - Neutral
3 - Negative
SITE
Proximity to
Crude Oil Supply
Proximity to
Potential Market
Availability of
T ransportation
Facilities
Suitability of Site
for:
Construction
Envi ro nm ental
Acceptability
r—
Local Resources
Average Rating
Murphy Dome
3
1
2
3
1
2
2. 0
Sheep Creek
1
1
1
2
3
1
1.5
Richardson Highway
Site Close to Fairbanks
2
1
1
3
2
1
1.7
North Pole
1
1
1
1
2
1
1.2
Delta Junction or Site
Outside Fairbanks -
North Pole Area
1
3
3
1
1
3
2. 0
-------
Shipment by pipeline from Delta, by installing a new line would
be cost prohibitive, both initially and operationally, and could in-
troduce environmental problems. Use of the military pipeline was sug-
gested, however, this possibility was not feasible for these reasons:
The military pipeline is not for sale and the line is not insulated,
thus is unsuitable for the transport of products with high pour points
(more viscous material).
With regard to crude oil pipeline tariffs, the cost of shipping
to Delta over North Pole is estimated at .25 to .5
-------
CRUDE
FROM
t OCT I hip
s
0—
I OPTIONAL 3,000 B/D
TO POWER GENERATION
t REQUIRING ADDITIONAL
13,000 B/0 DESALT ER
THROUGHPUT + • ¦
H
<£>c
DESALTER
25,000 B/D
DESIGN
1
m
STABIL-
IZER
<$>'
ATMOSPHERIC
DISTILLATION
TOWER
25,000 B/0
DESIGN
<$>
DISTILLATE
<*>
ATMOSPHERIC GAS OIL
fuel
^6^ REDUCED
v CRUDE
VACUUM
DISTILLATION
TOWER
"2,700 0/D
L
<°>h
<§>
VACUUM
RESIDUAL
O>5L0P WAX
FIGURE 12
BLOCK FLOW DIAGRAM
NORTH POLE TOPPING PLANT
- MILITARY
K>JET FUEL
UP-4)
reconstitute::
OH RETURN
TO PlPELJNc
-------
The process units will consist primarily of two main distillation
towers, 70 to 80 feet high, two heaters and associated air coolers and
pumps. The Energy Company of Alaska anticipates that approximately
half of the ultimate storage capacity (720,000 barrels) will be installed
in 1977.
Originally, the topping plant was to be located near the flood
control levee that transects the southwest corner of the ECA site
(See Figure 13). A revised plot plan was drawn by ECA's consultant
after extensive soil studies showed that soil conditions further away
from the levee were best suited for construction of the topping plant
and the power plant facilities (See Figure 14). Detailed equipment
layouts of the (1) process area, (2) tank farm, and (3) waste treatment
facilities are shown in Figures 15, 16, and 17, respectively.
The plant facilities will occupy 40 acres of the total leased
area of approximately 421 acres. The topping plant will be located
away from the Old Richardson Highway so as to maximize the distance
between the plant and the nearest inhabited properties. Much of the
existing vegetation on the site will be retained as natural barriers
to minimize aesthetic and noise impacts.
The Energy Company of Alaska anticipates that the plant will be
in operation 24-hours per day, 350 days per year with a possible 2-week
turnaround time for annual maintenance.
The delivery of products to market areas will be by rail, primar-
ily, to distributors' storage and by truck to individual consumers.
If the topping plant is constructed at the proposed site, fuel will
be piped to GVEA's power plant at very low costs, and military jet
fuel (JP-4) can be expeditiously transported to Eielson Air Force
Base and Fort Wainwright by rail or through the existing Military P.0.L,
(Petroleum Oil and Lubricants) Pipeline.
Supply and Retiam Pipelines: The crude oil supply for the topping
plant will come directly from the Alyeska Pipeline in an 8-inch pipeline
to be constructed by the Energy Company of Alaska. Unused products from
the distillation towers will be returned to the Alyeska Pipeline via a
6-inch reconstituted oil return pipeline which will be constructed along
side the supply line. Residual materials returning to the Alyeska Pipe-
line, may amount to about 10,000 barrels per day.
Figure 3 shows the proposed routing of these lines. This proposed
route is considered most feasible since it falls within an existing
easement held by Golden Valley Electric Association (GVEA). The corridor
has been cleared of vegetation and does parallel the existing Military
P.O.L. Pipeline.
79
-------
v\~-PROPOSED TIE-IN TO
y\ MIUTARY FMPEUNE
A C S. UNDERGROUND CABLE
HAINES TO FAIRBANKS MILITARY
PIPELINE
ALASKA R.R. EIELSON BRANCH
OLD RICHARDSON
HIGHWAY
FIGURE 13
OVERALL PLOT PLAN
NORTH POLE TOPPING PLANT
ORIGINAL ORIENTATION
NEW ROAD TO RICHARDSON HWY.
IOO 0 200 400
ts==l==^===l
SCALE ^'EET
-------
UNDERGROUND CABLE
TO FAIRBANKS MILITARY
NE
ALASKA 9. ft. CIELSON 0JUNCH
OLD RICHARDSON
HIGHWAY
FIGURE 14
REVISED PLOT PLAN
DRAWING 475-1
PREPAREO BY
R. W. BECK and ASSOCIATES
(Amended to show discharge)
acawt m rut
-------
SCALE IN FEET
FIGURE 15
PROCESS AREA
NORTH POLE TOPPING PLANT
-------
atmospheric gas oil
naptha
LVGO—
dilstiillate-
O
distillate
A
r
o
J
\ >
iOpOQBBL 24/X30BBL
© 0
24,000BBL 20,000BBL
-~® 0
^ J
2Q0Q0BBL 2^°°
0
5,000
20,000BBL 6BL
0 0""
~ *S
BLENDING STORAGE
vacuum residual
-fuel
military low-pour industrial
jet fuel diesel turbine fuel
return to pipe
75,000 BBL
crude
75,000 BBL
crude
ZO,OOOBBL
I®
5,000BBI
©
O
20,000 BB
L 20,000 BBL
© © ©
0 0©
15,000 BBL 15,000 BBL
FINISHED PR
DDUCT STORAGE
n fuel oil
asphalt
FIGURE 16
TANK FARM LAYOUT
NORTH POLE TOPPING PLANT
-------
FIGURE 17
WASTE WATER TREATMENT FACILITIES
NORTH POLE TOPPING PLANT
-------
PAGE NOT
AVAILABLE
DIGITALLY
-------
Steam Supply: The topping plant steam requirements consist of
approximately 20,000 pounds per hour for heating (under winter
conditions), 8,000 pounds per hour for the steam turbine-powered
crude oil charge pumps, and 2,000 pounds per hour for process use.
The total steam requirements, of some 30,000 pounds per hour, will be
supplied by a package boiler equipped to handle gas turbine exhaust
as combustion air. A second package boiler, similarly equipped, will
be utilized in a standby mode to provide emergency steam requirements.
Fuel oil with a maximum sulfur content of 0.8% will be utilized for
boiler fuel.
Makeup water for the steam system will be demineralized using an
evaporator. The source of heat for the evaporator will be combustion
products from the gas turbine noted above. The evaporator system was
selected in order to minimize the addition of dissolved solids to the
influent to the topping plant waste water treatment system.
Process steam will be used for reboiling in the atmospheric tower
This steam will be later reclaimed as condensate and used as a partial
source of makeup water for the desalting unit, thus minimizing the raw
makeup requirements for this unit.
Electrical Power Supply: All plant electric requirements will be
supplied by Golden Valley Electric Association. These requirements (for
lighting, electric motor drives, etc.) are estimated at 1,000 kW of
generating capacity. As indicated in the above section (Steam Supply),
steam turbine drives will be used to power certain plant equipment,
primarily crude charge pumps.
Water Supply; The topping plant will require approximately 37
gallons per minute (53 thousand gallons per day) of water for process
use and 2 gallons per minute (3 thousand gallons per day) for domestic
use. As shown in the Water Flow Schematic Diagram (Figure 18), process
water will be pumped from on site wells as required. Domestic water will
be provided by the City of North Pole Water System. (See page 140)
Figure 18 also shows the flow rates of the various waste water and supply
streams.
85
-------
FIGURE 18
NORTH POLE TOPPING PLANT
WATER FLOW SCHEMATIC DIAGRAM
ON SITE WELLS
37gpm
i
yl9gpm
1
gpm
BOILER
4 gpm
r
PROCESS
4 gpm
w5 gpm
PROCESS
AREA
i '6gpm
STORAGE
AREA
23 gpm
2 gpm
,(5gpm lr6gpm
WASTE WATER
TREATMENT
FACILITIES
I g pm
Dis. No. ooi 37gpm
TANANA RIVER
irl gpm
LAB AND
SERVICES
NORTH POLE
WATER SYSTFfl
pm
DOMESTIC
SERVICE
,r2 gpm
NORTH POLE
TREATMENT
PLANT
"Schematic of Water Flow"
Energy Company of Alaska
North Pole, Fairbanks North
Star Borough, Alaska
March 27, 1975
-------
Water for fire protection requirements will be supplied from on
site storage tanks. If necessary, the effluent from the plant's
waste treatment system (approximately 53,000 gallons per day) can
also be utilized for fire control purposes.
Waste Water Treatment: The degree and type of contaminants in
the various waste water streams in the topping plant necessitate the
segregation of these flows for separate treatment. The waste waters
from the plant will be (1) process and oily water sewer, (2) process
area storm and fire water collection,(3) non-process area storm water
and fire runoff collection, (4) oil free sewer, and (5) sanitary sewer.
Such segregation of each type of waste water will permit tailoring
of primary and secondary treatment methods and ensure optimum treatment.
The major sources of process and oily waste water are storage
tank drainoffs and crude desalting and distillation processes. Other
significant, if not major, sources are slab washdowns, vessel cleanouts,
laboratory wastes, spills and overflows. The volume of this waste water
has been estimated at 3b gpm (0.078 cfs). Quantifications of the concentra-
tion of a particular pollutant in the untreated process waste water is
difficult since wide variation may be encountered, depending on the
quality of North Slope crude, refinery technology and process efficien-
cies. An estimate of the average concentration of certain constituents
of the untreated waste water has been developed by Energy Company of
Alaska and is presented below.
Constituents of
Untreated Process and Oily Waste Mater
Effluent
Characteristic
Estimated Average Value
lbs/1000 bbl of feedstock
BODc
COD
TSS
Oil and Grease
Phenolic Compounds
Ammonia as N
Sulfides
Total Chromium
hexavalent Chromium
Cadmi urn
Cyanide
pH (units)
17
58
33
7*
0.24
0.17
0.16
Nil
Nil
Nil
Nil
6.0 to 9.0
*After American Petroleum Institute (API) separator
87
-------
Sanitary waste volume from the plant is estimated at 3,000 gallons
per day based on average per capita water usage in the Fairbanks vicin-
ity.
Process area storm runoff may contain moderate concentrations of
oil and grease with associated BOD, COD and suspended solids. Non-
process area storm runoff is not expected to be contaminated except by
naturally occurring pollutants.
Oil-free waste water will consist of evaporator blowdown and boiler
blowdown. The quantity of this waste stream is estimated to be 2 gpm.
Total dissolved solids content of this waste water is expected to be in
the range of 0.4 to 0.6 pounds per 1,000 barrels of feedstock, and am-
monia (as N) is expected to be less than 0.0002 pounds per 1,000 barrels
of feedstock.
After waste-water treatment, the average waste-water constituents
(as shown in Table 11) will remain in the refinery effluent, based on
the untreated waste-water quality analysis developed by Energy Company
of Alaska and estimated equipment removal efficiencies. This does not
include process and non-process storm runoff. Average Federal effluent
guidelines for the North Pole topping plant are shown for comparison.
The treatment processes which will be applied to various waste
streams are delineated in a block flow diagram on the following page
(Figure 19).
The process and oil waste water enters a treatment facility with the
following unit processes:
1) Primary clarification with oil skim for removal of heavy
suspended solids as sludge from the bottom and floating
oil and grease from the top.
2) Equalization to smooth the variability in waste-water flow
and constituents, and to afford spill protection. Optimum
efficiency of downstream unit processes is achieved through
steady average hydraulic loadings and closely controlled
chemical feed rates tailored to the equalized waste. In-
plant storage capacity permits isolation of potential spills
to permit special treatment and/or gradual feeding back into
the normal waste flow.
3) Neutralization for pH control.
4) Chemical addition and flocculatfon for increased solids removal.
5) Dissolved air flotation for removal of fine suspended solids,
emulsified oil and other emulsions and colloidal substances.
6) Activated sludge with associated secondary clarification for
biological destruciton of BOD, COD, emulsified oil, phenols,
sulfides and ammonia.
88
-------
TABLE 11
CONSTITUENTS OF
TREATED PROCESS AND OILY WASTE WATER
Effluent
Character!stic
Estimated Average Value
(lbs/1000 bbl of feedstock)
Biochemical Oxygen Demand —^ o,9
Total Suspended Solids
Chemical Oxygen Demand 5^3
Oil and Grease 0.2
Phenolic Compounds 0.007
Ammonia (as N) 0.024
Sulfides 0.004
Total Chromium Nil
Hexavalent
Chromium Nil
pH (units) 7 to 8
Federal Guidelines—
(lbs/1000 bbl of feedstock)
Average of Daily Values
for 30 Consecutive Days
Shall Not Exceed -
1.6
1.4
7.9
0.5
0.011
0.32
0.008
0.026
c/
.0018
6 to 9
Federal Guidelines*
(lbs/1000 bbl of feedstock)
Maximum for any one day
Shall Not Exceed -
3.0
2.1
15.4
0.92 c/
0.022-
0.71
0.019
0.045
0.0037
6 to 9
(Values for temperature, dissolved oxygen, color, total dissolved solids, chlorinated hydrocarbons and
biocides are not available.)
a.
J>.
c.
5-day
Federal Register 39(91): May 9, 1974
and Revisions, Federal Register, 40 (98): May 20, 1975
Section 419.15 (Standards of Performance for New Sources - Topping Subcategory)
In order to satisfy Alaska State Water Quality Standards, the proposed permit limitation for phe-
nolic compounds has been reduced to 0.26 lbs/day for the 25,000 bbl/day throughput for a maximum,
compared to 0.55 lbs/day based on the effluent guidelines. No explicit limitation on the daily
average is set in the proposed permit.
-------
RAW
SEWAGE -
INLET
RAW SEWAGE
LIFT STATION
WITH COMMINUTOR
3000 GPD
TO NORTH POLE
¦CITY WASTE
DISPOSAL SYSTEM
NORTH POLE TOPPING PLANT
REVISED VERSION July 7 8, 1975
-------
7) Sludge from the primary clarifier, dissolved air flotation
unit and secondary clarifier is concentrated in a sludge
gravity thickener, incinerated and the ash disposed of by
landfill. This ash (which will amount to approximately
43 lbs/month) will be disposed of at the South Cushman site.
8) Oily water skimmed off the primary clarifier and the dis-
solved air flotation unit is treated in an agitated reactor
to break emulsions and returned to slip oil storage.
Process area storm drainage will pass through an API separator
for removal of separable oil, then routed to a diversion tank for
inspection. If the quality of the storm water is acceptable for
direct discharge in accordance with Federal regulation, then it will
be discharged. If not, it will be pumped to the head of the waste
water treatment facility.
Non-process area storm drainage is passed through an API separator
for removal of separable oil, then directly discharged. Provisions
will be made for quality inspection of this storm water for compliance
with Federal regulations and for alternate piping to the diversion tank
for spill protection.
Oil-free waste water will be neutralized for pH control and directly
discharged.
All unit processes will be covered or enclosed to prevent the gen-
eration of ice fog during winter operation.
The raw sanitary sewage will be pumped by a sewage lift station
to the North Pole sewage treatment facility where it will undergo
secondary treatment before discharge.
WcutzA Quatitq MonvtosUng: Discharges from the North Pole topping
plant will be monitored by tne Energy Company of Alaska in such a way
as to insure a complete record of performance for comparison with
Federal effluent limitations. In addition, the constituency of the
untreated process and oily waste water shall be monitored in order to
provide control of waste water treatment processes.
The pH, oil concentration and flow volume of the treated process
and oily waste water will be continuously and automatically recorded.
In addition, the refinery will supply a qualified chemist and the
necessary laboratory methods as approved by EPA regulation: 5-day
biochemical oxygen demand (BOD5), chemical oxygen demand (COD), total
suspended solids, phenols, sulfides, ammonia and total and hexavalent
chromium, oil and grease, pH, and TOC. Samples shall be obtained from
the discharge by a proportional composite sampler.
91
-------
Process area storm water will be collected by grab sampling in
the diversion tank and tested in the laboratory for the following:
(1) chemical oxygen demand, (2) total suspended solids, (3) oil and
grease, and (4) pH. A BOD5 - COD relationship can be developed em-
pirically to circumvent the time lag in the BOD5 test.
Non-process area storm water will be grab sampled and tested in
the laboratory for total organic carbon and oil and grease.
Air Coolers: The topping plant will employ air coolers to handle
all process cooling requirements. The use of air cooling instead of
water cooling has several important advantages, the most obvious being
(1) a significant reduction in waste water discharge volumes and (2)
the lack of evaporative heat transfer to the atmosphere.
Air coolers, which are oftentimes referred to as "dry towers,"
operate in much the same manner as automobile radiators, transferring
heat directly to the atmosphere by utilizing finned-tube heat exchange
surfaces. The air flow is provided by motor driven fans. In addition
to the absence of evaporative heat transfer, which is basic to wet
cooling operations and which may contribute to ice fog formation, the
air coolers are expected to have the added beneficial effect of enhancing
plume rise of the topping plant stack. Heat released by the air coolers
is expected to be 110 million Btu per hour.
Stack and Flare: Only one stack will be utilized to discharge
combustion products from the topping plant. The crude oil charge heater
and vacuum tower feed heater combustion products will comprise the
majority of the effluent discharged by the stack. In addition, the
combustion products of the steam supply boiler will be exhausted to
the stack. Combustion products from the gas turbine used to provide
heat for the evaporator system and from the sludge incinerator will
also be discharged via the stack. Consolidation of air emissions in
this manner will improve dispersion of air contaminants generated by
the topping plant.
An elevated flare will also be provided to consume petroleum frac-
tions in the event of upset or emergency conditions. As shown in the
overall plot plan, Figure 14, this flare will be remotely located from
the process area and tank farm. Under normal operating conditions, only
the pilot flame using light petroleum fractions will be burning.
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The pressure vessel relief piping system will deliver all vented
products to the elevated flare.
Schedule for Construction and Operation: The Energy Company of
Alaska anticipates that site clearing for the North Pole topping plant
will be completed by summer of 1975. This initial operation will be
followed by site preparation, including roads, railway spur, fencing
and building foundations which are scheduled for completion by the end
of 1976. During 1977, construction will be completed in the process
units, tankage, utilities, and other facilities. The proposed start-up
and water discharge is scheduled for October, 1977.
The Energy Company of Alaska cannot discharge waste water into
the Tanana River until approval is granted by the U.S. Environmental
Protection Agency. No administrative decision on the discharge per-
mit can be made by the Regional Administrator of the Environmental
Protection Agency until thirty days after the final EIS is transmitted
to the Council on Environmental Quality and not until a minimum of
ninety days after the draft EIS is published.
Future Facility Expansion: The Energy Company of Alaska's long
range plans include expanding the topping plant facilities to manufacture
gasolines, propane and butane, and possibly, commercial jet fuel. While
the planned expansion could give the Energy Company of Alaska the capa-
bility to supply a large percentage of the Interior demand for these
products, the decision to expand will ultimately depend on market potential
and demonstrated environmental acceptability. As yet the Energy Company
of Alaska has no definite plan to manufacture low-volume specialty
products such as sulfur, building materials, petrochemicals and fer-
tilizer.
The manufacture of unleaded and low lead gasoline will require
the addition of a 1700 B/D Reforming Unit to improve the octane of
naphtha (JP-4 jet fuel). Propane and butane are by-products of this
process. The unit, if installed, will be similar to that being built
by Tesoro, but about 1/3 the size. It will be integrated with the
topping plant and will use the same fuel, steam, air and effluent
treating systems. All flue gases from fuel burned in the unit will be
ducted to the existing stack. Physically, the unit will require an
area of about 100' x 200' and conventional heaters, towers, vessels,
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pumps, and exchangers will be used. Expansion of the tank farm will
be required to blend and load gasoline. ECA will probably add four
10,000 bbl floating roof tanks. If ECA decides to recover the pro-
pane and the butane rather than burn them, additional towers, pumps
and exchangers will be installed, requiring an area of about 50' x
50'. No heater will be required. A small addition to the existing
storage and loading facilities will be necessary for the propane and
butane. ECA anticipates that the earliest possible date the reform-
ing unit can be in operation is late 1978, and only after the topping
plant has demonstrated environmental acceptability.
With regard to the manufacture of commercial jet fuel, ECA's plans
are less certain. Based on laboratory work on North Slope crude, the
distillate fraction from the topping plant itself is extremely close
to meeting commercial jet fuel specifications with no further treatment
Only after the topping plant is in operation will ECA know whether or
not further treating is required. The most that will be required is
mild saturation of aromatics to improve burning quality. If ECA does
follow that route, a 2,000 B/D Hydrotreater will be installed. Essen-
tially the equipment required will be the same as the Reformer, how-
ever, the area required will be smaller. The Hydrotreater would be
integrated with the existing process units, and the tank farm and load-
ing facilities would require expansion.
The unit could not be installed until after the Reformer is in
operation since it requires by - product hydrogen production from the
Reformer.
Total water effluent from the refinery after installation of both
the Reformer and Hydrotreater would be 43 gpm (.096 cfs), an increase
of 6 gpm (.013 cfs) over effluent from the topping plant. Quality of
the effluent is not expected to change significantly.
Operation of the two units will require a total of four (4) per-
sons per shift. Total increase in refinery personnel would be 15-20
persons.
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CHAPTER 5
ENVIRONMENTAL
IMPACTS OF
PROPOSED PROJECT
-------
WATER QUALITY IMPACTS
Primary impacts on water quality result from site development and
construction and subsequent operation of the topping plant. No signi-
ficant adverse long-term impacts on water quality are anticipated from
normal plant operations or construction. Adverse impacts from oil spills
depend on the measures used to reduce their impact and probability of
occurrence.
Construction, including site preparation and installation of the
effluent outfall pipe and the tie line to the Trans-Alaska pipeline,
is expected to have little impact on the quality and quantity of ground
and surface water. Vegetation and soil will be cleared from the refinery
site, creating increased opportunity for erosion. However, the site is
relatively level and no perennial streams are known in the immediate
vicinity, so no significant adverse impacts from erosion are expected.
Some alteration of drainage patterns may result from site preparation.
An effluent line must be constructed to discharge waste water to the
Tanana across the Tanana-Chena levee. The levee crossing will be reviewed
by the Corps of Engineers to assure minimal impacts on this flood control
project. Furthermore, a Corps of Engineers permit is required for
construction of the outfall under the Rivers and Harbors Act of 1899,
33 U.S.C. § 403. EPA reviews such permits for environmental considera-
tions and makes recommendations for permit conditions where appropriate.
The proposed shoreside discharge consists of a two and one-half (2-1/2)
inch pipeline protected by riprap. The pipeline would be about four feet
below the river surface elevation measured in April 1970. During construc-
tion, disturbance of soils may increase sediment in the Tanana River, but
this would be a relatively minor addition to the heavy summer sediment
load. For construction in the Tanana, approval from the Alaska Department
of Fish and Game may be required under Alaska Statutes (Section 16.05.870).
The originally proposed discharge location described in the Corps of
Engineers permit application did not appear satsifactory during the
February 6, 1976 survey (see Hydrologic Conditions) because adequate
dilution was not available. Consequently, discharge to the channel which
had 140 cfs is now planned and an amendment to the Corps of Engineers
application would be necessary.
Because of the generally high groundwater table, dewatering operations
may be necessary during construction. Since these waters would not be
discharged to surface streams, no adverse impacts on water quality are
expected beyond short-term, local increases in groundwater turbidity from
excavation at the water table. If groundwater with high iron concentrations
is encountered, some reddish iron deposits may be noted.
Construction of the ECA feeder and return lines to the Trans-Alaska
Pipeline will be according to standards established by Alyeska, which
will be responsible for design, maintenance, and operation of the tie
lines.££/ According to A1yeska2°/standards for these lines will be at
least as stringent as those for the Trans-Alaska Pipelined contained
96
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in documents filed with the Department of Interior (Criteria and Design
Basis, Engineering Design, and Technical Specifications); Both lines
will be constructed during the same time and will be sized to accommodate
possible expansion, limiting construction impacts. For crossing of the
Chena Slough, approval may be required from the Alaska State Department
of Fish and Game. According to Alaska Statute 16.05.870, complete plans
and specifications for the proper protection of fish and game may be
required by the Commissioner for his review before granting approval
for construction in waters specified as important for the spawning or
migration of anadromous fish. Potential construction impacts include
temporary increases in turbidity and sediment load. According to the
Alaska State Department of Fish and Game,30/ Arctic grayling, an important
sports fish, spawns in the Chena Slough up to Laurence Road, which
parallels the pipeline right-of-way at this point (Figure 3). The
Department of Fish and Game may restrict tbe time of year for construction
to avoid critical seasons for the fishery.2z/
96a
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TONA RIVER IMPACTS
Primary impacts on the Tanana during plant operations would result
from discharges of treated process wastes, runoff, and domestic wastes
due to 60 plant employees over three shifts. (During construction, about
100 workers will be employed and those which are new residents of North
Pole may increase its municipal waste discharge). Under the proposed
permit conditions (see Appendix, Exhibit 5) ECA must assure secondary
treatment of domestic wastes prior to discharge to the Tanana via either
a properly operating municipal waste treatment plant or through a
treatment system operated by ECA.
No significant adverse impacts on the water quality of the Tanana
are expected from the topping plant under the proposed permit conditions.
Discharge limitations would be based on achieving water quality standards
after 200 to 1 dilution of the process effluent (maximum .09 cfs) and
would be stricter than if oased solely on EPA's New Source Performance
Standards (NSPS). Proposed permit conditions require routine winter studies
of the outfall location to ensure that 200 to 1 dilution is achieved during
the low flow season of the Tanana at the mixing zone boundary. Discharges
of runoff from process and non-process areas would be allowed only during
higher water flows of the Tanana so that adequate dilution for these_
additional discharges should present no difficulty. When concentrations
were within permit limitations based on EPA effluent guidelines (NSPS),
runoff could be discharged directly to the Tanana (process area runoff)
through the primary outfall #001 and to a drainage ditch (non-process
runoff). Otherwise, additional treatment would be required to discharge
to the Tanana River.
Water quality analyses of the Tanana River at the proposed discharge
location indicate that background levels of oil and grease, phenols, and
sulfides are at or below the detection level of the analytical methods.
Because these would be expected to be absent, it is reasonable to assume
that the lack of significantly detectable concentrations indicates their
absence. Consequently, the absolute minimum river flow required to
achieve 200 to 1 dilution of the effluent concentrations can be theoretically
estimated by assuming complete instantaneous mixing of river water at zero
concentrations with effluent at the maximum concentrations listed in the
proposed permit. For the winter discharge of process effluent (maximum
.09 cfs), an absolute theoretical minimum required flow of 18 cfs is
thus estimated although actual required river flows would be greater
because mixing does not occur instantly. Assuming a mid-stream single
port discharge into the channel with characteristics similar to the one
which had 140 cfs during the February 6, 1976 survey, the actual required
river flow for 200:1 dilution at 200 feet downstream was estimated using
a diffusion model (see Appendix, Exhibit 6). The results indicate that a
97
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flow of 59 cfs would orobabjv be adequate. For comparison, the estimated
dilution at 200 feet downstream during a river channel flow of 140 cfs
would be about'»600 to 1 for the same channel.
Table 12 summarizes the maximum expected river concentrations at the
mixing zone boundary based on 200 to 1 dilution. Also shown are estimated
increased river concentrations after complete mixing of the effluent
(maximum 0.09 cfs) with river flow of 3100 cfs to indicate potential
increases far downstream during low winter flows, making no allowance for
natural removal mechanisms.
Within the mixing zone established in the permit, concentrations may
exceed water quality standards. However, conditions at the mixing zone
boundary must be in compliance with Alaska Water Quality Standards.
The Alaska water quality standards for the Tanana require that the
1962 USPHS drinking water standards not be exceeded by toxic materials
in the river, thus limiting maximum concentrations of phenols to 0.001
mg/1 and hexavalent chromium to 0.05 mg/1. They also require that oil
and grease must be at or below levels which will make the receiving water
unfit or unsafe for all water uses and that substances such as sulfides
be low enough to avoid chronic toxicity (see Alternatives). For evaluating
ECA's discharge, it was determined that concentrations of 0.1 mg/1 for
oil and grease and 0.002 mg/1 for sulfides in the receiving water were
appropriate criteria. Thus, the above concentrations must be met at the
mixing zone boundary.
Impacts of oil would depend on physical, chemical and biological
factors of the aquatic environment as well as the quantity and composition
of the treated effluent. Crude oil and refined products, as complex mixtures
of chemical compounds, vary in properties relevant to toxicity such as
density, volatility, solubility and proportions of various types of hydro-
carbons. Appropriate numerical criteria are difficult to establish because
of these variable factors. Furthermore, analytical methods differ in their
sensitivity for some of the components in oil, particularly the more soluble
and volatile compounds which are thought to significantly contribute to
toxic effects.—' Sub-lethal, chronic effects may adversely impact
biological communities as well as acutely toxic effects. The ECA permit
was based on a criterion for oil and grease of 0.1 mg/1 in the receiving
water (see Proposed Action). Concentrations of oil which might adversely
affect fish and lower food organisms have not been specifically determined
for the Tanana environment. EPA1 s proposed Water Quality Criteria
(October 1973) did not set specific numerical standards for oil, "recommending
case-by-case evaluation using bioassay procedures. Proposed criteria
were limitations of (a) no visible oil on the water surface; (b) emulsified
oils not to exceed one twentieth (.05) of the 96-hour LCcg value using the
receiving water in question and the most sensitive important species in
the area; (c) hexane extractable substances (excluding elemental sulfur)
not to exceed 1000 mg/kg (air-dried weight basis). The criterion used in
the evaluation of the ECA discharge, 0.1 mg/1, is less than one-twentieth
of the lowest 96-hour LCgn value presented in the summary published by the
National Academy of Sciences, Water Quality Criteria 1972, but is greater
98
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than a criterion now under EPA review for technical accuracy and policy
imp!i cati ons.
The estimated threshold level of phenols that can cause tainting of
fish flesh is about 0.02 to 0.15 mg/1 for a polluted river, according to
an NAS report.31/ Concentrations of phenolic compounds in excess of 0.1
mg/1 are considered unacceptable for aquatic life and concentrations less
than 1/20 of the 96-hour LCcq for the most sensitive organism are recommended
in EPA1s Proposed Water Quality Criteria.^?/ (Phenolics appear to affect
the taste of fish at levels that do not seem to adversely affect fish
physiology)EPA1 s proposed criteria^/ f0r raw water for drinking
supplies is 0.001 mg/1, which is the same as the USPHS 1962 drinking water
standard.
Standards for discharge of toxic pollutants proposed by EPA^l/ refer
to the oil refining industry specifically in regard to limitations for
cadmium and cyanide. For the discharge from the North Pole topping plant
into the Tanana River under the proposed standards, cadmium would be
limited to 40 micrograms/1 iter and cyanide to 100 micrograms/1 iter. However,
the applicant has indicated that these constituents would be virtually
absent from the discharge. Consequently, the proposed permit limitations
make no allowance for discharges of cadmium and cyanide and no impacts on
water quality from these are expected.
Chlorides, although not specifically addressed in the permit, will
be expected in the discharge, primarily from the desalting operations.35/
Effluent from the desalter would contain about 47 pounds of chloride ion
per 1000 barrels according to the applicant. This would cause no discernible
increase in salinity of the Tanana at low flows. Concentrations of total
dissolved solids in the process effluent are estimated to average 2800 mg/1
during winter and would include chlorides.
No adverse temperature impacts on the Tanana River biota are expected
due to the small quantity of the effluent and the inherent constraint on
effluent temperature. For proper functioning of the biological treatment
unit, the temperature range of the process effluent should be within 50°F
to 95°F, according to the applicant. Some temperature drop would occur in
the discharge line so effluent entering the Tanana during winter months
(maximum value 0.09 cfs) would probably not exceed 60°F. Based on a 200
to 1 dilution requirement at 200 feet downstream, the maximum temperature
increase at any point on the mixing zone boundary would be quite small
(about 0.10F). However, at the point where the discharge occurs, some
fish may be attracted by the warmer waters (although the volume affected
would be small) and be exposed to higher concentrations of pollutants than
at the mixing zone boundary for varying durations.
During unusual conditions, plant discharges are expected to remain
within the permit conditions due to features of the plant design. For
example, special dried bacterial cultures accommodated to refinery wastes
98a
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TABLE 12
Effect of Proposed Maximum Allowable Process Discharge
on the Tanana River During Winter-^
Parameter
Flow
Biochemi cal
Oxygen Demand
(Fi ve-day)
Total Suspended
Soli ds
Chemical Oxygen
Demand
Proposed Permit
Maximum
Discharge
mg/1
N/A
N/A
N/A
10
Oil and Grease
Phenolic Compounds 0.1
Ammonia (as N/A
Ni trogen)
Sulfide 0.4
Total Chromium 0.02
Hexavalent Chromium 0.02
kg/day
.09 cfs
26
11.5
155
2.2
0.02
4.6
0.09
0.004
0.004
Increase in River Concentration
Due to Effluent (mq/1)
Two Hundred b/ After Complete
Feet Downstreanr^ Mixing with 3100 cfs —'
.59
.26
3.5
.05
.0005
.11
.002
.0001
.0001
.003
.002
.020
.0003
.000003
.0006
.00001
.000006
.000006
a/ Winter conditions present critical low Hows.
b/ Assumes a minimum dilution of 200 to 1 in the plume at 200 feet downstream
based on proposed permit requirements. tream
— Complete mixing Is not likely to occur for many miles downstream but values
no removal lnCreaS6S t°PPln9 pUnt far
d/ N/A - Not applicable as no concentration limit was proposed.
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will be available during start-up and as contingency if the biological
treatment process suffers an upset condition. Storage to retain process
effluent for about two weeks during start-up (or at other times) will be
included in the plant design. Also, effluent from the clarifier can be
recycled through the treatment system. Storm or fire flow runoff or oil
spills in the tank storage (non-process area) will be retained within berms
and released under controlled conditions to the treatment facilities.
Runoff or spills from the process areas (remainder of the refinery) could
be diverted for additional treatment.
Additional discharges of treated domestic wastes due to the small
refinery contribution (.003 mgd-60 employees) should have very little
impact on the Tanana River whether discharged through a properly
operating municipal plant at North Pole or through a separate treatment
facility by ECA. Present discharges of biochemical oxygen demand are
limited in the North Pole NPDES permit to 15 lbs/day on the average and
30 lbs/day as a maximum based on secondary treatment requirements and
a flow of 0.06 mgd to serve about 600 population equivalents. However,
the present treatment system is too small to serve the anticipated future
needs of the city. Consequently, by the time the refinery begins operation
in October 1977, it is likely that municipal waste discharges from the
City of North Pole will have increased due to growth and development. (See
Socio-economic Impacts).
Groundwater Impacts
Groundwater withdrawals for the topping plant operation would
have an insignificant impact on groundwater supply. Although short-
term impacts of construction may slightly increase local turbidity
in the groundwater where construction intercepts the water table, no
significant, long-term, adverse impacts are expected. During operation,
there would be an increased potential for oil spills; however, plant
construction should minimize the possibility of significant impacts
on the relatively shallow water table. Three different methods may
be employed for protection of groundwater quality.
1. Reinforced concrete deck, curbed and drained to the sewer
system will be employed for areas such as the process units and rail
and truck loading racks where small spills will occur (primarily due
to maintenance).
99a
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2. A mechanically compacted layer of suitable soil (12 to 18
inches thick), possibly augmented with bentonite or a similar material
to improve impermeable characteristics, is planned for the diked
area surrounding the storage tanks where leaks should be rare. This,
with the capability for rapid removal of spilled oil from the diked
area,would minimize the possibility of oil reaching the relatively
shallow water table. Guidelines for spill prevention plans (40 CFR
Part 112.7(e)(2)(x)) stipulate prompt correction for any visible oil
leaks which result in a loss of oil from tank seams, gaskets, rivets,
and bolts sufficiently large to cause the accumulation of oil in
diked areas. According to ECA, major spills within the tank farm
compounds could be contained within the dikes and drawn off immedi-
ately into a closed piping drainage system. If spilled oil were not
rapidly removed, some migration of oil into the groundwater might
eventually occur. This could result either indirectly from the
percolation of meltwater or stormwater through the oil-contaminated
soil, or directly from migration of the oil and would depend on the
quantity involved, soil properties such as moisture, and other factors
such as disturbance of the compacted layer. (Inspections to determine
maintenance of compaction would be made.)
3. An impermeable membrane (such as neoprene) will be installed
directly beneath each storage tank but will not extend into the
surrounding diked area.
Tests of the permeability of the compacted earth to both oil and
water are now being conducted. If compaction alone or with a soil
sealant (such as bentonite) appears unsatisfactory, an impermeable
membrane on a compacted layer will be used in the diked area around
the storage tanks. Spill prevention plan guidelines state that diked
areas should be sufficiently impervious to contain spilled oil (40 CFR
112.7(3)(2)(ii)).
Stormwater retention ponds will be lined with a compacted soil
layer, possibly augmented with bentonite or similar sealant (as in
the diked area) or an impermeable membrane.
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AIR QUALITY irPACTS
Air Pollution Conditions
Fairbanks is surrounded on three sides by hills that rise to a height
of about 500 meters above the city, and is located on the north side of
the Tanana River. Downslope drainage of cold air from these hills and
along the natural river drainage contribute to the formation of inversions
in addition to radiational cooling of the land surface. In winter, a
combination of short days with low sun angle, light winds and an abundance
of clear or mostly clear skies create conditions under which surface-
based inversions can exist for days or even weeks. It is during these
periods that the potential is high for trapping pollutants in the lowest
layers of the atmosphere.M/ Some mitigation of this potential does
occur as a result of the Fairbanks heat island.5?/
The Fairbanks inversions are exceptionally strong. A temperature
difference of 20°C in the lowest 200 meters is not uncommon. The
Fairbanks inversions are not only strong and persistent, but they have
a complex structure as well. Studies with the acoustic sounder^!/ have
shown as many as 10 to 20 separate, quasi-horizontal backscatter bands
within the height interval from the surface up to 500 meters in situations
with well-developed inversions. During these multi-layered conditions,
profile measurements using conventional wind and temperature sensors on
a tethered balloon have shown a conspicuously strong temperature gradient
in the lowest few tens of meters, and a wind speed at the 2-meter level
of less than 0.5 meters per second. Above this extremely stable surface
layer there is often a step-like buildup on the inversion; between layers
of small temperature gradients, there are then layers of sharp inversions.
There may also be two or more low-speed jets; often in diametrically
opposed directions.
The Pasqui11-Gifford dispersion analysis which has been used to
predict the air quality impact of ECA's topping plant was developed for
and has been verified in other regions of the country not subject to
inversions of the severity experienced in Fairbanks. However, for most
of the year unstable and neutral conditions are present which should not
be dissimilar to the same atmospheric stability categories elsewhere.
Therefore, only stable conditions, and more precisely the extremely
stable (Class G in table on page 49) conditions are not well described
by the usual dispersion analysis. These conditions are known to occur
approximately 10 to 20 percent of the time in Fairbanks.
Comparison of air quality impact as predicted by the usual dispersion
analysis with impacts estimated for G stability should be segregated into
sub-categories of ground-level sources and elevated sources. Automobiles,
home heating equipment and cooling ponds emit hydrocarbons, carbon monoxide
and water vapor at or near the surface. Extremely stable conditions will
tend to concentrate these emissions in the immediate locale pf tbe sources
beyond normally predicted concentrations. Numerous studies §2/
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support this conclusion. On the other hand, elevated sources of sulfur
dioxide, oxides of nitrogen and water vapor, such as power plant stacks
and ECA's proposed exhaust stack will have higher-than-expected pollu-
tant concentrations at the plume centerline. Under non-ice-fog cir-
cumstances, these plume centerlines should remain elevated for considerable
distances downwind. Because plume rise should be less under extremely
stable conditions than under conditions described by the usual dispersion
analysis, ground-level impacts will be comparable, although the downwind
distance of maximum impact will be farther away from the source.
Mention has not been made of the complications which no extant
model can handle and which are also characteristic of extremely stable
conditions. Severe wind shears in both speed and direction greatly
affect the location and disperison of elevated plumes. There have been
numerous examples of simultaneous plume dispersion in directions almost
180 degrees apart due solely to the effective stack height differences
of two or more sources. And, of course, this effective height will vary
greatly for a single source depending upon the characteristics of the
several layers through which the plume passes enroute to this height.
A further complication is that of ice fog formation at temperatures
as warm as -23°C. Ice fog forms when water vapor is rapidly cooled and
condensed to tiny droplets, then frozen to form ice crystals. The ice
fog is caused by the Fairbanks heat island and is a visible indicator of
wintertime inversion conditions. However, there must also be strong
radiational cooling to bring about the change of phase of man-made moisture.
The ice fog plays an important role in determining the thermal characteristics
of the layer of air in which it is formed. It has been shown that an iso-
thermal or even adiabatic lapse rate often develops through the ice fog
layer once it has been well established, and that the level of radiational
cooling is then effectively transferred to the top of the ice fog layer.
This produces a large volume of air through which atmospheric pollutants
can be dispersed, especially during prolonged cold periods when the ice
fog is well developed. The air quality impacts of this phenomenon are
that ground-level sources are dispersed into a less stable air mass of
limited mixing height which results in lower pollutant concentrations;
but plumes from elevated sources have been observed to be effectively
lowered into the ice fog layer below^O/ due to the sublimation and sug-
sequent fallout of ice fog particles resulting in higher concentrations
of those pollutants associated with industrial facilities. The redeeming
feature of elevated sources is their dispersion within a layer of air
which is usually warmer than the surface and may also be warmer than the
required temperature for sublimation (approximately -35°C, colder tempera-
ture required than at surface because of smaller water vapor source).
Recognition of these characteristics of the Fairbanks area and of
the qualifications which need to be made to the usual dispersion analysis,
will allow the estimation of reliable air quality impacts for the ECA
topping plant.
100b
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Primary Impacts - Stationary Source
In full recognition of the unique climatological conditions in
the area, EPA evaluated the results of R. W. Beck's modeling program
and concluded that the operation of the topping plant will have mini-
mal impact on the ambient air.
The following sections provide the basis of this evaluation.
Fuel: The primary fuel for the North Pole topping plant will be
a combination of approximately 70% distilled products and 30% propane/
butane. This fuel will be used for the crude oil charge and vacuum
tower feed heaters, and also as supplementary fuel for the steam supply
package boiler.
A typical analysis for the distilled product is as follows:
This analysis was used in computer models to estimate the maximum
impact of the topping plant combustion products on the environment.
However, ECA has indicated that during normal plant operation the blend
of distilled product and propane/butane will be used which will result
in lower S02 and particulate emissions.
It is necessary during normal operation of the topping plant to
maintain a continuous flame at the plant flare. The fuel consumed in
the pilot will be primarily propane, and the quantity consumed will be
approximately 0.3% of the fuel consumed by the topping plant.
It is also necessary to dispose of sludge generated by the plant's
waste water treatment facilities. This sludge amounts to approximately
0.25 gpm, with solids content of 8 to 10 wt. %.
The magnitudes of the flare and sludge incinerator emissions were
considered to be negligible relative to the emissions from other topping
plant sources, and they have therefore been excluded from consideration
in air dispersion models.
In order to achieve and maintain National Ambient Air Quality
Standards and to provide a mechanism for enforcement, emission limitations
for various categories of sources have been established. A topping plant
is classified as "industrial processes and fuel burning equipment" by
the State of Alaska, and as a "Petroleum refinery" by EPA. Pertinent
emission regulations are summarized in Table 13. Compliance by the
topping plant with these regulations is demonstrated below.
Sulfur (wt. %)
Ash (wt. %)
0.8
0.02
146,000
18,900
HHV (Btu/gallon)
HHV (Btu/oound)
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TABLE 13
ALASKA INDUSTRIAL PROCESSES AND FUEL
BURNING EQUIPMENT EMISSIONS REGULATIONS
All Sources
Particulates
SOz
0.05 gr/scf
500 ppm
1 - May not exceed 20% opacity more
than 3 minutes in any hour
FEDERAL PETROLEUM REFINERY EMISSION REGULATIONS
Topping Plant
S02
No combustion of fuel gas containing H2S in
excess of 0.10 gr/dscf
-------
Topping Plant Regulation
0.008
330
0.05
500
Federal
combustion fuel H2S
(gr/dscf) nil 0.10
Control of Emissions: Anticipated analysis of the fuel to be
burned by the topping plant indicates that no control measures are
necessary in order to limit SO2 and particulate emissions below the
regulated quantities. It will be possible to further reduce these
emissions by burning No. 2 fuel oil and/or topping plant off-gas as
such is available for fuel or under conditions of severe atmospheric
pollution.
Nitrogen oxide emissions fluctuate with several variables of unit
operation; i.e., firing temperature and excess air. They are not
primarily dependent on fuel quality. The expected emission rates for
the topping plant stack have been calculated from the emission factors
pub7?sfted in the EPA document AP-42, "Emission Factors"
Water vapor emissions are of concern only under winter conditions
and depend on the amount of hydrogen in the fuel that is burned.
Other possible air pollutants resulting from topping plant opera-
tion are carbon monoxide, hydrogen sulfide and hydrocarbons. Although
emission rates have been computed for these contaminants, they have
been excluded from R. W. Beck's modeling calculations because of their
magnitude relative to other emissions.
Carbon monoxide and hydrocarbon emissions from the stack will be
controlled by maintenance of the proper excess air ratio in combus-
tion processes. Hydrocarbon emissions can also occur as a result of
leakage from process equipment and from storage and terminating facili-
ties. ECA has indicated that these emissions will be controlled by
proper selection of equipment and good maintenance practices. ECA's
air permit application to the Alaska Department of Environmental Con-
servation indicates that storage and process equipment hydrocarbon
emissions will be less than 1000 lbs/day based on the use of floating
roof tanks and emission factors in AP-42. Hydrogen*sulfide emissions
should be negligible because of the lack of this contaminant in the
crude oil supply and the fact that no cracking processes will be employed
in the topping plant.
Emission Modeling: Two methods were used by R. W. Beck to assess
the probable impact on ambient air quality from the topping plant stack.
103
-------
1) For annual effect, the CIimatological Dispersion Model (CDM)
distributed by the Environmental Protection Agency (EPA) was used.
This computer program determines long-term pollutant concentrations
at any ground-level receptor using average emission rates from point
and area sources and a joint frequency distribution of wind speed,
wind direction and stability category for the same period. For the
calculation of effective stack height, Briggs' plume rise theory is
utilized with an assumed power law increase in wind speed with height
that is dependent upon stability. The program has been designed to be
strictly applicable to the lowest layer of the urban atmosphere, which
is generally more unstable than the adjacent rural atmosphere. However,
some input data for the program has been adjusted at the suggestion
of EPA's Model Development Branch. Specifically, these suggestions
were to initialize the vertical dispersion parameters (useful in re-
presenting the roughness of urban topography) at zero, and to model
the topping plant stack as a point source.
2) For short-term effects EPA's PTDIS computer program has
been utilized. PTDIS calculates downwind ground-level concentrations
for various downwind distances for the input meteorological conditions.
Primary output of the program consists of a table with effective
height of emission and concentration given for each downwind distance.
The user is also given the option of either specifying effective height
of emission or having it calculated using Brigg's plume rise methods.
The parameters established for the computer models appear in the table
on the following page.
104
-------
PROPOSED TOPPING PLANT UNITS
Crude
Oil
Charge
Heater
Vacuum
Tower
Feed
Heater
Package
Boilers
Makeup
Water
Evaporator
Combined
Effluent
Stack
Bated Capacity
(MM Btu/hr)
(gpni)
89. 1
23.4
39.6
6.0
-
Fuel Consumed (gal/hr)
Average
610
160
224
-
-
Waste Heat Consumed
(Ib/hr G.V.E. A. flue gas)1
-
-
42,100
62,000
-
Exhaust Gas (lb/hr)
90,700
23,500
43,800
62,000
220,000
SO;j Emission Rate (lb/hr)2
75
19
42
22
158
Particulate Emission Rate (lb/hr)
2 0.95
0. 25
0. 35
-
1.55
NC>2 Emission Rate (lb/hr)3
64
17
33
13
127
H2O Emission Rate (lb/hr)2
5, 100
1,300
2,700
1,100
10,200
CO Emission Rate (lb/hr)3
2.5
0.7
1.3
0. 5
5.0
H2S Emission Rate (lb/hr)2
neg.
neg.
neg.
neg.
neg.
HC Emission Rate (lb/hr)
1.9
0.5
1.0
0.4
3.8
Stack
Stack Height (ft)
-
-
-
-
200
Stack Diameter (ft)
-
-
-
-
5.0
Stack Exit Temperature (F)
685
685
350
350
525
Stack Exit Velocity (ft/sec)
77
1 Golden Valley Electric Association 60-MW combustion turbine.
2 Calculated by material balance.
3 Calculated from AP-42 emisBion factors:
105 lb NQ2 4 lb CO 3 lb HC
103 gal fuel , 10-* gal fuel , 10^ gal fuel
105
-------
Meteorological Study Program: Mr. Loren W. Crow, certified
consulting meteorologist, has been retained by ECA to study the strength
and depth of inversions in the Fairbanks area. Prior observed weather
data both at the Fairbanks International Airport and at Eielson Air
Force Base were analyzed in order to develop reliable frequency arrays
of airflow patterns within identifiable stability regimes for use in
estimating the impact of topping plant effluents. The following para-
graphs describe in general, and in particular, the results of this
study program.
The low speeds of surface winds will permit relatively high ther-
mal rise for any heated plume released from an elevated stack in the
vicinity of North Pole. Under such conditions, the vertical range of
the stack height will extend from 100 meters upward to more than 300
meters above the exit point at the top of a stack. Any dispersed plume,
whether visible or invisible, will gradually assume the flow pattern
of air motion in the height range from 250 up to 400 meters or more
above the ground. During extended periods, when deep layers of stable
air conditions prevail, the plume will move horizontally with almost
zero vertical mixing for many kilometers.
The layers of ice fog which develop first in the lower 50 to
100 meters in the Fairbanks metropolitan area gradually spread south-
ward and southwestward with time. The downslope drainage of cold
surface air from the arc of higher ground to the northwest, north,
and northeast of Fairbanks furnishes semi-continuous downslope flow
during all hours of the day in winter. This drainage results in the
southward flow of ice fog and can result in ice fog persistence (at
temperatures colder than -20°F) for more than two weeks.
Airflow near effective stack height in the vicinity of North Pole
is predominantly from some easterly direction. The second most fre-
quent wind direction quadrant is from the west. The least frequent
wind direction quadrant is from the south.
Winds During Ioe Fog Conditions: The set of data chosen for de-
tail eTTrfiTysesuPthTssUiHyTiTatFd to ice fog includes the coldest
periods during the last five winters (December through February for
the years 1969-1974). The selection of days for which hourly records
from Fairbanks Airport were obtained was based primarily on periods
when maximum temperature was below 0°F. The set of days also included
some days at the end of cold periods for investigating the typical
requirements for ice fog disappearance. Some 225 days of observations
were obtained for Fairbanks Airport.
Following the determination of major ice fog periods, using Fair-
banks hourly observations, a comparative set of hourly observations was
obtained for Eielson Air Force Base (approximately 126 days of observa-
tions). Within this set of data for five winter seasons, the most
lengthy periods of ice fog conditions occurred during the month of January.
106
-------
Stagnant air periods (low wind speeds) permit a building of ice
fog in Fairbanks. The low sun angle during winter days prevents
significant solar heating. In fact, a new radiation-reflecting surface
1s created in the upper portion of the ice fog layer. Extended periods
of a week or more of ice fog condltons reported at both Fairbanks Air-
port and Eielson Air Force Base are not difficult to find. Two extended
periods were chosen for more extensive analysis: January 15-21, 1973
and January 16-29, 1971. During these two periods, wind conditions at
Eielson were almost always calm. During most of the hours when wind
speeds were equal to or greater than one knot (approximately 30# of
the time) at Fairbanks, the direction was from a northerly component.
From the set of 126 days of hourly data at Eielson, 106 had one
or more hours of ice fog. Many of the days had a full 24 hours with
coincidental ice fog and visibility below 6 miles. As shown in Figure
20, the dominant coincident wind observation at Eielson is calm. Of
the 2016 hours with coincident ice fog, 1907 were listed as calm. When
wind speeds were equal to or greater than one knot, the dominant direc-
tion was from the south quadrant.
At Fairbanks Airport there were 1728 hours with coincident ice fog
during a 108-day period. Of the 1728 hours, 912 were listed as calm.
For the hours when wind speeds were equal to or greater than one knot,
the direction was most frequently from the north. The downslope drain-
age wind from higher terrain in the arc of direction north of Fairbanks
Airport supports the high frequency of north winds during ice fog
conditions at that location.
There is very little downslope drainage of airflow at Eielson. The
net downslope flow is toward the north-northwest. The conditions near
North Pole are more closely related to those at Eielson than at Fairbanks.
Typical periods of ice fog are coincident with both very strong and
very deep temperature inversions. Rawinsonde observations indicate
surface winds to be calm or very light and upper winds to be generally
from the east. There is insignificant warming between the early morning
(0200 local time) and early afternoon (1400 local time) hours during
such persistent ice fog periods.
Temperature Inversions Related to Winds: A computer analysis of
all Fairbanks rawinsonde date for the five-year period 1960-1964 was made
to determine frequency of inversions and the estimated wind speed and
direction within four quadrants. This program treated seasonal frequen-
cies. A summary of the findings for wind speed ranges at the surface
and at 600 meters above the surface for three-month periods for early
morning hours and early afternoon hours is presented in Table 14. The
winter period for both temperature-sounding periods shows an overwhelm-
ing predominance of inversions. Of the 448 available morning soundings,
only one did not indicate a temperature inversion near the ground.
107
-------
CAL-M 19o,
SPEED >/1K
1800 -
NORTH EAST SOUTH WEST £
320-040° 050-130 140-220° 230-310
600
1600 -
400 -
n
M
«
a 200
o ->
Fairbanks AP
1400 -
1200 -
1000 -
200
n
u
K
§
Eielson AFB
800-
600-
400-
200-
0 -»
FIGURE 20
S)
§
tn
H
4)
•H
M
coincident winds with hours of ico fog at Fairbanks AP (108 days) and
Eielson AI-B (106 days) during live winters 1959-70 through l«J73-74.
-------
Even in the afternoon hours during the same three months there were
only 5 out of 450 soundings which did not have an inversion near the
surface.
There is still a predominance of strong inversions at the
surface during the early morning and early afternoon in both spring
and fall. Only in the summer season, for the afternoon sounding, is
there a higher frequency of lapse conditions than temperature inversions
near the surface, 349 to 109, However, the morning soundings, even
in summer, indicate a predominance of inversions.
There is a notable increase in wind speed at the 600 mb level
(approximately 14,000 feet) as compared to the surface wind speed.
Generally, wind speeds are greater than 5.0 meters per second at 600
mb, whereas they are almost all below 5.0 meters per second at the
surface.
As a part of the computer analysis, both wind speed and direction
were determined for the surface, 150 meters, 300 meters and 600 meters
by seasonal periods. Data presented in Tables 15 and 16 have been
extracted from these results. Table 15 contains a summary of frequen-
cies for the winter and summer quarters and for the year as a whole.
The possible number of soundings in each quarter during five years
would have been near 450 (90 days x 5 years). In Table 15 the coinci-
dent wind speed and direction which occurred at a frequency greater
than 10% of the total set within one combination of direction and speed
have been boxed for emphasis.
During the winter months, surface winds at Fairbanks are predom-
inantly from the northern quadrant. At 300 meters and higher, the
predominant direction is from an easterly component. Note that at
150 meters above the surface there is a rather broad range of nearly
equal frequency for both north and east and wind speeds of 1 to 5 meters
per second. There is, however, a large frequency of calm conditions
at both the surface and 150 meters above the surface during winter.
For summer months, winds are still predominantly from the north
in the early morning. There is no persistent easterly component at
300 meters and higher. Instead, there is a slightly higher incidence
of westerly winds.
For the year as a whole, the northerly surface winds gradually
change to easterly at 300 meters. For the annual period, the set of
data is four times the quantity of each quarter. Therefore, a thresh-
old value of 180 cases (near 10%) was used to indicate an important
level of significance. The all-year data tend to repeat the peak
frequencies in the same wind ranges as during winter.
109
-------
TABLE 14
ffrouencies of wind srr;:-:D ranges at surface and 600 meters arove the
SURFACE .'OK TlU::t>!w::T!! I EP.IOOS AS 1IIDICATED BY RAV/IMSONDE DATA FOR 12007. (0200 LOCAL)
AND 000OZ "(1400 LOCAL) EASED ON FIVE YEARS OF RECORD, 1960-64, AT FAIRBANKS, ALASKA.
1.200Z (0200 local)
December - February
Surfaco
No Inversions
All Inversions
No Inversions
All Inversions
No Inversions
All Inversions
No Inversions
All Inversions
0 0 1
134 192 116
MARCH - -MAY
2
36
9 33
125 218
0
5
7
53
JUNE - AUGUST
4
29
33
190
53
131
9
6
SEPTEMBER - NOVEMBER
5
56
16
191
21
152
3
5
0
0
0
0
1
0
0
0
3-Month
Total
1
447
51
403
600 Meters
100
356
44
404
0
2
0
0
0
1
0
0
0 10
50 108 173
4 11 22
52 140 147
14
66
5
47
21 40
13 0 130
14
112
9
167
~'1
0
81
12
51
22
46
14
55
OOOOZ (1400 local)
No Inversions
All Inversions
DECEMBER - FEBRUARY
0
127
3
204
1
105
0
9
1
0
5
445
0 10 2 2
O 57 131 161 82
No inversions
All Inversions
MARCH - MAY
9
27
33 88
91 134
27
46
1
1
158
299
0 28 68 50 10
O 52 111 112 20
No Inversions
All Inversions
JUNE - AUGUST
14
4
89
25
177
61
69
19
0
0
349
109
1 83 129 100 31
0 19 40 44 5
No Inversions
All Inversions
SEPTEMBER - NOVEMBER
11
61
30
128
51
140
12
20
0
0
104
349
0 16 34 35
0 62 104 128
12
41
KEY
Speed
C
< 00.1
m/sec
1
00.1
- 02.5
m/sec
2
02.6
- 05.0
m/sec
3
05.1
- 10.0
m/sec
4
>10.0
m./scc
-------
TABLE 15
QUADRANT OF WIITD DTPECTICUS FOR ALL INVERSIONS AT 12002 (0200 LOCAL) AT
FAIRBANKS, ALASKA, FROM SURFACE THROUGH 600 METERS FOR WINTER, SUMMER, AND ENTIRE YEAR.
WINTER: DECEMBER - FEBRUARY
N
E
S
w
c
N
E
S
w
c
Surface
38 14
26 9
13 12
134
131 75
25 9
11 24
23 23
2
3
29
N 437 433) 20
E 115 51 2
S 74 67 4
W 70 61 16
C
255
150 meters
12 3
-i r
300 meters
600 voters
54
74
9
26
23
19
1
17
11
7
55
49
12
~~1 >
49
112
60
11
21
52
105
G2f
24
17
27
21
6
6
28
36
4
10
14
7
13
18
9
2
6
17
25
15
~3
21
SUMMER; JUNE - AUGUST
|66 691 12
29 34 4
11 19 5
17 38 25 1
17 41 12
26
52
20
10 18 11 3
22 |44 56| 9
23
ALL YEAR
201 371
195
139
72
41
60 64 10
54 88 50
2
2
2
3
74 163 78
128
349 201
4
36
57 64 28 4
71 114 99 22
1 181
50
KEY
Speed
Direction
C
<00.1
m/sec
N
316-045
1 00.1
- 02-5
m/sec
E
046-135
2 02.6
- 05.0
m/sec
S
136-225
3 05.1
- 10.0
m/sec
w
226-315
4
>10.0
m/sec
c
Calm
16 20 5
15 32 29 4
18 23 27 7
17 35 69 35
60 62 22
66
209 335
2
124
47 90 100 22
43 109 159 83
111
-------
TABLE 16
guADPAtrr or wh:d directions for all inversions at ooooz (1400 local) at
FAIRl!.r>NKS, AI/'.SKA, FROM SUFPACE THROUGH 600 METERS FOR WINTER, SUMMER, AND ENTIRE YEAR.
W
C
WINTER; DECEMBER - FEBRUARY
Surface
150 nvcttrs
1 r
300 maters
1 r
.600 rantfrc;
n
45 | 17
15 6
127
1
3
N
112
63
&
65
54
12
24
25
11
2
12
]1
5
?
E
32
19
1
57
49
~13 " >
69
110
62
7
17
69
102
68
97
30 21
21 9
1
3
27 14
21 19
28
6
4
1
3
14 30 32 2
14 21 22 10
DEI
N
E
S
W
c
6 7
5 9
7 24 8
7 21 11
SUMMER: JUNE - AUGUST
5 3 2 1
5 10 1
11 20 7
4 20 14
3 3 2
5 11 1
7 18 3
7 15 25
3 4 2
4 11 5
3 6 6
9 19 31
1
4
19
ALL YEAR
N
E
S
W
c
191 1162 24
91 96 22
120 122 16
45 62 33
217
120 120 44 4
126 145 53 4
105 101 16
51 73 41 4
60 67 37 4
142 21
152
239
67 80 18 2
64 85 58 16
41 58 23 2
58 152 [2551 HI
37 81 65
55 94 103 32
163
60
191
KEY
Speed
Direction
C 00.1 m/sec
N
316-045
1 00.1 - 02.5 m/sec
E
046-135
2 02.6 - 05.0 m/sec
S
136-225
3 05.1-10.0 m/sec
VJ
226-315
4 10.0 m/sec
c
Calm
112
-------
The low frequency of strong temperature inversions in the after-
noon hours during the summer accounts for the near random directional
range and relatively stronger winds. Otherwise Table 16, which indi-
cates wind speed and frequencies from the afternoon rawinsonde observa-
tions, is quite similar to Table 15.
Typical Airflow During Persistent Ice Fog Episodes: In the
vicinity of Fairbanks Airport, the direction of net airflow near the
surface in persistent ice fog periods is from a northerly component.
Once formed, the ice fog layer initially tends to move southward,
spreading toward and often beyond the Tanana River. When ice fog
episodes persist for several days, the ice fog area expands toward
the west on the south side of the Tanana River.
During these extended ice fog periods in Metropolitan Fairbanks,
particles of ice fog are formed along the Richardson Highway. Most of
the time these particles move away from the highway toward the west,
but this is by no means a consistent flow path.
There is a slight net downslope flow from southeast toward north-
west in the vicinity of Eielson. Any elevated plume emanating from a
stack 100 meters or more above the ground in the vicinity of North Pole
would have a path of motion which would rise and turn toward the west.
An illustration of the estimated combined flow patterns for both the
ice fog area and the elevated plume is presented in Figure 21.
East to west flow of the elevated plume is the most frequent and
persistent pattern. The second highest frequency of wind direction
near the effective stack height is from a westerly component, which
would move the plume almost 180 degrees opposite to that shown in
Figure 21. The least frequent quadrant of airflow in the height range
from 150 to 600 meters above the ground is from a southerly component.
Disappearance of Ice Fog: Three major factors cause ice fog
conditions to disappear in tne Fairbanks area. The first is the removal
of ice fog by horizontal transport winds generally stronger than seven
knots. The second reason for ice fog disappearance is the advent of
warmer temperatures. The warmer temperatures may or may not be associa-
ted with strong winds. A third factor in eliminating or preventing
ice fog is the onset of snow. Here there is a combination of warmer
temperature and coincident cloud cover. The cloud cover helps reduce
radiation from the top of the ice fog layer, thus preventing growth
of the layer.
Airflow Frequency Near Effective Stack Height: The effective
stack height of any plume emanating from an elevated stack is dependent
on several factors. These include the height and volumetric discharge
of the stack, comparative temperature of the stack effluent versus
113
-------
FIGURE 21
Typical patterns o£ Ii
-------
ambient air, stability of the atmosphere, and wind speed. Indications
are that the topping plant effective stack height would be in the range
of from 200 to 350 meters.
Resource information which forms the basis of the airflow esti-
mates presented in Table 17 and Figure 22 includes a STAR Program
analysis from five years of surface data at both Fairbanks Airport and
Eielson Air Force Base, and a five-year analysis of twice-daily rawin-
sondes from Fairbanks Airport.
During all of the winter months and most of the fall and spring
months, there are very few unstable hours. The hours during
which unstable conditions exist are concentrated mostly in the
summer months and constitute less than one-fourth of all hours
per year. The unstable conditions (Pasquill categories A + B
+ C) are shown on the right-hand side of Table 17. There is
no dominant wind direction for unstable air conditions. There
is a slightly higher frequency for west-southwest and west winds.
The greatest focusing (see boxed entries in Table 15 which are
wind directions within a stability range more frequent than 3.0& of
the time) occurs under stable air conditions, which constitute nearly
one-half of all the hours in the year. The peak direction range is
from the east-northeast and east. There is a secondary maximum from
the north and north-northwest. However, the most notable factor related
to stable conditions is the coincident light winds, particularly at
the surface. The wind speed at effective stack height should not be
considered as calm. A heated plume under calm conditions near the sur-
face will continue to rise until it meets a horizontal flow component
capable of moving the plume in some meandering dominant direction away
from the source.
The neutral stability category includes approximately one-third
of all hours per year and shows a near random direction pattern with a
slightly higher frequency of winds from southwest and west-southwest.
For the three winter months, essentially all hours are included under
stable conditions with relatively few hours of neutral conditions.
The estimated distribution of the annual percentage frequencies within
seasonal periods for the three stability classes is tabulated on the
following page. (Table 17 and the tabulation following have been uti-
lized for the meteorological input into long-term estimates of ground-
level pollutant concentrations accomplished with the CDM computer model).
115
-------
PERCENTAGE FREQUENCY OF WIND DIRECTION IN VELOCITY CLASSES BY STABILITY CATEGORIES FOR AIRFLOW !n;.AR
EFFECTIVE STACK HEIGHT (200-350 METERS) IN THE VICINITY OF NORTH POLE, ALASKA.
STABLE (E+F+G)
NEUTRAL
(D)
UNSTABLE
(A+BJ-C)
(meters/sec
1-2 3-4
.)
5-6 7-3
9 Total
1-2
3-4
5-6
7-8
9
Total
1-2
3-4
5-6 7-
8 9 Total
N
3.0
.6
.1
3 •7 |
.5
.6
.3
.1
1.5
1.1
.4
.2
1.7
NNE
2.2
.5
.1
2.8
.4
.4
.3
.2
1.3
1.0
.2
.1
1.3
NE
1.8
.5
.1
2.4
.3
.3
.3
.2
1.1
.7
.2
.1
1.0
ENE
5.0
.6
.1
5.7
.5
.6
.5
.2
1.8
.7
.2
.1
1.0
E
4.9
.5
.1
5.5
.5
.8
.6
.2
2.1
.6
.2
.1
, Q
ESE
3.2
.4
.1
3.7
.3
.8
.5
.2
1.8
.6
.2
.1
.9
SE
2.4
.4
.1
2.9
.4
.8
.4
.2
1.8
. 6
.2
.1
.9
SSE
2.4
.4
.1
2.9
.7
.B
.3
.1
1.9
.8
.2
.1
1.1
S
2.4
.3
.1
2.8
.7
.8
.4
.2
2.1
1.1
.3
.2
1.6
SSW
1.7
.2
1.9
.7
.9
.1
,2
2.5
1.2
.3
.1
1.6
SVi
1.5
.1
1.6
.8
1.1
.8
.5
.1
3.3
1.2
.3
.1
1.6
wsw
1.5
.2
1.7
.8
1.0
.9
.6
.2
3.5
1.5
.4
.2
2.1
w
1.7
.3
.1
2.1
.7
.9
.8
.4
.1
2.9
1.9
.5
.3
2.7
wkw
1.0
.2
1.2
.2
.4
.3
.1
1.0
1.4
.3
.1
1.8
NW
1.3
.2
1.5
.4
.3
.2
.1
1.0
1.3
.3
.1
1.7
2.8
.4
.1
3.3?
. 5
.5
.3
.1
1.4
1.1
.2
.1
1.4
38.8
5. 8
1.1
45.7
8.4
11.0
7.6
3.6
.4
31.0
16.8
4.4
2.1
23.3
Average Wind Velocity
1.9
irtps
3.9
mps
2.2 r?.ps
Average Mixing Depth
400 meters
TABLE
17
600
meters
2400 meters j
!
-------
METERS/SECOND
1-2 3-4 5-6 +
% CALM INCLUDED IN I "2 m/sec VALUES
FIGURE 22
NORTH POLE
ANNUAL WINDROSE
-------
Estimated Seasonal Distribution
of Annual Percentage Frequencies
Within Three Stability Classes
for Airflow Near Effective Stack Height
Stab!e
Neutral
Unstable
Winter
Spring
Summer
Fall
20
10
5
10
6
10
0
5
13.3
5
5.7
10
Total:
45.7
31.0
23.3
Possibility of Conveotive Cell Formation Due to the Fairbanks
Heat Island: An investigation has been made of the possibility of
a convective cell forming around Fairbanks due to the heat input of
the area. A requirement for convective cell formation is a uniformity
of heat input over an extended surface area. It has been concluded
that the City of Fairbanks more closely resembles a series of point
sources rather than the configuration required to form a convective
cell, and that the air mass displaced by these point sources is replaced
by low-level advective winds. In addition, it is not expected that
this heat island could draw pollutants into the area from as far away
as North Pole.
The total heat release for the area is estimated tube 150,000 million
Btu per day and observations indicate that a heat island strength of
some 10°F can develop over a 3-day period. It encompasses approxi-
mately 30 square miles to a depth of about 500 feet. Eased on these
observations, it appears that the effect of infiltration into the
heat island would extend no more than 3 miles from the edge of the
area.
Stack Height Determination: A computer program distributed by
the Environmental Protection Agency (PTMAX, which predicts the maximum
3-minute surface pollutant concentration downwind of a specified source
for a particular combination of stability and wind speed) has been util-
ized to determine the optimum topping plant stack height. The criteria
used to determine the optimum stack height was that the concentration
addition resulting from the stack would b§ less than 1* of the 3-hour
ambient air quality standard of 1300 ug/mJ of S0? or 13 ug/m3. The
following table displays the modeling results.
118
-------
Maximum SQp Concentration (ug/m3 )
Stability Class
B
D
F
Weighted-Average
Concentration
(based on Table 17)
Wind Speed
(m/sec)
2
4
2
Stack Height (m/ft)
0/0 30/100 60/200* 90/300
32.
26.
83.
53.
26.
15.
27.
23.
21.
10.
9.3
12.
18.
6.5
4.1
8.0
Optimum stack height
Modeling Results: In Figures 23-a through 23-d the short term
worst expected surface concentrations of SOg, NO2 and water vapor
due to the topping plant are plotted with respect to downwind distance
from the plant stack. Those meteorological conditions considered are
representative of the stability classes and average wind speeds deter-
mined to be typical of the North Pole area by ECA's consulting meteor-
ologist (see Table 17). A further consideration was made of the worst
anticipated limited mixing height condition ( a 100m mixing height and
Pasquill stability class F).
Since weather conditions vary and since the topping plant will be
in operation year round, a better appreciation for the impact of the
plant emissions on air quality can be obtained by a presentation of
seasonal and annual mean concentrations. (Seasonal calculations were
made by weight averaging the annual results for each of three distinct
stability categories).
It should be noted that the results are not predicated on the basis
of plume rise enhancement due to the proximity of the dry cooling towers
to the plant stack. Such a beneficial effect (with attendant decrease
in ground-level concentrations) is anticipated based on the formulas
developed by Briggs.3Z/
The estimated air quality impact of the topping plant is minimal
with respect to air quality standards. Ice fog conditions have been
observed to develop to the point where even the plumes from elevated
sources, such as ECA's stack, can be mixed through the ice fog layer
and cause an increase in ground level concentrations of pollutants.
This ice fog-induced increase, however, is not expected to result in
violations of air quality standards due to the topping plant (even in
combination with GVEA gas turbines).
119
-------
FIGURE 23a
PTDIS - NORTH POLE TOPPING PLANT
3-MINUTE AVERAGE GROUND-LEVEL CONCENTRATION
-------
FIGURE 23b
PTDIS- NORTH POLE TOPPING PLANT
3-MINUTE AVERAGE GROUND-LEVEL CONCENTRATION
-------
DOWNWIND DISTANCE (KM)
FIGURE 23c
PTDIS- NORTH POLE TOPPING PLANT
3-MINUTE AVERAGE GROUND-LEVEL CONCENTRATION
-------
FIGURE 23d
PTDIS - NORTH POLE TOPPING PLANT
3-MINUTE AVERAGE GROUND-LEVEL CONCENTRATION
-------
Sulfur Dioxide: The following are the maximum ground-level concen-
tration results calculated for sulfur dioxide.
Stability
Class
B
D
F
F
Season
Annual
Winter
Spring or Fall
Summer
Short-Term
Maximums
Wind
Distance
Speed
(m/sec)
Downwi nd
(km)
Concentrati
(ug/m3)
2
2.
21.
4
8.
9.5
2
30.
11.
2
15.
28.
Long-Term Averages
Distance
Direction
(miles)
(from
stack)
1.5
N or
S
4.0
N, S
or W
2.5
N or
S
1.5
N, E
or S
Special Conditions
100 m mixing ht.
Concentration
(ug/m3)
0.3
0.2
0.3
0.5-0.7
Nitrogen Dioxide: The following are the maximum ground-level concen-
tration results calculated for nitrogen dioxide.
Short-Term Maximums
Stability
Class
B
D
F
F
Season
Annual
Winter
Spring
Summer
Wind
Speed
(m/sec)
2
4
2
2
or Fall
Distance
Downwi nd
(km)
2.
8.
30.
15.
Concentration
uq/m )
17.
8.0
8.5
23.
Special Conditions
Long-Term Averages
Distance
(miles)
1.5
4.5
1.5
1.5
Direction
(from stack)
N or S
S or W
N or S
N, E or S
100 m mixing ht.
Concentration
(uq/m3)
0.2
0.2
0.2
0.4
124
-------
Water Vapor: The following are the maximum ground-level concen-
tration results calculated for water vapor.
Short-Term Maximums
Wind
Distance
Stability
Speed
Downwind
Concentration
Class
(m/sec)
(km)
(mq/m3)
B
2
2.
1.3
D
4
8.
0.6
F
2
30.
0.7
F
2
15.
1.8
Special Conditions
100 m mixing ht.
In order to estimate the long-term average concentration of water
vapor at ground level, an emission rate ratio to NO2 (non-reactive pollu-
tant) has been factored into the NO;? results. Consequently, the highest
anticipated ground-level concentration of water vapor is .03 mg/m3.
It is interesting to compare these water vapor concentrations with
saturation conditions in order to determine if ice fog can possibly be
formed at ground level. The following tabulation illustrates the capacity
of air at various temperatures to contain water as vapor.
Temperature Saturation Water Vapor Concentration
ff) (mg/m3)
100
48,000
80
26,000
60
13,000
40
6,600
20
2,800
0
1,100
-10
680
-20
370
-30
230
-40
120
-50
60
-60
30
Therefore it is expected that under no usual extremes of temperature
would an ice fog plume reach ground level from the topping plant stack.
However, it is important to evaluate ice fog formation in the ele-
vated plume. Stack exhaust contains approximately 30,000 mg water vapor/
m3; however, the exit temperature is 525°F, well above the dew point of
approximately 80F. As the exhaust plume is dispersed down-wind, plume
centerline water vapor concentrations decrease as indicated in Figure
24. This concentration decrease is caused by entrainment of ambient
125
-------
air which also drastically lowers the plume temperature. Thus the
plume temperature asymptotically approaches ambient temperature.
An ice foq analysis has been performed, assuming ambient condi-
tions to be -3OT', moderately stable, with plume concentrations cal-
culated centerline with a 1 m/second wind (per Turner's Workbook of
Atmospheric Dispersion Estimates.38/ These calculated centerline
concentrations have then been compared to the original plume concen-
tration at stack exit, and dilution factor calculated. Then, a plume
temperature has been computed based on the dilution volume and temp-
erature of the ambient air (assuming that perfect mixing by volume is
equivalent to perfect mixing by mass). Comparison of saturation hu-
midity indicates fogging when the centerline value is larger. In
the case of the topping plant stack, fogging is indicated from approx-
imately 0.2 to 2.0 km downwind. It has been ascertained that fogging
is increased by any of the following system or ambient changes: an
increase in water vapor production per volume of flue gas, a decrease
in stack gas temperature, or a decrease in ambient temperature.
The dry cooling towers utilized by the topping plant for cooling
product streams prior to storage have been located adjacent to the stack
to help minimize ice fog formation. These towers discharge dry heated
air at a temperature of approximately 150°F during winter operation.
The heat content of this dry plume is approximately three times that
of the stack effluent based on relative mass flows and temperature.
Therefore, if perfect mixing were to occur between the stack and dry
tower effluents, a new plume temperature of approximately 180°F results
very close to the stack. Figure 24 indicates that the dry tower heat
rejection is just sufficient (theoretically) to unsaturate the stack
plume and to prevent ice fog formation in the range of 0.2 to 2.0 km
downwind of the unassisted stack.
Particulate, hydrocarbons* Hydrogen Sulfide and Carbon Monoxide:
The very small emission rates of particulate, hydrocarbon, hydrogen
sulfide and carbon monoxide relative to sulfur dioxide and nitrogen
dioxide indicate that ground-level concentrations due to the topping
plant stack are negligible (and probably below limits of detectability).
Therefore, no short-term or long-term graphs have been prepared. How-
ever, the following maximum concentrations have been calculated from
emission rate ratios.
126
-------
100
50
20
10
5
2
I
0.5
0.2
0.1
0.05
0.02
FIGURE 24
PLOT OF FOG/NO FOG VS DOWNWIND DISTANCE
-HUMiDIT
CENTER
Y AT P
LINE
LUME
SATURAT
WITHOUT
ON HUli
DRY T
rflDITY
OWERS-
rSATUR
WITH
AT ION HUH
DRY TOWE
/IIDITY
:rs
A-SS
m
y&im.
\
\
\
0.02 0.05 0.1 0.2 0.5 I 2 5
DOWNWIND DISTANCE (KM)
-------
Range of Short-Term Maximums (ug/m)
(over various stability classes)
Based on Nitrogen Dioxide
Based on Sulfur Dioxide
Hydrogen Carbon
Particulate Sulfide Monoxide
Hydrocarbons
.2 to .7
. 1 to .3
.3 to .9
Long-Term Averages (ug/m^)
(over various stability classes)
Based on Nitrogen Dioxide
Based on Sulfur Pi oxide
Hydrogen Carbon
Particulate Sulfide Monoxide
Hydrocarbons
.005 to .02
.002 to .005
.008 to .02
Odor: The principal gaseous pollutants that may cause odor emis-
sions from a typical refinery are hydrocarbons, hydrogen sulfide and
mercaptans. In addition, some water discharges containing phenols,
sulfides or ammonia can be odor sources. Odor can be minimized in a
number of ways, including good housekeeping and maintenance practices.
Primary methods of odor reduction, however, involve the control of
gaseous emissions and the proper treatment of waste water discharges.
Gaseous pollutants can be emitted from process heaters and pro-
duct storage tanks at the topping plant. However, no significant
amounts of hydrocarbons and hydrogen sulfide will be emitted from
ECA's stack. Since no cracking is involved in the topping plant op-
eration, the formation of hydrogen sulfide and mercaptans is also ex-
pected to be minimal. In addition, the storage tanks containing
volatile petroleum products will have floating roofs.
Consequently, negligible odor impact is expected from the top-
ping plant operation.
Plume Rise Enhancement: In addition to the ice fog mitigation
which could result from locating plant dry cooling towers adjacent to
the stack (and west of the stack to minimize the initial visual impact
of water vapor in the stack plume) plume rise enhancement may also
result, according to formulas developed by Briggs. Z/ Dry cooling tower
heat rejection amounts to approximately three times that from the
stack effluent. The other factor entering into the calculation of
128
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plume rise enhancement is the proximity of the two heated sources. A
total separation distance of 50 feet results in a theoretical calcu-
lation of a 50% increase in plume rise for the stack effluent. Such
an increase is expected to reduce ground-level concentrations by 50%.
However, as previously noted, credit for this beneficial effect has
not been taken.
Monlto^Una: ECA will monitor ambient air for sulfur dioxide and
nitrogen dioxide on-site at least one year before the plant becomes
operational and wiTl continue to monitor on a continuous basis after
startup. In addition, meteorological parameters and suspended parti-
culate matter will be measured. Consideration is being given to moni-
toring hydrocarbons, hydrogen sulfide and carbon monoxide at some time
in the future. ECA is working with the Fairbanks North Star Borough
Department of Environmental Services to investigate possibilities of
instituting a joint monitoring program in North Pole.
FueZ-SioiXcfUng Ca.pahlltf.yi Although a combination of distilled
products and propane/butane will normally be used to fuel the plant
heaters and package boiler, cleaner fuels could be made available on
an emergency basis to lower SO^ and particulate emissions should
conditions of severe air pollution occur.
Stack Testing: "Standards of Performance for New Stationary
Sources" have been published by the Environmental Protection Agency in
the Federal Register (Vol. 36, No, 247 - December 23, 1971, page 24876,
etc.: amended Vol. 39, No. 47 - March 8, 1974, pages 9308, etc.).
Performance testing and monitoring requirements for petroleum re-
fineries and storage vessels for petroleum liquids have been specified.
The only requirements for the topping plant per se are those
limiting the amount of hydrogen sulfide in fuel gas. This pollutant
content will be subject to performance testing within 60 days after
achieving maximum production rate, but not later than 180 days after
initial startup. Continuous monitoring is also required.
Regulations for storage tanks require that petroleum liquids
having true vapor pressures, at storage temperatures between 1.5 and
11.1 psia, must be equipped with floating roofs or a vapor recovery
system. Additional record-keeping on storage operations is also
required.
Up&zt OpeAcutiom Under startup and shutdown conditions (subse-
quent'2m3~prior~TonE1ie annual two-week maintenance period) vaporized
process fluids may be discharged to the plant flare. This normal
maintenance period will be scheduled during the summer.. If upset
conditions should occur due to power failure or over pressure, petro-
leum vapors within plant equipment will be discharged to the flare.
It is estimated that this upset condition could result in a maximum
rate of 100,000 pounds per hour of petroleum vapors being discharged
to the flare for approximately three minutes. Preliminary flare design
has been prepared on this basis.
129
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Combined Air Quality Effects of the ECA-GVEA Facilities
EPA evaluated the operation of the GVEA turbine power plant in
order to estimate the combined impact of the ECA-GVEA facilities on
S02 air quality in the vicinity of the proposed ECA topping plant.
The impact of SO2 was evaluated because, in this case, it was con-
sidered the most critical parameter.
According to analyses by the Alaska Department of Environmental
Conservation and R. W. Beck, the only pollutant which might result in
a measurable increase of ground-level concentrations is sulfur oxide.
The sulfur oxide emissions, however, would increase the ambient level
by less than 20% of the standards. Even under worst expected condi-
tions, ECA would not cause increases of sulfur dioxide ambient con-
centrations in North Pole or Fairbanks in excess of 3% of National
and State Ambient Air Quality Standards.
EPA estimates that at a fuel burning rate of 120,000 gallons per
day per turbine, SO2 emissions from the proposed GVEA power plant are
expected to range from 310 pounds per hour burning 0.2% sulfur fuel
to 1240 pounds per hour burning 0.8% sulfur fuel. These figures are
based on use of fuel produced by the ECA topping plant. Fuel used
for the GVEA power plant prior to the availability and use of ECA-
produced fuel will be much lower in sulfur content.
S0o emissions from the proposed ECA topping plant are estimated
to be 158 pounds per hour, or about one-eighth of GVEA's estimated
maximum SO2 emissions rate of 1240 pounds per hour.
State Evaluation of Air Impacts
The Alaska Department of Environmental Conservation (ADEC) evalu-
ated ECA's application for an Air Quality Control Permit to Operate
for the proposed topping plant.* The Department's evaluation took
into account the probability that ECA will expand the refinery to
manufacture low-lead and unleaded gasoline and analyzed the emissions
from both the refinery and GVEA's North Pole power plant presently
being constructed in the immediate vicinity. ADEC's report concluded
that "the ground level concentrations of pollutants emitted from the
ECA and GVEA North Pole facilities, even under 'worst' expected condi-
tions, should be well within the air quality standards established to
protect public health and welfare." "Worst" case conditions
assumed for ADEC's evaluation were as follows:
*Alaska Department of Environmental Conservation Review of Energy
Company of Alaska North Pole Refinery Air Quality Control Permit
to Operate Application, January, 1976.
129a
-------
- North Pole was assumed 2 kilometers and Fairbanks 20
kilometers from the site;
- winds were assumed to carry the plume directly toward
these communities, regardless of the real wind conditions;
- the GVEA plants were both assumed to be operating at full
capacity;
- the two expansions of ECA (the Hydrotreater and the Reformer)
were assumed to have been implemented using the heaters
proposed.
The Department further indicated that operation of the proposed
topping plant would not result in a measurable increase in ambient
air concentrations of particulate matter, hydrocarbons, carbon monoxide,
or nitrogen oxides in Fairbanks and should not significantly add to
the Fairbanks vehicle-related carbon monoxide emissions problem.
Water vapor emissions from the ECA and GVEA facilities were also
evaluated. Plumes from the GVEA turbines were anticipated to contri-
bute more than 80% of the total water vapor generated by the two
facilities, all of which was expected to rise well above the ground-
level inversions in which persistent ice fog forms. The remaining
vapor plume from the ECA facility was also expected to rise well
above the ice fog layer. The Department's calculations indicate
that the proposed ECA facility will not significantly add to the ice
fog conditions of downtown Fairbanks, although at times there will
be a visible fog plume in the vicinity of North Pole.
Noise Impacts
Ambient noise levels at the project site were analyzed by the
applicant. The data from these studies are included in the Appendix,
Exhibit 7. EPA has determined that the nearest major sensitive
receptor (a school) is at least 2500 feet from the source of noise.
EPA has estimated that Ldn=55 level will not be exceeded at the school.
For residences with outside space, the outside environmental noise
level of L(jn=55 was identified by EPA (Information on Levels of
Environmental Noise Requisite to Protect" Public Health and Welfare
with an Adequate Margin of Safety, March, 1974) as that level required
to protect against both hearing loss and activity interference with
an adequate margin of safety.
129b
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Secondary Air Quality Impacts - Mobile Sources
The primary air quality impact associated with the North Pole
topping plant will involve the emissions resulting from operation of
the plant itself. However, the effect of mobile sources cannot be
overlooked. The total project includes construction of a parking
facility for the use of employees and visitors who will drive auto-
mobiles to the site. Because vehicle emissions can significantly
affect air quality and since the topping plant can be expected to
attract increased traffic, the air quality impact of the mobile source
activity will be considered in this section of the EIS.
Correspondence with R.W. Beck and Associates, engineering con-
sultants for the project, has indicated that a parking lot of forty-
six spaces with heater outlets is presently planned to serve the needs
of the topping plant. At the present time, this will not be subject
to review under federal indirect-source regulations or Alaska's trans-
portation control plan regulations. The following two sections
summarize the current status of these regulations as they relate to
the proposed parking lot.
Current EPA Position Regarding Parking - Related Indirect Source
ReviewAs set forth in the July 3, 1975 Federal Register (40
FR 28064), EPA's indirect source review of parking-related facilities
has been indefinitely suspended. Consistent with EPA's belief that
indirect source regulations would be most effectively implemented at
the state or local level and in view of the consideration by Congress
of a possible amendment to the Clean Air Act requiring each state to
adopt and implement such a regulation in its State Implementation Plan
(SIP), EPA does not believe it is desirable to reinstate the parking-
related aspects of the federal indirect source review regulations at
this time. If Congress does not act within a reasonable period, EPA
may later reinstate these regulations in order to help insure the main-
tenance of air quality standards. In this event, the regulations
would apply only to facilities beginning construction six months after
reinstatement. State indirect source laws are not presently affected
by the suspension of federal regulations. In this event, the regulations
would apply only to facilities beginning construction six months after
reinstatement. State indirect source laws are not presently affected
by the suspension of federal regulations. Therefore, a federal indirect
source parking permit will not be required for construction of the topping
plant's parking facility.
Applicability of Alaska's TCP Parking Management Regulations:
Alaska's Transportaion Control Plan (TCP), as promulgated by EPA, in-
cludes a parking management provision for regulation for any new park-
ing lot construction or modification involving ten or more additional
parking spaces. At this time, implementation of the TCP's parking man-
agement regulation - 40 CFR 52.86, promulgated on November 27, 1973
130
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(38 FR 32659), and as amended on January 15, 1974 (39 FR 1849) - has
been stayed by the Ninth Circuit U.S. Court of Appeals until further
notice. Consequently, no permit will be required under this regula-
tion for construction of the facility's parking lot.
Methodology; The emission burden approach was chosen as the
type of air quality analysis to be conducted. We believe that rele-
vant conditions described below do not warrant a more complicated or
highly sophisticated analysis such as the use of a diffusion computer
model. In determining this, we considered the expected size of the
project, the immediate location, the applicability of pertinent regu-
lations, and the present air quality conditions. It is expected that
the topping plant will employ approximately forty-two people (twenty-
four daytime personnel and eighteen shift personnel) when it begins
operations and will attract about five visitors per day. This can be
considered a relatively low traffic generator. Also, its location near
North Pole does not place it in a large community. The existing air
quality conditions in this area, as described earlier in the EIS, in-
dicate that there are no serious problems at the present time. Consid-
ering all of these factors, the seriousness of any possible problem and
the according degree of resolution, along with the amount of data avail-
able and the additional time and expense involved with more complex
methods, the emission burden approach seems the most reasonable and
appropriate.
This emission burden analysis was conducted for carbon monoxide,
hydrocarbons and nitrogen oxides since these are the pollutants common-
ly associated with motor vehicles. The principal sources considered in
the analysis are the old Richardson Highway, the new Richardson High-
way and the parking lot itself. We looked at two cases, the "build"
and the "no build" alternatives, and two years, 1975 and 1977. Calen-
dar year 1975 was chosen to represent the construction phase of the
project and 1977 the operational phase or "opening year." Although
much construction will take place in 1976, the emission factors for
1975 are higher and since it is our intention to portray worst-case
conditions, it is appropriate to use 1975.
The topping plant environmental report (p. 3-17) prepared by R.W.
Beck and Associates for Energy Company of Alaska (ECA), discusses the
possibility of future expansion of the plant. It is conceivable that
the expanded refinery could be in operation as early as 1978 and this
would require additional employees, thus increasing mobile source
emissions in the area. We have decided not to include this potential
1978 situation in the analysis because it is not definite at this time
and also because any further expansion of the plant must also demon-
strate environmental acceptability. It would be much more advisable
to determine the impact of expansion at that time since better infor-
mation would be available for analysis, leading to a more accurate
representation of conditions and effects.
331
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Assumptions: The emission factors used to calculate the
emission burden were based upon the documented methodology found in
"Supplement No. 5 for Compilation of Air Pollutant Emission Factors."
There were several assumptions made in order to complete the calcu-
lations. The major assumptions are listed as follows:
1. Because of the cold climate found in the North Pole region,
emission factors were corrected for ambient temperatures of less than
or equal to 20° F.
2. Because of the cold ambient temperatures and operational
characteristics of the parking facility, cold start emission factors
for idle were used.
3. To be conservative and reflect the worst possible case, it
was assumed that everyone who works or visits the facility drives his
or her own car.
4. During the construction phase it was assumed that there were
no head-bolt heaters installed in the parking lot and that each car
would run and idle 30 minutes per day at the site.
5. Based upon data received from R.W. Beck and Associates, during
the operational phase, it was assumed that each car would run 15 minutes
a day and that there would be 18 shift people and 24 day people at the
facility each day.
6. It was assumed that the traffic volume on the nearby streets
would also increase as a function of vehicle trips or vehicles attracted
to the facility.
7. To calculate the emission burden in the area, three sources
of emissions were considered including one mile segments of both the
new and old Richardson Highways and the parking facility itself.
8. Since there was no speed data available it was assumed that
during late fall the combined average speed for both the old and new
Richardson Highways was 15 mph.
9. Since there was no available data on vehicle mix or age dis-
tribution, a nationwide vehicle mix was assumed.
Results: Once the emission factors idle and 15 mph were cal-
culated, they were applied to the average daily traffic and estimated
running time in the parking lot for the build and the no-build alter-
natives. The areawide results are summarized in Table 18. All emissions
are expressed in terms of Kilograms per day (kg/day).
132
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Table 18 Emission Burden - Mobile Sources
Year
Pollutant
No Build
(kg/day)
With Facility
(kg/day)
Increase
(kg/day)
Percent
Increase
1975
Construction
—
CO
560.8
924.5
363.7
64.9
HC
49.1
67.8
18.7
38.1
N0X
22.9
24.1
1.2
5.2
1977
—
Operational
—
—
CO
555.0
637.6
82.6
14.9
HC
47.1
51.4
4.3
9.1
N0X
24.3
24.8
0.5
2.1
Conclusion: Table 18 illustrates the resulting emission burden
levels for the construction phase and for the operational phase of the
topping plant. The highest levels will occur during the short-term con-
struction phase. Although the relative impact during the initial con-
struction appears large for CO and HC emissions, it is necessary to
look at this in terms of the relevant considerations. First of all,
these levels are only temporary, representing the expected peak emissions
for the period of construction. Secondly, the increase in emissions
is minor when compared to increases which could result from major sources.
And finally, since this area is undeveloped with very low traffic vol-
umes, the present air quality in the vicinity is good. Taking these
points into consideration, the impact of the parking facility will be
small and will not jeopardize the ambient air quality standards.
133
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Table 19 Number of Idling Cars Necessary to Produce Emissions
Equivalent to Expected Increased in Emissions
Increased Number of
Emissions Idling Cars
Pollutant (kg/day) per day*
Construction
Phase (1975)
CO
363.7
2.2
HC
18.7
2.3
N0X
1.2
9.5
Operational
Phase (1977)
CO
82.6
0.6
HC
4.3
0.6
NOx
0.5
4.4
* Based upon cold start idle emission factors.
Table 19 expresses the relative impact of mobile source activity
in terms of the number of cars idling twenty-four hours which would
produce emissions equivalent to the predicted increase per day due to
the traffic generated by the facility. As can be seen by this compar-
ison, the impact of the increased emissions is low, even during con-
struction. Since the existing air pollutant concentrations near the site
are very low (trace) as stated in the section entitled, "Existing Air
Quality", mobile sources will not result in air quality violations.
Mitigating measures could be quite effective in minimizing the
impact of the facility on peak hour traffic and vehicle miles of travel
near the facility. It is presently planned that work hours will be
staggered and approximately one half of the employees will have shift
jobs. These measures should lead to reduced peak hour traffic. It
should be recognized that carpooling represents a realistic possibility
and could decrease emissions considerably. Also, the heater outlets
which will be provided for parking spaces will reduce the amount of
time cars must idle in order to warm up.
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SOCIO-ECONOMIC IMPACTS
Demographics
The construction and operation of the topping plant will cause an
influx of employees and their families into the Fairbanks-North Pole
area. Some of these people will be directly employed by ECA and others
will be employed by supportive facilities and service industries neces-
sary to serve the additional people.
ECA and other contractors will employ approximately 60 permanent
employees for operation of the plant and up to 100 persons for con-
struction. Of the 60 permanent positions ECA expects that all but 5-10
positions will be filled by persons now living in Alaska. Most of the
construction personnel will be persons currently living in the Borough.
With the addition of a Hydrotreater and Reformer an additional 15-20
persons will be employed. The effect of 60-80 additional people and
their respective families, assuming that all now live outside the
Borough, on the existing population (approximately 63,350) of the FNSB
is not expected to be significant, especially in light of the recent
population changes in Fairbanks due to the pipeline construction.
However, if all the new employees decide to live in North Pole, the
relative impact of the additional people on the community (3,598 people)
will be much more significant.
In 1974 the population of North Pole was at 325. At that time the
City's population was projected to reach 1500 by the end of 1976.3£/
Growth in the City has not occurred as rapidly as predicted, however,
since several developers encountered obstacles which led to the delay
or cancellation of their projects. The most obvious constraining
factors have been (1) the City's inability to provide sewer and water
services to new residential developments, (2) the delays in industrial
development caused by complex permit procedures and mandatory impact
assessments, and (3) the general depressed state of the economy.
More recent (and conservative) population projections developed
by R. W. Pavitt and Associates®!/ for the North Pole Planning Area
are shown below:
Within
Outside
Year
City Limits
City Limits
Total
1976
562
3036
3598
1980
715
3862
4577
1985
828
4477
5305
These population projections take into account a number of new
or anticipated developments of which the proposed refinery is but one.
In light of the continued development of the Interior's petroleum and gas
resources, the new business/shopping mall and other planned developments,
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it is anticipated that growth in the North Pole will take place in
the presence or absence of the ECA topping plantV—/ The presence of
the refinery, however, will serve to significantly affect the magni-
tude and rate of growth if (1) the availability of cheaper fuels
stimulates further industrial (and light industrial) developments,
(2) the Fairbanks route for the natural gas pipeline project is
selected, and (3) the state of the economy is such that the develop-
ment of a petrochemical complex becomes feasible and is deemed desirable
by local officials.
The growth potential for the City of North Pole is high, and the
incentives are clear. Around North Pole there is much vacant land
suitable to accommodate development; there is good soil and water,7n/
and the Tanana-Chena levee provides virtual freedom from flooding.
The recreation opportunities expected to be provided by the Chena
River Lakes Flood Control Project (Alaska District, Corps of Engineers)
will further enhance North Pole's growth potential. Z/ The Corps
proposal to create a recreation lake and numerous trail systems is
expected to attract numerous visitors to the North Pole area and to
have substantial beneficial impacts on the City.
The Fairbanks North Star Borough is expected to grow from 63,350
(1975) to 69,870 by the year 1980. The table, "Estimated Population
for the Fairbanks North Star Borough 1975-1980," on the following
page shows anticipated conservative increases in the Borough popula-
tion due to the Alyeska pipeline and other related developments,
including the proposed refinery. The Fairbanks area is considered a
prime growth area, and it is evident that growth here is not dependent
on the proposed facility. The area is an important "jumping off
place" for people and materials enroute to the North Slope or bush
areas; it is strategically located at the confluence of several
transportation routes, both land and air; there is much land around
the cities of Fairbanks and North Pole that is available for expansion
and development, and the expansion of the area's economic base due to
the continued development of the Interior's energy sources has not yet
been fully realized.1!/ It is reasonable to expect, however, that if the
topping plant is constructed, it will greatly enhance the area's growth
potential. Whether or not the further development of the area is
desirable constitutes an issue which must be decided locally. EPA
recognizes that while urbanization and development may have beneficial
economic and social effects, these effects are often overshadowed by
serious social, economic and other environmental problems commonly
associated with such growth. Comprehensive solutions to these problems
must be provided by proper planning by local officials with the help
of the public.
135a
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ESTIMATED POPULATION FOR FAIRBANKS NORTH STAR BOROUGH 1975 - 1980
Includes civilian population, military and dependent population and anticipated
conservative increase in population due to pipeline impact.
19Z5
12Z6
1977
12ZS
mi
1980
Civilian Population
36,683
38,097
39 , 524
41,026
42,585
44,203
Wainwright Military & Dependents
7,833
7,833
7,833
7,833
7,833
7,833
Wainwright Military
3,486
3,486
3,486
3,486
3,486
3,486
Wainwright Dependents
4,347
4,347
4,347
4,347
4,347
4,347
25% Wainwright Military & Dependents
1,958
1,958
1,958
1,958
1,958
1,958
75% Wainwright Military & Dependents
5,875
5,875
5,875
5,875
5,875
5,875
Eielson AFB Military & Dependents
7,695
7,695
7,695
7,695
7,695
7,695
Eielson Military
2,732
2,732
2,732
2,732
2,732
2,732
Eielson Dependents
4,963
4,963
4,963
4,963
4,963
4,963
Murphy Dome Military & Dependents
100
100
100
100
100
100
Murphy Dome Military
100
100
100
100
100
100
Murphy Dome Dependents
0
0
0
0
0
0
Fairbanks Military & Dependents
39
39
39
39
39
39
Fairbanks Military
9
9
9
9
9
9
Fairbanks Dependents
30
30
30
30
30
30
Expected civilian impact on population
due to pipeline
11,000
10,000
10,000
10,000
10,000
10,000
Total Population Fairbanks North Star
Borough
63,350
63,744
65,191
66,693
68,252
69,870
Civilian including military dependents
57,023
57,417
58,864
60,366
61,925
63,543
Civilian excluding military dependents
47,683
48,077
49,524
51 ,026
52,585
54,203
Information obtained from Bill Rose, Research Analyst, Fairbanks North Star Borough Planning Department
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Employment
According to Its present schedule, ECA anticipates that site
preparation, grading, construction of buildings and fences, and
building of roads and railroad spurs will be completed in 1976.
During this time, ECA will employ 10 people and local contractors
will employ about 50 construction personnel. Up to 10 additional
people may be employed on the plant site at various times during
construction. In 1977, construction personnel will vary between 50
and 100, and permanent ECA employment will increase to approximately
60 people as the facilities are placed into operation. Of the 60
permanent positions, ECA expects all but 5-10 positions to be filled
by Alaska residents. A breakdown of personnel requirements is shown
in Table 20. Initial plant operation is anticipated for October of
1977.
Table 20
North Pole Topping Plant
Refinery and Marketing Personnel
Administrative and Technical 10
Operations and Laboratory 30
Maintenance 10
Secretarial and Clerical Support 1J3
Total 60
In addition to the personnel requirements noted above, it has been
estimated that for every 100 positions created at the topping plant,
75 additional jobs will be generated elsewhere in the community in
supportive facilities and service industries.^2/ This amounts to about
45 additional indirect employment opportunities when ECA reaches its
full employment figure. The topping plant is expected to be one of the
major sources of employment and payroll in the entire North Star Borough
and will be the first major industry to be located in North Pole. Its
operation will be uniform throughout the year, which is a favorable
consideration in an area with extreme seasonal employment variations.
Economic Base
One favorable impact of the topping plant on the local economy will
be the generation of additional tax revenues through the application of
property taxes to the assessed value of the plant. It is estimated
that the investment required to construct the plant will amount to
approximately $25 to $30 million and will represent slightly less than
one-tenth of the total current assessed value of the entire Fairbanks
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North Star Borough, The present tax rate for the Borough is 8.5
mills per dollar of assessed value. The tax rate for improvements
for the City of North Pole was 2 mills per dollar of assessed value;
however, since the passing of the proposition which repealed the
temporary charter tax limitation amendment in Ouly of 1975, the City
is expected to increase the tax rate on property, improvements and
sales, i/ This action should substantially increase the City's
total assessed value. Also, it is expected that once the plant is
in operation, it will generate an annual payroll of approximately
$1 million to $1.5 million. For further discussion see "Existing
Socio-Economic Environment."
While the generation of additional tax revenues is the most
significant economic benefit, other expected impacts include increased
payrolls, direct and indirect, increased real estate values (and
taxes) and a substantially expanded economic base. The presence of
the new facility (and the availability of cheaper fuels) may stimu-
late land prices and value as pressures to develop the area increase.
In this event, landowners, developers and speculators will be finan-
cially benefited by the further inducement of development. Spin-off
industries, by reducing the outflow of monies from the local economy,
will further increase the internal development potential of the
Borough. If such growth occurs without proper restraint, the costs
of growth will be borne by all residents of the Tanana Valley as
natural (water and air) and manmade (transportation, sewage,utility)
systems are overtaxed and pollution becomes the visible result.
At the present time, very little is known of the impacts various
kinds of growth and land uses have on local jurisdictions' tax base
and expenditures. In this period of fiscal consciousness, cost
revenue analyses provide part of the information essential to effec-
tive land-use decisionmaking by local government officials. In order
to decide how their land should be used and how much and what kinds
of development should be encouraged, officials must necessarily
understand the extent to which the added tax base would compensate
for the additional costs that would be incurred by their decisions.
It 1s,therefore, extremely important that planning be done early in
the City's development process. The emphasis again must be placed on
the effectiveness of the local land use plan as it will essentially
be the only identifiable growth and development policy statement
regarding the desired uses of lands within the North Pole area.
ECA indicates that a second economic Impact from the topping
plant should be expected to occur in the form of reduced prices of
petroleum products in the Fairbanks North Star Borough area. Since
there is presently no local refinery, all petroleum products must be
imported from either Anchorage or Seward, and, in some cases, from
the Tower 48 states. For the year 1972, transportation costs for
petroleum products being shipped from Anchorage to Fairbanks ranged
between 74 and 94 per gallon, not including distributor handling
costs. A saving of these transportation costs would result in a
reduction in the cost of products of approximately 5-94 per gallon.
137a
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According to the economic Impact study by Larry Smith and
Company, Incorporated,^2/ the net savings to the region will be
considerable If the cost of fuel was reduced by an average of
5tf per gallon. Table 21 shows the demand projections for certain
fuel products in the region and the potential savings that could
be achieved with a per gallon reduction. These figures represent
potential savings that could occur as a result of construction of the
topping plant and addition of a Hydrotreater and Reformer. Military
jet fuel and industrial turbine fuel are not included in these
estimates.
Table 21
Civilian Market Demand Levels
(In 1000's of gallons) and Potential Savings
1976
1978
1980
1985
Jet Fuel - Domestic
12,300
13,200
14,000
18,000
Aviation Gasoline
5,600
6,600
7,500
10,400
Highway Gasoline
26,500
28,700
30,900
37,200
Diesel/Heating Fuel
31,800
76,200
34,500
§3,0(56
37,000
89,400
43,800
109,400
Potential Savings
0 5
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Services And Facilities
Since the construction of the topping plant will occur during the
same time period as the Trans Alaska Pipeline construction, it is antici-
pated that the in-migration of people associated with the topping plant
will intensify demand on public services, facilities and utility systems.
The relative impacts during construction of these two projects are expected
to be proportional to the number of people employed for each project in
the Fairbanks North Star Borough area. Alyeska will have a peak employ-
ment of approximately 2400 people, compared to approximately 160 people
employed for the ECA project. (This 2.400 fiqure is for the Borough.
Alyeska's peak employment is approximately 20,000).
The demands of the 60 permanently employed ECA personnel and their
families on the services and facilities of Fairbanks and the Borough are
expected to be adequately met with minimal impact. However, if all 60
persons and their families decide to reside in North Pole, the impacts
on the City's existing facilities and services will be substantial.
Already officials in North Pole realize that the City's existing
sewer system and other "facilities could be severely overtaxed if growth
should occur as projected..3° at.!/ The building of the topping plant in
North Pole may serve as a stimulus to additional growth, thus, in the
long term, may be considered a major contributor to the overtaxing of
the City's services.
It is anticipated that capital and operating expenses for public
services in the City will increase beyond the City's capability during
the anticipated growth period, between 1976-1978. This projected deficit
was reflected in the City's application for discretionary impact funds
for 1975. Projected expenses resulting from growth impacts included
$72,000 for police protection, $88,485 for fire protection, $25,000 for
water and sewer operations, $64,692 for other public works activities,
and $17,359 for administrative services^!/. The application was ultimately
rejected by the State, resulting in a substantial loss of operating funds.
This loss, coupled with the City's small tax base, has greatly constrained
North Pole's efforts to become an economically viable city.
As previously discussed, the topping plant will help generate tax
revenue for the City of North Pole and the Fairbanks North Star Borough.
However, while the services for new employees and residents of the City
and Borough will be required immediately, additional revenues will not
be immediately received.
WateA. Supply and Seioage TAe.dtme.nt FacltCtitA! The City of" North
Pole has agreed to supply potable water and treatment for the refinery's
domestic waste. During operation about sixty employees will be served
during three shifts, creating a demand of 2 gallons per minute. The
direct impact of this demand will be minimal because it 1s relatively
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small. However, growth and development In the area, which may be
stimulated by the existence of the plant, will create additional
demands for waste treatment and water supply as well as fire pro-
tection services. (Water for refinery fire protection requirements
will be supplied from on site storage tanks and possibly from-
refinery wastewater effluent.)
As previously discussed (section on Existing Socio-Economic
Environment), the North Pole secondary sewage treatment plant has
not been operating properly, and numerous attempts have been made
to identify the cause {or causes) of the problem. Before the City
of North Pole can adequately serve any additional growth, the
problems must be resolved and the present system must be improved
to eventually provide additional collection lines and treatment
facilities. Under the proposed NPDES permit for ECA, no domestic
waste from the topping plant may be discharged through the North
Pole facility until the municipal treatment system is achieving
secondary treatment levels (see Water Quality Impacts section).
For industrial and public developments, treatment and water supply
plans for additional service or new facilities must be approved by the
Alaska Department of Environmental Conservation. In an area recently
annexed by the City, there is a major private development (Columbia
Mobile Home Park) now under construction which plans to provide its
own sewage treatment facilities, but with sufficient capacity 1n the
design so that it could serve future municipal needs, including
service to ECA's refinery. The expected population of Columbia
Mobile Home Park is about 1500, and the proposed two-cell aerated
lagoon system design would serve 3000 persons. Plans for this treat-
ment facility have been reviewed and approved by DEC. These plans
provide for additional suspended solids removal equipment (a dissolved
air flotation unit) to be available in case it is needed to achieve
secondary treatment standards.
The City of North Pole has formally expressed its intent to
acquire the Columbia Mobile Home Park treatment facility (when it is
in a financial position to do so) in a letter to the Borough and the
developers dated July 29, 1975. Final costs to the City have not yet
been determined. Because the intended location is on the ECA site,
the City has also discussed acquisition with ECA who has indicated
that a sub-lease is possible.
About three years ago, a new potable water supply and distribution
system was installed by the City consisting of a deep well, a storage
tank (0.1 million gallons), chlorlnation, a green sand pressure filter,
and constant pressure and circulating pumps. Although the present
well has sufficient capacity to supply domestic water for 4000 people,
fire protection requirements for additional growth will necessitate
improvements. For example, to meet demands of the Columbia Mobile
Home Park, a backup well, a pump, and additional storage tank capacity
for fire protection will be necessary. Reduction of high Iron
139
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concentrations in the existing water supply, which exceed the recom-
mended USPHS drinking water standards, may also be required and has
been recommended by EPA to possibly alleviate wastewater treatment
problems. However, the iron content does not present a health hazard.
Costs of improvements would be negotiated by the City with the
developer.
The City of North Pole must resolve the problems causing the
improper operation of the treatment plant before it can qualify for
complete payment of the EPA grant which was to- provide partial financing
for the new plant. Although future municipal treatment facilities couid
be partially funded by EPA and/or State grants, certain conditions must
be met for a project to be eligible. The Columbia Mobile Home Park is
privately financed.
Fire Protection: Fire protection will be required from the
City during plant construction. Additional requirements for fire pro-
tection from the City will be an indirect result of the growth and
development related to the industrial plant. The additional needs will
place greater demands on the volunteer fire fighting force and may
require the City to obtain additional equipment.
Special fire protection equipment will be required for safe plant
operation. ECA has indicated that this equipment will be available as
needed to the City of North Pole,
Police Protection: ECA will require police protection during
the construction period and during operation. Police protection require-
ments for an industrial plant are normally higher during the construction
period than when the plant is in operation. Police protection require-
ments for the entire North Pole area can be expected to increase as an
indirect result of the topping plant's effect on population growth.
Presently, the City has one Police Chief and no city-supported
police force. This situation presents several problems since the
force must necessarily be expanded to deal with the increased growth.
The lack of funds prevents expansion of the City's police force at this
time, thus ECA will probably have to consider the possibility of employ-
ing a private security force to provide the police protection needed
for the plant during construction.
The problem of providing adequate police protection villi have to
be dealt with as soon as possible since criminal violations within the
City limits have been on the increase. In 1.974, City officials reported
a 25 percent increase in drug abuse apprehensions, and a 25-30 percent
increase in general crime within the City limits.27/ There was also
a 10 percent increase in motor vehicle accidents and 15 percent in
traffic offenses.
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Schools: Borough officials predict that educational facilities
for the City and the Fairbanks North Star Borough will be inadequate in
the foreseeable future if the growth in the area occurs as projected.^!/
The education impacts of the Alyeska Pipeline and pipeline related
industries on the Borough School District will be severe. The School
District estimates that for 1977, 545 new classrooms will be neededW,
and additional State funding totaling $7.5 million in 1975 and $25
million between 1974 and 1980 will be needed.W
Since Fairbanks will receive most of the dependents during the
influx, it is expected that the Fairbanks schools will be more severely
impacted than the schools in North Pole. Most of the incoming school
children are expected to be young, hence lower grades (kindergarten
through sixth grade) will be most affected. For Fairbanks, the school
children influx is estimated as follows: 2,600 in 1976; 1 ,100 in 1977;
and 600 each in 1978, 1979, and 1980JZ/ While the education impact
of the topping plant will be minimal compared to the impacts of the
Alyeska Pipeline, any incremental increase in school children numbers
will add greatly to schools which are now operating above normal capacity.
Medical Services: There are presently no health care or ambulance
services in North Pole. The City's Chief-of-Police provides emergency
transportation service to the Fairbanks hospital as needed.
ECA will require an on-site ambulance for normal plant operation.
This ambulance service will be available for emergency use by community
residents.
'Housing: A demand for additional housing units in the North
Pole area and the Borough in general can be expected as a result of the
installation of the topping plant. Presently, housing in both Fairbanks
and North Pole is a scarce commodity.^/ Vacancy rate is persistently
low; turnover is slovr,26/ rents are high; and the demand continues to
exceed the supply. The housing situation is further aggravated by the
rising cost of building materials, severe topographic and climatic con-
straints,the traditional volatility of the Alaskan economy, and the
ralatively small number of financing institutions.42/
Recently, however, the number of new housing starts have begun to
Increase in both Fairbanks and Horth Pole. In July, 1975, it was reported
that lending institutions in Fairbanks financed 333 - 363 new housing
starts, including single family dwellings and 28 condominiums. Also
financing was made available for two 12-plexes, five 4-plexes and a 9 story
hotel.43/- This surge in new construction should help ease, but not
eliminate, the critical housing problem in Fairbanks.
The availability of housing in North Pole is also expected to increase
in the near future. (See discussion in Existing Socio-Economic Environ-
ment section). The $3.5 million Columbia Mobile Home Park project, which
will be located near the topping plant site, is expected, to accommodate
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over 1,QQD residents. The Borough Planning Commission recently (August
7, 1975) voted to approve the plan for the park pending approval of
its water treatment and supply systems by the State Department of
Environmental Conservation and the removal of some spaces over the
sewer outfall Tine.*!/ When completed, the park will provide 500
units with single or multiple bedrooms. The park 1s scheduled for
completion before the topping plant 1s completed and put into operation.
The future of the housing market and the housing impact of the
Pipeline and associated industries are difficult to predict at this
time; however, there are Indications that in the near future the demand
for housing will continue to exceed the supply. On April 28, 1975,
Golden Valley Electric Association announced a moratorium on new
electric heat installations.4!/ The effect of the moratorium on new
housing starts is yet not known, however financiers have indicated
that the moratorium has caused builders to change their construction
plans. They have also indicated that while this has not significantly
affected the number of single unit dwellings being constructed, it may
affect other types of buildings, such as large hotels. •=/
Recreation Fa&cUtl&n The influx of people associated with the
construction and operation of the topping plant, both directly and
indirectly, will intensify use of existing recreation areas in the
vicinity of North Pole and Fairbanks. The population increase will
intensify the shortage of informal park areas and recreational faci-
lities needed for organized sports."ȣ5/ The magnitude of the Impact
directly attributable to the refinery is expected to be minimal (60
employees and their families for the first phase and 20 additional
for the expansion).
Camping and picnic areas which will be impacted include the Chena
River Wayside (62 camping units, 30 picnicking units), the Harding
Lake Recreation Area (located 40-42 miles from Fairbanks, providing
89 camping units and 52 picnicking units), the Salcha River Picnic
Wayside (20 picnicking units), Growden Memorial Park (20 picnicking
units), and the North Pole City Park (2-3 picnic tables). These
facilities are expected to be used more frequently by visitors than
residents of the area, especially during the summer season.
While the influx of people associated with the topping plant will
contribute to the overtaxing of the community's presently limited recre-
ational facilities, the outlook for new recreational opportunities
appears favorable. A trail route 1s proposed to parallel the Corps
of Engineers levee which transects ECA's property on the southeast
corner. The trail will be used for hiking or bicycling 1n the summer
and for cross-country skiing in the winter. A 2.5 acre recreation area,
including a borrow-plt lake, picnic areas, volleyball facilities and
playground equipment, will.be constructed in conjunction with ttie
Columbia Mobile Home Park.4!' The Chena River State Recreation Area
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now being planned for development is expected to provide a signifi-
cant number of summer and winter recreational opportunities and is
expected to be used intensively. These new developments will provide
additional recreation areas and should help to minimize the overtaxing
of existing facilities.
Othvi F(LcilUiu>: It is not possible to accurately predict what
percentage of the EGA-related personnel and their families will reside
in North Pole, and what percentage will reside in other areas such as
Fairbanks. Fairbanks presently can provide more in the way of public
facilities and goods and services for the convenience of its inhabi-
tants. However, North Pole is becoming a more desirable location in
terms of providing convenient facilities: a new library has been
built here, the new shopping center and business mall will provide
local goods and services and a new Junior-Senior High School is near
completion.
One specific impact which is expected in the City as a result
of the population influx associated with the construction and oper-
ation of the topping plant concerns traffic circulation on existing
roads. The New Richardson Highway bypasses the primary activity
centers in and around North Pole, diverting heavy traffic and
Fairbanks-to-Eielson traffic away from town. The Old Richardson
Highway runs directly through town, alongside ECA's property and the
new Junior-Senior High School and is one block away from the proposed
shopping center-business mall site. These three major activity
centers will increase the amount of traffic on this arterial.
Traffic due to construction and permanent ECA personnel will be
substantial relative to the existing traffic flow, particularly at
peak traffic hours of the day. This traffic will necessarily affect
the in-town circulation patterns to some degree. Any additional
traffic, particularly truck traffic for the transport of ECA's
refined petroleum prouucts, would add further to the already pro-
jected impact on the city's traffic patterns. Truck traffic is
expected to be minimal, however, since most of the finished products
will be transported by rail. Rail shipments will affect traffic flow
in the city since shipments from the refinery will increase the
number of times street crossings are blocked. A new rail crossing
will be added on the Old Richardson Highway.
Increased use of existing roads will intensify the need for
increased maintenance and repair. There will also be an increase
in traffic hazards and noise levels.
Construction refuse and major items of solid waste will be
disposed of at the Fairbanks dump (presently being upgraded to a
sanitary landfill). Ash will be accumulated at the sludge incinerator
and used for landfill. The ash will amount to 43 pounds per month.
People associated with the topping plant will contribute to the pro-
jected increase in the volume of solid waste generated by the areafs
growing population. The incremental increase in solid waste per day is
expected to approximate 1900-2000 lbs/day, assuming a maximum of 80 employees
and their families of four generating 6 pounds of waste per day (each).
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Potential for Future Development
Comments EPA received on the draft EIS included concerns that
the building of the ECA topping plant might foster undesirable in-
dustrial growth in the area. Many people were concerned that ECA
might at some future date expand its operations to include the manu-
facture of petrochemical products and that such expansion might result
in more pollution and possible air emissions-related health hazards.
ECA has stated its intent to expand its facility to include a Hydro-
treater and Reformer, and the additional impact of these units have
been addressed. ECA has not stated any definite plans to expand its
facility to include the manufacture of petrochemical products,*
However, in order to be responsive to these concerns, EPA felt it
appropriate that some discussion of the probability of such future
expansion be included in this statement.
Almost all petrochemicals have their origins in feedstocks from
petroleum or natural gas. The economics of petrochemical Industry
development in Alaska are similar regardless of the source of these
feedstocks. Resource Planning Associates, in a report to the Federal
Power Commission,7!/ conducted a review of companies in the petro-
chemical industry to determine whether the availability of North
Slope natural gas in Alaska would attract them to the state. Most
companies indicated that the benefits of proximity to a raw material
feedstock supply would be outweighed by the disadvantages of expansive
construction and labor costs; high capital investment; the small local
Alaskan market and high transportation costs for distribution to major
markets, primarily those located on the eastern and southeastern coasts
of the United States.
ECA has expressed similar reasons why they are not considering
expansion to petrochemical products manufacture. Petroleum refinery
economics in Interior Alaska are most sensitive to transportation
costs. If the Interior's demand for petrochemicals were not great
enough to support a manufacturing facility of economical size (the
larger the size the lower the cost per unit of production) products
would have to be exported, and high transportation costs would make
such export economically unfeasible.
It is difficult to accurately predict the nature and extent to
which petroleum/natural gas-related industrial development will occur
in the future. It is reasonable to assume that the availability of
natural gas in Alaska and in the Fairbanks area will foster growth,
and that that attendant growth may lead to an increase in the Alaskan
* As defined by Ruggles®!/ and Gloyna and Malinafi/ "Petrochemicals"
mean compounds derived from petroleum or natural hydrocarbons which
are used in the chemical industry rather than being primary sources
of fuels or lubricants.
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market for petrochemical products. However, even with that increased
demand, petrochemical industry development in the Interior would not
be profitable unless the demand were coupled with the availability
of sufficient raw materials and lower construction, labor and trans-
portation costs.
Summary
Overall, the impact of the topping plant on the economies of
North Pole and the Borough is expected to be substantial and bene-
ficial. 4£/ It is important to emphasize, however, that the intro-
duction of this new industry, by itself and in conjunction with other
industries which may be drawn to the area in the future, may initiate
a course of development which could irreversibly alter the rural
residential character of North Pole, Just how the character of North
Pole will be changed can be best predicted by taking an in-depty look
at the experience of other non-metropolitan areas in the United States
which have independently sought to attract industry to their towns.
In a review of studies conducted between 1962 and 1972, of 178
different instances of industrial development in non-metropolitan
areas,46/ it was determined that the introduction of new industry
into a rural community usually brings about major changes in (1) popula-
tion, (2) economy, and (3) public attitude. While the observations
made in these studies do not allow us to accurately predict the future
of North Pole, they do provide valuable insight as to the types of changes
that can be expected in the community's structure. The experiences of
other towns allow us to identify the concerns that should be considered
and provide us with several answers to the critical question, "What effect
will industrial development have on the North Pole community?"
Hence, assuming that the North Pole situation parallels that of the
178 other instances, the following impacts on population and economics
can be expected:
(1) The populations of the community and the Borough will increase -
the largest percent increase will occur in North Pole.
(2) The stimulation of industrial development will not stop the
outflow of young people from the community to larger cities.
There will be instead an in-migration of people, 70 percent
of whom will probably be from outside the Borough.
(3) Associated with the population increase will be the emergence
of a wide commuter field. Carpooling, 1n all probability,
will not be a common means of transportation.
(4) The average income of adult residents will increase.
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(5) New jobs and expanded employment opportunities will be created.
However, most new jobs will probably require persons who are
at least "semi-skilled." Since very few unskilled workers
will be employed by the plants, the industry should have no
significant effect on unemployment rates. However, the job
opportunities created elsewhere, in supportive facilities
and service industries, may favorably affect unemployment
rates.
(6) Two groups, in particular, will benefit least from the new
developments: the elderly and female heads of households.
Neither group will benefit from new job opportunities; the
elderly cannot take advantage of new positions and the new
labor force will probably be predominantly male. The relative
status of both groups may deteriorate as other groups gain
income.
(7) The new industry will generate a process which is referred
to as a "multiplier effect," i.e. "growth in one facet of
the econoiny stimulates growth in other facets."46/ in other
words, it can be expected that the new industry will stimulate
the local econony.
(8) If most of the refinery employees live in Fairbanks and commute
to North Pole, there will be a "leakage"46/ of wages to
areas outside the North Pole community. If the leakage is
great, this could evolve into a critical problem. The City
of North Pole would be burdened with the problems of accom-
modating the needs of new industry without the means to do
so. The community may have to pay for the necessary public
services while, at the same time, wages are "leaking" to
other areas.W
Of the 178 instances studied it was found that in all -instances
more people expressed satisfaction with industrial development than
expressed dissatisfaction, and most residents expressed the desire for
more development. There was a slight trend, however, for residents to
feel less favorably toward industrial development after such development
occurred than before it took place.
There are a number of reasons why public attitudes change. One,
1n particular, is the influx of new people, bringing new ideas, values
and behavior patterns to the community. Whether good or bad, change
will inevitably occur as the community is compelled to adjust to the
new growth. Generally, changes in the developing communities brought
about a heightened sense of community satisfaction since development
often led to better facilities in the areas of health, education,
public services and roads. Thus, in view of the experiences of other
communities, it is reasonable to expect that change in public attitude
will occur in North Pole. While this change is expected to be largely
favorable, the degree and extent of this change is yet unknown.
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In conclusion, the consequences of industrial development in North
Pole will be both positive and negative. Haphazard economic growth can
have extremely adverse impacts on the community, however careful planning
can result in favorable social and economic changes.z®/ A significant
conclusion of the study of the aforementioned instances was that while
industrial development was certainly not a panacea for the problems of
small towns, it did provide numerous benefits which formed a solid basis
for their general prosperity. It is appropriate to emphasize, however,
that such prosperity will depend on proper planning on the part of the
City of North Pole and the Borough.
Although information on the experience of small towns (population
less than 500 or 1,000) undergoing development is quite limited, there
are numerous studies on changes in the quality of living in large cities
(10,000 or more). Statistics^/ show that the quality of life can be
severely diminished when cities of several thousands grow into cities of
hundreds of thousands. Statistics generally indicate that as population
increases (generally from 10,000 to 1,000,000), the tax burden per capita
increases, total expenditure by local government increases, outstanding
debts by government increases, cost of services and welfare increases,
pavement area and population density increase, major crime rates increase,
and quiet open space areas decrease. These factors collectively contribute
to a decrease in the quality of life for city residents.
While the anticipated growth experience of the City of North Pole
cannot be equated with that of the larger cities in the U.S., simply
because of the difference in magnitudes, it is not unreasonable to
expect that North Pole will undergo similar experiences, however to a
lesser degree. It is, therefore, extremely important that City officials
and residents plan a well thought-out course of development which will
ensure that the quality of life they desire is achieved and preserved.
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LAND USE IMPACTS
The most significant land use impact will be the conversion of the
refinery site from undeveloped woodland to an industrial site. The
commitment of this land area to heavy industrial use will make it un-
available for other uses. Since this small area, zoned for heavy
industrial use, is presently surrounded by land zoned for less intensive
uses, such a commitment may give rise to conflicts between incompatible
uses. To avoid such land use conflicts, lands immediately adjacent to
the site will probably be rezoned for more intensive uses in the future.
A primary objective in the utilization of the site is to isolate
the refinery from its immediate surroundings by retaining a maximum of
natural vegetation as a green belt around the perimeter of the site.
While this will tend to minimize noise and aesthetic impacts, portions
of the refinery facilities will be visible from several vantage points.
In terms of land available for development, the potential for
additional facilities is substantial since the ECA and GVEA facilities
will occupy only forty acres of the 421 acre site. Also, areas south
and southeast of the site can be rezoned to accommodate industrial
development if the City and Borough planning bodies determine that
such action is appropriate or desirable.
Presently, the major thrust of existing land use and development
pressures in the Fairbanks - North Pole area is provided by nonrenewable
resource developments on the North Slope and elsewhere in the Interior.
The area is an important inception point for people and materials enroute
to the North Slope and is strategically located at the confluence of
several land and air transportation routes. These factors and the
flood protection provided by the recent Corps project all contribute to
the high growth potential of the area.
Relative to these on-going developments and other socio-economic
influences, the impact of the refinery on land use patterns in the
Borough is expected to be minimal. However, the total refinery influence
on land use patterns in North Pole is expected to be significant. The
presence of the refinery may stimulate, 1n the long term, the emplace-
ment of commercial development on major roads in the vicinity of the
project site and on currently vacant land near the city center. The
degree to which the refinery will Influence the City's land use pattern
1s yet uncertain since this Influence will be tempered by the effective-
ness of local planning decisions and locally adopted growth policies.
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HISTORIC AND ARCHAEOLOGICAL SITES
In keeping with the EPA policy of identifying and preserving
historic and archaeological resources which could be impacted by EPA
permitted projects, the procedures for assessing the impact of the
proposed topping plant have been followed. The National Historic
Preservation Act of 1966 requires the Federal agency involved to
ascertain whether the proposed undertaking will impact any property
listed on the National Register of Historic Places or any property
eligible for listing on the Register. EPA's finding that there is no
National Register site in the proposed project area has been confirmed
by the Alaska State Historic Preservation Officer.4!/ Although there
is no known historic or archaeological site in the area eligible for
inclusion in the Register, completion of the applicant's and the
Agency's responsibility under the National Historic Preservation Act
and under Executive Order 11593 requires performance, by a professional
archaeologist, of a preliminary survey of the project's area of primary
impact. The area of primary impact is defined as the area where ground
will be disturbed during construction or the area in which the facility
will have direct visual or olfactory effects if the area contains
property the cultural value of which would be impacted by such impacts.
Dr. John Cook, research archaeologist, Institute of Arctic Biology,
Fairbanks, Alaska, has conducted archaeological investigations on
portions of Section 16 and has made the determination that a surface
survey for the entire section would not be productive. Dr. Cook
recommended, however, that a qualified archaeologist be present during
ground stripping in the event that archaeological resources are un-
earthed in the project's primary impact area. ECA will retain Dr.
Cook's services during stripping operations.
The results of the subsurface survey will be reported to EPA and
to the State Historic Preservation Officer (SHPO). If the subsurface
survey indicates a strong probability that an archaeological site
exists in the primary impact area, additional arahaeological investi-
gations will be performed only to the extent that EPA and the SHPO
agree is reasonable based on the degree of probability of discovery
of an archaeological site. If the survey or additional investigation
identified cultural resources, or if significant resources are dis-
covered during construction, EPA and the applicant will consult with
the SHPO, and the Advisory Council on Historic Preservation if necessary,
to determine the site's eligibility for inclusion on the National
Register and to determine the project's impact on the cultural resource.
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FUQRA AND FAUMA IMPACTS
Wildlife Impacts
If ECA's request for a new source discharge permit is approved
and the topping plant at North Pole is constructed as planned, primary
and secondary impacts on wildlife can be expected. The direct and
indirect impacts of the project on waterfowl, fur-bearers, and large
mammals are difficult to quantify or predict since much of the area
near the site has already been subject to human disturbance. Influ-
ential factors such as increasing urban development in the Fairbanks-
North Pole area, the recently constructed flood control levee (which
transects the southwest corner of the site), the Chena River Lakes
flood control project, and the on-going construction of GVEA's power
generating facility on the ECA site have collectively contributed to
the decreased suitability of the area for wildlife.
Species of small mammals, such as shrews, rats, porcupines, voles,
and muskrat presently found on the site would be displaced or signi-
ficantly reduced because construction of the facility will result in
removal of vegetation and the subsequent disturbance and loss of animal
habitat. While many small mammals are expected to continue to occupy
timbered areas on the site, those presently occupying the 40 acres that
will be committed to the process area and tank farm will be lost or
displaced. Those displaced will be forced to compete for comparable
habitat which may exist In the surrounding area. The competition for
food and cover and other environmental stresses, such as Increased
predator pressure, may collectively contribute to substantial reductions
in the populations of small mammals in the area.
The vicinity of the topping plant site is not considered as
winter range for moose (Alces alces); however, moose have been observed
in the area during summer montHs! It can be expected that moose and
other large mammals, such as black bear (Ursus americanush will not
frequent the project site area due to increased levels of human
activity and disturbance, but this disturbance and increase 1n acti-
vity cannot be solely attributed to the construction of the topping
plant.
As numbers of people increase, so do the opportunities for human-
wildlife interaction. In Alaska, the biological productivity of certain
species have been steadily declining as more and more people place new
pressures on wildlife habitat. The moose population in particular has
been clearly affected by such factors as the encroachment of urban areas
on pristine areas, recreational and subsistence hunting, and sightseeing.
In 1963, 32,412 hunters harvested 8,860 moose. In 1973, 53,482 hunters
killed only 7,482 moose despite the advantages of (and perhaps as a
result of) more machines, more access and probably more t1me.®Z/
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The incremental increase in people (60 as proposed and an addi-
tional 20 persons with the addition of a Hydrotreater and Reformer)
associated with the topping plant is not expected to be significant.
Howver, the increase in population associated with growth attribu-
table to the availability of cheaper fuels can have significant
impacts on woldlife habitat in the long term, particularly in the
absence of proper planning by wildlife managers, recreation, trans-
portation and communicy planners.
If the topping plant is constructed and if it should serve as
a catalyst for additional industrial development, impacts on terres-
trial wildlife would be intensified. The exact degree of environ-
mental degradation associated with increased industrialization cannot
be determined at the present time since this is largely dependent on
the incremental nature of growth, the ability of the community to
accommodate such growth (i.e. the ability to treat domestic wastes
prior to discharge), and the desired growth policy of the City of
North Pole and the Borough.
Fisheries Impacts
Construction of the outfall to the Tanana and of the tie pipe-
lines across the Chena Slough as well as discharge of treated effluent
to the Tanana River are not expected to have significant adverse
impacts on the fisheries resource of the affected waters. Short-term,
reversible impacts from construction of the outfall and the pipeline
would be increases in turbidity and sediment load. Such increases in
the Tanana River would be insignificant during the summer, when the
river carries a heavy silt load; winter construction of the outfall
is unlikely. Because arctic grayling spawn in the Chena Slough,
sediment increases could be detrimental. The Alaska Department of
Fish and Game may restrict construction during critical seasons to
minimize potential impacts and may require methods to reduce erosion
before issuing permits for construction. Permit conditions would pro-
tect the fisheries resource.
If spills of oil from any of the pipelines crossing the slough
occurred, the severity of the impacts would depend on the quantity
and quality of oil, the time of year, and the effectiveness of spill
recovery methods. Construction methods are expected to minimize spill
potential (see page 154). Oil spills could have adverse impacts from
physical effects such as coating of fish, food or organisms, and habitat,
as well as from chemical toxic effects.
Discharges of treated effluent are not expected to have signifi-
cant adverse Impacts on the biota of the Tanana River. Water quality
standards must necessarily be met outside the mixing zone.
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According to the Alaska water quality standards, oil and grease
shall be at or below levels which will make the receiving water unfit
or unsafe for all uses. For fish migration, very low levels of oil and
grease may alter behavior and could prove detrimental. Current labora-
tory studies by National Marine Fisheries using pink salmon in fresh
water may provide insight for the salmonid species of the Tanana River.
Previous laboratory studies in marine water for the pink salmon found
that fish can detect, and under certain conditions will avoid oil and
grease. To protect the migratory route of pink salmon, at Valdez the
following criteria were established for a mixing zone: 0.10 mg/1 at
the sides and 0.05 mg/1 at the top and bottom.
Although it is unknown whether the species of the Tanana River
(Arctic grayling, chum, silver and king salmon) may be less or more
sensitive than pink salmon in marine water, EPA considers It advisable
to evaluate the proposed permit limitations for ECA's discharge of oil
and grease using 0.10 mg/1 as the receiving water quality criterion at
this time.
The estimated threshold level of phenols that can cause tainting
of fish flesh is about 0.02 to 0.15 mg/1 for a polluted river, accord-
ing to an NAS report.3J7 Concentrations of phenolic compounds 1n
excess of 0.1 mg/1 are considered unacceptable for aquatic life and
concentrations less than 1/20 of the 96-hour LC50 for- the most sensi-
tive organism are recommended in EPA's Proposed Water Quality Criteria?i/
{Phenolics appear to affect the taste of fish at levels that do not
seem to adversely affect fish physiology.) ¦=/ EPA's proposed cri-
teria for raw water for drinking supplies is 0.001 mg/1, which is
the same as the USPHS 1962 drinking water standard. On the basis of
the strict limitations then, we expect that tainting of fish flesh
will not occur. The most sensitive aquatic species are not expected to
be adversely affected outside of the defined mixing zone.
No significant temperature effects on the Tanana biota are expected
due to the small quantity of the effluent and the inherent constraint
on effluent temperature. Based on an estimated dilution of 590 to 1,
the increased river temperature a few hundred feet downstream would be
less than 0.05°F. Although some fish are attracted and some repelled
by warmer waters, such effects are not expected due to the extremely
small temperature increments after rapid mixing. See also discussion
on pages 98 and 98a and on the "Action" alternative.
Vegetation Impacts
The primary Impact of the construction of the topping plant on
vegetation will be the elimination of 40 acres of vegetative cover.
The vegetation which will be eliminated will include those species
which characterize bog-type communities; such as stunted, non-commercial
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tree species (dwarf birch and black spruce) and numerous shrubs. The
species found on the site are common throughout much of the lowland
areas in the Alaska Interior; therefore, the probability is low that
these species will be totally lost from the lowlands due to these
localized habitat changes. None of the species affected are classi-
fied by the U. S. Fish and Wildlife Service as threatened or endangered.
Although much of the Fairbanks - North Pole area is still heavily
vegetated, the possibility exists that the forested character of the
area will be lost as suburban, urban and industrial areas expand. The
Impacts on vegetation will be minimized by ECA's plans to restrict
clearing. A "greenway" will be maintained between the Corps of En-
gineers flood control levee and the Tanana River, and along the north
and east sides of the site. In addition to this greenway, ECA plans
to restore some of the lost vegetation by replanting and reseeding
of the site. EPA has recommended that ECA use the Soil Conservation
Service publication, "A Vegetative Guide for Alaska" in planning this
site restoration. The natural vegetation should help minimize visual
aesthetic and noise impacts.
AESTHETIC IfPACTS
The visual impact of the topping plant itself will be minimal,
with only the stacks and distillation towers being visible from a
distance. It is presently planned that the stack for the plant will
be between 150 and 200 feet high and 5 feet in diameter. It will emit
a water vapor plume which will be invisible, for the most part, during
the summer. Colder temperatures, however, will cause the vapor plume
to condense, forming a visible plume. This plume should rise in a
transparent state to some point above the stack where the vapor plume
condenses and the plume will then be visible from all directions. The
location of the air coolers adjacent to the plant stack is expected to
reduce the condensation and, therefore, the visibility of this plume.
An elevated flare will be required at the plant. This flare will
have a continuous pilot flame during normal operation. The flare stack
will be approximately 2 feet in diameter and 200 feet high. During
upset conditions, the flare is designed to release petroleum vapors
at a rate of 100,000 pounds per hour for a 3-minute interval. These
vapors will be ignited by the pilot flame at the top of the flare stack.
ECA estimates that these upset conditions could occur 1 to 3 times per
year.
In keeping with environmental considerations that will be used in
the plant design, much of the site will be left in its natural state.
The total site contains about 420 acres. It is planned that approxi-
mately forth acres will be occupied by the refinery. The remaining
380 acres will be mlntained in a natural state.
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CONSTRUCTION IMPACTS
Permafrost
Permafrost can be destroyed in several ways such as by the removal
of vegetation from a land area or by the installation of heated struc-
tures.
Since the topping plant is located in a region of discontinuous
permafrost, several detailed soil surveys must be conducted prior to
construction. As discussed on page 28, two soil exploration studies
have already been conducted on site. Further studies will be conducted
on the construction site and along the route of the proposed tie-in
lines. The ECA and GVEA facilities will be located in an area where
soil conditions are best suited for construction and where permafrost
is largely absent. Comments from the Soil Conservation Service in
Anchorage (December 1, 1975) indicate that the findings of the subsur-
face investigations are typical of the area. The SCS confirms that
(1) permafrost will, in all probability, disappear after clearing,
without soil subsidence; (2) the area is flat, has high permeability,
and is of low erosion hazard; and (3) the site is highly suitable for
the purpose proposed.
In those areas where continuous permafrost 1s found to exist, there
are two basic engineering approaches that will be used to prevent thaw-
ing problems. The first approach is to design the facility in a manner
that preserves the permafrost. The second technique 1s to allow the
permafrost to thaw, and then recondition the soil materials to provide
a suitable base for. foundations. In this area of discontinuous perma-
frost, thermal erosion or thermal melting (which results from the
exposure of ice-rich soil to solar radiation and running water) or frost
heaving will not be significant problems. The Impact of construction
of the facility on permafrost will be insignificant.
Erosion
The Soil Conservation Service (Anchorage) confirms that erosion
potential on the site is low. However, clearing for construction will
increase erosion potential on the site until cover vegetation is pro-
vided. ECA will minimize site clearing in order to preserve as much
of the existing vegetation as possible and will revegetate cleared
areas with native plant species.
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Water
The Tanana-Chena levee and the Old Richardson Highway block
drainage from ECA's property to the Tanana River and Badger Slough,
respectively, so that runoff is not expected to be a problem. Some
means of drainage will be provided to ensure that the site will
accommodate construction; however, all runoff resulting from this
activity will be contained on site in holding ponds.
Air
The creation of fugitive dust is a potential problem during con-
struction due to excavation and traffic over construction roads. This
increase in particulate matter may cause an increase in short-term
particulate matter concentration values, the magnitude of which will
be difficult to ascertain. The impact of fugitive dust is expected
to be minimal since there are no permanent residences in the immediate
vicinity of the site and the sprinkling of work areas is expected to
effectively minimize dust potential except under extreme wind conditions.
Solid Waste
Construction debris disposal will be controlled by each contractor
and monitored by ECA. The Fairbanks North Star Borough Environmental
Services Department has indicated that the South Cushman land fill site
would be the better of the two Borough land fills to handle the waste
generated during construction.
Noise
Noise resulting from construction and the movement of machinery
is expected to be heard beyond the boundaries of the site; however,
noise levels are not expected to be of the magnitude and duration that
will be detrimental to public health and welfare. EPA, in a publication
Public Healtlh^a nd^We 1 far e^witan"Adequate^Ma ^*974)
Identified Lh^ a 55 as that level required to protect against hearing
loss and activity interference. Since there are no permanent residences
in the immediate vicinity of the construction site, significant noise
impacts on residential, hospital or educational establishments are not
expected.
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MITIGATING fEASURES
The overall design philosophy of the topping plant will include
(1) the utilization of extensive design and operational measures to
reduce and/or recycle emissions, (2) numerous control devices to
minimize emissions and (3) the most advanced processing technology
which is advantageous from the standpoint of safety and low emissions.
Immediately after startup ECA will institute a vigorous monitoring
program under EPA and DEC supervision. ECA will monitor its wastewater
effluent as specified in the NPDES Permit (Exhibit 5) and will be subject
to inspection by EPA. If necessary, additional compliance measures will
be selected to reduce ambient concentrations in certain areas or to
maintain standards within acceptable limits. This could involve relocating
the discharge structure (such as to another channel).
ECA will monitor for N0X and SO? one year before startup and will
monitor on a continuous basis following startup. ECA is currently in-
vestigating the possibility of establishing a joint monitoring program
with the Borough. Since both ECA and the Borough plan to monitor ambient
air at North Pole a program of this nature will eliminate duplication of
effort and the expenditure of excess funds. The Air Quality Control
Permit to Operate to be obtained from the Alaska Department of Environ-
mental Conservation will specify operating conditions and monitoring,
requirements.
Site IfriuzATiON
The ECA site will be utilized in a manner in which environmental
impacts will be minimized. Equipment which inherently generate sound
will be located near the center of the facility area to reduce sound
levels at adjacent properties. Tall pieces of equipment will be centrally
located to reduce their visibility from surrounding areas. Approximately
380 acres of the site will remain in undisturbed vegetation, providing a
"greenbelt" around the refinery. The vegetation will create a buffer
zone which will minimize noise and aesthetic impacts.
Modular Construction
Modular techniques will be used to construct the topping plant.
The majority of structures and equipment will be prefabricated and
brought to the site in finished form to be placed and secured on
foundations. This method will reduce the number of construction
personnel required and can, therefore, be expected to minimize the
disruptive effects of construction on surrounding areas (Including
traffic, noise, dust, etc.) compared to alternative methods. In addition,
modular construction techniques will result in a shorter construction
period.
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Seismic Activity
Since the topping plant win be located in Seismic Probability Zone
3 (experiencing earthquakes that can cause major structural damage)
design criteria will be employed to insure against strctural and other
damage to the facility and pipelines. There is no active fault in the
immediate vicinity of the site.
Storage Facilities
Blending and product storage tanks containing petroleum fractions
with true vapor pressures greater than 1.5 psia at storage temperatures
will be equipped with floating roofs. These roofs will help minimize
hydrocarbon emissions. To prevent occurrence of vapor pressures in
excess of 11.1 psia petroleum liquid storage temperatures will be maintained.
Tank contents and vapor pressure at storage temperature will be kept on
record.
Air Coolers
Because of the concern in the Fairbanks area over ice fog formation,
the topping plant will employ air coolers to handle all process cooling
requirements. These air coolers, sometimes referred to as "dry towers",
operate in much the same manner as automobile radiators, transferring
eat directly to the air by utilizing finned-tube heat exchange surfaces,
ir flow is provided by motor driven fans. In addition to the lack of
evaporative heat transfer which is basic to wet cooling tower operation,
and can possibly result in ice fog formation, the air coolers are expected
to have the added benefit of enhancing the plume rise of the topping plant
stack, according to formulas developed by Brlggs.lZ/ This plume enhancement
is proportional to the relative buoyancy of the coolers to the stack
itself. Heat release by the air coolers will amount to approximately 110
million Btu per hour. All unit processes will be covered or enclosed to
prevent generation of ice fog during winter operation.
Odor
Odor emissions will be minimized by proper maintenance practices.
Regular equipment inspection and adequate maintenance will keep mal-
odorous leaks to a minimum. However, primary methods of odor reduction
will involve the control of gaseous emissions and the proper treatment
of wastewater discharges.
While wastewater discharges from large refineries are common odor
sources due to the presence of phenols, sulfides or ammonia, odor from
ECA's wastewater discharge is expected to be minimal due to relatively
small size of the refinery and lack of cracking facilities. Effluent
wastewater will comply with Federal and State regulations for these con-
taminants. Odors caused by hydrocarbons and hydrogen sulfide emissions
from the stack will not be significant. However, odors resulting from
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increased traffic, especially under severe winter and inversion conditions,
can be significant.
Oil Spill Prevention
A major possible source of oil spills at the topping plant will be
blending and product-storage tanks. A system of berms will be installed
around the tankage to contain spills resulting from accidents and
natural catastrophies. There will be no opportunity for an oil spill
occurring within the plant area to reach the Tanana River because of the
barrier created by the Tanana-Chena levee and the berm system.
Other areas of the plant where minor spills could occur will be
protected by proper maintenance, monitoring techniques and suitable
drainage-collection facilities. A compacted soil layer (with soil
sealants) will be used where the possibility of leaching into the groundwater
supply exists. Compacted earthfill and berms to retain oil will be
provided in the tank storage area. These measures will minimize the possi-
bility of long-term impacts on groundwater quality. See also discussion
on page 96.
Other potential sources of spills are the crude oil supply and re-
constituted oil return pipelines between ECA's site and the Trans Alaska
Pipeline. Proper engineering design (including shut off valves at either
end of the transfer pipelines) taking into account possible corrosion,
permafrost and seismic problems, will minimize this possibility. It is
expected that these pipelines will result in less potential for oil spills
than would alternative rail or truck transport. It is noted that some
external corrosion problems have been experienced with the existing buried
military pipeline. No failures are known to have occurred as a result of
permafrost or seismic problems.
An oil spill prevention and countemeasure plan will be prepared 1n
accordance with EPA Guidelines (Federal Register, 38 (237): December 11,
1973). Spill Prevention Control and Countermeasure (SPCC) plans must be
prepared within six months after commencement of operations and shall be
fully implemented as soon as possible but not later than one year after
operations begin {40 CFR Part 112.3 (b)). A registered professional
engineer must review and certify the SPCC plan before it is considered to
be implemented or effective.
The foregoing requirements apply to non-transportation related facili-
ties (such as the refinery) but would not apply to the supply and return
lines transporting oil between the refinery and the Trans-Alaska pipeline.
(Under the Memorandum of Understanding, with the Department of Transportation
(40 CFR, Part 112, Appendix 2,A)t the crude oil supply and return tie lines
would be classified as a transportation-related facility and would not be
subject to SPCC plan requirements). Although financed by ECA, the tie
lines will be designed by Alyeska as a branch line to the main system, using
the same design standards for spill prevention measures. Present planning,
calls for operation and maintenance by Alyeska Pipeline Service Company.—
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Emi ss i otj/Effujhnt Controls
As previously indicated, the primary fuel for the North Pole facility
will be the combination of approximately 70% distilled products and 30%
propane/butane. The fuel will be used for the crude oil charge and
vacuum tower feed heaters, and as supplementary fuel for the steam
supply package boiler. Analyses indicate that the anticipated levels of
particulates and SO2 will be far below Federal and State standards and
CO, HC, and HpS levels will be negligible. No control measures are
necessary to limit SO2 and particulates, however ECA will burn "cleaner"
fuels (NO2 fuel oil or/and topping plant off-gas) as such is available
or under severe atmospheric conditions. Maintenance of proper excess air
ratio in combustion processes will control carbon monoxide antl hydrocarbon
emissions. Hydrocarbon emissions from storage and process equipment will
be less than 1000 lbs/day based on the use of floating roof tanks.
ECA will be required, through the Alaska Department of Environmental
Conservation (ADEC) permit process, to monitor for changes in ambient
air quality.
Dry cooling used by ECA will eliminate the need to dispose of large
volumes of cooling water which is typical of many refineries. Oil and grease,
phenols, and sulfides in the process effluent will be reduced by in-plant
controls and tertiary treatment as necessary to meet stringent limits
based on meeting Alaska State Water Quality Standards with 200:1 dilution.
Other constituents of the discharge would also be reduced to below levels
established as New Source Performance Standards. ECA will be required to
monitor the effluent routinely and perform dye dilution studies of the
Tanana River during months of low winter flows to determine that
adequate dilution will occur. If necessary, discharge will be temporarily
curtailed or eliminated to insure that 200:1 dilution is achieved. No
discharge of runoff from process and non-process areas will occur during
low winter flow conditions. Runoff will be segregated and monitored
prior to discharge (or treatment, if monitoring so indicates).
ECA will assure that secondary treatment for domestic wastes of the
topping plant is attained prior to discharge to the Tanana. Otherwise, such
waste must be totally contained.
Proper operation and maintenance of ECA's process operations, collection
wastewater treatment systems should control effluent discharges to levels
required in the proposed permit.
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CHAPTER 6
UNAVOIDABLE
ADVERSE
ENVIRONMENTAL
EFFECTS
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ADVERSE IMPACTS WHICH CANNOT BE AVOIDED
SHOULD THE PROPOSED ACTION BE IMPLEMENTED
If the Environmental Protection Agency approves ECA's application
for a new source NPDES discharge permit and if the permit is certified
by the State, Energy Company of Alaska will begin construction of its
proposed topping plant. EPA's permitting action will therefore lead
to impacts associated with the construction and operation of the topping
plant.
Adverse impacts which cannot be avoided during the construction
of the topping plant consist primarily of the disruption of the existing
plant, soil, and animal communities on the site. The existing terres-
trial ecosystems will be lost on the 40 acres which will be committed
to processing facilities and the tank farm, and the decreased suit-
ability of the site as wildlife habitat will result in a decrease in
the quantity and diversity of birds and small mammals. Pre-existing
natural conditions cannot be recreated, but site restoration efforts
will improve the aesthetics of the site. As a result of information
provided by the Soil Conservation Service, EPA has recommended that
Energy Company use the SCS publication, "A Vegetative Guide for Alaska"
in planning the restoration of the site. The guide provides information
on classification of soils and proper seed selection, seedbed preparation,
and fertilizing.
Temporary adverse impacts which cannot be avoided during the cons-
struction of the facility include Increased noise levels, temporary
disruption of traffic on the Old Richardson Highway and streets in the
North Pole area, and Increased particulate matter 1n the vicinity of
the site due to dust created by movement of vehicles. This increase
in particulate matter may result in temporary violations of ambient
air quality standards for particulates.
The topping plant will have a long-term Impact upon land resources
in the area, for the very presence of the plant will influence decision
makers in the land use planning process. The existence of this refining
industry may encourage industrial and commercial growth on undeveloped
areas and may intensify development on currently developed areas. While
this accelerated growth may greatly enhance the local and regional
economy, such growth will present problems normally associated with
urbanization and industrialization. These include an increase in popu-
lation, noise, air pollution (primarily from mobile sources), 1ce fog
generation (especially during winter and extreme Inversion conditions),
congestion, ecosystem destruction and disturbance, and a plethora of
social problems related to urbanization. The extent to which this will
occur depends on the rate of growth and the effectiveness of planning
efforts. Also, it is significant to note that compared to the Impacts
created by the construction of the Alyeska Pipeline, the impact of the
topping plant is relatively insignificant.
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The proposed phase of the topping plant is not expected to directly
sacrifice to any significant extent arty of the goals of the National
Environmental Policy Act as stated in Section 101(b), Indirectly,
hwoever, if the proposed project acts as a catalyst to growth and if
this growth occurs in an unplanned manner, some of these goals may be
sacrificed. While haphazard economic growth can have extreme adverse
impacts on the North Pole community, careful planning can result in
favorable social and economic changes,
o In summary, the unavoidable impacts of the project are:
0 the removal of natural vegetation from about 40 acres of the site
and the subsequent reduction 1n ecosystem diversity,
° a reduction in the suitability of habitat for small and large
mammals and resident and migratory birds by the removal of
vegetative cover and the enhancement of human activity and
disturbances,
° an increase in noise levels 1n the vicinity of the facility during
construction due to increased traffic flow, the movement of con-
struction equipment, and construction activity (any incremental
increase in noise levels could result in complaints from residents
near the site),
0 an increase in concentrations of certain pollutants in the ambient
air due to increased vehicular traffic (during construction, dust
will be generated by movement of vehicles over unpaved surfaces
and excavation activity),
° the commitment of the site to heavy industrial use,
0 visual Impacts of the tank farm and process area (visibility of
different parts of the facility can create negative reactions and
may be regarded as unaesthetic),
0 greater demands on the housing market which is already greatly
strained and additional demands on public services and facilities,
° a decrease 1n water quality in the Tanana River at the discharge
point,
° increased potential for ice fog formation during winter and under
extreme inversion conditions.
Overall, the impact of the topping plant on ambient air and water
quality is not expected to be significant. It is anticipated that the
utilization of extensive design and operational measure, control devices,
and the most advanced processing technology, advantageous from the
standpoint of safety and low emissions, will mitigate adverse impacts
on air and water quality. The problems associated with increased growth
from the Alyeska Pipeline construction, topping plant construction and
other spin-off industries must necessarily be mitigated by proper trans-
portation control and land use planning by local decision-makers, planners
citizens.
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CHAPTER 7
RELATIONSHIP
BETWEEN LOCAL
SHORT TERM USE
AND MAINTENANCE
OF LONG TERM
PRODUCTIVITY
-------
THE RELATIONSHIP BETWEEN THE LOCAL SHORT-TERM
USES OF MAN'S ENVIRONMENT AND THE MAINTENANCE
AND ENHANCETOIT OF LONG-TERM PRODUCTIVITY
In the short-term, the proposed phase of the topping plant is
not expected to produce adverse environmental effects which cannot be
effectively minimized. To date, the concerns of citizens have focused
on the incremental expansion of the facility rather than the proposed
phase discussed in this impact statement. It is appropriate to em-
phasize that any expansion of the proposed facility will take place
only after environmental acceptability of the project has been demon-
strated and after the appropriate permits are obtained from the State
and Federal governments. The State will also review and approve
operating permits every five years. These procedures, designed to
protect and enhance the long-term productivity of the environment, will
also allow local planners, citizens, and other decision-makers the
opportunity to determine the extent and degree of growth that will or
will not take place.
The proposed phase of the facility represents a potential regional
resource that, measured against its largely controllable environmental
impacts, will be of strong positive benefit to North Pole and the
Borough. It is significant to note, however, that the project will
also exert a strong influence on land use developments in the
future. The emplacement of new industries and businesses could be a
beneficial long-term effect of the proposed project, if development is
carefully controlled. If such development is not effectively planned
for and if changing land uses are not controlled, a serious decline
in the quality of life and environment in the Borough can be expected.
Any new industrial growth will change the character of the City
of North Pole. The existing predominantly rural residential atmosphere
is likely to be lost as intensive land uses (a possible reaction to
the availability of cheaper petroleum products) replace existing land
uses. Future urbanization may intensify levels of pollutants generated
by mobile sources as more people move into the area. This will increase
long-term risks to public health and safety. Under certain meteorolo-
gical conditions, increases in air pollutants could represent a signi-
ficant threat to public health. The extent to which this will occur is
yet unknown as this will depend on the effectiveness of transportation
planning, the local and national economy, and numerous other factors
which influence rates of growth. In Fairbanks, as in most urban areas,
the primary sources of carbon monoxide, hydrocarbon, and nitrogen oxide
pollutants are motor vehicles rather than stationary sources.
Land prices in the Fairbanks - North Pole area are likely to con-
tinue to increase as the area is developed. Major landowners, developers
and speculators will benefit from the sale of land capable of accommo-
dating industrial and residential development, and the City and Borough
will benefit from an increased tax base.
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The public costs associated with increased development will be
substantial. The costs of providing services and facilities, and
utilities to developing areas will ultimately accrue to the taxpayer.
A sharply increased demand for public facilities will occur if develop-
ment 1s allowed to occur in an uncontrolled manner.
Overall, it appears that the environmental resources involved in
the proposed project do not foreclose any important choices of resource
use by future generations. The topping plant, as proposed, will add
substantially to the City of North Pole's tax base and will employ the
best available technology to prevent environmental degradation. Install-
ation of the proposed water quality control equipment will provide almost
fail-safe treatment of wastewater. The impact of the discharge on the
Tanana River is expected to be very minimal, therefore, EPA's permitting
action will not lead to the deterioration of the water quality of the
Tanana. The current uses, quality and character of the Tanana will not
be substantially affected by the ECA discharge.
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CHAPTER 8
IRREVERSIBLE AND
IRRETRIEVABLE
COMMITMENT OF
RESOURCES
-------
The principal natural resource which will be irretrievably lost as
a result of the proposed action will be the land necessary for the
construction of the facility. The muskeg vegetation covering the 40
acres upon which the tank farm and process facilities will be built
will be lost. The removal of this vegetative cover and other human
disturbances will lead to the loss of habitat for the small mammals
and birds which presently occupy the area. This land, which is considered
by the Soil Conservation Service as good agriculture land, will also be
lost to such use.
The project will involve the commitment of large amounts of renewable
and non-renewable resources. The substantial amount of man-months of
labor, time, energy, asphalt, gravel, cement, steel, and other construction
materials will be irretrievably committed to the proposed use. The
construction of the refining facility is an irreversible action since the
removal or the non-use of the facility is unlikely.
The commitment of the land area to industrial use is irreversible
since GVEA has already begun construction of its power generating
facility on the site and this designated use is consistent with the
North Star Borough's Comprehensive Plan. Once the facility is completed,
the lands adjacent to the 421-acre site may be restudied to redesignate
uses which may be most compatible with industrial use. If the availability
of cheaper fuel leads to increased industrial and commercial development,
the trend in North Pole may be away from a rural community toward an
urban/industrial city. However, cheaper fuels will benefit both present
and future agricultural and agri-business activities.
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CHAPTER 9
ALTERNATIVES TO
PROPOSED ACTION
-------
ALTERiWIVES
Issuance of an NPDES permit or denial of a permit are the two
basic alternatives for the EPA. Denial of an NPDES permit would
result in no direct discharge to the Tanana by ECA. Operation of the
plant might be technically feasible without an NPDES permit, although
other considerations might make such operation unfeasible.
ISSUE PERMIT (ACTION)
EPA proposes to issue an NPDES permit to ECA for discharge of
treated effluent and stormwater to the Tanana and uncontaminated
runoff from non-process areas (including oil storage tank areas) to
a drainage ditch on the east side of the Tanana levee. The drainage
ditch will be constructed as part of the Corps of Engineers project
and present planning is for Storm Drainage Channel "C" to enter the
Chena Slough.
Effluent limitations based on the New Source Performance Standards
for the Petroleum Refining Industry promulgated by EPA must be modi-
fied to satisfy Alaska Water Quality Standards (AWQS). Either
stricter limitations, a mixing zone, or a combination of stricter
limitations and a mixing zone would be necessary to prevent violations
of the AWQS. Recognizing this, EPA has options for permit issuance
based on variables such as level of treatment required, type of dis-
charge (process waste or storm runoff), time of discharge, size of
mixing zone, and location and design of the outfall.
iIixing Zone Considerations
Water quality standards must be met at the boundaries of mixing
zones which are defined to protect fish migration and aquatic life.
For the ECA discharge, the mixing zone should be less than or equal
to 15% of the river volume. Limitations on the allowable width
assures a zone for fish passage through the discharge area. To
protect aquatic life near the surface and bottom (where productivity
may be greater), mixing zones may reserve space to avoid effects on
these areas, particularly for large mixing zones. For the ECA dis-
charge, the maximum allowable mixing zone of 200 feet was considered
to be reasonable. Very long mixing zones are inappropriate since the
intent is to limit potential impacts to the area near the discharge.
Special consideration of available flow at the point of discharge
is necessary for rivers such as the Tanana which have many small
channels subject to winter icing. Flows may be considerably reduced
164
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or eliminated in frozen channels. Permits based on achieving water
quality standards through definition of mixing zones would thus
incorporate provisions for assuring that adequate flow is available
in the selected discharge channel at all times of discharge. Special
outfall configurations (such as multiport diffusers), pre-operational
studies of low flow characteristics, inspection of flow conditions
during operation (and prohibition of discharge when inadequate flow
is available) are examples of provisions that EPA could require as
permit conditions.
Mixing zones would be defined based on the requirements of the
AWQS. For the ECA permit, the numerical criteria in Table 22 with
an oil and grease limitation of 0.10 mg/1 (see Fisheries Impact)
must be achieved in the receiving water.
TABLE 22.
Parameter
Phenolic Compounds
Hexavalent Chromium
Sulfides
Maximum Allowable Concentrations in the Tanana River
Maximum Concentration
According to AWQS
0.001 mg/1
Oil and Grease
Comment
0.05 mg/1
Less than acute or chronic
problem levels as revealed
by bioassay or other appro-
priate methods and below
concentrations affecting
the ecological balance.
At or below levels which
will make the receiving
water unfit or unsafe for
all uses; no visible film,
sheen, discoloration, sludge
or emulsion. Less than
levels which cause tainting
of fish or other organisms
and less than acute or
problem toxic levels as
determined by bioassay.
1962 USPHS Drinking
Water Standard
1962 USPHS Drinking
Water Standard
0.002 mg/1, according
to Water Quality Cri-
teria, 1972 by the
National Academy of
Sciences
For the Valdez marine
water mixing zone,
0.10 mg/1 at the
sides and 0.05 mg/1
at the top and bottom.
Major Permit Issuance Alternatives
Table 23 summarizes the major permit issuance alternatives con-
sidered by EPA for the discharge of treated process effluent. All
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alternatives Include the same type of provisions for stormwater runoff
limitations. Because discharge of stormwater runoff during the low
winter flow season is not likely to occur, no discharge of runoff
would be permitted during this time (specified as November 1 through
April 30). The mixing zone defined for the higher summer flows in
the Tanana would accommodate the additional discharge through the
process effluent outfall. No more than 85 gpm total would be allowed
for the combined runoff plus process effluent discharge. During low
flow periods, discharge would be limited to 40 gpm (process effluent).
TABLE 23; Major Permit Issuance Alternatives for Process Effluent Limitations
Alternative
Permit Basis
Mixing Zone
Comment
1A New Source Perfor-
mance Standards
(NSPS)
IB NSPS combines with
AWQS for stricter
limitations
2A Tertiary treatment
2B AWQS and tertiary
treatment
3A Recycle treated
effluent within
plant and discharge
only 10% bleed-off
3B Recycle treated
effluent within
plant and discharge
only 10% bleed-off
4 No discharge of
process effluent.
Discharge storm
run-off only
As necessary to
achieve AWQS at
the boundary
Maximum length
of 200 feet
Maximum length
of 200 feet
None
Maximum length
of 200 feet
None
Maximum length
of 200 feet for
stormwater
166
A mixing zone longer than
200 feet would be neces-
sary
Smaller dilution flow
than for alternative 1A
A smaller river dilution
flow than for alterna-
tives IA and IB would
satisfy AWQS
Because no mixing zone
is defined, effluent
must meet AWQS at the
end of the pipe
Volume of discharge
would be less than for
alternatives 1 and 2
The effluent must meet
AWQS at the end of the
pi pe
Potential methods for
achieving no discharge
of process effluent
exist but do not appear
to be realistic: a) eva-
poration of effluent
with recycle', b) deep
well disposal; c) dis-
charge to North Pole
municipal waste treatment
facility; d) discharge to
trans-Alaska pipeline
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Both process area and non-process area runoff (including oil
tank storage areas) would be monitored separately in holding ponds
before discharge. If the quality met EPA new source performance
standards (Table 24), no further treatment would be required before
discharge. Otherwise, the stormwater would require further treat-
ment. Under alternatives 2A, 2B, 3A and 3B, concentration levels
for phenols, sulfides and oil and grease achieved by the main process
waste treatment system would be required in the combined effluent.
For the other alternatives, only load allocations based on NSPS
must be met for each type of runoff.
TABLE 24. NSPS for Storm Runoff
Storm Runoff - Non-process Areas, Tankfieldsl^ Daily Avq. Daily Max.
Oil and Grease, mg/1 — 15
Total Organic Carbon, mg/1 --- 35
Storm Runoff - Process Areas!/
B0D5, mg/1 26 48
Total Suspended Solids, mg/1 21 33
COD, mg/1 190 370
Oil and Grease, mg/1 8 15
y These limits are for storm runoff flows (non-process areas,
tankfields) which are segregated from the process treatment
system.
2/ This is an allocation applicable only for process area storm
runoff.
All the alternatives in Table 23 assume that sanitary wastes will,
as a minimum, be treated to secondary levels before discharge. Because
secondary treatment levels are not presently achieved by the present
municipal facility, permit requirements will require that ECA ensure
that secondary treatment for the topping plant's sanitary wastes be
provided. This could be accomplished by either total containment of
sanitary wastes or treatment by ECA of sanitary wastes to secondary
levels before discharge. If consistent achievement of secondary
levels by a municipal or private treatment facility can be demonstrated,
ECA will be allowed to connect with such a system.
The alternatives for the process effluent limitations listed in
Table 23 are based on different types of treatment and mixing zone
considerations. Alternative 1A based on EPA's New Source Performance
Standards would require a mixing zone larger than is considered
reasonable for this situation. Alternative IB (essentially the
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proposed alternative in the DEIS) requires a smaller mixing zone with
a dilution of 590:1. Although complete instantaneous mixing of the
process effluent with about 49 cfs would achieve AWQS, assuring
adequate dilution would be difficult under winter conditions.
Because mixing is not instantaneous, dilution to AWQS requires more
than 49 cfs of available river flow.
Alternatives based on tertiary treatment processes, (2A and 2B)
would further reduce the size of mixing zones required by reducing
effluent concentrations. If AWQS were met in the effluent (alter-
native 2B), no mixing zone would be necessary, and the point of
discharge would be of little or no concern from the standpoint of
AWQS.
Tertiary treatment processes and estimated average effluent con-
centrations considered feasible by ECA are summarized in Table 25.
For ozonation, phenols would be reduced to non-detectable levels and
would pose no problem in the receiving waters. A dilution ratio of
110 to 1 would be necessary to reduce the average oil and grease
to 0.1 mg/1 in the receiving water. For a flow of 0.09 cfs (40 gpm),
instantaneous complete mixing with about 10 cfs would dilute oil and
grease to 0.1 mg/1. For a single port, midstream discharge, mixing
would not be instantaneous. ECA indicates that operating problems
have been experienced with ozonation units, and that activated carbon
filtration would be more attractive as a polishing step.
Granular media filtration applied as a polishing step to efflu-
ent from other treatment processes may typically be expected to
reduce oil and grease by 65 to 95%, phenols by 5 to 20%, and suspended
solids by 75 to 95%, according to the Development Document for Efflu-
ent Limitations Guidelines and New Source Performance Standards for
the Petroleum Refining Point Source Category, (EPA-44Q/1-74-Q14-aJ.
This document states that consistent operation at 5 to 10 mg/1 of oil
in the effluent has been demonstrated for granular media filters.
As water passes down through the filter (which may be a sand, dual
media, or multimedia filter), suspended matter is collected in the
filter. Flow is reversed about once per day to backflush out the
trapped solids when excessive pressure drops have built up. Multi-
media filters use coarse coal, fine sand, and a denser, very fine
material (usually garnet) to solve the problem of keeping the finest
filter media on the bottom of the filter after backwashing.
Because phenol removal by granular media filtration alone would
not be adequate, effluent characteristics from addition of this
process were not estimated by ECA. To obtain desired removal of
phenols and oil and grease, activated carbon filtration processes
were Investigated by ECA.
Adsorption on granular activated carbon can effectively remove
certain types of pollutants as water flows through the carbon column.
Periodic replacement or regeneration of activated carbon after its
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TABLE 25. Comparison of Selected Tertiary Treatment Processes
Applied to ECA Topping Plant Effluent,®/ - Average
Concentrations, ing/1
Process Activated Carbon£/
Parameter Ozonation Filtration
Flow
.082
.082
Temperature
95°F Max.
95°F Max
bod5
18
< 37
COD
225
225
TSS
no data
18
TDS
2800
2800
Oil & Grease
11
2.2
Ammonia
no data
6.4
Sulfides
— y
.2
Phenols
< .002
< .002
Chromium
— hJ
— y
a/ Ozonation and activated carbon filtration processes (data
supplied by ECA).
b/ Value would be less than detectable levels.
c/ Maximum concentrations for oil and grease, sulfides, and
phenols in the proposed permit conditions (Appendix,
Exhibit 5) can be met by utilizing this tertiary treatment
process.
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useful adsorptive capacity has been reached 1s necessary. Re-
generation furnaces, which have high energy requirements, burn off
substances adsorbed on the spent carbon which can then be reused.
Because ECA would not have carbon regeneration facilities, spent
carbon would probably go to landfill (20,000 to 30,000 Ibs/yr).
It should be noted that influent to the activated carbon process
should already be low in suspended sol Ids and oil. Granular
media filtration (or other solids removal) often precedes acti-
vated carbon filtration.
According to the development document on petroleum refining
(EPA-440/1-74-014-a) cited earlier, activated carbon can typically
be expected to remove 70 to 95% of the oil and grease, and 90 to
99% of the phenols in the effluent from an activated sludge process.
After activated carbon, expected effluent concentrations would be
0.8 to 2.5 mg/1 oil and grease and 0 to 0.1 mg/1 for phenols. This
end-of-pipe process was proposed for inclusion in the Best Available
Technology Economically Achievable (1983 effluent guidelines).
ECA has estimated that activated carbon filtration not preceded
by multimedia filtration could achieve the effluent quality shown
on Table 24 for the topping plant discharge. At these levels,
sulfides (if present) would be the limiting parameter requiring a
minimum dilution ratio of about 200:1 to achieve AWQS for a maximum
effluent concentration of 0.4 mg/1. Otherwise, oil and grease
would be limiting, requiring a minimum dilution ratio of 100:1 for
a maximum concentration of 10 mg/1.
Alternative 2B, achieving AWQS in the effluent does not appear
technically feasible with the treatment processes discussed for 2A.
Alternatives 3A and 3B involve recycling treated effluent
within the plant. Process effluent flow would be reduced. Because
of recirculation, total dissolved solids would be higher than for
other alternatives. ECA has not estimated levels of pollutants
for this alternative because activated carbon filtration was indi-
cated as proposed Best Available Technology Economically Achievable
for end-of-pipe in the EPA development document.
Several potential methods for achieving no discharge of process
effluent (Alternative 4) exist, but do not appear to be realistic.
For example, to completely recycle effluent within the plant would
require addition of a treatment process to reduce sol Ids build-up.
Reverse osmosis, a process using high pressure and a semipermeable
membrane to separate waste Into a concentrated brine and a purer
solution, followed by evaporation of the brine and disposal of the
solids might be required. However, according to the development
document, the semipermeable membranes which have been available
tend to foul and blind, requiring frequent replacement. Energy
requirements for this process are also high.
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Deep well disposal beneath permafrost lenses would require
subsurface investigations before feasibility could be demonstrated.
There is some question as to whether it could be conclusively deter-
mined that such a discharge could be made satisfactorily. EPA
policy®/ on deep well injection would have to be considered as
well, as any requirements developed under the Drinking Water Act of
1974°/
Discharge of process effluent to a municipal treatment facility
at North Pole appears to be the most feasible of the alternatives
involving no discharge of the process effluent. However, pretreat-
ment of the refinery process waste, substantial improvement of the
North Pole treatment system, and revision of the North Pole NPDES
permit would be necessary. Joint treatment was originally considered
by ECA. One factor favoring separation of the wastes was concern
about production of toxic chlorinated organics during disinfection
of the combined wastes. Other disinfection processes (ozonation,
for example) do not produce toxic compounds and could be applied if
this alternative were chosen.
Return of ECA's process effluent to the Trans-Alaska Pipeline
would add about 1300 bbl/day of contaminated water to the crude oil.
ECA has approached one member of the eleven-company consortium to
explore the feasibility of this alternative. This company was very
dubious about the idea and stated that consideration by the consor-
tium would not be made until an operating agreement had been reached.
This would not be decided upon until mid-1977. Potential concerns
include decrease in the value of the crude oil, discharge problems
in the Trans-Alaska Pipeline were shut down (ECA could operate on
stored crude oil}, and oil/water phase separation in the pipelines.
ECA has indicated that heated storage of the wastewater effluent
would likely be necessary to meet situations when the Trans-Alaska
Pipeline is shut down.
EPA recommends Alternative 2A, issuance of an NPDES permit which
would require tertiary treatment of ECA's effluent to meet proposed
permit limitations. Activated carbon filtration and in-plant controls
are the processes that ECA plans to apply in order to achieve the
proposed requirements. Alaskan water quality standards would be
met within 200 feet downstream from the discharge point. Impacts
of the proposed action on water quality are discussed in the section,
"Water Quality Impacts." No significant adverse impacts on water
quality are expected as a result of issuance of the proposed permit
(Appendix, Exhibit 5).
a. U.S. EPA, SUBSURFACE EMPLACEMENT OF FLUIDS, Administrator's Deci-
sion Statement No. 5, Federal Register, Volume 39, No. 69,
April 9, 1974.
b. Safe Drinking Water Act, PL 93-523, December 16, 1974, U. S. 93rd
Congress.
171
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m PERMIT (NO ACTIOfO
Presently, EPA can deny approval of applications for new source
NPDES permits if the agency determines that the proposed discharge
will violate effluent limitations as defined in the Effluent Guide-
lines and Standards for the Petroleum Refining Point Source Category
or if violations of the Alaska Water Quality Standards are anticipated.
EPA1s authority to deny a new source NPDES permit for other than water
quality considerations are addressed in EPA's NEPA regulation for new
source NPDES permits which is proposed in the Federal Register (Octo-
ber 9, 1975, 40 CFR 6.900). This regulation authorizes the responsible
official (Regional Administrator of the Region) to approve or deny a
new source application after a complete evaluation of the environmental
Impacts consistent with, but not limited to, EPA's legal authority
under the various Federal environmental statutes which EPA implements.
Energy Company of Alaska will not be allowed to discharge efflu-
ent into the Tanana River at the proposed site and/or on the proposed
date of discharge (1) if EPA denies issuance of a permit or (2) if
certification of the permit is denied by the State of Alaska. Denial
of a discharge permit by either EPA or the State will result in no
wastewater discharge from a facility.
If Energy Company is denied a new source permit, the company will
be required to pursue alternative means of wastewater disposal which
necessarily involve no discharge, or the company can decide to cancel
construction plans. If the company is able to feasibly recycle efflu-
ent completely or discharge all effluent into the Alyeska pipeline, 1t
can feasibly operate without a new source NPDES permit from EPA.
Without treatment, ECA has estimated that stormwater flow combined
with process flow would total 85 gpm (average), which 1s about twice
the process flow. Even without a discharge from the ECA facility to
the Tanana, ECA would need state approval for water supply and waste-
water plans.
If Energy Company of Alaska decides that the topping plant is not
to be constructed, no negative or positive impacts, direct or Indirect,
associated with the construction and operation of the facility would
occur. With respect to the petroleum products supply, a status quo
situation will be maintained 1n the Interior and petroleum products
will continue to be Imported from the Kenal Peninsula or Cook Inlet
area. In this event, ECA would be eliminated as a potential supplier
of operating fuel for Alyeska's pump stations which are located near
North Pole, and GVEA would necessarily continue to utilize Tesoro
Arctic Diesel fuel from the Kenal Peninsula.
The impact of a decision to not build would have a significant
economic impact on North Pole. The city would continue to operate on
whatever revenue is currently generated by taxes on goods, services
and property. North Pole would not realize the benefits of an expanded
tax base which could be provided by the refinery. In the same respect,
172
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the Borough would not benefit from taxes generated by the facility
and from additional commercial establishments which may indirectly
result if the availability of cheaper fuels serves to stimulate the
local economy.
Even if the ECA facility is not constructed, many adverse impacts
such as (1) the destruction and disturbance of wildlife habitat, (2)
commitment of land to industrial use, (3) dust and noise during
construction, and (4) loss of the aesthetic forested appearance of
the site would still occur since GVEA has already begun construction
on the site, and the area is already zoned for industrial use. These
impacts on the environment will be,however, less in magnitude in the
short and long term.
Without the topping plant, air quality and water quality impacts
resulting from the incremental increase in population due to the faci-
lity or spin-off industries or development will not occur to the extent
that would be allowed by the presence of the topping plant. The
additional number of people (maximum of 80 employees and their families)
directly associated with the topping plant would not be located in the
Borough if the facility were not constructed. Without this incremental
increase in population, there will be less of a demand for services,
less of an impact on public facilities, and problems normally associ-
ated with population growth (i.e. traffic congestion, crime, air
pollution due to mobile sources, over-utilization of the area's
resources, etc.) will not be further aggravated.
173
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CHAPTER 10
CONSULTATION AND
COORDINATION
WITH OTHERS
-------
CONSULTATION m COORDINATION WITH OTHERS
A Notice of Intent to prepare the draft environmental impact
statement for the proposed action was issued to various Federal, State,
and local agencies and other individuals and groups early in the EIS
process. In its notice the Environmental Protection Agency (1) discussed
the issues involved, (2) provided a short description of the project,
and (3) requested that interested parties contribute information or
submit comments which might aid in developing a more comprehensive
statement.
A public meeting was then held during the comment period on the
draft environmental impact statement on November 12, 1975 at North
Pole, Alaska. Numerous individuals presented testimony at the meeting
on the adequacy of the impact statement and on the desirability of
the topping plant. The main issues raised dealt with (1) air quality
impacts, (2) water quality impacts, (3) quality of life and (4) growth.
All of the comments made at this meeting will be considered in the
final decision.
Comments received on the draft environmental impact statement
have been substantive and highly informative. EPA, in this final
statement, has responded to the various questions raised and has
made appropriate changes in the text. Comment letters were received
from the following groups and individuals:
North Pole City Council
Fairbanks Environmental Center
Fairbanks North Star Borough, Environmental Services Department
Fairbanks North Star Borough, Pollution Control Commission
Alaska Conservation Society, Tanana-Yukon Chapter
Daniel Swift
Dan Huttunen
Earl Beistline
Bob Thomas
Dennis Schlotfeldt
Bertold Puchtler
Thomas Miklautsch
Frances Cork
F. Wayne Jones
Merdes, Schaible, Staley & DeLisio, Inc.
L.A. Korvola
Robert Fedeler
George Utermohle, Or.
175
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Alaska Department of Community and Regional Affairs
Alaska Department of Environmental Conservation
Alaska Department of Fish and Game
Alaska Department of Highways, Transportation Planning Division
Alaska Department of Natural Resources
Advisory Council on Historic Preservation
USDA Soil Conservation Service
NOAA Environmental Data Service
NOAA Air Resources Laboratories
NOAA National Weather Service
NOAA National Marine Fisheries Service
DOT United States Coast Guard
DOT 'Federal Aviation Administration
U.S. Department of Interior
EPA also received numerous letters which did not specifically
address the environmental impact statement but which expressed views
on the desirability of the project. These letters have been included
in the EIS and are considered a valuable part of the decisionmaking
process.
The Agency will be holding a hearing on the draft permit (the
proposed action) in March prior to the Administrator's final decision
on whether or not the permit will be issued to Energy Company of Alaska
176
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CHAPTER IX
COMMENTS AND
RESPONSES TO THE
DRAFT
ENVIRONMENTAL
IMPACT STATEMENT
-------
COMMENTS AND RESPONSES TO THE DRAFT EIS
This chapter contains letters and comments from individuals
and groups on the draft environmental impact statement which was
issued to the public for review in October 1975. These letters
have been reproduced as received. Wherever a response is required
of EPA, a response page follows that letter.
The following table is a listing of the comment letters
received indicating the general tone and nature of concerns. Comment
categories are shown in an attempt to indicate those aspects of
the proposed action or facility about which the commentors were
most interested and concerned . This table may serve to direct
the interested reader or reviewer to those portions of the
statement which raised the greatest concerns and where necessary
changes have been made.
On November 12, 1975 at the North Pole Elementary School, EPA
held a public meeting on the draft EIS. The meeting was attended by
approximately 200-250 people. Because of the length of the meeting
record and the costs involved,we have not included the record in this
statement.
The Environmental Protection Agency, Region X, wishes to
express its appreciation to all commenting agencies, groups and indi-
viduals for the time and effort spent in reviewing the draft EIS.
All comments have been presented to the Regional Administrator and will be
considered by him in the final decisionmaking process.
178
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TABLE 26
COMMENTS RECEIVED ON THE DRAFT ENVIRONMENTAL
IMPACT STATEMENT
-179-
Air Quality
Water Quality/Supply
Energy Needs/Fuel Costs
•»-
T3
is
Recreation
Solid Waste
Aquatic Fauna
Mitigation/Controls
Population Projection/Growth
Historic Preservation
Land Use, Planning
Agriculture
Alternatives
Quality of Life
Economic s/Emp1oymen t
Sludge Disposal
Health and Sanitation
Noise
Industrial Expansion
Overtaxing of Existing Facilities
No Specific Reason Cited
Date
Received
From
General
Tone
1975
12/1
M. H. Cornelius
North Pole City Council
Supportive
X
X
12/1
Fairbanks Environmental Center
Informative
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
12/4
Fairbanks North Star Borough,
Environmental Services Department
Informative
X
X
X
12/29
Fairbanks North Star Borough,
Pollution Control Commission
Informative
X
12/29
Tanana-Yukon Chapter,
Alaska Conservation Society
Critical
X
X
X
X
X
X
11/20
Daniel W. Swift
Critical
X
X
X
X
U/21
Dan Huttunen
Critical
X
X
X
X
X
X
X
11/24
Earl H. Beistline
Supportive
X
X
X
X
11/24
Bob Thomas
Supporti ve
X
X
X
11/24
Dennis M. Schlotfeldt
Supportive
X
X
X
X
X
-------
TABLE 26
COMMENTS RECEIVED ON THE DRAFT ENVIRONMENTAL
IMPACT STATEMENT
-180-
Air Quality
Water Quality/Supply
Energy Needs/Fuel Costs
Wildlife
Recreation
Solid Waste
Aquatic Fauna
Mi ti gation/Control s
Population Projection/Growth
Historic Preservation
Land Use, Planning
Agriculture
Alternatives
Quality of Life
Economi cs/Employment
Sludge Disposal
Health and Sanitation
Noise
Industrial Expansion
Overtaxing of Existing Facilities
No Specific Reason Cited
Date
Received
From
General
Tone
12/12
Bertold Puchtler
Critical
X
X
12/12
Thomas J. Miklautsch
Supportive
X
X
X
12/1
Frances G. Cork
Supportive
X
12/16
F. Wayne Jones
Supportive
X
X
X
X
X
X
12/16
Mercies, Schaible, Staley & DeLisio, Inc.
Supporti ve
X
12/22
Leslye A. Korvola
Critical
X
X
X
X
12/29
Robert A. Fedeler
Cri ti cal
X
X
X
12/5
George E. Utermohle, Jr.
Critical
X
X
X
12/29
Alaska Department of Community
and Regional Affairs
Informative
X
12/29
Alaska Department of Environmental
Conservation
Critical
X
X
X
X
X
-------
TABLE 26
COMMENTS RECEIVED ON THE DRAFT ENVIRONMENTAL
IMPACT STATEMENT
-181-
Air Quality
Water Quality/Supply
Energy Needs/Fuel Costs
Wildlife
Recreation
Solid Waste
Aquatic Fauna
Mi ti gation/Controls
Population Projection/Growth
Historic Preservation
Land Use, Planning
Agriculture
A1 ternatives
Quality of Life
Economics/Employment
Sludge Disposal
Health and Sanitation
Noise
Industrial Expansion
Overtaxing of Existing Facilitle
No Specific Reason Cited
Date
Received
From
General
Tone
12/29
Alaska Department of Fish and Game
Critical
X
X
X
X
X
X
X
X
12/29
Alaska Department of Highways,
Transportation Planning Division
Informative^
Supportive
X
X
X
X
X
12/22
Alaska Department of Natural Resources
Informative
X
X
12/1
Advisory Council on Historic Preservation
Informative
X
12/8
USDA Soil Conservation Service
Informative
X
X
X
12/31
NOAA Environmental Data Service
Informative
X
12/31
NOAA Air Resources Laboratories
Informative
X
12/31
NOAA National Weather Service
Informative
X
12/31
NOAA National Marine Fisheries Service
Informative
X
11/28
DOT. United States Coast Guard
Informative
X
X
i
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TABLE 26
COMMENTS RECEIVED ON THE DRAFT ENVIRONMENTAL
IMPACT STATEMENT
-182-
Air Quality
Water Quality/Supply
Energy Needs/Fuel Costs
Wildlife
¦
C
o
T"
CO
•r*
o
z
Industrial Expansion
Overtaxing of Existing Facilities
No Specific Reason Cited
Date
Recei ved
From
General
Tone
12/22
DOT Federal Aviation Administration
Informative
X
1976
1/22
Department of the Interior
Informative
X
X
X
X
X
-------
P. 0. BOX 902
NORTH POLE. ALASKA
99705
TOP OF THE WORLD
PHONE: 488-2281
AT YOUR SERVICE
November 26, 1975
Walter D. Jaspers
Director
U.S. Environmental Protection Agency
Seattle, Washington 98101
Dear Mr. Jaspers,
The council for the City of North Pole- has recently reviewed
the draft of the Environmental Impact Statement on the proposed
installation of Energy Company of Alaska's Topping Plant to be
located in our community of North Pole, and we conclude that
they (ECA) have met all the EPA requirements as set forth in the
draft.
Naturally, the City of North Pole can foresee a substantial
increase in its revenue, a direct result of the Energy Company of
Alask's Topping Plant. Since the advent of the Alaskan Pipe Line,
North Pole nas seen a tremendous increase in population which
resulted in having.a definite strain on our ability to provide the
necessary services to adequately meet the requirements of our
citizens. So, in this respect the Topping Plant is most favorable
to the city.
One of the main concerns of the council was the effect the
plant would have on our environment'and effects to the surrounding
area. From the review of the Environmental Impact Statement and
several meetings with Mr. Rod Bouchard, a representative from
Energy Company of Alaska, we are substantially convinced that ECA
appears to have taken all precautions necessary to ensure that
the environment (in all aspect) will not adversely be affected
concerning Phase I of the project.
In light of the above the City Council for the City of North
Pole supports the issuance of the permit for Energy Company of
Alaska's proposed endeavor.
Ipwpainistrator
y bt North Pole
183
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RESPONSE TO
M. H. OOFNELIUS
NORTH POLE CITY COUNCIL
These comments from the North Pole City Council will be given
due consideration at the time the final decision is made on the
proposed permit. EPA recognizes the economic benefits which may accrue
to the City of North Pole from the construction and operation of the
topping plant. However, we do emphasize that these benefits can be
greatly diminished in the long term if the town residents, Advisory
Planning Council, and City Council do not join in a concerted effort
to preserve the fine qualities of the area. This will involve the
adoption of a strong grov/th policy and a clear definition of the City's
land use, social and economic goals.
EPA recommends that the City and ECA work closely to find means
of compensation to deal with the impacts which will occur during the
lag period between commencement of construction and first payment of
taxes. This might involve pre-payment of taxes, in whole or in part.
The expected revenue from the facility will not be a panacea for all
the City's problems. Without proper constraint, increased growth
may adversely affect the existing quality of life in North Pole.
EPA stresses that good planning for North Pole should arise out
of the small town context rather than being imposed onto it. Goals
and objectives should be decided locally, by all the town residents,
before specific means of implementation are sought from outside sources.
R. W. Pavitt, planning consultant for North Pole, predicts that growth
in North Pole, with or without the topping plant, is inevitable.
Therefore, the time is now for the City to work with its planners to
size up external forces, analyze internal potential for discourse and
local decisionmaking and to define its specific needs.
184
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©
- Fairbanks Environmental Center
Box 1796
Fairbanks, Alaska 99707
(907) 479-3684
November 26, 1975
The following are the specific comments of the Fairbanks Environmental
Center on the draft environmental impact statement on the
Company of Alaska's proposed topping plant at aorth 1ole, Alaska.
These comments are to augment the testimony given y ¦ t ^
the November 12, 1975 hearings held at North Pole o. the DLao. e
our oral testimony, these comments are split into two sections, one
dealing with water quality impacts, and the other dealing with ir,
solid waste, and social impacts.
ol9 cnotft' " A decision on this should be made in October,
Comment^ * In an August 1?? 1975 meeting Commissioner of Natural,
resources Guy Martin, said that the State Royalty ijoard has decided
to proceed slowly on considering applications lor
royalty oil. My guess is that they will wait to ma.ee a decision
until close to the time when the pipeline is finisned so that they
can assess the market at that time. A year from now
ILC euro to time frame.
T ?5 Statement: " The only existing facility on the^ECA rite is the
l^.L. Army Corps of Engineers Flood Control Levee...
Comment: This summer GVEA started construction of a 70,000 K». r
iturbine on the ECA site.
p
b\
- not only a concern *tth locution,
p. 26 Comment: Permairost i® (oil and sevvn£«).
but »Uo ,1th Pipeline location (oil •» <- ^ ^
T. I|? Comment: The bockprottnd data of lhfl refinery.
to use -s baseline data lot de*®1"];.- <£ short time period, in the
The data was collected over a Jel®4V°nythe plant location rather
spring when dispersion was goo » should bo most concerned
than in the town of Uorth Pole w . Q recornmendations ol the
about pollutant levels. A'® Sl^ P onmental Services Department o
Fairbanks North Star Borough Environmental
fchis matter. _ _
- „ effective barrier to the flow
P. U3 Statement: " ••• Sea." T- <+«,
of warm moist air from tho her « E (.air«banliv
Pole are similar to those at le durinp the winter is considerably
Comment: The temperature fit i*o. "•? elevation. Wind speeds and
colder than Pairbnaks due to its lower
directions will probably be different.
185
'Gateway to tho Arctic'
.b' i.. » ¦ •
-------
FEC Comments
Page 'd
p. 1;5 Comment: The factors which make the I-'airbanks wind patterns
complex aro known, why don't you describe them? Some of the unique
characteristics of the Fairbanks airshed are listed below.
a. The air structure is complex, often showing several vertical
layers seperated by wind shear zones or temperature changes. Plumes
released at various elevations are commonly observed to travel in
widely different directions.
b. Complex wave phenomena occur in the boundary layer over Fairbanks.
At times breaking waves occur at or near the top of the boundary layer,
these hav^/been identified as being Kelvin Hemholz instabilities.
This wave action can mechanically transfer pollutants in plumes downward
to the surface.
c. The extremely stable air conditions mean that pollutant dispersion
in the air is very different than that found in less stable areas.
p. |p0 Comment: Your ice fog data is very old. Ice fog now occurs at
temperatures around - 10, starts occurring around lote October, and
certainly extends past January. Ice fog depth of 600 ft. has been
observed.
p. 50 Statement: " Photographs taken from the high terrain to the
northeast of Fairbanks shows that the power plant plumes remain eloft
and move with the elevated winds."
Comment: The only plume which consistantly shows this type ol' behavior
is the plume from GVEA's gas turbine on Illinois street. All the rest
will break through the lower levels of the inversion and then drop back
down to join the ice fog. The plume from the power plant at Eielson
Air Force Base is an excellent example of this, and it is amazing that
they can continue to land planes there. Some plumes tend to break through
the lower ice foej level and then form an icc for layer higher up.
p. 58 Statement: " Most of the Fairbanks - North Pole area is still
heavily forested and wildlife is plentiful."
Comment: Compared to Seattle, Fairbanks is heavily forested. However,
anyone who has flown over the area can tell that in most places the
native vegetation has been disturbed. As the hurnar population increases
the wildlife becomes more scarce. Moose hunting in the area was
closed this year because of low populations. This statement is just
not applicable to the populated sections of the Borough.
p. 60 Comment: Peregrine falcons have been sighted in the Fairbanks area.
p. 62 Statement: "It appears that the use of the proposed site for a
topping plant is not only consistent with the Fairbanks North Star
Borough Comprohensjve Plan, but also with the goals of both the
City and Borough. "
Comment: One has to be careful not to equate the goals of the City
and Borough with the goals of the inhabitants of the area. I'm sure
the attitudes of the people of Fairbanks have changed quite a bit
since the Borough passed its resolution in 1970.
m
-------
Page 3
p. 65 Statement: "Some problems may be related to the high iron
content of the potable water supply."
Comment: It is hard to believe that the iron levels found in drinking
water which has been treated would cause the North Pole treatment
plant to malfunction. If iron is found in the drinking water most
of it should have oxidizeci and precipitated out by the time the water
peaches the treatment plr>nt.
p. 66 Statement: " According to the North Star Borough Comprehensive
Plan fill material on the site has been inadequate, hense contamination
of the ground water is frequent."
Comment: The Borough has h.'=d trouble finding adequate cover material.
A leachate study done in 197^ showed that no contamination of the
ground water was occurring.
[p. 68 Comment: In July 1975 the Borough Assembly certified the Borough
[population at 63, 350.
|p. 73 Statement: " Currently, the petroleum products consumption in
[Interior Alaska averages 10,000 barrels per day."
•Comment: No date or reference is given for this figure, it may be
jout of date.
p. 73 Statement: "... it is anticipated that petroleum products
will be made available to Interior communities at prices comparable
to those in Anchorage."
Comment: EPA seems to be taking for granted ECA's promise on this.
When Tesoro built a refinery in Kenai they promised local residents
that gasoline would be cheaper. It isn't. One has to remember that the
cost of doing business in Fairbanks is higher than Anchorage, so that
the increased price of products is not solely due to freight rates.
P. 73 Statement: " The Energy Company of Alaska also plans to provide
.^lyeska with prestartup turbine fuel by mid- 1977 and operating fuel for
pump station o."
Comment: How can ECA provide prestartup fuel for pump station 8 if they
are taking fuel from the pipeline? In the first week of November,
Larry Carpenter, public relations for Alyeska, stated that no
agreement had been reached with ECA on providing fuel for pump
station 8. Carpenter also stated that work had already begun on the
foundation for the topping plant at pump station 8.
73 Comment: Energy Co. of Alaska claims that they will market
10,000 barrels of products a day. These products will not include
gasoline or commercial jet fuel. Since the total consumption of
all refined products is 10,000 barrels, a substantial increase in
consumption may have to occur to consume all that ECA produces. If
one assumes that other firms currently marketing petroleum products
in Fairbanks continue to supply the area, then the increase in
consumption will have to be even greater.
Most of the air pollution in Fairbanks comes as a result of
combustion of petroleum products. Any increase in consumption means
an increase in pollutant levels in the ambient air. This is a secondary
impact which EPA has totally ignored.
187
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FEC Comments
Page ^
p.75 Statement: " The impact of such traffic on air quality could be
extremely significant."
Comment: It would be good-for EPA to calculate just how significant.
Impact ¦= increased traffic due to Delta refinery - increased truck
traffic due to North Pole refinery.
p.77 Comment: I do think that awhile back the military was trying
to sell their pipeline.
More attention should be given to the Delta alternative. The
only reason it seems to be unacceptable is because the transportation
costs make what is already a marginally profitable venture unprofitable.
The fact that having to transport products just 60 miles further makes
this venture unfeasible shows how shRkey it is to begin with. We
guess that the reason that ECA was able to fund this venture is because
they «re banking on a considerable increase in consumption of petroleum
products in Interior Alaska. This also means they are planning to
expand their operation in the future. The question is whether tho
air in Fairbanks can take the added residue from increased burntoj
of petroleum products.
p". 79 Statement: " Residual materials returning to the Alycjska Pipeline,
may amount to about 10,000 barrels perday. "
Comment: If the capacity of the topping plant is 25,000 barrels perday
and ECA is returning 10,000 bnrrels/day to the pipeline, this should
mean that .they are producing 15,000 barrels of refined products instead
of the 10,000 stated in the DEIS. V/hat happen to the extra 5,000 barrels'
Hopefully this won't be lost into the atmosphere,
p. 8L(. Comment: The diagram of the waste treatment plant tells us
little. It is reminiscent of the plans Alyeska turned in for approval.
Since Alyeska's plants seem to have trouble functioning properly we
think you should ask for more complete design information.
"p. 91 Statement: " Sludge from the primary clarificr, dissolved air
flotation unit, and secondary clerifier is concentrated in a sludge
gravity thickener, incinerated and the ash disposed of by land fill."
Comment: Vfhich landfill? An incenerator does require an air discharge
permit from the State. What is ECA planning to do if the incenerator
doesn't work, which is a frequent occurence. If the incenerator is
not operated properly it could be a significant source of particulate
natter.
Ash should not be disposed of on the plant site because of the
high ground water level. Before ECA can establish a landfill on their
^ite they need a permit from the State and the Borough.
p. 100 Statement: "EPA's evaluation of the results of R.W. Beck's
modelling program indicates that uho operation of the topping plant will
have minimal impact on tho ambient air quality of the surrounding
area. It is approprnite to emphasize..."
Comment: " The existence of narrow bands of aerosol was predicted theroeti
years ago by C.G. Rossby, in an article in the Rossby Memorial Volume,
where he shows that a square horizontal surface in an air mass tends
to be deforemed into a long band as the air mass moves... Curiously,
diffusion of pollutants out of these bands seems to be much less than
predicted by classical models; otherwise the bands would soon lose
their integrity." (letter from Dr. Kenneth Rahn to Dr. Glenn Shaw)
188
-------
Page 5
Fairbanks experiences multi-layered inversions which contain
shear winds. This fact plus the extreme calmness make the use of
conventional models questionable.
At the hearing in Fairbanks, the representative from fl.W. Beck
made the statement that the models used by the jj1™ 1may tely
predict the dispersions of pollutants from the Worth Pole ^fJ"ery»
out the model is the best EPA has, so its . t
accepted. This is a poor statment, and brings R.W.> £
question. If a model is not applicable to a specific situation,
it should not be used, even if it is the best EPA h^s* ,
We obiect strongly to the above quoted statement from the DI.1S.
It is a ?oo?"ciStilli practice to .tat. '""I"'1"?" 'rom
a questionable technique, and afterwards add the qualifier b
the technique. The qualifiers belong at the beginning of the statement.
P. 100 Statement: " EPA's evaluation was limited to the proposed first
phased of the topping plant..." . nnmni«v •*a
Comment: The entire Worth Pole refinery/power gyrating coinplex ^
beinc divided into five separate permit applications. Lach application
is being considered by itself with no attempt being made to look at
the total Impact of (hJ» tl thU f^Uity
i»p«t ^^oa^^rting
permit is granted, me do not think this piecemeal approach to S"ntinb
permits is legal, or conforms with the intention o. NBPA. lo tpote
from PPA Region X's own comments on the ftiavy s DIMS ^ t +.
4 A . fE "l .j ^ l ij i l._ l- i r this action leads to further developments
iia stated in the draft E1S tna* i* this act ion xu ,tt concerning
in zone A of NPK-U, other impact ®JatamenJ" W"J; «f thiS o°S°ect
those developments. While the environmental impact of this p'-tject
may not be significant,this approach in determining the envitonmantal
iir.pact of a possible series of actions may very well lead to a]piece-
meal evaluation of the impact. This, in turn, may tend to mask the
overall imosct of the project. For this reason we stress tnai Ui. iong-
ranpe impacts due to possjbl~future developments be discussed^in no»
detail as required in the Council of Environmental Quality s, Guidelines
for Federal Agencies under the National Environmental Policy Act issued
August 1, 1973V' ( emphasis added)
We suggest EPA follow their own advice and in the final impact statement
look at the impacts of the total proposed complex at North J®^e;
If ECA wants to expand on the facility under question then; the impact
or the expansion should be determor* bejorj the Permit £h®,*irk,t
ohase is given. Once ECA has committed millions of dollars to the
building of the topping plant they are not going to Pick £P the /^ole
operation and move it once it comes time for phase II. NH£S
total facility Energy Company of Alaska has in mind for their
Pole refinery is unsuitable for this location, then the time to locate
it elsewhere is now, not later.
P. 101 statement: " The magnitudes of the flare and slu^ge incineration
emissions were considered to be negligible relative to the emissions
from other topping plant sources..."
Comment: Just about anything can be negligible compared to something
°f larger magnitude, this doesn' mean that it isn't important. Flare
-------
^agu b
and Sludge incineration emissions will probably be discharged at lower
levels than stack emissions. This means that they will not have the
aid of the strck to discharge them above the inversions, and so could
contribute to local ambient air levels of pollutants.
It is best to always state the quantities of emissions from
various sources even though they are considered insignificant.
Different types of flares emit:; different quantities of pollutants.
It would be good to know specifically what type ECA plans to install.
p. 103 Statement: " Hydrocarbon emissions can also occur as a result
of leakage from process equipment and from storage and terminating
facilities. ECA has indicated that these omissions will be controlled
by proper selection of equipment and good maintenai/e..e practices."
Comment: This discussion of hydrocarbon emissions from the refinery
is totally inadequate. Nowhere in the discussion is there a figure give)
for hydrocarbon levels from these sources, or exactly how it is that
ECA is going to control them. If the specific data given EPA regarding
plant design is as sketchy as that presented in the DEIS, thon there
is no way that SPA can determine whether ECA can adequately control
hydrocarbon emissions due to leakage.
We developed some grosr? hydrocarbon emission figures for a best and
worse case situation using the refinery process capacity figures in the
DFIS. Under the best conditions one can expect the refinery to emit
140,927 lbs/day of hydrocarbons. Under a worse cose situation one
could expect the refinery to emit 361).,901 lbs/day.
Hydrocarbon emissions from storage and process equipment will vary
with the ambient air temperature. One should probably figure a summer
emission rate and a winter emission rate. Hydrocarbons released by
pipeline valves, vessel relief valves, pipeline relief valves, purnpseals,
compressor seals, ect. will be essentailly emitted at ground level
and will not have the aid of a stack to boost them above the inversions.
p. 128 Comment: Odors will probably be a bigger problem than the DEIS
indicates. Any odors released at ground level, eg.storage tanks, will
tend to sit during a strong inversion and cause a significant odor
problem. Downtown Fairbanks smells terrible during the winter because
auto exhaust does not disperse well.
EC/\ has stated that they plan to produce asphalt. No discussion
is given as to the specific technique they plan to use. If an
airblowing still is used, it could be a significant source of odors.
Oxygen, nitrogen and its compounds, water vapcr, sulfur compounds,
hydrocarbons as ^ases, odors and aerosols may be emitted from this
type of operation. Carcinagenic polynuclear hydrocarbons may be given
off as well.
p. 129 Comment: No discussion is given in this section to the permit
process ECA must go through to obtain an air discharge permit. There
is also no discussion of how this facility relates to the significant
deterioration guidelines that EPA has promulgated.
It is our feeling that if the total refinery/ generating complex
at North Pole is considered together, that it seems certain that the
impacts of the developments on the air quality of the area will be signif
One of the purposes of the Clean Air Act is " to protect and enhance the
quality of the Nation's air resources so as to promote the public health
and welfare and the productive capacity of its population. " It hns
boen asserted that "protect" means that " the air would not bo further
harmed or injured by lowering its quality." This interpretation is
190
-------
Page 7
known as the nondegradation policy of the Clean Air A
mo?t recently been upheld by the ninth Circuit Court of Appe
who stated. " ...we recognize that the Act intends a policy ot
"nondegradation," i.e., those geographic areas enjoying air ^lity
superior to that mandated by the Act are not to be made to suxfer
a reduction in such quality to national standards, . ¦
We think we are justified in being concerned about significant
deterioration of our air quality becuase it happens so easily. EPA
does not seem to recognize this fact when drawing their conclusions
about impacts.
[p. 131 Statement: " We have decided not include this potential
I1978 situation in the analysis."
jCominent: This relates to a point brough up
lyou include future expansions but also the
earlier,
exis ting
j\ot
GVEA
only should
1'ucility.
P« 133 Comment: Why was the pollution due to truck traffic loft out of
your analysis? Earlier in the DEIS you stated thut this could have
significant impact. Tanker trucks coming to the refinery vuould not
only omit pollutants from their exhaust, but would release hydrocarbons
upon loading as well.
We think the amount of truck traffic generated by this facility
will be greater tnan EGA has indicated. It makes more sense to load
tanker trucks directly at the facility then to load railroad cars at
North Pole, unlodd them at Fairbanks, and then load the trucks.
An effort should be made to make an estimate of increased traffic
in North Pole as a result of population expansions brought by the
planned facility. Estimates of increased population generated by
the facility are included in the DEIS*
MM*
[p* 135 Comment: Again, the Borough population is 63>350 people.
B. 135 statement: - The area Is an latent -j«»pine o« pl.c for
- people end materials."
not
in
the
want , and
the
basin
38 [|
»|r.
7. ^ , Tt ,, reasonable to expect that If the toppine plant
?s const rue ted" it .111 greatly enhance the City's attractlo,. as a
Oo™L?rW'mrrs-exactly *.« rtopp?ne plan;
is the reason many people are a£ai Doll»tion levels in
Fairbanks area. If we already hive high pollution wveis m
|we should not be thinking of ways to increase growth.
^ 1-11 j ononiic ijiip©ct fc
P» 137 Comment; There is no discuss* n aftY,yj.rflq because of the
refinery^ Ala^a's^e?L°ncf has been that developments'of ten cost
government more than they receive in taxes.
138 Comment: Alyeska-s peak employment Is around 20,000 people,
where did the 21+00 figure come from.
I Ikl Cogent: Please frlve specific details on RCA'. plans to give
H re equipment to North pole*
Comments Though the vacancy rate is low in the Borough. I
jver rate is fairly high considering tho mobility
191
raaglne the turnover
-------
FEC Comments
Page 8
[of the population.
Py» Comment: " A historical survey of the trends in solids
disposal at refineries and petrolchemical plants indicate that this
is a significant problem according to W. Jewell and D.L. Ford...
Report 12020 EID 03/711 Washington, D.C., EPA ." Jones, Hr.rold.
Pollution Control in the Petroleum Industry, park flidge, NJ 1973
p. lljlj Statement: " Overall, tho impact of the topping plant on the economic
of North Pole and the Borough is expected to be substantial and benefical."
Comment: Why does EPA take for granted statements such aa these which
are made by a firm hired by ECA to sell the refinery? Nowhere in
the DEIS is there an adequate discussion of the economics costs vs.
benefits of such a project to the community. If this project spurs
further growth things could become quite unbearable in the Borough,
especially since services are about taxed to their limits now. The
amount of thoughtput into this section of the DEIS is too small to
come to such glowing conclusions.
11(6 Statement: " Generally, changes in the developing coiruiiunities
Drought about e heightened sense of community satisfaction since
development often led to better facilities in the areas of health,
education, public services and roads."
Comment: This is the exact opposite of the Fairbanks pipeline impact
experience, an' experience which has left many people bitter. To
provide any service in Alaska takes enormous amounts of money, and
governments frequently don't have this money available to upgrade
services. The state of Alaska has to scrape hard each year to raise
tho funds necessary to keep from going into the red. Because of this
money shortage the lag time between the onset of a need for a service
and the time that the need is mot is longer than normal.
A good example of this is shown by the housing situation in
Fairbanks. There has been a need for housing in Fairbanks since the
1968 flood, 'i'hat need was not met before the pipeline came because of
the difficulty private banking institutions were having in raising
the capital to develop new housing. Private banking institutions are
still faced with this problem even after the pipeline boom.
Enclosed is a report on the consequences of growth which should
Trovide a good balance to the one study cited here.
p. lk.b Statement: "... however careful planning can result in favorable
social and economic changes."
Comment: Planning is a word foreign to the Alaskan vocabulary.
Don't count on it happening at North Pole.
p. II4.6 Statement: " To avoid such land use conflicts, lands immediately
adjacent to the site will probably be rezoned for more intensive uses
in the future."
Comment: Where does this end? It sounds like a classic explanation
for why urban sprawls develop .
|p. 1U? Comment: Who is conducting the archeological and historical
Isurvey and when will it take place?
P. 151 Comment: The solid waste section should be upgraded to reflect
ae comments made earlier. On-site burning of materials is generally
192
-------
rac Comments
Page 9
Idiscouraged. The Borough doesn't approve of any dump sites other
,,|than the Borough run landfills. Solid waste is a big problem in the
CWI f JJB o rough.
4ft
p. 151 Statement: " A vigorous monitoring program will be instituted
immediately after the refinery begins operation to ascertain the
Incremental impacts of water and air emissions."
Comment: Certainly hope this monitoring program is more vigorous than
the rest of EPA's work in the state. ( How about vigorously monitoring
some of the existing polluters in the Borough?)
p. 153 Comment: Some of the largest oil spills on the trans-Alaska
pipeline project have come from breaks in lines leading from storage
acilities. The Final statement might give a bit more discussion
on what measures there are to stop flow in these lines onco such a
break occurs.
Please include a copy of ECA's Spill Prevention Control and Counter
Measure Plan.
156
p. Statement: "... compared to the impacts created by the construction
of the Alyeska Pipeline, the impact 01' the topping plant is relatively
insignificant."
Comment: In the short term this is probably true. It all depends on
how much growth occurs because of the availability of fuel in the area.
so |;nt
57 Comment: The list of unavoidable impacts is defioient. No
tion is given of dppr^asad water quality.
51
52,
S3
p. 157 Statement: Overall, the impact of the topping plant on ambient
aii"1 and waterquality is not expected to be significant.11
Comsrent; Considering the inadequacies of the analysis done to
determine probable air and water impacts, we do not think this statement
can be truthfully made. In determining the impacts of a project like
this one should do a worse case and best case analysis.
For example, sewot^ treatment facilities rarely seem to function
properly in the arctic ( one month all 17 of Alyeska's sewage treatment
facilities were out of compliance). V/hat would be the impact to the
Tanana lUver if the sewage treatment facilities at the refinery were
not to function properly? What would be the impacts if they did
¦Tunction properly? One should never take permit criteria levels of
pollutants to determine worse case impacts, in fact they should probably
be used for best case calculations.
P« 159 Statement: "... will also allow local planners the opportunity
to determine the extent and degree of growth that will or will not
take place.n
Comment: These decisions are not made by local planners. They are
determined by the condition of the current national economic picture,
and if anyone makes decisions about growth it is people with politivoal
and economic power. Planned growth is a myth.
am
P* 159 Statement: " The proposed phase of the facility represents
193
-------
FKU Uoramenis
Page 10
'a potential regional resource that, measured against its largely
controlable environmental impacts, will be of strong positive benefit
to North Pole and the Borough."
,Comment: This is the most upsetting statement in the whole DEIS*
The impact statement admits that this is the first industrial
development in the Borough and also states that it may spur further
development in the Borough. V.'heroCas EPA may think that the air
pollutants from this development can be controled, they haven't even
attempted to measure the environmental impacts of the industrial growth
that it might bring. There seepis to be n very serious lack of understandini
about the seriousness of the potential air pollution problem in this
area. If this project brings with it more industrial development,
then it may be the beginning of a serious decline in the quality of
the environment in the Borough. Looking at only part of the total
picture and then making such a blatent value judgement about its
contribution to the well-being of the borough is extremely poor.
p. 160 " ... proposed water quality control equipment will provide
almost fail-safe treatment of wa^ewater."
Comment: Considering that few wastewater treatment facilities seem to
work properly in this region, we find the above statement hard to believe.
p. 162 Comment: The quality of life in North Pole will also be irrevorsibl
lost as a result of the refinery. Many people at the hearings stated
that they like living in North Pole because it wasn't as polluted
(lower ice fog levels) as Fairbanks. With the coming of this development
North Pole will look more and more like Fairbanks.
p. 16lj. Statement: " Energy Co. of Alska would be eliminated as a
potential supplier of preatartup and operating fuel for Alveska's
pump stations..."
Comment: This should not be of concern since Alyeska is building
their own topping plants.
165 Statement: " The Fairbanks North Star Borough would benefit
from tax revenue generated by this new industry and"by other industries
that may be attracted to the area due to the availability of cheaper
fue1."
Comment: We may be better off not having the extra tax money and having
a better place to live.
-------
Corrnop-ta cr the Water Quality Portic.rs of the Draft :~r.vironnental
Impact St?2te^ent (EIS), Ener^v Co^n-Ti^y of Alaske (ECA'i Topping
Pl^rit, North Pole, Alaska, by th-? F,->:,rh-.n'qe 30 - Existing Hvdrological Conditions:
As indicated in this section, the.Tapana Hiver is a wide, he&vily
braided strtsam. Therefore, the flow o^ ths rivax is split between
the channels and sloughs formeo by the gravel and sand bnrs of ths
active river bed, which is subject to shifting over a period of time.
The first available flow r^easurEment of the Tanana River at Fair-
banks is June 1973. Low flow data is crrly presented in the draft
EIS for the winter of 1973-1974. Data for the winter of 1974-1975
should also be available at this time-, but wag not oresented. The
vfilue of 3,100 cubic feet per second (cfs) for March 1974 is a
npan value. Therefore, lower flows must have occurred during that
month. Due to the small amount of data, calculation of the 7 day,
10 year dr.ounht flow is not possible, 7i:e data presented-in Table
2 of the draft EIS would indicate that low flows- occur?during the
cold weather oeriod of October through" April when- the-'river is ice-
covered. Accurate characterization"of- the magnitude cf low flows
is not possible with only one year's worth of data.
Although a detailed plan of the location of thne proposed wastewater
discharge is not orcvided in the draft EI'S.,. • the1 revised -plot plar
given as Figure 14 indicates'something of t^frn^tuxff-of the river
bed near North Pole. Piver flow is scjiit-.betwfie:0-sweral channels.
A direct line from the proposFd to-poio^' plaFrt' weuidr ffrs^t- intersect
a side channel. Flow in • such a: side channel., might-be;:- considerably
less than 3,100 cfs during the- coia-WBm-t-hrwT-^ftactoiJr.wteich^lAsta1- west '.
of the year. Flow might further be; reduced. ar- Bliraixiated by ice
formations or shifting sediments;
It is stated on page 36 of the draft EIS that iron correentxetions
in the North Pole water supply wells, at~a level, e# '0X6- w^/XiarB-
"excessive" and may contribute? tom w-aeteweter- treatment-profcrleiwrs»
Whereas such levels may exceed the 1962 Uv3w Public::Heelth"Service
Drinking Water Standards (DV/5) rwcoimwfrd*,t±Of»-of-"(»-• re«e«w«.•
mendation based on adverse taster stainiQ-e- of • 1'auwdac.y-amirpiymteing
fixtures, and deposita in distrxboti^rr" s' ixiwr* has a; verjr low
order of toxicity and would not be BxpectedctaraE^B-x^ttly e#feet
aiological wastewater treatment at such- law*scrasce»tlsetiorrain- (which
are considerably lower than- concentxa frtorrsr cpmnon-ly fo^d^'in-- Alaskan
water supply wells).
Pegs 56 - Aquatic Fawner
Eleven soBciea--- of - fish known"' ttr. inhafclfett*-Ta^w»~rf?®.w«»rr-8ae lis'ted; :•
in Table: 6. Four othext-sraecie»"-are'?'e^s«^iT^ntriomrd!-'roi^!pefe'':-56-. It-
is stated that" w'there*'ls-e-peeulationrthatrs«lir?jtr?ef»^n-'i#^-slettfh«v:
along the Tanana. " " No.-. informa'tixttr-ajstreifxtsttii.:,.the^prc^cme^^diairharg-e
site is giverr, . No^.in-fdrtnatio^'" is ¦ giu»"c«jpc.ea;r*.ia''g-:jOTtja«ii'aiaa-l^a-r..
in the food chaio; s«ch as berrttei-c stp*eia«E-
r§§
-------
Ernft EIS, ECA
-2-
12 November 1975
Page B5 - Water Supply:
It is stated that "the topping plant will require approximately
37 gpm (53,280 gpd; 202 cubic meters per day, cmd) of water for
process use and 2 gpm (2,860 gpd; 10.9 cmd) for domestic use." The
process water will be supplied from wells drilled on site. Domestic
water will be supplied by the North Pole water system. Wo infor-
mation concerning the capability of the North Pole water system to
supply domestic needs at the proposed topping plant or for the ex-
panded city system that will result is discussed.
Groundwater information would indicate ample water is available
to be tapped for on site wells; however, the city system may require
expansion to supply increased demand.
Fire protection water storage tanks are mentioned with regard to
Ficure. 16. These are not labelled on Figure 16 and no discussion
of fire protection requirements is included. It is also stated
that wastewater could be utilized for fire protection but no infor-
mation as to how this would be accomplished is presented.
Page 87 - Wastewater Treatment:
Wastewater flows.are segregated into five streams -
1. Process and oily wastewater: This wastewater flow stream is
estimated at 35 gpm. The estimated untreated process and oily
wastewater "average concentrations" listed on page Q7 are only
possible to consider as "concentrations" if a wastewater flow is
assumed. Assuming a wastewater flow of 35 gpm anc topping plant
capacity at 25,000 barrels per day (bpd) of feedstock:
Effluent Average Pnunds per Average Concen-
Characteristic 1000 Barrels tration in mq/1
B0D5
COD
T5S**
Oil and Grease
Phenolic Compounds
Ammonia as N
Sulfides
Chromium, Cadmium, and Cyanide
pH (units)
17
58
33
7*
.24
.17
.16
1010
3450
1960
416
14.3
10.1
9.52
Nil
6-9
*After API Separator
**Assumfid to be Filterable Residue
196
-------
Draft EIS, ECA -3- 12 November 1975
The basis for this ECA estimate of untreated waste load is not
discussed} however, it is noted that the values listed are some-
what higher than those listed as median values in Table lfl of the
petroleum refining development document for effluent limitations
guidelines and new source performance standards (EPA-d40/l-74-Q14-a)
for both effluent characteristics and flow.
A size factor and process factor are given on page 71. Insufficient
data is presented in the draft EIS to check the process factor. The
process factor given assumes an asphalt production capacity of 1170
bpd. These values are critical in determining the actual effluent
limitations which apply. Converting the values presented in Table 11
of the draft EIS to concentrations by assuming a wastewater flow of
35 gpm and topping plant capacity at 25,000 bpd of feedstock:
Effluent
Characteristic
ECA Est.
Ava. ma/1
Std. Avg
mq/1
Std. Max
mq/1
ECA
2&
Avg
rfo
B0D5
53.6
95.2
178
95
91
COD
315
470
916
91
86
TSS
47.6
63.3
125
98
96
Oil and Grease
11.9
29.8
54.7
97
93
Phenolic Compounds
.416
.654
1.31
97
95
Ammonia as N
1.43
19.0
42.2
87
+
Sulfides
.238
.476
1.13
98
95
Total Chromium
Nil
in
in
•
2.68
-
-
Hexavalent Chromium
Nil
.107
.220
-
-
pH (units)
7-8
6 — 9
Based on the untreated wastewater values from page 87 ECA estimated
average treatment efficiency removals and the removals necessary to
comply with the proposed permit have been calculated as shown above.
It can be seen that fairly high efficiency is both prognosticated
by ECA and required by law.
The treatment system is described only in terms of processes to
be employed. A flow diacram is presented as Figure 19. Process
desion oarameters are not included and therefore process efficiency
cannot be properly evaluated. It is imoortant to note that effluent
guideline development is based on a similar process combination with
two important differences:
1. Granular media filtration was assumed as a "polishing
step" to achieve suspended solids and oil and grease limits* although »
197
-------
Draft EI 5, ECA
-4-
12 November 1975
13
cm'4
(A
15
(eta
it might be possible for some refineries to meet the limits with-
out the need for filtration.
2. A parallel process design was assumed for reliability
and flexibility.
Failure to include the above two factors in the design for the
proposed ECA tooning plant wastewater treatment system seriously
reduces the potential for reliable achievement of the high treat-
ment efficiencies necessary.
The proposed permit discharge limitations do not include any
limitation on process water flow rate. This is an important
perametpr which should be limited to prevent hydraulic overloading
of treatment equipment and to encourage water conservation.
Since phenolic compounds aopear to be one of the more important
effluent parameters and the only one for which an effluent maximum
concentration is specified, the monitoring frequency should be at
least weekly rather than the twice per month proposed.
The temperature characteristics of the wastewater are not discussed.
This could be an imocrtant omission. The presence or absence of
cooling system biocides which may result intermittently from dry
cooling towers is not discussed.
2. Process area storm and fire funoff: proposed concentra-
tion limits are listed in units of kilograms per cubic meter (re-
quiring multiplication by 1,000 to convert to mg/1) and pounds per
1,000 gallons rather than the accepted normal expression of mg/1
for concentrations. The proposed permit footnote indicates that
these limits will only apply to treated process area runoff. When
will process area runoff be untreated, how will it be collected
and sampled, who makes the decision to treat or not, and what is
the basis for these limits?
3. Non-process area storm and fire runoff; why is TOC used
rather than COD or BOD, the oxygen demand parameters used for the
other effluent limitations, how will this water be collected and
samoled, what is the basis for thesB limits, and what steps are
olanned in the event that limits are exceeded since this flow
stream is not normally treated?
4. Oil free wastewater: is any other wastewater in this
stream other than boiler blowdown, what chemicals will be utilized
for boiler water chemistry control and have they been considered in
this analysis, and how will the pH control mentioned on page 91 be
accomplished since it is not shown in Figure 19?
I"~ 5. Sanitary wastewater? it is stated that all sanitary
¦wastewater will be pumped to the Morth Pole wastewater treatment
198
-------
Draft EIS, EGA -5- 12 November 1975
Can'i
plant for secondary treatment. However, the draft EIS also men-
tions on pages 65, 139, end 140 that this treatment plant is not
functioning properly. The [*arch 1975 report listed as reference
number 19 indicated that this treatment plant had failed. Average
removal efficiencies observed during sampling in 1973 and 1974 were
COD 15%
Total*Solids 5%
Suspended Solids - 9%
Effluent lim
Elimination
treatment an
to and inclu
ditions have
overloaded,
specified in
the three wh
a violation
itations specified in the National Pollutant Discharge
System permit for this treatment plant specify secondary
d a maximum flow rate. 1975 self-monitoring data up
ding the month of September indicate that permit con-
been violated and that the treatment plant is hydraulicallyl
Of the five parameters for which an effluent limit is
the permit BOD and fecal coliform bacteria (two of
ich define secondary treatment) were not even raported,
of permit monitoring requirements.
&
&
10
This treetment plant does not appear to be capable of treating any
additional wastewater, does not appear to be capable of adequately
treating its current wastewater loading, and is apparently in vio-
lation of both state laws and its federal permit. Wo effective
enforcement of state laws or the federal permit is evident. Although
the technology for proper treatment of such municipal wastewaters
is readily available it does not appear to have been applied and
technical assistance from the U.S. Environmental Protection Agency
tbs been of questionable effectiveness.
|Fiqure 19 indicates a flow stream labelled slop oil. It is not
[indicated what the ultimate fate of this waste is.
Page 96 - Water Quality Impacts:
lit is stated on page 96 that dewatering operations would not dis-
Icharge water to surface streams. Where will such waters be directed?
The analysis of Tanana River impacts is simplistic and unrealistic.
Insufficient information is presented to evaluate stated calcula-
tions, The draft EIS acknowledges that complete mixing will not
occur immediately due to the nature of the river bed. In fact,
mixing might be greatly inhibited during winter low flow conditions
bs previously mentioned. The mixing zone is poorly defined in the
proposed permit and may not exist depending on ice conditions,
location of the discharge, water depths, outfall configuration,
and other factors at certain times of the year (and assuming that
the proposed mixing zone is one foot above the bottom rather than
below it).
How can a diffusion study be accomolished if the outfall has not
yet been designed and river flow measurements near the outfall
199
-------
Draft EIS, ECA -6- 12 November 1975
have not been taken. For the stated diffusion study a water depth
of four feet was assumed. It is difficult to imagine the discharge
staying within the described two foot vertical limits of the mixing
zone or not breaking the surface normally if it is heated signifi-
cantly above ambient river temperatures as is likely and contains
oil and grease. It should also be noted that winter ice thicknesses
in excess of four feet are frequently observed in interior Alaska,
again depending on a variety of factors including discharge temper-
ature. It is possible that the discharge could reduce ice thick-
ness or cause open water near the vicinity of the discharge.
The calculated permit maximum allowable phenolic compound concen-
tration in the effluent is shown on page 3 of these comments as
1.31 mg/1. State Water Quality Standards would require the re-
ceiving water concentration not exceed 0.001 mg/1. The stated
diffusion study dilution factor of 590 to 1 would be insufficient
to dilute the effluent meeting average or maximum permit require-
ments to concentrations in compliance with the V.'ater Quality
Standards and it aopears that the dilution factor mentioned may
be of questionable validity.
The assumption of complete mixing with 3,100 cfs or total Tanana
River flow in Table 12 is misleading and not justified when con-
sidering the potential impact of this discharge in the local area.
The provisions mentioned on page 98 fo,r biological treatment process
malfunctions may help to mitigate the adverse condition; however,
it would be possible to prevent effluent degradation almost entirely
if a parallel process design and filtration were utilized as men-
tioned earlier and if conditions were written into the permit limit-
ing process flow (and therefore topping plant feedstock input)
during wastewater treatment plant equinment casualties to a level
which could be handled by remaining treatment equipment.
The permit limitations for the North Pole wastewater treatment
plant listed on paqe 100 are likely being violated} however, the
reouired measurements have not been reported. Additionally, the
Alaska Department of Environmental Conservation approved plans
for an aerated lagoon wastewater treatment plant submitted by the
Columbia Park Developers as of 7 August 1975. These plans call
for the discharge of 331,000 gpd at design capacity to be dis-
charged in a common outfall with the North Pole wastewater treat-
ment plant. The approval of such plans is a questionable action
since the ability of such treatment plants to achieve secondary
standards in both warm and cold weather is in doubt. The U.S. Air
Force currently operates several aerated lagoon war-tewater treat-
ment plants in Alaska and is in the process of designing add on
equinment to upgrade them to comply with secondary treatment re-
quirements. These discharges, which may or may not meet second-
ary treatment standards by 1977 but which will likely receive
additional wastewater loading could act synergistically with the
200
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r raft EI 5, ECA
-7-
12 November 19"5
{proposed toopinn plant discharpe to adversely in-.act
cont | R i
:hti Tsnana
ivrr.
There is no mention in the draft EIS and no provision in the pro-
posed permit for receiving water monitoring to snsura that watsr
cuality standards are not violated. There should be a requirement
for such monitoring and a provision prohibiting visible oil
slicks in the w3ter resulting from the discharge.
Page 139 - V.'ater Supply and Sewaqs Treatment facilities:
The inadequacies of the presentation in the draft EIS and the
described facilities has already been discussed in these comments.
It should be noted that construction may have commenced on the
Columbia wastewater treatment plant prior to plan review approval.
The need for additional water supply facilities and solution of
wastewater' treatment problems is mentioned. Proper planning to
implement solutions is not discussed. The same can be said for
fire protection requirements.
Page 150 - Construction Impacts:
Parma frost conditions are mentioned as well as construction
techniques applicable in permafrost areas. The need for a soil
survey is mentioned. Why wasn't such a survey conducted pre-
viously?
How will drainage of runoff be accommodated during construction?
Paqe 153 - Oil Spill Prevention;
It is stated that a spill prevention control and counter measure
plan will be required within six months after the proposed facility
begins operation. Why couldn't such a plan be in effect when
operations commence?
Page 156 - Unavoidable Adverse Environmental Impacts;
No water quality impact is listed and it is stated that the impact
on water wuality is not expected to be significant. Ms outlined
in these comments the data to support such a conclusion is not
contained in the draft EIS.
Page 165 - Action;
The draft EIS concludes that it La planned to issue a permit,
A discussion of the formulation of the receiving water mixing
zone limits is given. The difficulty in meeting Water Quality
Standards for phenolic compounds is mentioned and the use of a
maximum effluent concentration limit of 0.59 mg/1 based on ©dilution
201
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Draft EIS, ECA
-B-
12 November 1975
factor of 590 is discussed. The basis for the diffusion study
is of concern and the validity of the stated dilution factor is
questionable. Did this study take into acount cold weather con-
ditions? What is the width of the river channel being discharged
to and does the mixing zone width limitation of 15;'j apply to the
channel or the entire river? What is the design of the outfall
and the diffusor section and where is it located in the river?
What is the measured river velocity at the point of discharge under
normal and low flow conditions?
5ummarv and Conclusions;
There are numerous technical deficiencies in the preparation of
the draft EI5 for the proposed ECA topping plant. Available in-
formation has been omitted. Assumptions and calculations are
questionable and insufficient data is presented to check many of
them.
The proposed discharge site is not shown, there is no information
presented regarding receiving water flow at the point of discharge,
the outfall and dif^user are not shown or described and the draft
EIS states they have not yet been designed, and aquatic fauna have
not been characterized in the vicinity of the proposed discharge.
The Alaska Department of Fish and Gane has expressed some concern
(in a memorandum dated 25 July 1975 to the Alaska Department of
Environmental Conservation) that oxygen demand and temperature
components of this oroposed discharge in combination with other
proposed and existing discharges "could prove detrimental to
overwintering fishes."
Domestic water supply and fire protection services from the city
of North Pole are uncertain and likely insufficient. 5anitary
wastewater disposal is presently in violation of both state and
federal laws and the North Pole treatment plant is hydraulically
overloaded. Therefore, it is not adequate to receive additional
wastewater. The new Columbia treatment plant may have difficulty
in achieving secondary treatment standards.
The untreated wastewater strength is high. Process and oily waste-
water treatment design information is not provided. The process
description is such that reliability and flexibility appear to be
low and imocrtant processes are not included. Therefore, the
ability to achieve the high treatment efficiency required is un-
certain. An effluent meeting permit requirements woulo still
contain relatively high concentrations of pollutants compared to
.secondary treatment standards for municipal plants (BOD of 95.2
and TSS of 03.3 nq/1 compared to 30 mg/1 for each).
It is therefore concluded that the information presentnd in the
draft EIS is inadequate to properly quantify the water quality
impacts which would result fro^i the proposed topping plant. However,
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Draft EIS, ECA
-9-
12 November 1975
8Z. JthB draft EIS does serve to hinhlight the deficiencies in the
con'i tez* liable data and indirect support facilities now existing.
Several additional comments are pertinent to this discussion:
1. The effluent limits which have been derived as a
of the Federal Weter Pollution Control Act
are exoressed in terms of pollutant output
input {pounds of BOD per 1,000 barrels
Such numbers are meaningless in trying
impact and require that assumations be
water flow rate so that
environmental impact of
tration is ammenBble to
effluent limits and the
result
Ammendments of 1975
per unit of production
of feedstock for example),
to evaluate environmental
made with regard to waste-
a concentration nay be calculated. The
an assumed flow rate and pollutant concen-
discussion. The method of calculating
system of units is complice-ted to the
point that it is doubtful that the general public can comprehend
the situation without technical advice. In this draft LIS the
presentation was such that a complete evaluation was not possible
(due to lack of information provided) and the information that
was provided was unnecessarily confusing. The calculations which
I was forced to make for these comments should have been presented
in the draft EIS to encourage public participation and comprehen-
sion. A maximum flow rate limit should be specified in the permit
for process wastewater and estimated concentrations should be
presented es limits. In this nronosed permit three wastewater
flow streams have effluent limits expressed in three different
ways (pounds per dayt pounds per 1,DC0 gallons, and mg/l).
"""" 2. The draft EI5 assumes that the proposed discharge would
meet permit conditions. In view of the history nf permit non-
compliance in combination with apparent lack Df enforcement which
seems to oreriominate in Alaska such an assumption is not rational.
Therefore, it would be appropriate for xhe draft EIS to evaluate
the environmental impact of the discharge not meeting permit con-
ditions.
3. It does not apnnar
considered in the draft EIS.
expansion of the city of Nor
in any detail. What is the
plant in relation to the pro
rumored that wastewater from
charged with the topping pla
be discharged? Additional e
planned by the EGA; however
in the draft EIS. This piec
priate and fails to consider
project.
that all pertinent factors h
For example, the impact of
th Pole is mentioned but not
status of the new gas turbin
posed topping plant? It has
the generating plant will b
nt wastewater. If not, whtfr
xpansions of the topuing pla
, they were not discussed in
emeal, isolated approach is
the real environmental impa
ave been
increased
discussed
e generator
been
e dis-
e will it
nt are
detail
innappro-
ct of the
G. M, Zemsnsky
203
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JH1F
1. Since the decision date is yet uncertain, the sentence has been
deleted.
2. This statement has been revised to conform with the last paragraph
of page 21 and paragraph 2 (page 25, DEIS).
3. Comment considered and appropriate changes made in text.
4. Comment considered and appropriate changes made in the text.
Additional monitoring is planned.
While additional data would provide a more complete picture of
of the ambient air quality in North Pole, it is not likely that
any increase 1n the measured pollutant levels would be significant
enough to alter EPA's conclusions regarding the air quality
impacts of the topping plant. This statement is substantiated by
the following factors: (1) the anticipated addition of pollutants
to the atmosphere from the facility will be small (2) the pollution
levels measured during the test period were low, (3) there are no
important sources of N0X or SO2 in the area at the present time.
In regard to future monitoring plans however, ECA has contacted the
FNSB Environmental Services Department to discuss the possibility
of implementing a joint air quality monitoring program in North Pole.
Although prospects for the initiation of this program appear
favorable, details have not been worked out completely. Should the
program fail to be implemented, FNSB plans to monitor meteorological
data, CO and particulates at a FNSB selected site in North Pole.
ECA plans to monitor SCL and N0X at the topping plant on a continuous
basis beginning at least one year before the plant begins operation
and will continue to investigate ambient air quality of the North
Pole area after the plant becomes operational.
5. The statement has been revised to read "...which act as a barrier
to the flow of warm moist air from the Bering Sea, except during
periods of persistent precipitation." This statement on page 43
was intended to reflect the concept expressed in the Narrative
Climatological Summary for Fairbanks, "Local Climatologlcal Data,
Fairbanks, Alaska", U.S. Department of Commerce, National Oceanic
and Atmospheric Administration, 1973.
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6. Comment considered and appropriate changes made 1n text.
7. Refer to changes in text (pages 100-A through 100-B, "Air Quality
Impacts - Air Pollution Conditions").
8. Comment considered and appropriate changes made in text.
9. Comment considered and appropriate changes made in text.
10. Comment considered and appropriate changes made in text.
11. Appropriate changes made on page 58.
12. Theoretically, local government represents the will of the majority
of the people. We do realize that the stated goals of the City of
North Pole and the Fairbanks North Star Borough may not be consistent
with the personal goals of each and every one of the local citizens.
However, the FNSB Comprehensive Plan was officially adopted as the
regional plan for the Borough, and public officials, who pass resolu-
tions, are generally elected by the people.
13. Failure of the sewage treatment plant to function properly is thought
to be partly due to complex precipitation of iron and some toxic
factors in the plant influent which may not occur elsewhere. Iron
present in the potable water supply is not adequately removed by the
present water treatment due to lack of chemical feed equipment for
permanganate additions before the greensand filter. Although some
iron would be oxidized and precipitated out before reaching the
sewage treatment plant, some iron enters the sewage treatment and is
thought to be contributed in part by the water supply. Infiltration
and groundwater inflow would be additional sources of iron in the
sewage.
14. Comment considered and appropriate changes made 1n text.
15. Comment considered and appropriate changes made.
16. Comment considered and appropriate changes made in text.
17. ECA anticipates that savings incurred from the elimination of
transportation costs will benefit the consumer. The very fact
that most goods and materials must be transported into the Interior
from distant places accounts to a large degree, for the "high cost
of doing business in Fairbanks." It is significant to note that
if ECA does not sell at well below present Fairbanks prices, it will
fail to capture the market necessary to support the project.
18. Comment considered and appropriate revisions made in text.
19. It is reasonable to expect that ECA can only meet the market demand,
not exceed it. The dally average throughout during the first year of
operation will be about 20,000 barrels per day. ECA plans to market
about half of this amount, and return half to the pipeline. Through-
205
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put will be determined by market demands.
See discussion of this secondary impact on pages 159 - 160.
20. It is clear that the impact of additional trucks at the Delta
Junction site would be an increase in emissions and a resultant
decrease in air quality. Retailers must travel a greater distance
to obtain fuel and more trucks would be necessary to transport
those products to military establishments, storage facilities in
Fairbanks, and to GVEA. The parking facility would be the same
whether the topping plant is located at North Pole or Delta
Junction and thus the associated impact would be as described for
North Pole.
21. The military is not currently trying to sell the pipeline. Refer
to paragraph 1, page 77.
The 90 miles to Delta Junction versus the 14 miles to North Pole
(from Fairbanks) is highly significant in terms of economic
feasibility since the difference in miles will reduce the potential
differential in consumer savings.
22. The extra 5,000 barrels will not be lost to the atmosDhere.
Projected fuel use for the topping plant and the two GVEA turbines
is approximately 5,000 barrels per day. See also response to comment
number 19.
23. More complete design information on ECA's waste water treatment
facilities is presented in Figure 17-A, and further information
is available from the State of Alaska Department of Environmental
Conservation. Design details were not included in the DEIS for three
reasons: (l) this is not usually done unless a relatively new
and untried technology is being used, and (2) the printing of these
details is costly. (3) Not all details have been finalized.
24. The FNSB Environmental Services Department has indicated the South
Cushman site would be the best choice for the disposal of solid
waste and ash.
If the incinerator does not work properly it can be supplementally
fired if necessary. See also page 144.
25. See changes made on page 100-A, "Air Pollution Conditions."
26. As discussed on pages 93 and 94 of the draft EIS, the addition of
a Hydro Treater and Reformer will require a total increase of 15-
20 persons. Total water effluent would be 43 gallons per minute
(gpm), an increase of 6 gpm over effluent from the proposed plant.
Quality of the effluent is not expected to change significantly.
Burning of low sulphur fuel will be increased by 26%. It is antici-
pated that the increase in SOg and NOg will not change ambient air
quality significantly because of the improved dispersion characteris-
tics of the combined plume. Storage facilities will increase by
206
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about 70,000 barrels.
The long term use of the Tanana River will be restricted by Federal
and State Water Quality Standards and by permit requirements. If
it were ascertained that ECA was planning to exploit the total
resources of the Tanana by building a number of refineries within
the Tanana Basin, then a generic EIS, investigating the total
impact in a holistic perspective, would be required. In this case,
however, ECA's objective has been defined (ECA's future plans
include the addition of a 1700 barrel per day Reforming Unit and
a 2000 barrel per day Hydro Treater), and the point of discharge
and the anticipated magnitude of discharge has been evaluated.
ECA's plans do not include addition of cracking units and does
not include expansion into a "full blown" refinery operation.
With the information currently available, EPA has attempted to
deal with the "knowns", making the determination that the carrying
capacity of the Tanana River and the Tanana air basin can effectively
handle the effluents from the proposed plant. The philosophical
carrying capacity of the area is, however, more difficult to
ascertain, and cannot be determined by EPA's staff. The philosophical
limits to growth (i.e., what type and magnitude of growth is
desirable, what levels of pollution will be tolerated, what patterns
of development are desirable, etc.) must be determined by the resi-
dents and planners of the area.
Additional information on the combined effect power generating complex
on air quality is included in the EIS. EPA did not, however,
discuss the GVEA facility in great detail because (1) Rural Electrifi-
cation Administration will issue an EIS on the facility in March
and (2) both projects are not interdependent although if both are
constructed, they will be mutually beneficial. Neither project is
essential to the operation of the other.
27. Refer to pages 92 and 150.
28. Process equipment and storage hydrocarbon emissions will be limited
to 1000 lb/day according to ECA's permit application to the Alaska
Department of Environmental Conservation (ADEC). An appropriate
change has been made in the text to reflect this. No response can
be made to the hydrocarbon emission figures quoted in the comment
since no indication is given as to their origin.
29. Asphalt will be produced by blending residual and distilled products.
The airblower (asphalt cooking unit) will not be used. As Indicated
on page 128, the use of floating roofs in storage tanks containing
volatile products will help to minimize hydrocarbon emissions.
30. The prevention of significant deterioration (PSD) regulation Includes
in the definition of "commence construction", entering Into a
contractual obligation to undertake a construction program. There-
fore, based on EPA's review of the Company's contractual obligations
executed prior to June 1, 1975, we determined thatconstruction had
commenced prior to the PSD review effective date and 1s exempt from
review.
207
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On March 31, 1975, ECA submitted to the Alaska State Department
of Environmental Conservation an application for an Air Quality
Control Permit to Operate. Specific information can be obtained
from Mr. Thomas R. Hanna of the Department of Environmental
Conservation.
31. See response to Comment #26.
32. The statement referred to "earlier in the DEIS" was made in regard
to increased truck traffic at the Delta Junction site only, as
addressed in our response above. Traffic projections are dependent
on many variables, requiring an extensive data base which does not
exist for North Pole. Some idea of the air quality impact due to
increased traffic can be gained by taking a simple proportional
rollback approach to compare air quality in Fairbanks to air
quality at North Pole for an increase in population. If we conserva-
tively estimate air quality in the City of Fairbanks to be 30 parts
per million carbon monoxide (8 hour duration) and look at population
within the city limits of about 15,000, the proportional equivalent
for North Pole with a projected population of 1500 (a liberal
estimate) is only 3 parts per million CO. It should be remembered
that growth at North Pole has not occurred as rapidly as predicted
and that the topping plant alone is not responsible for the popu-
lation growth expected in the area. There are several other new
facilities under construction which will attract additional people
to the area regardless of the existence of the topping plant.
33. Comment considered and appropriate changes made,
34. Appropriate changes made in text.
35. FEC and EPA agree that it is reasonable to expect that construction
of the topping plant will enhance growth potential of the area.
The question of whether or not (or what type of) growth is desirable
must be resolved locally.
As aptly expressed by Gordon Wright, Editor of the Alaska Conservation
Review and other contributing writers (Alaska Conservation Review, li5
(3):1974), the task of measuring good growth against bad growth is a
difficult one. While EPA's staff and other professionals can review
projects on an individual basis and make decisions as to what levels
of pollutants exists in a river, or what the level of pollutants will
be in effluent streams, decisions relating to philosophical limits to
growth, or how much pollution will be tolerated, are political
phenomena which must be decided by local citizens, planners and
other decisions makers.
Relative to this, EPA has received several comments criticizing the
effectiveness of planning in the Borough. Criticisms of this nature
are not unique to the Fairbanks North Star Borough; ineffective
planning is a national issue. Nationwide, numerous case studies
have identified the lack of effective planning at the local level and
208
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the sporadic development of unincorporated areas by private developers
as the "priming actions" from which land use planning problems have
originated. Ineffective planning, however, cannot be blamed on
planners alone. The task of controlling growth in the most democratic
way possible is a formidable one which requires the active participa-
tion of decision and policy makers at all levels of government and
the public.
Doug McConnell and Stephen Reeve, contributing authors ("Another
Look at Growth Policy", Alaska Conservation Review, 15(3):1974,
define the problem and offer possible mechanisms for effective
planning in Alaska: "We (Alaskans) don't need a growth policy as
much as we need to create, at the State and local levels, capacities
for (1) considering the implication of growth options; (2) relating
them to public values and concerns; and (3) developing optimal
policies. In short, we need good planning and good public involve-
ment, and we need them both inextricably linked with good policy
making and evaluation procedures...The State's population is still
small enough for people to have direct access to their decisionmakers.
There is a strong heritage of public participation in decisionmaking
which continues to survive the influx of new people. Governmental
institutions and social infrastructures are young and malleable.
And partly because of its physical isolation and removal from the
mainstream of American communications, there is a more consuming
interest in state and local affairs here than is usually found in
the "Lower 48." We believe an on-going dialogue, decisionmaking,
and evaluation process can be employed with some success in Alaska
and in communities throughout the State. At least it should be tried."
In view of the numerous case histories and in recognition of the fact
that existing land use plans and local government policies strongly
influence development patterns, EPA encourages decisionmakers to
provide opportunity for widespread citizen participation in determining
alternative futures for the cities in the Borough. Everyone must be
involved if planning efforts are to be visibly productive.
36. As stated on page 139, it is anticipated that capital and operating
expenses for public services in the City will increase beyond the
City's capability between 1976 and 1978. One primary reason 1s that
the City will not receive projected revenues immediately.
37. Employment figures are for the Borough, and the source is Alyeska.
38. ECA intends to enter into a mutual aid program with North Pole and
the military. Further, ECA envisions a tie-in from the plant's
fire hydrant system to a North Pole fire hydrant system to provide
a dual source of fire water. Both would serve to lower North Pole
fire insurance rates.
39. EPA agrees.
40. The significance of the problem depends on the magnitude of the
facility and the types of products produced.
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41. The effects of the pipeline, when equated with the potential impacts
of the topping plant, are of such magnitude that the total impact of
the topping plant, with the addition of the Hydro Treater and Reformer
on water and air resources appear minimal. The economic impact of
the plant on the City of North Pole and Borough is projected to be
favorable because it will provide substantial revenue and year-round
employment to the Borough and City.
As indicated on page 138, Alyeska's peak employment is approximately
20,000 (2400 within the Borough), and the peak employment figure for
ECA is 160 people. While we believe that this additional 160 people
will have substantial impact on the City, the total impact of this
additional number on the Borough will be relatively insignificant.
It is anticipated that when the pipeline is completed, many people
connected with the project will leave the area. Therefore, in the
long term, it is not unreasonable to assume that there will be a
reduction in the numbers of people and cars in Fairbanks and thus,
a net reduction in the current air pollution levels and the demands
placed on infrastructure systems, housing, and other facilities.
42. The Alaska Conservation Review issue on growth provided some valuable
statistics and information on growth (Mayo, Larry, "Learning to
Think Small"), in burgeoning U.S. Cities. Unfortunately, the article
falls short in that it fails to discuss how these trends and statistics
relate to cities similar to those in Alaska, particularly those cities
with populations of less than a thousand.
We have, however, used Mr. Mayo's information in discussing potential
socio-economic impacts (pages 144, 145).
43. To quote Gordon Wright, editor of the Alaska Conservation Review
(15.(3): 1974), "For any of us to sit back and throw up our hands
in despair at this stage of the game is nothing short of criminal."
44. This statement was made to reflect what has occurred in other areas
undergoing development. Whether or not these areas will in fact be
rezoned for more intensive uses will be decided by local and Borough
planners and citizens.
45. Please see appropriate changes in the text. The consultant will be
associated with the University of Alaska.
46. Comment considered and appropriate changes made.
47. ECA will be required to monitor its wastewater effluent as specified
in the NPDES permit. As indicated in the draft permit (Exhibit 5),
monitoring of several parameters is required on a weekly or bi-weekly
basis.
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EPA will, on a periodic basis, inspect the facility for compliance
with the conditions set forth in the NPDES permit. EPA will not
perform routine or continuous monitoring of the facility and the
effluent, as this 1s done by the applicant.
48. Comment considered and appropriate changes made in the text. As
stated on page 154, a SPCC Plan must be prepared within 6 months
after startup. The facility will be subject to inspection by
EPA after this date.
49. Agree; it will depend on the amount of growth which occurs as a
result of cheaper fuels, the availability of fuel, the state of
the local and national economy, and such variables as the effective-
ness of planning efforts.
50. Comment considered and appropriate changes made in text.
51. For purposes of evaluating the impact of the ECA discharge on the
Tanana River, the worst case analysis was determined to be the
maximum permit conditions allowable. This is a valid assumption
as violations of this permit will result in enforcement actions by
EPA agains ECA.
Since a worst case analysis was studied, little would be gained in
studying the best case. If the worst case analysis indicates that
no environmental damage wf71 occur, the best case will, by deduction
affect the environment even less.
ECA will be required to treat sewage to secondary levels or assume
that secondary levels are achieved prior to ultimate discharge to the
Tanana River.
If the sewage treatment facilities at the refinery failed to function
properly, and effluent thus failed to meet permit limitations,
continued discharge would be in violation of the Federal NPDES
permit. The applicant has stated that recycling of unsatisfactory
effluent into the treatment facility would be possible and that
continuous monitoring would Indicate when such measures should be
taken. To attempt evaluation of a worst case, 1t would thus be
necessary to determine to what extent the system (treatment and
monitoring) fails to function properly emd/or to what extent the
permittee Is willing to knowingly discharge in violation of permit
conditions. Rather than attempt such an analysis, the water quality
evaluation uses the maximum allowable discharge as the worst case
during normal operation, barring natural catastrophes.
52. Comment considered.
53. Comment considered.
54. The proposed system including treatment, monitoring and diversion
capability is expected to provide adequate treatment with a high
degree of reliability.
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The effluent will be treated and monitored until specified permit
levels are achieved. When this occurs, discharge will occur. As
can be seen in the Process and Instrument diagram (Figure 17-A),
an off-stream emergency storage area has been allocated for control
of effluent in case of treatment upset conditions. Under foreseeable
circumstances, this emergency storage area combined with proper
monitoring, and routing of waste water flows will assure that permit
levels are not violated.
55. While physical changes may bring about changes in the quality of
life in North Pole, it cannot be said that "the quality of life in
North Pole will be irreversibly lost." Every person's perception
of "quality" differs, hence, depending on personal perspective,
the quality of living may be greatly enhanced for some and signifi-
cantly diminished for others.
56. ECA is still considered a potential fuel supplier. If Alyeska
determines that the operation of their topping plants is less cost
effective, they will cease operation.
57. Conment considered.
58. During Karch 1974, mean, maximum and minimum flows for the month
were estimated by the U.S. Geological Survey as 3100 cfs, indicating
that no better estimates were possible due to ice conditions.
Accurate characterization of low flows is generally not possible even
with several years of record. Nevertheless, a comparison of the
short record at Fairbanks with the longer record at Nenana was made.
It indicates that the 3100 cfs at Fairbanks occurred during a year
corresponding to the lowest 25% of flows at Henana. This suggests
that flows of 3100 cfs are lower than average, although no frequency
can be assigned.
59. Iron alone is not suspected of being toxic to the activated sludge.
Rather, the iron may act to concentrate toxic metals present in the
sewage, thus adversely affecting biological treatment.
60. Some information on benthic and invertebrate organisms in the Tanana
has been added to the EIS. It is important to note that the Alaska
Water Quality Standards applicable to the Tanana requires protection
for the growth and propagation of fish and other aquatic life, including
waterfowl and furbearers, as well as for such uses as water supply,
drinking, culinary and food processing.
61. Sufficient quantity of water is available from the town of North
Pole for the domestic water requirements of the ECA refinery.
Additional treatment for iron removal is necessary, however.
Growth and development may cause additional demands as was discussed
on page 140 (DEIS).
62. Size and location details of the water storage tanks have not yet
been finalized. The use of wastewater for fire will be accomplished
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by attaching pump and hose to wastewater holding tanks when necessary.
63. Parallel unit design is provided in much of the wastewater treatment
plant design including pumps, oil/water separator and peripheral
equipment. (See Process & Instrument Diagram Figure 17-A). Other
treatment units are not duplicated due to the econony of space
required in the waste treatment building. Adequate treatment of
wastewater during periods of unit maintenance or downtime can be
assured by the excess storage capacity provided at the head of the
treatment facility. Wastes produced during maintenance periods can
be held in storage and slowly fed to the treatment plant once normal
operations resume.
Granular media filtration is not considered an appropriate polishing
step since the final clarifier, operating properly and efficiently,
in conjunction with an activated carbon system, which ECA has agreed
to install, will result in an effluent of much higher quality than
that required by the effluent guidelines. The plant efficiencies for
removal of contaminants used in the analysis are realistic under
present technology.
The revised permit now includes a total flow restriction.
Phenolic compounds specified 1n the revised permit are based on water
quality restrictions. By use of the activated carbon system there will
be little difficulty in achieving the phenol limits specified in the
permit. Therefore, increased monitoring as proposed is not felt
to be necessary.
To operate the treatment facility properly and efficiently, the
activated sludge unit should be maintained at a temperature range
of 50° to 95°F. The temperature in the unit is expected to vary
within this range depending on time of year. A small amount of
cooling can be expected between the activated sludge unit and the
point of discharge resulting in a slightly lower temperature range
for the actual discharge.
No cooling system biocides will be used associated with the dry
cooling towers.
64. The units in the revised permit are now expressed in mg/1 and lbs/day.
65. The parameter of TOC was used rather than BOD or COD because this
parameter was specified in the Petroleum Refining guidelines
published in the Federal Register on May 20, 1975
The non-process area runoff shall be sampled 1n the impoundment
area with use of grab samples. If the samples indicate that permit
levels will be achieved, the effluent will be discharged to natural
drainage. If the samples in the impoundment area indicate that high
levels of oil and grease and TOC are present, the wastewater will be
routed to the main treatment system.
213
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66. Oil free wastewater will consist of boiler blowdown only. Chemicals
added for boiler water chemistry are expected to consist of a phosphate
hardness scavenger, a sulfite oxygen scavenger and an amine for
corrosion control. The pH is controlled by the addition of amines to
the boiler water and is maintained very slightly alkaline (pH 8 - 8.5).
Once diluted with other wastewater?, the effect on the neutrality of
the total wastewater is negligible.
67. Technical problems associated with the present North Pole sewage
treatment facility have not yet been overcome, although some recommended
actions have been carried out by the city. For example, the city
recently found and corrected what it believes was a major source of
infiltration. Iron removal for the water supply is not yet effective;
however, the city states that before water service will be granted
to a major developer, (Columbia Park) the water plant must be up-
graded. Because iron, in combination with other metals or toxic
factors, is thought to contribute to malfunctions of the biological
treatment process, removal of iron from the water supply has been
recommended. The possibility exists that a similar malfunction
could occur with other biological treatment processes, if iron is not
removed and if iron plus other toxic factors is, in fact, a major
cause of the current problems at the North Pole sewage treatment
facility. EPA is now exploring possible courses of action towards
a solution to the problems posed by the inadequate facility, the
anticipated growth and the poor financial resources of North Pole.
The City of North Pole has recently indicated that they intend to
discharge wastewater from their existing plant into the aerated
lagoon, being proposed by Columbia Park Developers. The City also
stated that plans have been drawn up to treat the groundwater supply
in order to remove heavy metals. If this system can be worked out
by the City and the Columbia Park Developers there is a good chance
that secondary treatment of all the sanitary wastewaters in the
area can be achieved. The EPA is watching this situation closely.
68. Figure 19 indicated a flow stream labeled "to slop oil storage."
This waste oil is collected and is sent back to the refinery for
recovery.
69. If dewatering operations are necessary during construction, the
water will be discharged to areas on-site where it will presumably
percolate to the groundwater table.
70. Although complete mixing will probably not occur until many miles
downstream, the example calculation presented in the tabid illustrates
the overall increase in river parameters possible at far downstream
locations. Complete, instantaneous mixing of the 0.09 cfs or process
effluent with the 18 cfs of river flow would dilute the maximum
allowable discharge of phenols to concentrations meeting Alaskan water
quality standards.
See the Alternatives Section which discusses the revised mixing zone.
214
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71. Calculations performed to determine if phenols were sufficiently
diluted in order to satisfy Alaska Water Quality Standards (AWQS)
were based on a maximum concentration of 1.24 mg/1. This concentra-
tion was based on the maximum discharge loading allowable by the
effluent guidelines. It was determined that at 1.24 mg/1 insufficient
diluation would be available to achieve AWQS at the mixing zone
boundary. Because of this, the maximum concentration was changed
in the permit to be 0.59 mg/1. With a dilution of 590 to 1, phenols
would be diluted so that 0.59 mg/1 = 0.001 mg/1 of phenols at the
mixing zone boundary 590
See revised Alternatives Section which discusses a smaller mixing
zone superceeding the above comment.
72. This table was placed in the EIS to give an indication of what effect
the effluent would have on the total stream at some location down-
stream. The revised permit conditions and water quality evaluations
of effluent are based on 200 to 1 dilution. This is discussed
further in the Alternatives Section.
73. Refer to response to comment 63.
74. Refer to response to comment 67.
75. After treatment there should be no free oil discharged. It should
all be in an emulsified form which is not readily visible. In
addition, the Alaska Water Quality Standards (AWQS) specify that
there shall be no visible oil outside of the mixing zone (defined)
in the permit. These factors in addition to a dye study will assure
that no oil will be visible outside of the defined mixing zone.
See permit conditions (Exhibit 5) for further discussion of the
dye study required in the revised permit. This study will insure
that adequate dilution is achieved to meet AWQS.
76. Comment considered and appropriate changes made.
77. Soil surveys were conducted on the site by Arctic Alaska Testing
Laboratories in April of 1970 and by Shannon & Wilson, Inc., in
April of 1975. Further studies will be conducted prior to construc-
tion. These future detailed studies are what are referred to on
page 150.
78. Runoff during construction will drain naturally to the drainage
ditch on the landward side of the Tanana-Chena levee.
79. Federal regulation does not require it.
80. Comment considered and appropriate changes made.
81. See the revised Hydrologic Conditions and Alternatives sections as
well as the Appendix, Exhibit 6. The statement was intended to
exemplify the "action" alternative, I.e., No action: EPA denies the
permit. Action: EPA Issues the permit.
82. See responses to preceding comments.
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83. The following calculations were used in determining the effluent
limitations in the initial draft penrit:
Effluent Guidelines
Ref: Federal Register Vol. 39, No. 91, May 9, 1974 and Revisions
Federal Register Vol. 40, No. 98, May 20, 1975
§419.15 Standards of Performance for New Sources - Topping
Subcategory
ECA Topping Plant Products
heating oils
diesel fuel
industrial turbine fuel
military jet fuel and asphalt
Determination of Process Factor and Size Factor
ECA Processes
Crude
Atmospheri c
Vacuum
Desalting
Asphalt
lOOObbl/day
Capacity
25
12.7
25
1.159
(Factor)
1
1
1
12
Capacity
Relative to
throughput
Process
Configuration
.51
.51
1
.046
2.51
.56
Process configuration =
3.07
Per 5-20-75 Federal Register the process factor is 0.67 for a facility with a
process configuration of 3.07, For a 25,000Bbl per day plant the size factor is
1.06.
(Process factor = .67) x (Size Factor = 1.06) = .71
.71 x 25 = 17.75
Multiply 17.75 times (lbs/1000 Bbl) to obtain (lbs/day)
216
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Ibs/lOOObbl
BODc
TSS
COD
Oil and Grease
Phenolic Compounds
Ammonia as N
Sulfide
Total Chromium
Hexavalent Chromium
PH
4.2
3.0
21.7
1.3
.031
1.0
.027
.064
.0052
6.0 to 9.0
lbs/IOOObbl
MAXIMUM
ECA's at 25,000bbl
Total lbs/day
75
53
383
22.8
.55
17.5
.48
1.13
.093
AVERAGE
Total lbs/day
ECA's at 25,000bbl
Total kg/day
34
24
174
10.4
.25
8.0
.22
.51
.042
Total kg/day
BODc 2.2 39 18
TSS 1.9 33 15
COD 11.2 198 90
Oil and Grease .70 12.3 5.6
Phenolic Compounds .016 .28 .13
Ammonia as N .45 8.0 3.6
Sulfide .012 .21 .095
Total Chromium .037 .65 .30
Hexavalent Chromium .0025 .045 .020
PH
The only limitation which was not entirely based on these calculations
was that for phenolic compounds. The limitations for this parameter were
determined through water quality restrictions and are more strict than the
effluent limitations calculated from the Federal Register.
The restrictions for phenols were based on water quality restrictions
requiring that phenols be present 1n concentrations of 0.001 or less
outside of the mixing zone. The effluent as originally calculated diluted
by a factor of 590 at 200 feet. Therefore, the maximum concentration of
effluent allowable - (590) (.001) - .59 mg/1.
For a maximum flow of 53,000 gallons per day the maximum pounds per
day would be calculated as (0.053)(8.34)(0.59) * ,26 lb/day. The above
calculations are now superceeded. See revised Alternatives Section for
discussion of new effluent limitations based on tertiary treatment.
84. The draft EIS Included a copy of a draft permit to be issued to ECA.
This permit once issued 1s a legal document which can and will be
enforced If violated. The treatment system proposed by ECA should
assure that these permit limitations be achieved. In the case of
another oil refinery located in Alaska and presently operating,
monitoring data has shown that consistent compliance with the permit
217
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has been achieved. ECA Is using the latest technology and should
have no problems meeting the permit limitations.
If there is noncompliance, enforcement action will be instituted.
Past enforcement actions in Alaska on industrial permits have
been few due to the lack of violations but for those enforcement
actions brought, compliance has been achieved. The EPA record
of enforcement actions on industrial permits in Alaska has been
good.
218
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FAIRBAh
OROUGH
November 24, 1975t
Mr. Oscar Gene Dickason
Environmental Protection Agency
Alaska Operations Office
605 W. Fourth Avenue
Anchorage, Alaska 99501
Dear Mr. Dickason:
Due to a conflict in meetings, I was unable to attend the public hearing at
North Pole in reference to the Energy Company of Alaska's Topping Plant. Mr.
Don Moore, our Environmental Services Director, was in attendance and presented
the attached testimony.
As in the past, the Fairbanks North Star Borough Assembly has gone on record as
supporting a refinery in North Pole. We foresee the economic impact that such
a refinery will have on our area, to meet the need for energy.
The position that we took at the public hearing, was to critique the Environ-
mental Impact Statement prepared by the U. S. Environmental Protection Agency,
Region X, Seattle, Washington 98101. I feel that Mr. Moore brought forth
questions of concern which we feel should be looked at and could be rectified
if valid. It is our intention to point out these areas of concern in order
that they will not pose problems in the future when this refinery is under con-
struction.
Very truly yours,
/aJOHN A. CARLSON
^ Borough Mayor
0AC:nic
219
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Testimony Presented on Draft Environmental Impact Statement
"Energy Company of Alaska Topping Plant"
North Pole, Alaska
November 12, 1975
My name is Don Moore. I am presenting this testimony as Director of
the Environmental Services Department of the Fairbanks North Star Borough.
Our review of the Environmental Impact Statement was done under the
scope of two objectives. This first is to examine this draft impartially
for errors, omissions, and shortfalls that we wish to see the regulator agency
address in the final statement. Secondly, we sought information on those
relevant matters that require the attention of our offices. Wa endeavored
to strike the balance between, what we know, and what we must yat do to mini-
mize any adverse environmental effects frcn this construction. We would thus
expect a clear delineation to result of where the responsibilities are dis-
tributed among the regulatory agencies and the Energy Company of Alaska.
In this fashion, the Environmental Impact Statement serves a valuable
purpose if we all follow through and incorporate our findings from it into
action during the construction and operation of this facility.
Accordingly, we do not wish to use these hearings tonight as the platform
for either opposition or advocacy of the proposed construction.
Although the Environmental Services Director is tangentally concerned
with social and economic impacts of the proposed refinery, my comments will
address those areas in direct purview of ay office. Specifically, Air Quality
and Solid Waste.
Under Air Quality, the statement on page 13 paragraph 3(d) is a concise
summation with which I think most of us agree, but may not necessarily like.
We are in effect being told we think the refinery will have little impact on
air quality, but will not really know until a refinery is placed in this sub-
arctic locale.
We feel this gap in our knowledge could perhaps be somewhat obviated if
more on site study were done and less reliance placed on computer modeling
techniques, particularly when these models are developed for considerably
different applications and conditions than those of the North Pole area. On
pages 42 and 45 reference is made to the background study and the paucity of
weather and pollutant data in this area, t'e feel this is all the more reason
to supplement computer modeling with site testing. Ue should also point out
that what background study was done took place in April of 1975 (See page 42.)
Since the air quality problems that solicit our concern occur during the winter,
we feel some testing should be conducted during December through February to
get a more accurate estimate of pollutant concentration behavior. The Environ-
ner.tal Services Department is endeavoring to establish a continuous monitoring
site in this area that will supply sons, but by no means all, of this desired
information.
Ice fog is, of course, a paramount concern regarding the proposed operation.
Although the Environmental Impact Statement r.akes considerable reference to the
220
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expected plume behavior, we find several vagaries and perhaps invalid assump-
tions in the theory.
On page 14,paragraph 3, it is stated "no ground level ice fog is expected,
however some ice fog is expected in the elevated plume." First, we would like
to examine the basis for the conjecture that no ground level ice fog is expected.
We take particular exception to the statement on page 50, paragraph b, that the
exhaust plumes of other local power plants provide an excellent example of high
altitude plumes remaining aloft.
Quoting from the Impact Statement, "Photographs taken from the high terrain
northeast of Fairbanks show that power plant plumes remain aloft and move with
the elevated winds, rarely joining the tnair. mass of ice fog before they dissipate.
We believe the preponderance of fact speaks otherwise. To the contrary, the
'plumes usually join the ice fog mass in the vicinity of the plants.
""" Another parameter that bears on ice fog formation is Che temperature of the
discharge waters. On page 98, paragraph 4, it is stated that temperature
estimates are not available, and the temperature difference between discharge
and receiving water is more pronounced during winter.
These "pronounced differences" are the cause of ice fog, and winter is
the season of concern here. We feel these estimates should and can be made.
It's a standard engineering task to calculate heat transfer, and we would like
to see it done in this case.
Turning now to the matter of solid waste, we have noted a general tone
of vagueness and some misinfortoation. on refuse' handling associated ^ith this
proposed development.
On page 56, paragraphs, reference is made to the Borough Landfill south
of Fairbanks. This reference states "contamination of the groundwater is a
frequent occurrence." We take exception to this statement because the findings
of cur leachate study at the S. Cushman site indicate that groundwater contami-
nation does not occur in this area.
The first paragraph on page 144 is particularly evasive when it states
''the incremental increase [from North Pole development] is not expected to be
significant, however." North Pole has a significant solid waste problem right
now, and we certainly expect projected developments considered for the future
in ^orth Pole will be indeed significant if not critical if the solid waste
problem is not properly addressed.
T^orth Pole is a difficult area in which to locate a landfill because of
the high water table. The Environmental Services Department is doing what it
can to handle the present waste situation, and future planning must incorporate
input from our agencies, citizens, and development interests. A particular
example of the prevalent attitude tovards solid waste matters is found on
rae-5 151, paragraph 3.
In two brief sentences the natter is laid to rest in unacceptable alter-
natives. On site burning requires a permit from the Environmental Services
Department, and we are quite frankly resistive to this practice because such
fires frequently violate state and borough law. As for ''off site disposal at
approved borough dump sites," there is simply no such thing. Both the borough
221
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and the state approve landfill operations, and there are presently two for
oubl.ic use. One is the S. Cushman landfill, and the other is at 36 mile
?.ichardson Highway. We need to know, and would like to see in the impact
statement.which of these sites is expected to handle the refuse from this
proposed construction.
'Chess points demonstrate the need for'utilization of this Environmental
i:~r??..:c Stat;-rent as a guide for our respective agencies and the Energy Company
of .-.I?..-1.:.? to do what ve can to nitigf.te any effects of this refinery on the
In our technological age, most of the adverse effects presented by the
nroposed construction are within our grasp to control. The task at hand now
is to make certain all parties do their best to implement these mitigative
Our summation can be covered in the following four elements of prime
concern to the Environmental Services Department.
1. Collect some background data during the season of concern, namely, the
wintertime.
2. Calculate the temperature, of the plant effluent discharged into the
receiving water.
3. Address more thoroughly the question of plume rise and path from the stacks.
Provide considerably more thought to solid waste generation and disposal
problems. This is perhaps the most readily apparent omission of this
report that concerns the Environmental Services Department.
That concludes my testimony. Thank you for your attention.
Lronmar.t of the area
•-ensures
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RESPONSE ID FAIFBANKS NORTH STAR BOROUGH,
ENVIRCNIOTAL SERVICES IEPflRHEMT
1. Please refer to response H to the Fairbanks Environmental Center.
To briefly reiterate, further on-site monitoring will be conducted
prior to start-up, and continuous monitoring will take place after
the plant becomes operational.
EPA agrees that it is essential that computer modelinq is supplemented
with on-site testing. EPA encourages both ECA and ESD to actively
study the possibility of a joint monitoring program in North Pole.
Such a program could prove to be beneficial to both parties involved.
2. Comment considered and appropriate changes made. Please refer to
page 50 and pages 100a and 100b.
3. See response above.
4. See response to comment #63 from the Fairbanks Environmental Center.
5. Comment considered and appropriate changes made.
6. Comment considered and appropriate changes made.
7. Comment considered and appropriate changes made.
8. Comments received from the Fairbanks North Star Borough Environmental
Services Department have been extremely helpful in bringing to our
attention those matters of concern which were not properly addressed.
9. See above comments.
223
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FAIRBAh
OROUGH
December 22, 1975
Walter 0. Jaspers, Director
DEC 2 91975
OFFICE OF FEDERAL AFFAIRS
Office of Federal Affairs, M/S 623 v
U.S. Environmental Protection Agency -, .''-i•
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Jaspers:
This letter presents comments of the Pollution Control
Commission of the Fairbanks North Star Borough in regard to the draft
environmental impact statement for the proposed Energy Company
of Alaska topping plant at North Pole, Alaska.
We believe that this impact statement will be a valuable tool
in planning for borough development, provided that it accurately
forecasts environmental conditions as they will exist after construction
of the topping plant. We therefore believe that it is desirable to
consider the environmental effects of the adjacent Golden Valley
Electric Association power plant operation together with those of
the ECA topping plant. This would serve to provide a more meaningful
measure of the impact of the proposed project, since the location
of the GVEA plant at the North Pole site has apparently been selected
on the basis of its proximity to the ECA facility.
In this context, it is erroneous to omit the considerable
emissions associated with the GVEA operation and compare only ECA
emissions with the existing "no build" background level in calculating
the percent of increase in pollution levels.
Further, it would appear that the calculated results for the
dispersion of water vapor in the topping plant plume could be signifi-
cantly in error when water vapor from the adjacent plumes of the GVEA
stacks is ignored—particularly since It is our understanding that
the water vapor in these GVEA plumes may total perhaps five times that
of the topping plant plume.
* It has been observed by members of the Pollution Control Commission
that, contrary to the implication of the Draft Environmental Impact
Statement, the plume from the Fairbanks city power plant does contribute
to the ground layer of ice fog under extreme weather conditions. Should
this occur with the plumes from the topping plant and GVEA stacks, it
is likely that the resultant ground level ice fog would move in a north-
westerly (downslope) direction towards Fairbanks along the populated
224
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Walter 0. Jaspers, Director Dec. 22, 1975 Page 2
Iarea near the Richardson Highway, rather than in a westerly direction
over the Tanana Flats as suggested by the Draft Environmental Impact
I Statement. Should this be the case, the ice fog would slgnlflcatnly
^affect both motorists and residents in the area.
The Draft Environmental Impact Statement analysis of ice fog
potential indicates that, for the assumed conditions of operation,
the threshold temperature for the formation of ice fog in the plume
would be about -30°F. This is similar to the -20'F to -30°F temperatures
at which ice fog usually begins to form in the Fairbanks area. Because
of our concern that moisture within the plumes could contribute to
the ice fog intensity at ground level, we believe that this analysis
should be extended to include a study of ice fog potential under
a range of temperature, wind, and operating conditions, rather than
the present study of only a single set of weather and operating con-
ditions. Certainly an analysis indicating an incipient ice fog condition
at -30°F does not serve to fully assess the potential for ice fog forma-
tion when, at present, such conditions usually do not become severe
unless temperatures are in the -40° to -60°F. range.
"""" In reviewing the analysis of emissions from the topping plant
stack as presented in the Draft Environmental Impact Statement, it is
evident that considerable reliance has been placed on the application
of EPA. dispersion models and handbook calculation methods. Because
of the unique conditions at the North Pole site, including the occur-
rence of extreme inversions and cold ambient temperatures, any calcu-
lation methods or assumptions that are applied under these conditions
are of questionable reliability unless a definite correlation is first
established between field measurements taken under these conditions
and theoretical results calculated from the models. We request that
documentation of this validation be included with the analysis.
As an additional consideration, it would be more meaningful to
use winter pollution conditions as the background levels in the Statement,
rather than those pollutants as measured in April, 1975—particularly
with regard to the level of carbon monoxide.
We again wish to emphasize the potential value of this Impact Statement
In guiding future development in the Borough. We look forward to the
publication of the final Statement for this project.
Sincerely,
CLJU'
Vern Carlson
Chairman, Pollution Control Commission
Fairbanks North Star Borough
225
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RESPONSE ID FAIRBANKS
NORTH STAR BOROUGH
POLLUTION CONTROL OMISSION
1. The combined effect of the two facilities on air quality was
assessed. However, EPA did not study the impact of the GVEA
facility, in combination with the ECA facility, on all other
environmental areas because (1) a draft EIS on the GVEA facility
will be published by Rural Electrification Administration in
March and (2) the two projects are not interdependent, although
if both are constructed they would be mutually beneficial.
Neither project is dependent on the other for operation.
2. Comment considered.
3. Comment considered.
4. It would be very difficult to validate any model for this specific
application prior to the construction and operation of the facility.
Please refer to comments made by the Department of Environmental
Conservation and to appropriate revisions in the text.
226
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TANANA -YUKON CHAPTER
Alaska Conservation Society
DEC 291975
Box 80071
College, Alaska 99701
j OFFICE Of FEDERAL tfFMMT
i
Decerber 22, 1975
Walter D. Jaspers, Director
Office of Federal Affairs, M/S 623
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Jaspers:
EncHosed are comments on the Draft Environmental Impact State-
ment for the Energy Company of Alaska Topping Pi! ant, North Pole,
Alaska submitted by the Tanana-Yukon Chapter, Alaska Conserva-
tion Society and prepared by Chapter member RJchard D. Seifert.
We hope you will find these comments useful in preparing the
Pinal Environmental Impact Statement.
Sincerely yours
¦i t
John A. Dunker, "'resident
Tar.ana-Yukon Chapter
Alaska Conferretion Society
Enclosures
227
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Dec. 21, 1975
The following is a listing of comments concerning the draft
environmental Impact statement (DEIS) on the EnergyCor.pany of
Alaska's proposed topping plant at North Pole, Alaska. Comments
will be indexed to the p'sge no. of the text which induced the coa-
inent..
p. *1-3: A generalization is cade in the weather description section
which states that weather is similar to Fairbanks in the KOrth Pole
area. This is hardly the esse. Because of its elevation and surround-
ing topograghy, North Pole is often 5-10 degrees coldter in the
winter during strong inversion conditions. Weather anomalies are
numerous in the Tanana Valley, As anyone who has bean here for any
time can easily observe. Precipitation is also strongly influenced
by local conditions*.
¦5
p. 50s Your ice fog/jis no longer valid. Ice fog is worse now than
most of the darkest predictions of what it would be like because
of pipeline activities. A week-long episode of ice f6g occurred
in October of this jtear and this reviewftr has photographs of ice
fog which occurred in early March of 1971. During a major period
of -^0 to *50 degree temperatures in early december of this ye&rr
the horthStarr borough issued its first ice fog hazard warning to
the public because, by its own measurements, visibility had decreased
to 75 feet in downtown Fairbanks. Last ytnr th& minimum visibility
measured w-*s 200 feet. Due to the truck traffic around the pipe
storage y^rd on the Steese highway north of Fairbanks, icefog has
incre*s»;d and the noxious *smell of unburned diesil fuel and diesel
exhaust is an ever present feature of that area now. Although it
cannot be substatiated, it is the opinion of the reviewer that
the refinery could be expected toproduce an even worse odor condition
Pi- 58: You state " Must of the Fairbanks- Korth Pole area is still
heavily forested and wildlife is plentiful." This statement is
simply not so, although r*m sure- many people believe it is. Many
residents of the area who have been here more than ten years will
agree that a steady declinfe in animals has taken place. Mbose in
particular have declined, and to such a degree that closure of the
moose hunting season early this year occurred, and the take in the
Tanana flats ( unit 20-A) w*«s only JO moose as opposed to last year's
approximately 300. This area is directly across the fanana River
from North Pole.
p. 62; The inferrence on this page is that the comprehensiue plan
of the Fairbanks .North Star borough had the industrialization of
the Worth Pole fre.- in mind v.ten it w^'s desired. You give them far
too much credit for foresight. If this were so,why is it necessary
for you to state on pnge l£6 " to avoid such l?nd use conflicts,
lands immediately adjacent to t:-e stte will probablybe rezonedfor
more- intensive use." Hot surprisingly, this conflicting statement
wfeiit unnoticed by the authors of theDEIS.
228
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p.2
p.100: Your statement: "EPA*s evaluation was limited to the prop-
osed first phase, of the topping plant.*
This npprosch to environmental Impact Is disastrous and one of
the major problems we' found In this DEIS. The establishment of the
topping plant will only be the planting of the seed of Industrial-
isation, By taking ench s*2a,ll phise sep^r^tely and ninimlzfcng the
impact It will create., the developments are treated -as though bh*y
i've -independent of er--ch other, vrhen it is obvious thst they sre
not. This sproach Is archaic *rul been «t the root o? r.sny
of tha major development problems in this country, including tirie
u-ij'n sprjiv/1, dac.iy of th*- Inner city, :>nd genera], ji stsrior.r ell. In AI^sIva We carts inly do not n=«d sn aavoc'tte
of questionable growth and development at a tia? ".vtfian the pressures
• isre nlready enormous for that uiy>??tnt«d gro"itli»
p. 103 " Hydrocarbon emissions o«n also occur as ? rsault of le
'¦135 frora process equipment and from storage• nn4 tsrfllrntlng facil-
ities, ECA h--s iridic¦¦?tad 'that these emissions will be controlled
by pro-.-ej* sel-votlon of equipment :Oid &ood maintenance practices*"
I certainly hops this is the c_;ae, becauaa it is very critical to
the health of the refinery workers and th? ooreaiunity *3 «>' whole.
The reviewer h-'-s voi'ked In' s. refinery a net is aw^ra they ara
:»rpp'i«ied vto fcherj« ooemesata,, It is cartalnly
obvious why this Information "v:if5'not include^ in the kELS, since I
doubt th»-t tUe EGA ev^n V.ncwe or oh res thnt this la so. Hoover»it
certainly behooves the ErA to include this study .1:1 -mEIS since It
Is obviously a con;? id tfr it ion o'f auverse and perhpp? urt^i voidable
envlronnental impact.
229
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P. 3
ACS comments
p. 133s The problem of Truck traffic possibilities was not considered!
I would refer to earlier consents which I m?'d« oon.cern.Lrvg the -ad-
verse effects of the truck traffic ^t the pipe storage yard on the
£teese highway.
p. 135 There is a comment here which is ft perfect example of how
out of touch with the publLc sentiaent and common sense the CJ5IS
really is. I quote," It is reasonable to expsct that if the topping
pl^nt is constructed, it will greatly enhance the city's attraction
as *1 prime growth area."
How sad it will be if that is the case. Again the DEIS comes
off sounding like a chamber of cocnierce endorsement of the plant.
The stable air of the Banana Basin precludes the ability of the
region to sustain more growth at a reasonable quality of atr rvn&life.
^hy would any rational person wish to stimulate further growth,
pollution and deterioration of the environment.
p. 15?! The possibility for incr^sed Incidence of some types of
lcs>r.cer should be included as an unavoidable impact.
"p. 159s The l?r,t sentence of th- first paragraph on this p^ge is/nonsense.
Lfeicnl planners in the borough ar* the most frustrated group of prof-
ess lone>ls I hnve £Xiir encountered. Their present role is only
advisory and they^io vested power or control, ^hat .gives anyone
th.- irlsa th^t they will be s'ble to determine future growth? After
all Ivjvo they excercised •*ny vanl influence over the citing of the
proposed topping .plant? The borough ¦¦tnd city councils both endorsed
fN project before' theycven had 3 comprehensive pl.-.n to kick around;
CUkOLUwIUG CufuvtwTS:
G*np-r*lly the fact that the E*-j» did not do its own work speolcs
for itself in both the point of view nnd the quality of the DEIS,
hopefully this will be ren»died an- o .rnore objective, up-to-d^ta
r-dfi coaplete fin*l impact statement will result. This impact state-
icant hr-s severely sh ken the coafi.;-:ncd of the reviewer in the EPA,
It is of utmost import ••nor th*t these statements be m?de with grent love
and care for the people and essence of Alaska. Nothing short of
this will be acceptable.
Most respectfully,
P .CSAJ&XL5LtT
Rich-;rd Seifort, nyr
The Alaska Conservation society
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RESPONSE TO
ALASKA COf*lSERVATIQ'i SOCIETY
1. Comment considered, appropriate changes made.
2. Comment considered. Odor from truck and automobile traffic can
bo significant under extreme winter conditions. See revision on
page 153.
3. Comment considered, appropriate changes made.
4. Refer to comment #42, Alaska Department of Fish and Game. The
intention of this statement is to alert planners and local decision-
makers of the trend which has occurred in other Indus trail zed-
urbanized communities. The emplacement of a single large facility in
an undeveloped area can significantly influence the future emplace-
ment of other facilities. In other words, such a facility can
greatly influence future land use patterns. The role of the planner
in North Pole is to determine whether or not this nattern of growth
is desirable.
5. Refer to response to comment #26, Fairbanks Environmental Center.
Your point is very well taken. We agree that this has been the
root of the many major development problems 1n this country.
While we can certainly learn from the experience of large metro-
politan areas, we cannot equate North Pole's situation with that
of these large cities. North Pole has already taken steps to
plan for growth, and the community is acutely aware of thp potential
problems associated with uncontrolled grovth. This awareness is of
paramount importance since effective planning is largely dependent
on active public participation. The City and Borough planners and
decisionmakers will closely scrutinize new development simply because
North Pole residents do not want their community to be a mere mirror
image of its urban counterparts and because the City cannot afford
to allow new development to diminish the existing quality of life.
6. Please refer to response to Alaska Department of F1sh and Game
Comment #4.
7. To keep things in perspective, the proposed topping plant is a
distillation plant without catalytic cracking units. The odor
from the large refineries you refer to is usually the result of
hydrogen sul ffde^S). We do not anticipate that odors will be
a problem for two reasons:
(1) the plant, being new, will incorporate the latest
technology to control spills and other leakage,
(2) the sulfur content of North Slope crude relatively
low.
231
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The information on the incidence of cancer (correlated with the
location of petrochemical industries) is not included in the EIS for
some very obvious reasons. This information was left out because,
in the context in which you speak, it is not relevant, and not
because ECA does not care or is not aware of such possibilities.
You express concern about control of hydrocarbon emissions at the
proposed topping plant and suggest that the EIS include as an unavoidable
impact the possibility for increased incidence of some types of cancer as
a result of exposure to such emissions. With regard to control of hydro-
carbon emissions, the Energy Company of Alaska plans to install floatirg
tank roofs on all tanks which store highly volatile materials and will
employ the latest spill prevention and control technology to control the
emissions.
We feel it is not relevant to add a statement of unavoidable impact
to the EIS based on the Hoover and Fraumeni study (Environmental Research,
9: 196-207, September 1975) of chemical industries you have cited
because the study is not specific to theggperation of the proposed
topping plant. Several authors, Ruggles— and Gloyna & Malina^ have
defined petrochemicals as compounds derived from petroleum or natural
gas hydrocarbons which are used in the chemical industry rather than
being primary sources of fuels or lubricants. The proposed ECA plant
will utilize a distillation process to produce heating oils, diesel,
industrial turbine and military jet fuels and asphalt; it will not
manufacture petrochemical products and cannot be categorized as a
chemical industry. The study by Hoover and Fraumeni analyzed workers
involved in the manufacture of specific chemical products; e.g. dyes,
dye intermediates and organic pigments; pharmaceutical preparations;
perfumes, cosmetics and other toilet preparations; industrial gases;
soaps and detergents; paints; glue; synthetic rubber and printing ink.
In addition, there are several factors that might limit the possi-
bility of Energy Company expanding their proposed facility to include
the manufacture of petrochemical products. First, a source of raw
material must be available. Second, the point of manufacture must be
close to the consumer. Third, the market must be large enough to
support a manufacturing facility of economical size (the larger the
size, the lower the cost per unit of production). In Interior Alaska
petroleum refine^ economics are most sensitive to the second factor
because of high surface transportation costs. Petrochemical products
would have to be exported if the Interior's demand for them were not
great enough to support an economically sized manufacturing facility.
The high transportation costs from Fairbanks to Anchorage would make
exporting economically unfeasible. See also discussion of future
expansion.
8. Refer to response to comment #10 from the Department of Environmental
Conservation and #18 from the Alaska DeDartment of Fish amf Game.
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9. This statement is intended to illustrate a point of fact. This
increased potential for growth is the exact issue at hand. Whether
or not this growth is desirable is an issue which mu§t be decided
locally.
10. See response to comment #7.
11. No response necessary.
233
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RECEIVED
NOV 2 01975
OFFICE OF
REGIONAL ADMINISTRATOR
Box 30^98
Grenac Hd,
Fairbanks, Alaska 99701
November 16, 1975
Dr. Clifford V. Smith, Jr.
Regional Administrator
U.S. Environmental Protection Agency
Region X
Seattle, Washington 98.IOI
Dear Dr. Smlthi
T have reviewed the above referenced ETS, and T have attended the
hearing held on the EIS at North Pole on the evening of November 12.
Due to the number of people present and my late arrival, I was unable to
testify. The purpose of this letter Is to bring to your attention
a few points that were not covered, or were Inadequately covered, at the
hearing.
1.) In the listing of earthquakes In the Fairbanks area on page 29 of
the EIS, the 6.1 to 6.5 magnitude earthquake of June 196? was omitted.
Moreover, the epicenter of this earthquake was in the Badger Road area,
which seems to contradict the statement also on page 29 that there are
no active faults in the area of the proposed refinery. The Geophysical
Institute of the University of Alaska has Identified an active fault
In the area of the 196? earthquake. Further Information can be obtained
from Mr. Larry Gedney of the Geophysical Institute.
2.) On page 153» the EIS states that odors will be minimized by proper
malntenence procedures. What guarentee Is there that proper malntenence
practices will be followed? Valves tend to leak. Pipe fittings and seals
may react In unknown ways to extreme cold. Problems are bound to arrise.
Trouble shooting can be time-consuming and expensive. How agresslvely
will the refinery managers seek to to correct problems?
The Fairbanks Municipal Utilities System new Chena 5 power plant is
capable of operating cleanly, but It rarely does. The almost continual
pall of black smoke over the community Is variously blalmed on bad coal
and Inexperienced workers. The spills associated with the Alyeska
pipeline project can be ascribed to similar sloth and mismanagement.
Official response to these environmental assaults does not give the
public much confidence that respon^tt&a. to chronic pollution will be
adequate. The ETS should address Itself to methods of ensuring proper
corrective measures and malntence should there be complaints of odors.
The proposed measures should recognize the political realities of the
fact that fifty Jobs will be held hostage to a possible shutdown of the
refinery.
The EIS should also present an Independent engineering analysis of
problems of operating a facility of complicated plumbing during periods
of extreme cold and in a climate characterized by wide variations In
temperature.
Re. Environmental Impact
Statementj Energy Company of
Alaska Topping Plant, North
Pole, Alaska
234
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3.) It appears that the Initial phase of the refinery will not have
a large impact on air or water quality. However, the probable cumulative
effect of all likely additional phases of the refinery and industrial
activity spawned by the refinery should be addressed. The approach that
each additional discharge can be analyzed In separate Impact statements
Is Inadequate, The cumulative effect of each Increment In industrial-
ization can have a de'vA.statlng Impact on the quality of life in the
Fairbanks basin — even though each Increment may be small percentage
of what has gone before.
The E.P.A. should condUpt an Independent analysis of Industrialization
likely to be initiated by the refinery. The synergistic effect of the
availability of North Slope natural gas should also be analyzed. State-
ments by E.C.A. officials that a topping plant would have no spinoffs
should not be taken at face value, because there are people on the E.C.A.
board of directors and \n the Fairbanks business community who will
not rest until the people of the Fairbanks community are brought gasp-
ing to their knees with industrialization. Literature and testimony
of officers of OMAR (Organization for the Management of Alaska"s Res-
ources), FIDO (Fairbanks Industrial Development Company) and the
Fairbanks Chamber of Commercefehould be analyzed concerning the intent
of the business community. Pc5r an analysis of the spinoffs of the refin-
ery and the availability of natural gas, T would suggest that E.P.A.
solicit the services of the University of Alaska Institute of Social
Economic and Government Research.
k,) Finally, the North Pole hearing revealed that there Is a signif-
icant number of people In this community who value a lifestyle which
they feel would be be degraded by the availability of the means for
achieving greater comfort., convenience and economic prosperity. The
issue is that J® of diversity verses uniformity. The ETS should con-
tain an analysis of the benefits and disbenfiflts of turning Fairbanks
Into a community like any other in the lower forty-eight. The,desira-
bility of choice in lifestyles should be discussed^n a n
The choices Involved In the refinery may be one of the most Im-
portant ever faced by the Fairbanks community. The Impact statement
Is presently the only vehhcl« for adequately addressing these Issues.
Tt is worth taking the time and effort to present an adequate per-
spective.
T thank you for your consideration of the Issues raised in this
letter.
Sincerely yours,
U, ¦ jA
Daniel W. Swift
235
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RESPONSE TO DANIEL SWIFT
1. Mr. Larry Gedney of the Geophysical Institute provided us with
additional information on seismic activity in the area. See
appropriate changes made on page 29. Mr. Gedney indicated that
the largest of the earthquakes, which occurred in June 1967,
registered 6.1 on the Richter Scale. This comment proved to be
very helpful.
2. Refinery managers will very aggressively seek out preventive
measures to ensure that time-consuming and expensive problems
do not arise. ECA cannot afford to build a facility which is
not designed to operate properly in cold weather.
The facility will be subject to inspection by EPA for compliance
with the Spill Prevention Control and Countermeasure Plan.
3. Comment considered.
4. Comment considered. It is because of this "diversity of life-
styles" that there were numerous people at the public meeting who
felt that the quality of their lives would be enhanced by the
proposed project and an equally large number of people who felt
that the quality of their lives would be severely diminished.
Refer also to response to comment #55 from the Fairbanks Environ-
mental Center.
236
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105 Stevens Hall, U. of A
Fairbanks, Alaska 99701
November 18, 1975
U. S. Environmental Protection Agency
Region X
Seattle, Washington 98101
Gentlemen:
As a concerned Alaskan resident for nearly 22 years, I am intensly
interested in the economic and industrial development that will befall
this state in both the near and distant future. As such, I studied a
painstakingly procurred copy of the Draft EIS concerning the propossed
topping plant of Ncrth Pole, Alaska. Consequently, because of the fol-
lowing discrepancies and inaccurately considered problems which could
(in my opinion) cause substantial negative impacts to the towns of
North Pole and Fairbanks, the entire Fairbanks North Star Borough,
and (in the long run) the people and natural environments of the en-
tire state of Alaska, I find that I must go on record as opposing this
topping portion of an oil refinery as now proposed.
I shall first view those inaccurately considered physical impacts
which I feel will definitely influence both the present social and
the present natural environments of the Fairbanks North Star Borough
and the entire state of Alaska. On page 42, the draft EIS states:
"Because of the scarcity of data on ambient air quality in North Pole,
R. W. Beck and associates conducted a background data study during
April, 1975." Further, only 10 continuous days of data taking were
used as the entire year-long parameter estimates of the (5 specific
and one general) pollutants to be emitted by the refinery. Statis-
237
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2.
tically, the use of this one 10 day group of data is completely in-
valid, as I an aure you are well aware. You may assume these para-
meters to be correct, but you may not instill any confidence in these
values. This is especially true since that anount of ice fog pollu-
tion present in April jls negligable when compared to ice fog and
pollution levels extant from November through February. Therefore,
irou may not correctly infer anything about ambient plus introduced
air pollution levels in North Pole other than during that stretch
of time in April.
Another interesting problem which was only lightly considered
:hroughout several sections of the draft EIS was that of the aerial
environment, and many of the specific environmental controls which
govern the degree to which the atmosphere is polluted. For example,
from page 46: "Wind speed is one of the most important factors in
the dispersion of air pollutants." Furthermore: "... the mean wind
speed at Fairbanks is below 4.5 miles per hour for the months of Novem-
ier through February. Horizontal wind speeds below 4.5 miles per
hour are generally considered conducive to pollution potential."
These statements, coupled with another from page 45 stating that:
"The complex wind patterns have caused serious concern among air
pollution researchers who contend that the air quality and meteoro-
logical information is (not) yet adequate to fully assess the impact
of the incremental expansion to the refining facilities at North Pole."
These statements would indicate that a good deal of additional research
should be carried out before the refinery is to be built. This, I
feel, is a very important point, since time is not the pressing issue
238
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in this case. I could not find a statement anywhere in the Draft EIS
pertaining to a shortage of the distillates which this plant will be
refining (producing). Only from page JL3 (a), did I find that the ma-
jor benefit to the public (consumers) would be a 5<; to 90 reduction
in price per gallon of these products. The preceding information,
coupled with the data from pages A3 and 49, which state that: "... the
winds are calm in Fairbanks 60 percent of the time." and: "... in
Fairbanks, (temperature) inversions at or near the surface are present
both day and night over 50 percent of the time from November through
February, and about 80 percent of the time from December through Jan-
uary." - would seem to indicate that any additional pollution added
to the atmosphere during these winter months would certainly increase
the danger of approaching or exceeding lethal toxic levels. T feel
that the inclusion of this hazard to the health of the citizens of
both Fairbanks and Morth Pole would definitely decrease the Benefit/
Cost analysis of the project.
The foregoing information shows, I believe, a lack of concern
for certain impacts to the quality of the air in both North Pole
and Fairbanks, but the following passage appears to exhibit a lack
of interest in exposing negative impacts which you might be aware of.
On page 106, the Draft EIS states that: "... during extended periods,
when deep layers of stable air conditions prevail, the plume will
move horizontally with almost zero vertical mixing for many kilometers,"
Continuing, page 126 further states that: the dry tower heat
rejection is just sufficient (theoretically) to unsaturate the stack
plume and prevent ice fog formation in the rang of 0.2 to 2.0 kilo-
-------
4.
meters downwind of the unassisted stack." However, no further state-
ment was made as to what would occur to the plume further than 2.0
kilometers (1.2 statute miles) downwind. In an informal Interview
with Dr. M.W. Payne, professor of geology at the University of
Alaska, Fairbanks, I learned that this column of frozen water would
indeed settle later, the settling time being a function of the wind
and inversion layer present. Therefore, 1 must assume that this plume
of effluent will definitely add substantial amounts of fairly pure ice
fog to the Xanana Valley, which serves to collect air pollutants e-
mitted by other sources such as homes and automobiles, thereby in-
creasing the pollution levels already present. At best, this appears
to be a large oversight on the part of the preparing EIS team.
If approved, another physical effect this refinery will have is
the discharge of effluent into the Tanana River. Two points are worth
mentioning here: (page 87) "Quantifications of the concentration of
a particular pollutant in untreated process waste water is difficult
since wide variation may be encountered, depending on the quality of
North Slope Crude, refinery technology and process efficiencies;" and
(page 98): "Estimates of the effluent temperature are not available,
but it is reasonable to assume that the discharge would be slightly
warmer than the river, with a more pronounced temperature difference
during the winter months." This lack of information, appears to
warrant further research since it is this permit to discharge efflu-
ent into the Tanana River which prompted the hearing in North Pole
on November 12, 1975. It would seem also, that this warm discharge
of effluent might possibly serve to keep more of the Tanana River
240
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from freezing over in the winter, which in itself could cause an increase
in the amount of ice fog present in the immediate vicinity of the re-
finery.
A final physical impact that was not considered was the future
effect on the entire state, both socially and environmentally, caused
by the probable increased construction of roads which would be made
possible by the availability of large amounts of cheaper priced as-
phalt that this topping plant will produce. Since there appears to
be no shortage of asphalt indicated in your report, I must again assume
that the refinery will only create cheaper asphalt, making new roads
a more economically feasible possibility. This is one area that needs
additional inputs from the people of the entire state before any pro-
gress is warranted; in my opinion, this availability of relatively
cheap asphalt represents a major impetus to the one entity (roads)
which posses a very real threat to the unwise development of this
state.
In studying the physical impacts of the refinery, I, for the most
part, considered the effects of the refinery's operation on the sur-
rounding environment. I feel that impact of special peritinence to
the social welfare of the communities of North Pole and Fairbanks also
need more consideration than was indicated in the Draft EIS. For
example, page 62 states: "The city of North Pole (1974) and the
Fairbanks North Star Borough Assembly ( June 1970) have passed separ-
ate certified resolutions endorsing the location of the refinery and
the GVEA power plant at the proposed North Pole site." This does not
seem wise (if at all practical) since the Draft EIS was not available
for public inspection prior to October 24, 1975. If thefeasic premise
-------
of a controlling majority is that the public is aware and thus able to
decide for Itself its future progressions, then it does not seem likely
that these referendums are valid.
On page 14, I find that: "Direct economic 'benefits' to the
city of North Pole include increased levels of employment, payrolls,
and real estate property tax." In contradiction, however, on page 145
I find that: "Since very few unskilled workers will be employed by
the plants, the industry should have no significant effect on unemploy-
ment rates." In other words, the people of North Pole can expect
little to no additional work opportunities from this refinery, and
this should be removed from the list of benefits accrued. Furthermore,
while enjoying no significant unemployment rates in North Pole, the
inhabitants of that community will be forced to compete with many new
workers arriving from the T.A.P. for the already limited services
and commodities. This will be further complicated by the fact that:
while the services for new employees and residents will be re-
quired immediately, additional revenues will not be immediately re-
cieved." (page 139). These statements indicate that the social impacts
to the people of North Pole will be highly negative and will definitely
not enhance the living conditions or welfare of the present community.
In fact, it may well deteriorate the economical situation there for
a time as well. This would occur because, along with the previously
noted impacts, page 145 states that ; "If most refinery employees
live in Fairbanks and commute to North Pole, there will be a leakage
of wages to the areas outside the North Pole community," And it
242
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7.
I appears likely that most employees will live in Fairbanks because of
yhe very limited supply of housing in the North Pole area.
a
On page 14, the Draft E1S claims that secondary benefits are
also expected. Secondary benefits may not be used in a Benefit/Cost
analysis since the U. S. Congress declared in 1946 that the U.S. is
at full theoretical employment. Therefore, there is no such entity
as secondary benefits as far as we are concerned.
Several places in the Draft EIS, the basic premise that industrial
growth is good is accepted. For example, from page 13: "The emplace-
ment of new industries and businesses could be a beneficial long-term
effect of the proposed project, if the development is carefully con-
trolled. further, from page 135: "It is reasonable to expect that
if the topping plant is constructed, it will greatly 'enhance' the
City's attraction as a prime grpwth area." These assumptions along
with several others Indicate that industrial growth is a desired pro-
cess here. This is an assumption which I must suggest is not necessar-
ily valid, because the quality of life enjoyed by the citizens of the
Fairbanks North Star Borough may well decline due to "the adverse effects
that the proposed industry will have on the environment. Since the
needs of the people are presently being taken care of in North Pole,
the only benefits accrued will be purely economical in nature, and
not directly beneficial to the people of Worth Pole as a whole. Also
form the Draft EIS I find on page 1^9: "Any new industrial growth
will however change the character of the city of North Pole." Since
small towns are often desirable only to those people who live there
243
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8.
due to their character, this refinery may veil obliterate the life-
style that the people of North Pole are seeking to promote by living
where they do. In reference to the study of the effects of industrial-
ization (on page 178) on other small towns, I feel compelled to ask
where those other towns were located. Were any of them located in
Alaska^ If not, what inference may be drawn from the value judgements
of people in the 49 other states geographically removed from this state,
pertaining to the acceptability of industrialization?
Finally, I must consider the impacts of the proposed refinery
stemming from its location, First, the aesthetic effects from that
parcel of ground will be largely removed, for even though there will
be a green belt of vegetation left around the refinery, there does not
appear to be any way to hide the two 70 to 80 foot high distillation
towers, the 150 to 200 foot high main discharge stack, and the plume
of effluent to be discharged from it. Secondly, from fig. 3 on page
24, one can see that this refinery is located immediately adjacent to
an existing or planned airstrip. This airstrip will no doubt have to
be relocated since the plume of effluent may well obscure vision in
that area, and the three high towers pose a definite structural hazard
to flying aircraft, especially during.instances of poor visibility.
In conclusion, then, 1 must go on record as opposing the awarding
of the permit to the Energy Company of Alaska for the allowance of
the discharge of effluent into the Tanana River. This is because
much of the information pertaining to the environmental impacts this
plant will have are either speculation or inadequately researched.
244
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9.
Also, since there is no acute shortage of any of these distillates at
present, i* is not mandatory that this plant be built before we can
fully assess the impacts it will have. It would seem to me, that
after all of the hasty, unwise development that has befallen the rest
of the U.S., we would tend to be more careful with our especially
fragile subarctic environment. In addition, after studying the
Draft EIS, 1 feel that a definite reduction in the quality of life
will occur in both North Pole and Fairbanks due to the disappearance
of many of the characteristics that made us choose this area as our
homes.
As a short-run alternative to this refinery, I would recommend
not building it at the present time at all. Instead, I feel that we
should probably attempt to endorse measures to conserve these rapidly
depleating resources, If the refinery must be built in the long-run,
then I suggest that alternate areas be studied which could better
withstand the environmental stresses that this refinery will put on
it.
Please respond if you have considered this testimony, so that
I will be aware that it was indeed considered. Also, please enter
my name on the list of interested persons wishing to recieve a copy
of the Final Copy EIS.
Sincerely
Dan Huttunen
245
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RESPONSE TO
Ml HUTFUEfJ
1. Please refer to response to comment #4 from the Fairbanks
Envi ronmental Center
2. See appropriate changes made on page 100A and 100b. The increase
in numbers and use of automobiles in Fairbanks can contribute
that incremental amount of pollutant (particularly CO) to the
atmosphere during winter months, under extreme inversion conditions,
which would certainly increase the danger to the health of citizens.
3. Comment considered.
4. This information has been incorporated into the final.
5. Comment considered.
6. In regard to the validity of the referendums (resolutions) passed by
the Borough Assembly and City of North Pole and to the validity of
the FNSB Comprehensive Plan, see response to comment #12 from
Fairbanks Environmental Center.
7. While unemployment rates will not be significantly affected, the
total employment figure will be positively affected as more people
join the total working force in the Borough. Levels of employment
should certainly increase, however unemployment rates would not
necessarily decrease.
8. "Full theoretical employment" may have been reached in 1946, however
the population has greatly increased since 1946.
"Benefits" has been revised to read "effects."
9. The basic premise is that industrial development can be beneficial
to communities in the long term if properly planned for. We do not
assume that uncontrolled industrial development is desirable for
North Pole.
There is an inherent value in looking at the experience of other
developing small towns in the lower 48. Knowledge of these
experiences can serve to warn residents and planners of the changes
which may lead to increased problems rather than new solutions. We
feel that such information can help in saving small communities from
becoming poor duplicates of their urban counterparts. We do not
doubt that a "clean" industry would be more desirable for North Pole,
however such industries, like other industries, do rely on large
market areas, efficient modes of transportation, and in all orobability
a work force which would equal that of ECA.
246
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The EIS does state that the stacks will be visible from several
vantage points. Refer to comment #7 from the Alaska Department
of Highways.
247
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\b* '3
Fairbanks, Alaska 99701 ^
P. 0. Box 80148 j*1
November 18, 1975
Mr. Walter D. Jaspers, Director
Office of Federal Affairs, M/S 623
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Jaspers:
In response to your request for comments on the Draft Environmental Impact
Statement on "Energy Company of Alaska Topping Plant, North Pole, Alaska," the
following thoughts are offered. My remarks are based on observations at the
November 12, 1975, North Pole Public Hearing and on a lifetime in Alaska, of
which about forty years {exclusive of World War II years) have been in Interior
Alaska. I am not commenting on each specific statement made in the statement,
but rather I am giving my overall impressions.
Fundamental is that geologically and biologically the earth, as we know it, is
changing day by day. Human civilization on the earth requires resources to
allow the individual to survive—thus, farm products in the broadest sense
along with energy and mineral resources must be provided and when this is done
some environmental changes {certainly not all for the bad) take place.
in Alaska, as well as specifically Interior Alaska, resource development is
essential to give economic strength that will allow the people of the State to
live with today's standard of living and work toward a better society for the
future generations. Alaska's current adverse financial condition is clear indica-
tion of the need for such development and the well advertised possible shortage of
electrical energy in the Fairbanks area this winter further emphasizes this need.
Generally, the people of North Pole indicated this in the testimony presented at
the Public Hearings. They are and have been on the ground for numerous years and
have well stated their desires for a topping plant with appropriate and realistic
controls and I believe that their thoughts should be given major consideration.
In reference to the various comments made about information in the EPA draft
being out-of-date or inaccurate, I do not know the validity of each of such
remarks, but feel that all such accusations may not be absolutely accurate.
However, I suggest that each item be reviewed by EPA working with Energy Company
to assure that the information is accurate and factual. In other words, responses
can be made to the numerous type of remarks that attempted to show the draft
report was not sound. In this way, a solid presentation will result that will
most likely be supported by many people.
Changes in the environment are inevitable as long as people occupy the earth;
accordingly, I sincerely hope that EPA recognizes the need for this facility and
through its good efforts, help solve and resolve those problems that appear to
be obstacles. In this way, the people will have the industrial development neces-
sary, as well as giving due concern to the environment, pollution, and land
rehabilitation.
-------
Mr. W. D. Jaspers
Page two
November 18, 1975
I would appreciate receiving a copy of the final or next Environmental Impact
Statement. Also, I commend EPA for sponsoring the hearing that brought thoughts
of many people into the open.
Finally, for the good of th£ community and State, I strongly support the con-
struction of a Topping Plant as soon as possible and hope that the project is
not delayed due to the tactic of requiring additional unwarranted planning
detail.
Sincerely,
Earl H. BeistTine
EHB/jc
cc; Fairbanks Chamber of Commerce
North Pole Chamber of Commerce
Mr. Rod Bouchard, Energy Company of Alaska
2A9
-------
RESPaiSE TO
EARL H. BEISTLIfE
Mr. Beistline's comments present a point of view that has been
expressed by many concerned Borough residents. His perspective on
the potential benefits of the proposed project is, like all other
letters included in the statement, a valuable addition.
250
-------
0^
November 20, 1975
Mr. Walter 0. Jaspers, Director
Office of Federal Affairs, M/S 623
U.S. Environmental Protection Admin.
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Jaspers:
I have reviewed the Draft Environmental Impact Statement for the North
Pole Refinery, Using the EPA's method of rating I give it an LL01.
Those who prepared this draft are to be complemented pn a good report,
I'm syre you discovered at the public meeting that there is considerable
:unpublished information concerning air polution and icefog in the Fairbanks
basin. I'm sure you'll be considering this in your final statement and
for that reason I'd appreciate a copy of the final for my future reference.
In preparing the final, I think the current threat of insufficient
generating capacity in this area should be stressed. Then tie in the
refinery to GVEA's plans for their new generator in the North Pole area.
In addition it could be pointed out that the refinery could produce fuel
faster than power companies in the area could use it (I assume this is
true). That in itself eliminates one cause for power shortages (lack of
fuel). When it's i&0 below and the entire area depends upon electrical
power it is only prudent to eliminate as many notential cause of failure
as possible. Perhaps the damage from a prolonged power outage could be
assessed in dollars and compared to the other vague environmental effects
that may or my not occur. A comparison of the likelihoods of each and
the cost, whether it be in loss of fish in the Tanaria or loss of visibility
from icefog for short periods may shed a new prespective. We may well
be considering trading several days of reduced driving speed for frozen
pipes, loss of business, and damage of goods. Such a power loss or
limited generation capacity also effect the community's ability to draw
in new industry into the area. While this effect is moot, since the
community itself will have to decide whether or not it wants new industry,
it should be addressed. It should also be stressed that icefog from
cooling sources is not dangerous to the health, other than contributing
to accidents because of reduced visibility. I for one would rather drive
slower than replace pipes, comodes etc. The promise of at least a pause
in the escalating cost of fuel is also welcomed from me.
In closing I support the project because it will make the power companies
more reliable and it may make the economic ba^e a bit more stable.
Sincerely,
Bob Thomas, P. E.
cc: Or. William Wood
257
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RESPONSE TO
BOB 71IOWS, P.E.
1. The comments on air pollution, climatology and ice fog have been
considered. Appropriate changes have been made in the EIS.
2. Your comments on this matter are highly persceptive and are a
valuable addition to the EIS.
There is definitely a need for a reliable power source, and this
need can be fulfilled without significant deterioration of the
environment if future developments are carefully controlled by
effective planning. GVEA can obtain fuel from the Kenai Peninsula
if the topping plant is not constructed, however the cost of
transportation will reduce the cost-effectiveness of the facility's
total operation. GVEA can continue to operate the power generating
facility without the topping plant, however a topping plant located
adjacent to GVEA would make for a more desirable situation as both
facilities will be mutually beneficial.
252
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P.O.BOX 2B« ARR INDUSTRtAU ABEA
FAIRBANKS, ALASKA »«701
November 18, 1975
Enviornmental Protection Agency
Region X
1200 6th Ave
Seattle, Washington 98101
Gentlemen:
Please accept my written testimony in suppqrt of the Enviornmental
for the North Pole Refinery prepared by your
office and the Energy Company of Alaska.
ai-i are aWare of the m^nor discrepancies in this report that
were well documented at the public hearing held at North Pole on
were wexx uu^u SDite of these, an examination of your
S^L^cates io £e ?ha? pollutants discharged, both
oaseous and liquid, would be relatively insigmfxcant percentages
of Federal and State standards even if the models were grossly
mLc^culated. These ^e^S^deSy
^^rofaaapfrSi?9tohethf Energy Co.p.^n
asterous Enviornmental consequences. Let me explain...
T large number of concerned people jn this arjery
hard to develop a strong financial community for the North Star
Borouah The need for this is obvious; at present we rely almost
exclusively upon Federal and ?tate payrolls «»££> -d re-
search qrants to maintain a minimal standard of living m this
Historically the economy Ifiere has been so poor that
5e™ Sftli year our children have been forced to leave Alaska to
SSek ^bread and butter' employment 'outside'. We have been unable
to develop a tax base large enough, even, to support our efforts
at reducing Enviornmental Pollution (i.e. mass transit, parks,
traffic flow improvements, malls, etc).
are not working at the development of our economy at the expense
of lur enviornment, rather we are wooing to enhance our enviornment.
'we have lived here a long time ^nd will encourage our children to
because we appreciate otir clean air, land, and water. We
sincerely Sant to keep Alaska unspoiled by Industrial pollution.
It is fo? this reason that we encourage your office to approve
this EIS in a timely manner and a^lpw construction of the North
Pole refinery asap.
with the refinery in operation the North Star Borough can develop
its full potential as the transportation and distribution center
for Centaal and Northern Alaska. The refinery will provide badly
needed heating oil and erergy for large warehouse complexes,
253
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PHONE: 452-11*1
P.O.BOX ZBS ARR INDUSTRIAL AREA
FAIRBANKS, ALASKA 99701
Enviornmental Protection Agency Page two Nov 18, 1975
desperately needed fuel for commercial trucking to move supplies
over existing roads, and fuel for aircraft to fly people and
supplies into isolated outposts in Alaska.
On the other hand, if the refinery is delayed our enviornment will
be seriously threatened. The opportunity to selectively encourage
light industry, warehousing and distribution in our area will be
lost to more aggressive Alaskan communities. Just consider the
effect this would have on our lan^s. If economical fuel is not
available for aircraft to supply transportation to outlying areas
we will be forced to build roads and despoil our virgin wildernesses.
If our efforts to develop light industry are unsucessful we will
be forced by economic hardship(maybe New York style bankruptcy)
to develop any industry that presents itself, regardless of its
effects on our enviornment.
I strongly urge that your office approve the North Pole refinery
EIS without any further delay, I urge you to encourage speedy
construction of the refinery/ and I ask for your assistance with
our efforts to selectively develpp light industry in the Fairbanks
North Star Borough. With your help, our children will find jobs
available in this area, they will become productive members of
OUR community, and they will enjoy the same clean unpolluted enviornment
that we are so very proud of today.
Sincerely,
Dennis M. Schlotfeldt
2764 Totem Drive
Fairbanks, Alaska
p;:.' ^
NOV 2 4 1375
254
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RESPONSE TO
EENNIS M. SOjlOlPELDT
The comments made by Mr, Schlotfeldt have been considered. While
there is no Congressional directive which allows EPA to determine what
lands should be put to what uses, EPA does encourage elected officials,
the public, and other planners to define or redefine land use goals and
to adopt effective growth policies which will ensure that development
of the Borough's economy will not proceed at the expense of a clean
environment.
255
-------
Bertold Puchtler
3\ mile Coldstream
SR Box 20256
Fairbanks, Alaska 99701
December 8, 1975
Dr, Clifford Smith
US EPA
1200 6th Avenue
Seattle, Washington 98101
Dear Dr, Smith:
This letter is in reference to the EIS for the North Pole Refinery.
I recommend that EPA explore in greater depth secondary adverse effects
this refinery is likely to have on the Fairbanks environment. Alternate
locations for such a facility must more seriously be considered.
The EIS supports construction of the topping plant because of
strong positive benefit to fcks North Pple^d.the Borpi^gh. Such
strong positive benefits are far from ctrtain^yTfe/the plant were to be built
elsewhere, say south of Delta, such positive benefits would still
accrue to Alaska without burdening the Fairbanks vicinity with the
additional people and developments and pollutants.
Ice fog, as such, is not generally defined an air pollutant; yet within
the local context, as the intensity of the ice fog increases from year to year,
it is becoming the single most objectionable feature of the Fairbanks
winter. There is no doubt that the topping plant will add to the ice fog
kHXHst burden of the air shed. And if a major portion of the increase in
ice fogdoes not come from the topping plant directly but from concomitant
population and industrial growth, then this latter contribution can
not glibly be dismissed as a matter to be dealt with locally, by careful
Borough Assembly action and thru Planning and Zoning.
Sincerely youa^s,
i5t,/ /
Bertold Puchtler
256
-------
RESPONSE TO
BERTOLD PUOfTLER
1. EPA did not find the proposed site to be unsuitable for construction
of the topping plant. Economic benefits are cited as positive
benefits because of the proximity of the site to major marketing
areas. The discussion of site selection points out that there are
other sites which are more suitable in terms of air dispersion
characteristics. In terms of overall suitability, however, the
North Pole site is most suited for this use. ECA has strongly
emphasized that "such positive benefits" cannot benefit Alaska
if finished products must be transported long distances by truck,
2. Comment on ice fog considered.
While EPA, other Federal agencies, and the State can offer technical
assistance and, under certain circumstances, special funding,
acceptable limits to growth must be decided locally. Refer to
response to comment #26 from the Fairbanks Environmental Center
(4th paragraph). $ee also comment #35 (FEC) and #5 (Alaska
Department of Environmental Conservation).
257
-------
*Dfiomai Q.. aMj-^Lauitdt
£j cztyxi.oaiat&i.
Post Office Bo* 1
Fairbanks, Alaska 99707
Area Code 907
452-5503 - 452-5571 - 452-5574
December 8, 1975
U. S. Environmental Protection Agency
1200 Sixth Avenue, /S623
Seattle, Washington 98101
RE: 10FA - M/S 623
Dear Director:
I appreciate the opportunity to be able to respond to your notice of
October 28 inviting comments in reference to the issuance of new source
NPDES permit #AK-002546-l to Energy Company of Alaska. This permit will
allow discharge of waste water from E.C.A.rs proposed topping plant into
the Tanana River.
I would consider the draft impact statement issued by your agency well
done because it encompassed thought and attention to more than just
theoretical perfection which is impossible to achieve as a practical
measure while certain negative factions hold that is the only way.
The statement in its reasonable approach covers the areas that are re-
alistic, the aspects of our times and the attention to human needs that
should be considered at present.
One finds today that humans are willing to accept reasonable proposals
that will generally satisfy their needs, that allow for normal growth
and economic development and still not relegate the future to lower
quality living. In other words, people today want to preserve life for
today and tomorrow, and their attitudes toward conservation are no less
than the perfectionists who insist on precipitous action without allowance
for human needs and economic conditions. All conservation can be achieved
reasonably while giving satisfactory attention to all aspects that demand
it.
Your impact statement embraces these aspects commendably. I heartily
concur with your action and urge the issuance of the above mentioned
permit to Energy Company of Alaska.
Sincerely,
TJM/jf
258
-------
RESPONSE TO
TllOWS J, MIKLAIJTSCH
1. Comrnent considered.
2. One important result of the EIS process will hopefully be a
better planned, better designed project that will "not relegate
the future to lower quality living" for the majority of people
living in the area.
259
-------
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260
-------
COMBAT TO
MRS, FRANCES G, CORK
1. Comment
2. Comment
considered,
consi dered.
261
-------
QujuamA AFA
OEC 1 6 K76
December 10,1975
Director of Public Affairs,
U.S.Environmental Protection Agency,
1200 Sixth Avenue,M/S 605,
Seattle,Wn. 98101
REF: Refinery at North Pole,Alaska
Dear Sir:
I am taking this opportunity to write in
in reference the plans of Enercoa to build a refinery at North Pole.Alaska.
First, may I present my credentials? 1 am a graduate of the University
of Alaska,School of Mines,Mineral & Petroleum Technology with graduate study
in Arctic Engineering. 1 am a member of the Alaska Miner's Association, a
member of the North Pole Planning Committee and have been busy at construction
and mining projects in Alaska since 1967.
[As a private citizen living in the near vicinity of the proposed
efinery, I have to say that I have spent quite some time in studying this
proposal and feel that the project is well planned with a very limited
impact on the environment locally.
There can be no doubt as to prevailing winds in this area as 1 have
taken steps to inquire from long time residents of the area. Outside from
a temporary wind reversal, the main airflow is to the South-West out over
the Tanana River and the Military Bombing range. Should there be any ice-fog
created by the refinery, it will in no way affect the North Pole, Fairbanks,
or Eilsen Air Force Base air quality.
There should be little or no creation of ice-fog by the refinery.
Using a 200 foot stack,along with the air currents from the air coolers
the process should produce no local air pollution. Flaring of excess vapors
will be practically non-existent during winter months as the design of the
floating roofs on tankage tends to suppress vapors and any flaring,even in
the summer, would only be of short duration.
There has been some local concern about objectionable smells issuing
from the refinery. Most refinery smells are generated from the hydrogen-
sulphides in the crude oil. It is a well known fact that Prudhoe Crude is
very low to non-existence in hydrogen-sulphides and so there will be a min-
imum of objectionable smells originating from the refinery.And should any
smells be generated, the local wind and direction will divert them from the
populated sections of North Pole.
262
-------
Energy Company plans to discharge water into the Tanana River
should pose no environmental problems. Particularly in light of the fact
that there are many springs discharging directly into the river at temp-
eraturs of 34 to 38 degrees Fahrenheit. These places never freeze over in
the winter. The large mass of water coming down the river will be more
than able to break up the discharge flow from the refinery in short order
to prevent open water and associated biological problems. In as much as
the Energy Company plans to also disdiarge treated storm waters from dike
areas and work areas(which practice is not in use areund Fairbanks)any
pollution from the entire should more add to the care taken of the local
environment.
During the public hearing at North Pole, most of the objections to
the refinery concept were from the University of Alaska group who are not
living in the North Pole area. In fact the majority of the group do not
even own personal transportation and the degreed members of the delegation
are of the zero-growth persuasion. They could care less whether the
majority of people In the Interior have to operate vehicles that are fueled
with Anchorage based gasoline prices. They live in the close vicinity of
Fairbanks so their fuel bills are much less. I might also point out that
their expertize has made no improvement to the air pollution in Fairbanks,
College or at Ft. Wainwright, and here they are trying to solve non-existent
problems for us here in North Polei
Those persons of the zero-growth persuasion fail to realize or under-
stand that this area, particular the North Pole area, is growing due to
population pressure coming from people who cannot acquire land in the Fair-
banks area. Change is upon us and it is up to us here in North Pole to
take steps that the change is in line with our concept of what we want
Noeth Pole to be, and my I also point out that we have the best interests
of everybody in this area to heart and we have the expertize to do the job.
The North Pole area can only gain from the building of a refinery in
our area. It will mean more tax income for the city to give more services
to the people which they are not receiving from the North Star Borough.
The fire department from the refinery will be a backup for our ovm small
fire department. This area,as long as I can remember has been subject to
frequent power outage as we are on the tag-end of G.V.E.A's distribution
system. Should the refinery be built, G.V.E.A. will also build a new power
generation plant adjacent to the site to take advantage of the close source
for generation fuel and diminish our power problems and preclude fuel
shortages they have been experiencing over the past few weeks.
I sincerely endorse Energy Company of Alaska's plans to build a
refinery at North Pole and urge your agency to ipsue the necessary permits
to allow them to do so.
JinMirftlv Y/v ira
Box 1479
Fairbanks,Ak.,99707
-------
RESPONSE TO
F, WAYME JONES
1. Comment considered.
2. There is evidence which supports your observation.
3. Comment considered.
4. Comment considered.
5. Comment considered.
6. Comment considered.
7. Comment considered.
8. Comment considered.
264
-------
FAtRBAyKS OFFICE
Edward A. Merde*
Grace Berg Si-haible
Howard Stnley
Denni* E. Cook
Monroe N. Clayton
ANCHORAGE OFFICE
Stephen S. DeLisio
Alan Sherry
Henry J. Camarot
uMtk Ui UFA
I6«i
OfcC
LAW OFFICES OF
MERDES, SCHAIBLE, STALEY & DeLISIO, Inc.
A PROFESSIONAL CORPORATION
POST OFFICE BOX 810
FAIRBANKS, ALASKA 99707
December 10, 1975
300 Barnetle Street
Telephone: (907) 452-185J
Cable Addreti:
M Eur AIR
Director of Public Affairs
U. S. Environmental Protection Agency
1200 Sixth Avenue, 605
Seattle, Washington 98101
Re: North Pole, Alaska Refinery
Dear Sir:
This letter is written in support of a go-ahead for the North Pole Refinery.
The undersigned is the property owner of a 7,000 acre agricultural devel-
opment in Central niaska growing barley, oats and animal feed. My part-
ner and I have been in business six years and during this time purchased
many, many ton3 of commercial fertilizer.
In addition, our operation produces all the straw mulch requirements
prescribe d by the FPA for re-vegetation and erosion control on the Alaska
pipeline. A by-product of the North Pole Refinery will be ammonia nitrate
chemical that can be used for fertilizer production. In the future we are ad-
vised there are plans to build a fertilizer plant once natural gas is available.
Alaska's food needs, particularly red meat and animal feed, can be efficiently
produced in C.:::rtral Alaska, thus could provide food self-sufficiency for this
state. All Alaska's red meat is imported. In the event of any natural calami-
ties in the corn belt, such as the 1932 brought, Alaska being at the end of
the food chain, will suffer the most. Hence, we are working with the state
in planning to develop agriculture as one of Alaska's major renewable resources
The North Pole Refinery will be an integral and vital part of this planning and
for the food production industry.
With the construction of the North Pole Refinery and possible additional petr-
chemical complexes which can produce fertilizer, Alaska's agricultural future
will indeeci be bright.
All local farmers I've spoken to support the North Pol? Refinery for it is the
only practical source of reasonably priced fertilizer.
Sincerely yours,
MERDES, SCHAIBLE, STALEY & DeLISIO, INC.
By
Edward A. Merdes
a jjeuioiu , hn<
EAM: ret
265
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RESPONSE TO PERES,
SCHAIBLE, STALEY, and DELISIO, INC,
1. ECA has indicated that there are no certain plans to manufacture
fertilizer. With the availability of a primary source of fuels
and natural gas, however, fertilizer can be produced. Whether or
not an industry of this nature is desirable must be decided by
local decision-makers. Such a facility must obtain appropriate
permits and undergo evaluation by the State, EPA, and other agencies
before it will be allowed to operate.
2. Comment considered.
266
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7Cl£ - 18th Avenue
Fairbanks, Alaska 9°7.01
Deoembey'lSt""1975'
1
Walter D. Jaspers, Director
Office of Federal Affairs, M/S 523
U.S. Environmental Protection Agency
1200 Sixth Avenue
deattle, '4ashington 981C1
<®CE OF FEDERAL AFFAlt#
0EC221975
t
Dear Sir*
Trie days have passed into 'weeks and now over z month has lapsed
since the1 public meeting was held at the Porth Pole Elementary I-'ulti-
pur.oca rtoom regarding the Draft Environment!? 1 Impact Statement on
tae permits for Energy Company of Al^sKa's proposed topping plant.
It ass been an interesting period; what if we would have had. the
topping plant or worse yet the refinery that is to follow in operation
at liortn role during the two weeks of irinus tC and jO degree weather
and colder? The Draft Impact Statement did not have the benefit of
such a recent cold snap, for it has been several years since we hove
h'?d such weather for an extended period. During the we^ks since the
meeting Golden Valley Electric has (1) a nr. ouncjed a critical energy
shortage which was then supposedly averted by many sources coming
to t'-^eir aid, (2) announced that in a couple of ye^ra when they have
benefit of E3A' s fuel supply for their generators we will be p-ast the
-•rial 3 period, '.fna t subtile brainwashing I Will ' h" Er:vi ron-.ental
Protection Agency allow such poor planning by C~V~;A to atcnpe-Je us
into a project whose real and total iaspsct has not yet been clearly
defined?
Interestingly enough a good Je^l of the testimony given at the
November 12 public meeting was not addressed to the issue of the
Impact Statement. Why not? Because the Draft Environraenty.1 Impact
Statement was not readily available to the many eople >iho were ob-
viously interested in it. If people did not hsv;i the opportunity to
read It or even see it prior to the eeting, it 13 :nall wonder that
t.ieir testimony was not addressed to th-- I.-ip'--ct 5t.a tement, but rather
reduced to emotional pleas of "I want trie Norgn Pole Refinery." or "I
don't want the .North Pole Refinery." There Is nothing like the lack
of information to make people feel tnreatened — both sides'. And
Past lack of information was EPA's fault.
fortunately, I was on your mailing list and had the opportunity
to read the Environmental Impact Statement. 1 am not scientifically
informed enough to question most of your facts, out I did come to trie
meeting with questions which I had ho. ed would bn answered in a pre-
sentation by the writers of the Draft 3ta.ter.ent. Instead, however,
the only real sources of information were from those giving testimony
and waose credentials I did not always know. I -3s appalled by what
I-Ir. Tom Scarborough pointed out in his testimony; how can you claim
to have done your job if In fact what he stated is true? With great
interest and respect I listened to the testimony of Dr. larl Benson;
will you not consider his knowledge more valid than that of the
resident of North Pole who does not renlly know what may be involved
end only knows that if it me-ris money in sis jV'Ct, th * .viviror. Tpnt
he dv:-" '1V
-------
page 2 — Korth Pole, Alaska, topping plant proposed by ECA
My own questions as I read through the Draft ^environmental
Impact Statement were many, too many to go through. In such a letter-
because many of them are due to my own limitations rather than any
deficiencies on your part. But some of them regard what seems to
me basic information which has not been collected. For examples
(1) If EPA's evaluations cannot state conclusively the impact on
the ambient air quality, how can it discuss economic benefits; is
it economically beneficial if we experience increased health hazards
in the forms of water and air pollution? (2} Earthquake data shown
on page 29 was out of date; what -has happened In trie last 12 yr- rs?
I KNOW there have been earthquakes during that time that should be
listed because I've been here to personally experience the tremblers,,
(5) The temperature ranges given on page 43 are for FbI-banks: it is
J--viown that North Pole experiences much colder temperatures during the
winter, but where has that been considered? (4) It seems to me that
the critical housing shortage and the limited availability of essential
services in some areas of the Fairbanks North Star Borough have been
dealt with far too lightly; as a member of the borough's Pipeline
Impact Advisory Committee I am acutely aware of their severity and
of the human problems that are a result of these shortages. Health
services are currently being strained; our one puolic hosoitsl is
oeing used beyond the capacity level of greatest effecieney. Oan
vie afford to add to the stress not only with numbers of people but
also increased health hazards? (5)The Draft does not satisfy me that
enough consideration has been given to the impact on the air equality;
the density of the ice fog during our recent cold led the borough
mayor to call the first alert ever for this reason: we experienced
a carbon monoxide caused air quality alert too. Oan ISP A really say
tciat they have shown in their statement that we can afford to add
any contaminents to our air by any new source?
3T This proposed Topping Plant is but the first step in a. series
proposed by Energy Company of Alaska. Oan vie really l---t them conti-
nue to ma>e plans and invest their good money in a project of such,
a questionable future?
Sincerely
Lealye A. Korvols
268
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RESPONSE TO
LESLYE A, JORVOLA
1. The need for fuel is only one of the many factors involved in
the evaluation of the impacts of the refinery. While the EIS
attempts to deal with the anticipated impacts in a holistic
manner, the "real" impacts cannot be fully known until the
facility begins operating in this subarctic locale. This difference
between "real" and "anticipated" is important.
Anticipated impacts can be generally dealt with by proper planning,
design and control, however real impacts have presumably already
occurred. At the present time the real impacts that North Pole
and Fairbanks are experiencing are the result of the Trans Alaska
Pipeline construction and the rapidly growing population.
2. The Draft EIS was available for review at both the Fairbanks and
North Pole libraries. Over 200 DEIS1s were made available to the
public. The public meeting was intended to be a public information
meeting to benefit t'na public, EPA, and other Borough and
State officials.
3. Please refer to response to comment #4, Alaska Department of Fish
and Game.
We do not consider the knowledge of one citizen more imoortant or
valid than that of another. If a public participation meeting or
program is to be what it is defined to be we cannot place emphasis
on well-documented, scientific presentations. Such an emphasis
will, without question, build in a bias for only the well-funded
interest groups. The democratic philosophy in nlanning stresses
that all people be involved in decision-making, not just the more
well-equipped or well-prepared special interest representatives.
It is extremely important that planners use values in the development
of planning alternatives.
4. Please refer to responses to comments from the Fairbanks Environmental
Center. In particular, see paragraph |4, comment #26 and #35.
5. The two phases proposed by ECA includes the plant as proposed and
the addition of a Hydro Treater and Reformer.
269
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December 22, 1975
I—"
*v 0 w
f DEC291975
OFFICE OF FEDERAL AFFAIR#
December 22, 1975
Walter, D. Jaspers, Director
Office of Federal Affairs, M/S 623
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Jaspers:
As a resident of North Pole I would like to voice my objection to the
location of The Topping Plant of Energy Company of Alaska in North Pole.
I feel the draft environmental impact statement is inadequate and does
not meet the requirements of the National Environmental Policy Act of
1969.
Large portions of the impact statement appear to have been adopted
directly from the, applicant's assessment. It is the responsibility of
the agency preparing the statement, in this case EPA, to provide
a factual descriptive analysis of the applicant's proposal and all other
alternatives. In this statement the modelling program prepared by the
applicant is adopted, but then a qualifier "The results of EPA's
evaluation, however, can not be stated conclusively because of the
adequacy of applying current modelling techniques to an area with
extreme atmospheric stability and unique climatic conditions jis question-
able" is added. This leaves EPA an out, but what about myself and other
residents of North Pole? What if this model isn't applicable and re-
finery emissions lead to serious environmental and health hazards?
If EPA is going to include this qualifying statement, it is then it's
responsibility to consider alternate models, or to evaluate the impact
assuming the proposed model is not appropriate. The model may be the
best EPA has, but it may be wrong. A draft impact statement should
evaluate that potential impact.
EPA's evaluation was limited to the proposed Phase I of the topping
plant. Even though the applicant repeatedly alludes to future expansion.
Allowing this piecemeal approach of evaluation and permitting precludes an
assessment of the overall impact of the project. If ECA is planning a
refinery complex that is at any stage unsuitable for their North Pole
location, alternate locations should be considered now. If Phase I
is built, it won't be moved. Realistically, an approval of Phase I
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is committing the community to more than just a topping plant. I can
envision this scenario: Phase I is built. The applicant has $25-30 million
invested but finds Phase I economically unjustifiable. It needs Phase II
to remain solvent. Environmental standards are relaxed or the price
,of existing products goes up.
If ECA wants to expand this facility in the future, and there is every
indication they do, then the time to consider t}ie impact of the total
facility is now, not after North Pole is subjected to Ph^sp X.
I recognize the importance of petroleum products and their high price,
to Interior Alaska, but I question the location of a topping plant
in the Tanana Valley. The impact statement considered only those
alternate locations that the applicant considered. There was no
factual evidence provided to support the dismissal of any alternatives.
It is acknowledged that the extreme air stability of the Tanana Valley
aggrevates air pollution problems. Perhaps any additional cost of
another location would be offset by reducing future emission control
costs? At a minumum factual evidence should be presented to justify the
dismissal of any alternate locations.
During the first 12 days of this month Fairbanks and North Pole
experienced impact of the extreme climate and the stable air conditions
of the Tanana Valley. Fairbanks, Richardson Highway and North Pole
were subject to 10 consecutive days of extreme ice fog. The North
Star Borough called school off one day because of ice fog. The
Borough approved it's first ever "Public Ice Fog Warning" and a
health advisory warning because of extremely high carbon monoxide
levels.
Is this the kind of environment we want to build a topping plant in?
Do we want to encourage further industrial development in the Tanana
Valley, encourage more vehicular traffic by making gasoline cheaper?
I for one don't, and hope that the Environmental Protection Agency will
redraft this statement to reflect these extreme climatic conditions
and adequately consider alternate locations.
Sincerely,
• 'J C • 1 i' -) r '
l. . l\ / V
Robert A. Fedeler
SR 80001 Blanket Blvd.
Fairbanks, Alaska 99701
cc: Senator Gravel
Senator Stevens
Congressman Young
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RESPOTJSE TO
ROBERT A. FEDELER
1. Refer to response to Alaska Department of Fish arid Game
comment #4.
2. Refer to Fairbanks Environmental Center comment #26.
3. Refer to comment #18, Alaska Department of Fish and Game.
4. Comment considered and appropriate changes made.
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o'd*
Pox
Co 11 ®r*g , Alaska OQ?01
12 November 1975
U S Environmental Protection Asreney
Region X
1200 Sixth Avenue
Seattle, Washington 9^101
In Res* 10FA - M/S 623
Dear Sir,
The following remarks pertain to the Draft Environments 1
Impact Statement pertaining to the Energy Company of Alaska's
proposed topping plant in the vicinity of North Pole, Alaska 1-
1) It is questioned if exerpts from the L^rry Smith A
Company, Inc Economic Impact Study are pertinent to this Environ-
mental Impact Statement. If Table 21 and the remarks related to
production and cost.as a result of the proposed topping; plant arp
to be included in this statement, then other energy alternatives
and their economic consequences must also be considered. I believe
there is legal precedent for deleting alleged economic impacts as
stated on pages 137 and 138» -unless alternate energy solutions arc
considered.
The alleged economic impacts do not seem to be
properly indexed.
2) On Page 16k, "Alternatives to the Proposed Action"
alternative (c) is that should this facility not be built that
Golden Valley Electric Association will be required to construct
"its own topping plant". This is not a fact. The Fairbanks
Utility System generates electricity with coal. If GVEA has the
same degree of expertise they too have the alternative of gener-
ating with coal. Should the Energy Company of Alaska's North
Pole topping plant NOT be built, alternate "C" is not a bonafide
alternate.
The above are two examples which lead to a summary
conclusion that the Draft Environmental Impact Statement for
this facility has been hastily contrived and does not meet the
requirements of existing Federal Laws and Regulations related to
Environmental Protection.
It -is suggested that this Environmental Impact Statement
be properly and diligently prepared and resubmitted for consideration
of the public and governmental agencies.
GEORGE E UTERMCHLE, JR
Registered Engineering Geologist
Calif
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RESPONSE TO
GEORGE E. UTERMQHLE
1. EPA believes that potential economic impacts of a project must
be discussed whether or not the impacts are beneficial or adverse.
The information obtained from the report by Larry Smith and Company,
Incorporated was included in the EIS not to reflect the contention
that oil is a more economical source of energy than any other fuel
source but to show that oil produced near the Fairbanks market area
can result in potential savings to the Interior consumer. The basis
for this contention is that a savings in transoortation cost can
result in a reduction in fuel cost.
Larry Smith and Company, Incorporated engaged into a contract
with the Fairbanks North Star Borough in March 1972 to undertake
an Economic Base Analysis and Central Business District development
opportunities study. The scope of the study was expanded to
include evaluation of the economic impact of the proposed facility.
The intent of the study was not to derive justification of the
proposed project in economic terms but to obtain information which
would assist Borough planners and decision-makers in planning for
future growth.
2. Comment considered and approDriate changes made. GVEA will utilize
distillate oil from Tesoro Arctic Diesel. This fuel will be
transported by rail from the Tesoro plant on the Kenai Peninsula.
Four 10,000 barrel steel tanks will be used for on-site fuel storage.
274
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/If S. HAMMOND, SOVEMM
OFFICE OF THE GOVERNOR
state nucr amtoMKT m mmm men ao - muu mrit
PHOHE 4613512
December 22, 1975
1
Mr. Clifford V. Smith, Jr., Ph.D., P.E.
Regional Administrator
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
DECS 91975
»ft<£ OF FEDERAL AFFAIRS
Subject: Energy Company of Alaska Topping Plant
State I.D. No. 75102703
Dear Mr. Smith:
The Alaska State Clearinghouse has completed review on the subject project.
The following agencies were invited to review and comment:
State of Alaska
Department of Community & Regional Affairs
Office of Planning & Research
Department of Environmental Conservation
Department of Fish & Game (Fairbanks)
Department of Highways
Department of Law
Department of Natural Resources
Division of Parks
Department of Commerce & Economic Development
Four of the above agencies responded and their comments are attached.
The voluminous amount of material and the content of the State agencies
comments on this project expresses the need for a great deal of additional
coordination before any decision can be reached. We recommend that you
meet individually with each concerned State department before proceeding
with the final statement.
This letter will satisfy the review requirements of the Office of Manage-
ment and Budget Circular A-95.
Sincerely,
Attachments
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02-001B (REV. 08-73)
MEMORANDUM State of Alaska
DEPARTMENT OF COMMUNITY AND REGIONAL AFFAIRS
to: Raymond W. Estess
State-Federal Coordinator
Policy Development and Planning
Office of the Governor
date: December 19, 1975
FILE NO:
TELEPHONE NO:
from: Lee McAnerne
Commissione
SUBJECT:
Energy Company of Alaska
Topping Plant
State I. D. No. 75102703
Our staff has reviewed the Energy Company of Alaska's proposal to construct a
topping plant in North Pole. The following comments are based on the text of
the Draft Environmental Impact Statement (DEIS) prepared by the U.S.
Environmental Protection Agency as well as the Environmental Report prepared
by R. W. Beck and Associates (Beck).
A combination of city tax policies and the pipeline construction boom has
strained existing city services and housing supply. The recently constructed
waste treatment plant continues to operate improperly, failing to qualify for
complete payment of the EPA construction grant. To avoid adding to these
problems, it is imperative that the Fairbanks North Star Borough and City of
North Pole have adequate information on which to base policies and regulations
related to the construction of the topping plant. The intent of the following
comments is to identify potential impacts which have not been addressed or
adequately considered in the DEIS.
HIGHWAYS
"Traffic due to construction and permanent ECA personnel will be substantial
relative to the existing traffic, particularly at peak traffic hours" (DEIS,
page 143). "Some additional street maintenance, construction and lighting
may be needed to provide adequate access to the topping plant" (Beck,
page 4-28). Whether the products destined for Fairbanks are shipped by rail
or truck, traffic flows in North Pole will be affected. Significant truck traffic
will increase normal road maintenance expenses. Trucks must pass by the new
high school and through town. Likewise, rail shipments pass through town,
increasing the number of times street crossings are blocked. A new rail
crossing will be added on the Old Richardson Highway, a main street.
ECONOMIC BASE
(DEIS, pages 136-138)
lEven if one assumes ECA will, as indicated, pass along the transportation
pavings to area consumers, the estimated savings are grossly exaggerated
I (DEIS, Table 21, page 138). The topping plant wi II not produce domestic jet
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Raymond VV. Estess -2- December 19, 1975
I fuel, aviation gasoline or highway gasoline. Therefore, the potential savings
co»rt I figures are inflated by 60 percent.
SERVICES AND FACILITIES
(Pages 138-143)
The DEIS recognizes the biggest problem facing the City of North Pole, yet
fails to provide concrete information which will help officials determine the
magnitude of and plan for the impacts. As noted earlier, city services and
budget are already strained. The topping plant will place an additional direct
burden on these services and budget two, perhaps three, years before it will
generate tax revenue, Unanswered questions include: How many new police-
men or items of equipment will be required to adequately protect the plant?
(page 141); How much additional street maintenance can bo expected?; Will
new street construction or lighting be needed?; Are any extensions to the
sewer and water mains required?; and Will additional water storage capacity
be required to provide fire protection during construction?
Thanks for the opportunity to comment on this proposal. We hope, indeed
expect, the above comments and questions will be addressed in the final
Environmental Impact Statement.
LMcA: IDW: me
277
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RESPONSE TO ALASKA
DEPARTT'EfJT OF OTTUNITY and REGIOflAL AFFAIRS
1. Comment considered and appropriate information added to the
text. See page 143.
2. These figures represent potential savings which may result from
the proposed plant and possible future addition of a Hydro Treater
and Reformer. The table clearly specifies that domestic jet fuel,
aviation and highway gasoline and diesel and heating fuel as the
representative products taken into consideration. Military jet
fuel and industrial turbine fuel have been omitted from these
estimates.
3. It is extremely difficult to offer local decision-makers concrete
information on the exact magnitude of impacts (directly attributable
to the topping plant) on the total environment. Decision-makers
must rely on best estimates or guesstimates based on population
projections provided by the Borough. In this case, it is difficult
to distinguish between impacts associated with the construction of
the Alyeska Pipeline (peak employment of 20,000) and the proposed
construction of the plant (peak employment 160 people). When a
project such as this flies in the face of another project which is
over a hundred times larger in terms of people requirements, the
incremental increase in people associated with the smaller project
appears minimal. The EIS has attempted to highlight those areas
in which planning, funding, and assistance (from State and Federal),
is needed.
Security on-site will be provided by a private security force. ECA
will not require City policemen for on-site inspection.
On Page 143 it is stated that additional maintenance and repair can
be expected, but the exact magnitude due to the topping Dlant is
unknown.
New road and lighting will be required on-site.
Additional water storage capacity will not be necessary for fire
protection during construction.
No waste or sewer main extensions will be required. A long service
line of about 1/2 to 3/4 nile may be required. This expense will
be paid by ECA.
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02 00IB {Rr.V. 08-73)
MEMORANDUM
State of Alaska
TO
FROM;
Raymond W. Estess
State-Federal Coordinator
Division of Policy Development F,LE n<5;
and Planning
Office of the Governor telephone no
date: December 16, 19 75
SUBJECT:
Ernst W. Mueller
Commissioner
Dept. of Environmental Conservation
Energy Company of Alaska
Topping Plant, State
I. D. No. 75102703
The Department of Environmental Conservation has reviewed in
detail the draft environmental impact statement prepared by the
U. S. Environmental Protection Agency on the proposed Energy
Company of Alaska Topping Plant at North Pole, Alaska- The
statement was prepared at the urging of this Department and many
public interest groups to substantively and thoroughly address
the potential environmental problems associated with the proposed
project. We are disappointed that the statement did not ade-
quately fulfill this objective. Our detailed analysis is pre-
sented below.
INTRODUCTION
The Fairbanks airshed, of which the North Pole area is 3 part,
possesses one of the nation's most stable atmospheric conditions.
This stability, and the tendency to resist vertical mixing
causes pollutants to remain concentrated at the place of dis-
charge, rather than being dispersed by the wind. Recent severe
ice fog episodes in the Fairbanks area illustrate this point.
The ice fog phenomenon must be considered by government officials,
industrialists, and local planners when determining future
levels of urban-industrial growth in the area.
A second factor which must be considered is the impact on ambient
air quality if catalytic cracking and other unit processes are
subsequently added to the topping plant. The secondary effects
of this entire project must also be addressed. The construction
of the topping plant and the promise of "cheap" energy may act
as a catalyst for urban-industrial growth in the Fairbanks-
Tanana Valley area. The cumulative effects of such growth on
ambient air quality could be far greater than simply the impact
of the proposed North Pole refinery alone.
CLIMATIC FACTORS
A major concern in evaluating the environmental effects of
industrialization in the Fairbanks-North star vicinity is ice
fog, discussed on pages 50, 106, 125, and 126 of the DEIS. In
that discussion, more attention should be given to Pasquill's
stability class G. Average windspeeds used in statistical
modeling do not account for frequency or duration when windspeed
279
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Raymond W. Estess
- 2 -
December 16, 197 5
is less than one meter per second. Additional water vapor
sources in the Fairbanks-Tanana Valley area, such as the
10,200 lbs/hour (table on page 105) from the proposed topping
plant, may aggravate ice fog situations.
The possibility for localized augmentation of precipitation by
emissions from this source is not discussed in the DEIS. In an
ice fog situation, this precipitation would probably occur as
ice needles. Whether this effect is significant depends upon
a number of factors ranging from highway and airport visibility
to snow removal. This "artificial" precipitation may also
entrain some of the other gaseous or particulate emissions,
eventually bringing them to the ground. The basis for the com-
ment on page 103, "water vapor emissions are of concern only
under winter conditions..." should be reexamined closely in
view of these and other considerations not the least of which
is the duration of winter in this region!
COMMUNITY GROWTH CONSIDERATIONS
There is a need to formulate projects on maximum industrial and
population growth limits for the Borough, based upon the area's
environmental carrying capabilities. It is not enough to simply
state that the topping plant plus the subsequent oil-dependent
development will intensify industrial and commercial growth,
thereby increasing risks to public health and safety (as noted
on page 156, fourth paragraph and page 59, third paragraph). An
interagency, public and private, task force should be formed
to investigate optimum growth conditions from the standpoint
of the region's physical and socio-cultural limitations. While
it is recognized that the rate of industrial growth in this area
is primarily a responsibility of local government, appropriate
State and Federal agencies can assist, particularly in the
analysis of technical aspects.
Another aspect that may have to be faced in the near future
relates to the cumulative impacts associated with additional
oil processing and power generating facilities in the region.
Emissions from additional diesel generating plants could even-
tually become a major cause for concern, particularly if
generating facilities are needed to supply industries that have
high energy requirements.
On page 165, it is revealed that Golden Valley Electric Associa-
tion (GVEA) has already begun construction on a new power plant
on the North Pole site. In view of concern expressed that the
Borough's population growth is exerting an energy demand that
is straining the capabilities of existing power sources, it
would be valuable to know the electrical energy requirements
of the proposed topping plant, and how much of the output, if
any, from GVEA's new installation presently under consideration
will be required.
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Raymond W. Estess
- 3
Decamber 16, 19 7b
AIR QUALITY
GENERAL COMMENTS
1. The Environmental Protection Agency (EPA) did not
include in the DEIS a technical evaluation of the R. W. Beck
Ambient Air Quality Impact Analysis, which was the only analysis
presented.
2. EPA did not present an evaluation of the resultant
air quality to determine whether or not the ambient air quality
standards in the region will be maintained.
3. EPA did not present an evaluation of the refinery's
ability to comply with the New Spurce Performance Standards pro-
mulgated as Sections 60,100 and 60.110 of Title 40 in the
Federal Regis ber dated flarch 0, 1974 (39 .FR S315-9317), nor did
EPA discuss its responsibility to ensure compliance with these
s tandards.
4. EPA did not present or evaluate the existing air
quality of Fairbanks, only 14 miles away; all discussion of the
impact on air quality, whether from the plant .itself or the cars
and trucks involved in the plant operation, was limited to
about a one-mile radius around the proposed facility.
5. Only three sentences, drawing no conclusions, repre-
sent EPA1 s evaluation of the effect of the 213,0 00 BBL/day
refinery, while a disproportionate five pages are devoted to an
analysis of the impact of the plant's 46-car parking lot (page 100
and pages 130-134).
6. Discussion of secondary impact on air quality was very
limited, only the five-page discussion on the cars involved in
the parking lot was presented.
7. No analysis was made regarding pptential plant
expansion, which would significantly .increase emissions.
SPECIFIC COMMENTS
Page 100 states that EPA's evaluation indicates there
will be minimal, impact: on the arbient n,ir quality.
A. The evaluation .is not. included.
B. The amb.i en t ...ir data which was proscn ted .includes
par ticn la te o.;; t tor eoncentrations in Worth Pole
and Pa j.r banks that indicate the standai ds are
violated nearly every year. The other regulated
pollutants wore mon.i Lorod for a 10-day period only
in Nor 11; Pole (Apr.il 1975). No data is presented
t.o indicate the concernLrations of these1 pollutants
in Fairbanks (pp. 'I0-42) .
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Raymond W. Estess
- 4 _
December 1G, 1975
C.
15
c«n'+
1 (a E
n
There is no evaluation of the model used by R. W. Beck.
EPA states the "results" of its own "evaluation"
cannot be stated conclusively because the model is
questionable. No discussion is presented of the
inadequacies of that model. No discussion is made
of the assumptions that were made by Beck, to
provide the range of estimated impacts which might
be expected as "worst possible," "improbable,"
"probable," "minimum," or "average" cases.
There was no air quality assessment included in
Chapter 9, ALTERNATIVES TO PROPOSED ACTION.
E. Chapter 6, UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS,
page 156 "an increase in particulate matter is likely"
during construction. Referring to page 40, the
ambient standard for particulate matter weis violated
in North Pole two or more times each year. The
potential exists for increasing the rate of
violation of this standard during the construction
phase, at least in the immediate area of the pro-
, posed refinery.
"An increase in concentrations of certain
pollutants in the ambient air due to increased
vehicle traffic" page 157.
1. No data for these pollutants in the
Fairbanks area is presented.
2. No assurance this "traffic" will not
adversely affect Fairbanks' ambient air
which currently exceeds ambient air
standards for CO.
3. The following assumptions on page 132
have no basis:
(3) Everyone who works drives their own
car.
(5) Each car will run 15 minutes per day.
4. Truck traffic, page 143: EPA added that
the impact will be minimal since most
products will be shipped by rail—R. W.
Beck, pages docs not substantiate this.
The result, however, may be little
or no increase in truck traffic since
service stations and other users currently
are serviced by truck.
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Raymond W. Estess
5 >•"
December 16, 197 5
IX. Page 100—EPA states that the evaluation "was conducted
in full recognition of such climatic factors as low wind
speeds, strong and persistent inversions, a sheltered
topography and long daylight hours during the summer
months."
A. The degree to which these factors do, in fact, govern
the ambient air quality is not adequately explained.
The detailed results of the evaluation should be
presented.
B. On page 21, the description of the topping plant site
is a "relatively flat plain characterized by a few
shallow slough meanders and local depressions," is
far from the "sheltered topography" mentioned by EPA.
C. The limited EPA evaluation appears to ignore the
ice fog concerns presented by R. W. Beck's analysis.
[II. Floating roof tanks are presently required by EPA for
storage of certain petroleum liquids. No evidence is
presented that RPA evaluated the need for this require-
ment for control of hydrocarbon emissions where the
annual ambient temperature is 25°P, nor the ability of
such tanks to operate properly at -20°F.
WATER QUALITY
SPECIFIC COMMENTS
Water quality comments are categorized into the two areas of
concern noted below:
I. With respect to impact on the environment:
A. Plant Startups: One area which should have been
addressed in the DEIS is the effect of startup of the
plant on the environment. The plant will use a bio-
logical treatment method to reduce the concentration
of phenolic compounds and biochemical oxygen
demand (BOD) of the effluent. Biological treatment
units can take from a few days to a few months to
establish sufficient biological growth for the unit
to be able to operate well enough to meet effluent
limitation requirements. While the 351S (page 98.
paragraph 5) states that special dried bacterial
cultures will be available, it is not well documented
that these cultures can grow and adapt quickly enough
to eliminate the possibility of substantial amounts
of phenols and BOD being discharged into the Tanuna
River during a startup operation. Whether it is in
fact possible to eliminate the discharge of pollutants
283
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Raymond W. Estess
- G -
Doc ember 16, 197 5
during startup is not the point. What is important
is that an environmental assessment of the effects
of the startup operations on aquatic life should have
been explored.
Groundwater Impacts: The statement is made that "both
compacted earth fill and berms to retain oil would
be provided in the tank storage area" (page 100). On
page 153 under "oil spill prevention" this idea is
reiterated in the first paragraph. In the second
paragraph the statement is made that other areas of
the plant might use soil sealants, where the possi-
bility exists of oil leaching into groundwater.
It is not clear that sealants are .intended to be
used in tank storage areas on both the ground surface
and the berm surface. EPA guidelines do not address
groundwater pollution explicitly and the nPA spill
prevention and countermeasure plan (page 154} does
not require sealing of the ground, only of the berm
surface. If sealants are not used on the ground
surrounding the tank areas, it would be appropriate
in the EIS to assess the effect of oil spillages on
the groundwater quality.
Chlorides and Mercury: According to figure 18,
?age 87, 23 gallons per minute out of the total
flow of 37 gallons per minute will be coming from the
desalter operation. The purpose of the desalter is
to remove inorganic salts, sediment and water. The
inorganic salts are primarily sodium, calcium, and
magnesium chlorides. Over 60 percent of the total
flow will then be high in chloride salts. A typical
chloride concentration in the effluent due to desalting
oj>erations may range from 200 to 1,000 milligrams of
chloride per liter of wastewater. However, this
operation is not typical in that, by employing water
conservation techniques, ECA will use only about one-
tenth as much water as a "typical" refinery. Thai;
means that the concentration of pollutants in the
wastewater stream could be significantly greater
than would be found in a "typical" refinery.
Therefore, the concentration of chlorides could
be extremely high. The impact of chlorides on
the receiving water should have been addressed in
the fresh water environment. The high amount of
chlorides presents an interesting problem in an
irea not normally considered. In the NPDES permit
(Exhibit 5, page 5b), the chemical oxygen demand
est is required once per week. The chemical
r/.ygen demand (COD) test requires the: use of a
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Raymond VI. Kb toss - 7 - December 16, 197;
Zi
con'+
mercury salt to eliminate the interference caused
by high chloride concentrations. With extremely
high concentrations of chloride, very high amounts
of mercury would be put into the effluent from the
COD test, itself,*
Since the COD test may supply redundant information
to the BOD test, it would seem prudent
to consider eliminating it as a requirement of the
NPDES permit, thus eliminating the possibility of
high mercury levels in the wastewater discharge.
Because the waste stream being treated in this
refinery will contain pollutants in concentrtitions
those found in most
to be absolutely certain
to the organisms in the
With a high concentration
or even BOD, it is possible
II,
up to ten times higher than
refineries, it is important
the waste will not be toxic
biological treatment unit,
of materials like chlorides
that the biological treatment unit could not pro-
perly function. This possibility should be
explored with attention given to effects upon the
environment for the period of time it would take
to correct the problem.
With respect to analytical requirements:
A.
2>\
on page 91
a qualified
B ,
25
ASTM Requirement: The last paragraph
states that "the refinery will supply
chemist and the necessary laboratory methods of ASTM
procedures." Eight tests are then listed which will
be performed using ASTM px'ocodures. The EIS should
not be so restrictive as to state that ASTM standards
will be used—particularly so, since ASTM does not
have a valid test procedure for five of the eight
test methods listed (EPA regulation on Test Procedures
for the Analysis of Pollutants, 40 C.FR 136). I sug-
gest substituting the following phrase: "The refinery
will supply a qualified chemist and the necessary
laboratory methods as approved by EPA regulation.
The list should also have included oil and grease,
pi I and TOC since these tests are required by the
NPDL'S permit (Exhibit 5) .
Chromium Requirement: In the draft NPDES permit,
measurement of'The total and hexavalent chromium
are required twice a month. The chromium require-
ment should not be part of the permit since chromium
will not bo used in the process (page 168). As
stated in the Development Document for Petroleum
Re!i ni ng (EPA 44611-74~014a), chromi um saits are
285
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Raymond W. Estess
8 -
December 16, 197 5
7$
conH
used in a refinery for corrosion protection of piping
in the cooling water system. However, this refinery
would not use water cooling, but air cooling, hence
no chromium would be used in the cooling system.
The standards were written for refineries using
water cooling so they should not be imposed upon
this one as a "paper exercise."
* At 1000 rng/1 chlorides, one test for the COD would waste
enough mercury to require 89,000 gallons of water to dilute the
mercury to drinking water standards.
OTHER ISSUES
Under "Alternatives to the Proposed Action," one alternative not
discussed is the development .of this facility elsewhere. The
DEIS should address the possibility that some other Interior
community that has better atmospheric ventilation and a greater
need for expanded economic base may be a wise consideration for
the location of this facility. Also, as it is revealed on
page 135 that most of the 6 0 employees needed to operate the
plant will have to be brought in, the size of the available local
labor force after construction would not be an issue. It is
suggested that a site near an Interior community or near a pipe-
line construction camp away from the Fairbanks region be con-
to the Public Meeting:
EP7v regulations on preparation of the EIS (40 CFR
draft EIS shall be available for public review at
(30) days before the public hearing." The draft
October 24, .197 5 and the meeting was held
197 5, a difference of only 19 days.
siuerea.
With Respect
According to
6.42a), "The
least thirty
EIS is dated
November 12,
286
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DEPAKimtr P^yy®otisE!Wiriai
1. Additions to the text (pages 100-A, 100-B) recognize the area's
air pollution conditions. EPA fully agrees with DEC's contention
that ice fog phenomenon and climatological factors must be
considered by decision-makers when determining future levels of
growth in the area.
2. The addition of Catalytic Cracking Units is not planned for the
future. Such additions cannot take place without the appropriate
permits.
3. Refer to changes made in the text (Dages 100-A and 100-B).
4. There should not be enough water in the ECA stack to cause any
precipitation problems.
5. EPA has candidly expressed in those paragraphs (page 156, fourth
paragraph and page 159, third paragraph) those impacts which could
occur under the very worst of cases. As stated on page 159, the
extent to which these impacts will occur is yet unknown as this will
depend on the effectiveness of land use and transportation planning,
the local and national economy, and numerous other factors which
influence growth rates.
EPA agrees that both State and Federal agencies can assist local
government in planning. We do feel, however, that although techni-
cal assistance is needed in North Pole, Droner funding is a more
crucial factor. As indicated on nage 139, the lost of discretionary
impact funds (to deal with growth impacts) has greatly constrained
the City's ability to operate as an economically viable city.
As emphasized in comment #26 (to the Fairbanks Environmental Center),
EPA has made the determination that the carrying capacities of the
air and water "sinks" can effectively handle the anticipated effluents.
However, carrying capacity, in terms of philosophical limits, is more
difficult to ascertain. EPA agrees that Federal and State agencies
can assist in the analysis of technical aspects, however the task of
determining socio-cultural limitations is primarily the responsibility
of local government.
6. GVEA does not intend to build (or rely on) additional diesel generating
plants since this is not the most cost effective means of Droducing
power.
Also, as DEC well knows, any facility nrooosed for the future must
obtain necessary permits and receive approval (or certification)
from State and Federal agencies.
287
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7. As indicated on page 85 (DEIS), ECA will require 1000 Kto of
generating capacity.
8. A formally documented evaluation was not prepared. As you are
aware DEC will conduct such an evaluation orior to granting
ECA an Air Quality Control Permft to Operate.
In the Alaska DEC "Air Quality Evaluation of Golden Valley
Electric Association's Proposed North Pole Power Plant" it is
stated that even under "worst case" conditions, plume direction
will be such that Fairbanks ambient air quality levels will not
be affected. The evaluation also indicates that "the plume should
rise over 640 feet above the stack during winter conditions and
therefore should not add to the ground level ice fog conditions
since it should rise above most winter ground inversions."
9. The anticipated concentrations of pollutants will not exceed or
closely approach the ambient air quality standards, therefore EPA
expects that air quality standards will be maintained. The maintenance
of air quality in the long term is, however, dependent on the
character of future growth permitted in the area.
10. Refer to pages 101 and 129 of DEIS and comment 420 below.
11. The City of Fairbanks is fourteen miles away from Horth Pale. The
tobning plant at North Pole is expected to employ less than one
hundred people on a permanent basis. Using Turner's "Workbook of
Atmospheric Dispersion Estimates" we can aDProximate the impact of
the facility on air quality in Fairbanks. Assuming the worst
stability, the impact of the facility on Fairbanks will be approxi-
mately 3/10,000 of the impact in North Pole. Based on this, the
impact of traffic associated with the facility will not have an
appreciable impact on the air quality of the Fairbanks metronolitan
area with its population of over 60,000 people and at a distance of
14 miles away. Also aoplicable to comment #18.
12. On page 100 (DEIS) the conclusion is explicitly stated: "... the
operation of the tooping plant will have minimal impact on the
ambient air quality of the surrounding area." The next 29 pages
present the basis of this conclusion.
We believe the number of pages devoted to sections is inconsequential
and unimportant. EPA devoted these 5 pages to the parking lot
recognizing that the greatest contributor to air pollution in
Fairbanks( as in many U.S. cities) is the automobile, not stationary
sources.
13. Refer to comment #12.
14. Refer to response #26 to the Fairbanks Environmental Center.
288
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The question of potential Dlant expansion was discussed on page
131 of the DEIS. It is conceivable that the expanded refinery
could be in operation as early as 1978 and this would require
additional employees, thus increasing mobile source emissions in
the area. Although the potential 1978 situation is not included
in the analysis (because future plans are not definite at this
time and because any further expansion of the plant must demonstrate
environmental acceptability), the addition of a Hydro Treater and
Reformer is not expected to affect air quality significantly. In
terms of mobile source impacts, it is significant to note that only
15 - 20 additional employees are expected to be hired if expansion
actually does take place.
15. Same response as to comment 8 above.
It is felt that since the plant at North Pole will not impact the
ambient air quality in Fairbanks, the data does not need to be
included.
In addition to the response to comment 8 above, appropriate changes
have been made in the text.
16. Comment considered and appropriate changes made.
17. Comment considered and appropriate changes made.
18. The air quality analysis was conducted for North Pole. The minor
increase in pollutants due to increased traffic at North Pole will
not influence air quality in the Fairbanks area and thus no Fairbanks
data was necessary. (See response to comment 11).
The basis for the third assumption is as stated in the assumption
in the DEIS-- "to be conservative and reflect the worst Dossible
case." It is not expected that each employee will drive his/her
own car but by assuming it for the analysis, the maximum number of
employee cars which could possibly be attracted to the facility was
represented, so as not to underestimate the possible impact.
The reason for assuming that each car would run and idle 15 minutes
per day at the site (assumption number 5) was based upon consulta-
tion with Ron Malatesta (U.S. EPA) and the study conducted by
L. E. Leonard, "Cold Start Automotive Emissions in Fairbanks."
Even without headbolt heaters the study indicates that the automobiles
will warm up in less than 10 minutes. With headbolt heaters the study
indicates that the automobiles will warm up in less than 10 minutes.
With headbolt heaters, the warmup time would be even less. Clearly
our assumption is conservative to reflect the worst possible case.
269
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19. Refer to changes made on page 100a and 100b. The "sheltered
topography" refers to the fact that the weather in the Fairbanks
- North Pole area is influenced by mountain ranges on three
sides. The description of the site as a "relatively flat plain
characterized by a few shallow slough meanders and local
depressions" refers to the site.
20. No regional evaluation concerning the vicinity of floating roof
tanks can change the requirements of New Source Performance
Standards. Since the potential emissions from hydrocarbon
liquids decreases with decreasing temperature, operating at
low temperatures should present no problem.
21. ECA has indicated that it will start up the refinery at a capacity
of about 10-15,000 Bbl/day during summer months. Maximum capacity
is 25,000 Bbl/day. It will take approximately two (2) weeks to
get the treatment facility on line and nroperly operating. The
time schedule is aided by the addition of dried bacterial cultures
(dbc) that are facultative in nature.
ECA has indicated that storage capacity will be designed to hold
two weeks flow at 60 percent plant capacity. Discharge up to
permit limits will be allowed during this time Deriod with the
remaining flow stored for later treatment when the facility is
properly operating. With these safeguards there should be no
violations of permit conditions.
22. See response to Coast Guard comment #4 and revised text page 100
and page 154. Compacted earth (which may be augmented with
bentonite or a similar material, if tests indicate) is planned for
the ground surface in the tank storage area.
23. No significant impact for the Tanana River from chlorides in the
effluent is expected (page 92). The expected discharge of 47
pounds of chloride per 1000 barrels would result in discharge of
about 1180 pounds per day (525 kg/day) of chloride ion at 25,000
barrels per day.
Chlorides will be found in the desalting stream at estimated
concentrations of 2700 mg/1. These concentration levels should
not inhibit biological treatment but it is unknown what degree
of treatment removal (of chlorides) can be accomplished by the
planned treatment systems.
The COD test was specified by the effluent guidelines. Monitoring
of the effluent is required for parameters specified in the effluent
guidelines. After completion of the COD test, ECA will neutralize
the sample and discharge the sample through an ion exchange system,
or equivalent, which will remove most of the mercury from solution.
The small amount of mercury that may remain will not violate the
Alaska Water Quality Standards.
290
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24. Text change on page 91.
25. Total and hexavalent chromium are required to be in the permit
twice a month. Monitoring of the effluent is required for all
parameters specified in the effluent quidrlines. Less frequent
monitoring is required for total and hexavalent chromium than
other specified parameters as it is felt that total and hexavalent
chromium will not be problems.
26. For discussion of alternative sites, see pages 73-77. The DEIS
does address the possibility of locating the proposed oroject
in an area with better atmospheric ventilation. The discussion
points out that while Delta Junction is a good site due to the good
air dispersion characteristics, the site is not feasible from an
economic standpoint. This distance from major marketing areas
would be enough to make industries of this nature totally unfeasible.
27. We are well aware of the regulation. In this instance, EPA held a
public meeting instead of a hearing because meetings tend to be
less formal than hearings. The meeting was also held early enough
in the comment period to be highly informative.
291
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Oi-OOID (REV. 08-73)
MEMORANDUM State of Alaska
to: Raymond Estess DATE: December 11, 1975
State-Federal Coordinator
Alaska Division of Policy Development file no:
and Planning
Juneau telephone no:
'¦ I!
from: James W. Brooks, Commissioner subject: State I.D. No. 75102703
Alaska Department of Fish and Game Energy Company of Alaska
Topping Plant
BY: J. S. Grundy W/
Regional Supervisor
Habitat Protection Section
Fai rbanks
The Alaska Department of Fish and Game has reviewed the draft environmental
impact statement "Energy Company of Alaska Topping Plant, North Pole,
Alaska" prepared by the U.S. Environmental Protection Agency, Region X,
Seattle, Washington 98101.
lit appears the proposed action will have little direct effect on wildlife
4 [populations. As the plant brings more people to the interior and if it
* lleads to further industrialization in the Tanana Valley, however, it could
[have serious secondary impacts on wildlife populations.
The proposed action could have a significant adverse impact on the fishery
resources in the Tanana River and Chena Slough. Two major deficiencies
of the statement are its failure to discuss the impact of the construction,
y maintenance and oil spill potential of the feeder and return lines across
K> Chena Slough and its failure to locate and adequately consider the impacts
of the effluent on the aquatic habitat of the Tanana River. These two
deficiencies will have to be obviated before the Department of Fish and
Game will issue a permit for work affecting the Tanana River and Chena
Slough in accordance with A.S. 16.05.870.
The greatest potential impact appears to be on the residents of the Tanana
Valley. While the applicant has gone to great lengths to prepare effluent
3 estimates, a number of their underlying assumptions and procedures are
questionable. At the public meeting held in North Pole, November 12,
there was considerable professional testimony directly contradicting the
stated conclusions.
Unfortunately large blocks of the applicants assessment were incorporated
directly into this statement by EPA. Understandably, this greatly diminishes
the objectivity of the report. Portions of the statement read as if the
topping plant is already an approved project. The only alternatives con-
sidered were those considered by the applicant. There was no factual
y| evidence provided to support the dismissal of any alternatives.
For obvious reasons, we should not have to rely solely on the applicants
evaluation and data when considering a proposal. This lack of independent
investigation and willingness to adopt the applicants text and conclusions
does not meet the spirit or requirements of the National Environmental Policy
Act of 1969 (P.L. 91-190). We request that this statement be redrafted
292
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Raymond Lstess
December 11, 1975
and circulated for comments. In its present fori:; it more closely approaches
a project justification than an environmental ircpact statement. We question
EPA's procedure of limiting the scope of this impact statement to phase one.
There is every reason to believe that ECA fully intends to expand this
facility in the future. Tins piecemeal approach of evaluating and permitting
precludes consideration of the overall impact of the proposal. If ECA
is considering expansion that is unsuitable for this site the location
should be moved now - it will not be moved later. This impact statement
should reflect the entire complex impact, not just phase I.
The following questions or comments are directed at specific statements
in the text of the draft impact statement:
p. 14. To reduce necessary computations and improve readability, cons istant
units should be used in the table when comparing topping plant effluent
and regulations.
p. 19. ECA must also secure a permit from the Alaska Department of Fish
and Game for work affectinci the Tanana River and Cheria Slouch in accordance
with Alaska Statutes 15.05.fi70.
p. 23. In addition to the existing Corns of Engineers Flood Control levee,
f-ol<-;er. Valley Electric Association has bo gun construction on their gas
turbine venerator site.
p. 30 In the fifth line from the bottom it is inferred that the flow rate
presorted in Table ?. "indicate the dilution available for waste discharged
at ilorth Pole. . ." It is unrealistic to think of the entire flow of the
Tanana as available for dilution. The river is wide and heavily braided.
Effluent wi11 not be discharged across th breadth of the river hut rather
into one of the braided channels with only a portion of the total f1ow
available for dilution. Even this reduced, flow will be subject to annual
variation in response to icing conditions and channel charges.
p_. 34. (2nd paragraph) Chum and coho salmon migrate and spawn in the
Tanana River. Subsistence fishing is done primarily with nets. There is
also a significant commercial salmon fishery on the Tanana River,
p. _3!>. "... points upstream and downstream of the proposed >->ater dis-
charge wore sampled by the applicant. . ." Location of sample points
should be more closely identified than just "upstream and downstream".
These date and analyses are provided by the applicaiit as are four of the
six tables in exhibit 2, \!r> should not have to rely solely on appIicants
data when considering an iinpact statement.
pT 4?.. ECA's evaluation of existino air quality is based on on1;/ 10 days
data" gathered during Apri 1 ID75. I "doubt if anyone can get an accurate
assess iiient of existing air quality wi th only 10 days sampling, particularly
in an area that is subject to the climatic extremes of interior Alaska.
Climatic conditions and air pollution are most extreme during the fall and
'/inter months and should be included to accurately assess existing air
qua! i ty.
p. 50. "Photographs taken from the high terrain to the northeast of
Fairbanks show that sower olant nlumes remain aloft, and move with the
293
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Raymond Estess
-3-
December 11, 1975
elevated winds, rarely joining the main mass of ice fog before they
dissipate." To the contrary, numerous photographs are available and were
presented to EPA at the public meeting in North Pole, November 12, showing
power plant plumes rising, spreading over the city and then dropping back
down to join the ice fog.
flip. 5S. The qenus and soecies for broad whitefish (Coregonus nasus) should
'"¦be included.
§
I? d
14-
15
Salmon do not spawn in Piledriver Slough, however, chum salmon are known
to spawn in other sloughs along the Tanana River.
The discussion of fauna in the Tanana P,iver should be expanded to include
more than just fishes. Fishery resources a.re dependent on production of
lower food organisms. Invertebrate and benthic organisms can be affected
more directly by topping plant effluent than fish.
The discussion of fisheries should also include the importance of Badger
(Chena) Slough for Arctic grayling production and sport fishery. In 1973
nearly 10,000 grayling were harvested by sport fishermen from Badger Slough.
p758. Due to increasing encroachment and human disturbance, it is
questionable to describe wildlife as "plentiful" in the North Pole area.
Endangered species may not be known to occur on the project site, but
Peregrine falcons have been sighted in the Fairbanks area.
J3._62. The first sentence of the last paragraph is a supposition and
should be deleted from the imoact statement.
i? F
I I lane
jx_7J. The majority of annual precipitation occurs during the summer
and early fall (page 43) and can lead to high runoff values.
1$
p. '/{'>. The entire question of site selection is covered by U-. pages of
discussion and one ambiguous table. Only those alternatives proposed by
the applicant were considered. A table of "numercial ratings" provided
by the applicant is hardly adequate justification for dissmissal of any
alternati ve.
The Murphy Dome site was dismissed because of environmental reasons. Won't
these same negative factors affect the North Pole site?
"EGA has indicated that the distance from the refinery to the major marketing
areas alone would make this location unfeasible from an economic standpoint.11
Again, we should not have to rely on the applicants analysis. Perhaps
the additional cost of locating where there is sufficient exchange and the
potential impact to a major settlement area will be less could be offset by
reduced effluent control costs in the future.
An estimate is made of the truck traffic required by the Delta location
(". . . 50 to 100 trucks per day. . .") but there is no mention of the
required truck traffic for a North Pole site. The statement on page 77
regarding distribution "... by truck from the refinery direct to the
individual consumer. . ." would seen; to indicate cons icier able local truck
294
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Raymond Estess -A- December 11, 1975
It
«¦»•+
19
ao
ai
traffic at the North Pole site. It seems that EGA is overly optimistic
about the efficiency of rail traffic. Does EGA plan to lcac! the rail
tankers at North Pole, move them to Fairbanks, offload to distributor
storage then load trucks?
p. 77. The first sentence of the page is presumptive and requires justifi-
cation.
R._79. If the proposed supply and return pipelines are constructed along
the suggested routing there will be three pipelines crossing the upper
reaches of Chena Slough carrying in excess of 35,000 barrels of petroleum
products per day.
o. 91. The location of the landfill should be specified.
|T. 53. Doesn't "... to manufacture gasolines, propanes, butanes, and
possibly commercial jet fuel." mean cracking?
|p. 96. It is indicated that riewatering operations may be necessary but
YAI these waters would not be discharged to surface streams. Where v/i 11 it be
I discharged?
as
x
EGA will be constructing the tie line and return line across Chena Slough.
The impact of this crossing on Chena Slough should he addressed in this
statement. Hill both the tie line and return line be installed at the
sane time to minimise disturbance? Will the size of the pipeline be
adequate for the proposed action or expansion?
I EC A will have to secure a permit from the Alaska Department of Fish and
Gam'? for work affeefcino the Tannnfl r:iver and Chena Slouoh in accordance
[with A.S. 15.05.070.
—J7 - ICO. Any discussion of Tan ana River impacts is questionable at
best when "final design of the discharge structure is not complete" (page
05) and the point of outfall has not been identified.
A diffusion study is impossible until discharge structure design and
location are established. A discussion of mixing zones is unreal is 1 tic
unti 1 stream flow characteristics are established at the point of outfall.
Extreme climatic conditions, ice thickness, seasonal flow variations must
be considered.
It is acknowledged that "complete mixiiuj will not occur immediately" and
it is highly unlikely that the entire 3100 cfs will be available for mixing
and yet table 1? (page SD) assumes both. Fable 12 should also include
existing concentrations of the oaraineters in the Tan an a Pmver.
Estimates of effluent temperatures can be made and should be included.
Ourino critical winter months a very small temperature difference can ha
a pronounced effect on agnatic fauna.
lave
It appears that the .North Pole sewage treatment plant will be totally
inadequate and in violation of state and federal regulations. It is repeatedly
acknowledgeed in this DEIS, that the existing North Pole sewa.ge treatment
295
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Raymond Estess
-5-
December 11, 1975
system is inadequate to handle the present load (pages 65, 100, 13!?).
There is no reason to expect that in the future wastes would be more
adequately treated than at present.
Additional discharges from the refinery, the new high school (1000-1200
students) and an anticipated city population increase will further reduce
effective treatment. The cumulative affect of North Pole city discharge,
Columbia i'sobi 1 Home discharge and ECA discharge cou'id have serious adverse
effects on the aquatic fauna of the Tanana River, The applicant'has
estimated a discharge of M pounds of chloride ion per 1000 barrels. The
chloride ion itself is rather innocuous, but when combined with certain
organics can form toxic compounds. It is true chloride ions will not
increase solinity because cations, not anions, determine solinity.
p. 100. EPA has adopted the results of R.W. Beck's modeling program but
acknowledges that the modeling program may not be applicable to the North
Pole area. With this qualification the alternatives cannot be easily dis-
missed. What will be the air quality impact if the model is wrong?
It is essential that EPA expand the discussion of air quality impacts
to include the premise that the modeling program cannot be adopted.
Again, the final impact statement should be expanded to address the overall
impact of the project,
P. 101. The magnitudes of the flare and sludge incineration may be negligable
relative to other emissions, but still could be significant. Estimates
of flare and sludge incineratory emissions should be caluclated and included
in the report.
p. 103. "Anticipated analysis of the fuel. . ." Hasn't any analysis
been done? How can the statement continue to discuss control of emissions
if this first basic step hasn't been completed?
p*. 124-125. The table on page 49 indicated a class G stability 32.9
percent of the time during winter months at Eielson. The tables on pages
124 and 125 should be expanded to include short term maximums under this
stability condition.
p. 128. Emission and odor will increase at ground level due to increased
traffic and escaped hydrocarbons from spills, and loading operations,
p. 129, As with water quality, the regulatory agencies must also establish
a comprehensive ambient air quality monitoring and analyses program. On
page 102 it is stated that no control measures are needed to limit S02> On
page 128 it is stated that the formation of S09 is expected to be minimal.
u.
But on page 129 it is noted that cleaner fuels could be made available on
an emergency basis to lower SO2 and particulate emission. If emergency
measures are anticipated, shouldn't control measures be required, isn't
SO^ formation significant?
pT 130. On page 77 it is indicated that there will be truck delivery from
the refinery direct to the individual consumer, and there will undoubtedly
— 296
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Raymond Estess -6- December 11, 1975
35,
1 k- increased tanker traffic at the refinery and yet the emission burden
I be i r
'lof t!'
• II illVl Ul IV. IV. I I i 4 J JU Ivllt; Clllljp lUli
CQUtIof this increased traffic is omitted in the discussion of mobile
sources.
3*f
35
&
3?
3 %
31
Mo
41
p. 133. These final three sentences of this page are illogical and should
be rewritten. The emissions from "major sources" could be minor when compared
to a larger source. Mobil sources may be minor "when compared" but could
still be very significant. Because the existing air quality is good doss
not lead to the conclusion that "the impact of the parking facility will
be small and will not jeopardize the ambient air quality standards."
p_._J_34. "Mobile sources will not result in air quality violations" but
will" result in air quality degradation. The cumulative impact in this area
is obviously significant.
o. J_35. This DEIS refers to but does not discuss the secondary impacts
this proposed action might have on the North Pole community, "Soma of
these people will be directly employed by ECA and others v;ill be employed
by supportive facilities and service industries necessary to serve the
additional people." What supportive facilities and service industries?
Are these new facilities? Where are they located?
?? 135. The reference to "much land available for expansion and development"
should be deleted from this statement. The city's residents and North
Pole Coinprehensive .Advisory Planning Committee, not the topping plant,
should determine North Pole's growth potential. This facility will be
located in the heart of the North Pole area at some future date.
IT. 136. The third paragraph of this page reads as if the topping plant is
Ian approved project.
nr_133. Table 21 is misleading and should be modified. It includes
demand levels and potential savings for products (domestic jet fuel, highway
gasoline) that will not be produced in the proposed phase one of construction.
jT._J39 - 141. It is indicated that North Pole will have to improve and en-
large "its" sewage treatment plant, fire protection and equipment and police
protection but there is no discussion of how this economic impact will be
financed.
r VH. The North Pole elementary school is one of the most sever!
[impacted schools in the borough during the 1975-76 school year.
f2.
JJ5. The importance of proper planning is stressed in the second
paragraph. It should be mentioned that one option open to the planners
is a recommendation of disapproval of this proposed action.
. .lands immediately adjacent to the site will probably be rezoned
for more intensive uses in the future." This is a totally inappropriate
statement and should be deleted.
43 fc-
p. 151. Slow and where: will on-site runoff be contained?
p._154« Oil spill contingency plans should include the Badger Slough
crossing specifically, and should be completed and implemented prior to
operations, not "within six months aft^ the facility begins operation.'1
-------
Raymond Estess
-7-
December 11, 1975
Innovative spill prevention methods and procedures must be described.
p. 156. "... compared to the impacts created by the construction of
the Alyeska Pipeline, the impact of the topping plant is relatively
insignificant. When compared to existing florth Pole conditions, the
jyppact of the topping plant is extremely significant.
164. The phrase . .resulting in no possible reduction in the cost
48
of petroleum products" should be deleted.
p. 166. "ECA has indicated that meeting the Alaska Water Quality Standards
in the effluent may be very difficult to achieve, therefore, the only
feasible alternative. . ." Just because it "may be very difficult"
to meet AWQS in the effluent does not mean it is not feasible.
In conclusion, it is inevitable that the proposed project will produce
ice fog and particulate emissions. These may or may not be minimal
and may or may not be within specific health standards when considered
by themselves. But we must consider the cumulative effect of this
proposed project and the existing adverse environmental and socio-
economic impacts inposed on the Tanana Valley. At the time of this writing,
Fairbanks and the Richardson Highway south as far as the Eielson have
experienced 10 consecutive days of extreme ice fog. On Monday, November 8th>
the Fairbanks North Star Borough issued the first "ice fog warning" in the
history of Fairbanks. On Friday, November 12th, the Fairbanks Morth Star
Borough issued a health advisory warning because of extremely high carbon
monoxide levels. We recognize the necessity of petroleum products to
interior Alaska, but feel the quality of living in an area of extreme
climate should be paramount. We urge that the statement be redrafted
to reflect these extreme climate conditions and adequately consider alternate
locations.
Thank you for this opportunity to comment.
cc: D. Lowery - ADEC Fairbanks
W. Copeland - ADL Fairbanks
D. Ross USFWS Fairbanks
298
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RESPONSE TO ALASKA
DEPARTMBIT OF FISH and (WE
1. Agree; this point is reflected on page 149.
2. Note revised pages 81, 96, and 154. Additional information
regarding the proposed discharge (location and impacts) and
the feeder and return lines across the Chena Slough has been
incorporated in the final EIS. Note also responses to your
specific comments 14, 26, and 44 and to Fairbanks Environmental
Center comment #69.
3. Comment considered.
4. The proposed regulations for the preoaration of environmental
impact statements for New Source NPDES Permits (Federal Register
40 (197): Thursday, October 9, 1975) specify that the applicant
submit the information necessary for EPA's environmental review.
Refer, in particular, to section 6.908 (c). Nationwide, numerous
EIS1s are based on the work of consultants. The use of consultant's
data is not unusuaT.
There are two basic reasons why EPA requires that an apolleant for
a NPDES permit prepare an environmental assessment and that such
an environmental assessment be used as a basis for prenaration of
EPA's environmental impact statement.
First,preoaration of an NPDES permit environmental assessment for
a major industrial installation is a time consuming and expensive
procedure . l.'ithin Region X, EPA processes 10-20 new source
NPDES permits a year, any one of which may require such an assessment.
EPA does not have either the staff nor funds to prepare assessments.
In order to reduce government spending, the EPA uses as much
applicant prepared data as is available. Using EPA personnel to
advise the industry consultants and review the consultant procedures
reduces duplication and allows the best environmental return for the
dollar expended.
The second reason EPA utilizes the consultant's assessment as much
as possible is to foster an environmental ethic within the industry.
Environmental assessments are planning documents. They best serve
their purpose when they are prepared by the people most able to
make plant or process changes to protect the environment. EPA
encourages industry to integrate environmental planning into the
overall planning effort at the stage when changes are most easily
made. EPA's proper role is not to plan for industry but rather to
insure that Industry plans are environmentally sound.
Refer to FEC comment #26.
299
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5. Consistent units were used (ug/m3).
6. Appropriate changes made.
6a. Same comment as Fairbanks Environmental Center comment #2.
7. See revised Alternatives Section for discussion of basis of
defining a new mixing zone based on 200 to 1 dilution.
8. Comment considered and appropriate changes made.
9. See revised text on page 35 and Table 1, Exhibit 2. In addition
to the applicant's data, recent EPA data for the Tanana River
and North Pole groundwater were presented. Additional river
concentration data did not appear necessary to determine whether
water quality standards could be met with the proposed discharge
limitations.
10. Same as Fairbanks Environmental Center comment #4. Refer to response.
See also Fairbanks North Star Borough Environmental Services' letter,
comment #1 and #3.
11. Comment considered and appropriate changes made.
12. Comment considered and appropriate changes made.
13. The information regarding the possibility that salmon spawn in
Piledriver Slough was obtained from a memorandum from Stephen Tack,
Sport Fish Division, Department of Fish and Game; Fairbanks, Alaska,
to George Van Wyhe, Regional Supervisor, Sport Fish Division
(Reference #12). Other appropriate changes made in text.
14. Note revised page 56. Information from an unpublished EPA study
conducted uDstream from the ECA proposed discharge has been
included. Alaska water quality standards for the Tanana would
require protection of not only fish, but also other aquatic life.
15. Comment considered and appropriate changes made.
16. We do not believe that this is mere supposition. The existing
evidence (comprehensive plan and certified resolutions) supports
this position. Refer also to Fairbanks Environmental Center comment
#12.
17. Comment considered and appropriate changes made.
18. The Murphy Dome site was not dismissed for environmental reasons.
As stated on page 75, the air dispersion characteristics of the
area are good. This is reflected in the 1 rating attributed to
the site under "Environmental acceptability" on Table 10. The
300
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DEIS explicity states that distance from major marketing areas
alone would make certain locations unfeasible from an economic
standpoint.
For some products, ECA does plan to load the rail tankers at
North Pole and move them to Fairbanks for storage. For such
products as heating oils, retailers may load their trucks at
the North Pole site or at the Fairbanks storage area.
19. Comment considered.
20. Comment considered and appropriate changes made.
21. Comment considered and appropriate changes made.
22. No, it does not mean cracking.
23. Refer to response to comment #69 from the Fairbanks Environmental
Center. See text change, page 96.
24. Comment considered, appropriate changes made. See page 96a.
To minimize damage, both lines will be installed simultaneously.
The sizes will be adequate to accomnodate addition of a Hydro
Treater and Reformer.
25. Comment considered; appropriate revisions made. See page 96.
26. See revised Alternatives Section for discussion of outfall location.
See revised Hydrologic Conditions section for discussion of stream
hydrology.
See response to,comment #72 from the Fairbanks Environmental Center
and revised Alternatives Section.
Table 12 was intended to exemplify the potential increased concentra-
tions many miles downstream from the discharge. Estimated concentra-
tion increases a few hundred feet downstream are now included 1n the
Final EIS.
See revised Impacts Section for discussion of temperature effects
and comment #63 from the Fairbanks Environmental Center.
See Fairbanks Environmental Center comments #67 and 74 for discussion
of the North Pole sewage treatment facility.
301
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In addition large amounts of dilution of both the City of North
Pole's effluent and ECA's effluent will take place in the
Tanana River. This dilution effect will minimize, if not eliminate,
the possibility that toxic compounds will reach harmful levels.
Both cations and anions determine salinity.
27. The text has been expanded in its coverage of modeling.
28. With regard to the flare emissions, see appropriate changes in
the text. The sludge incinerator wil1 discharge into the main
stack and will contribute insignificantly to the emissions from
that source.
29. The fuel referred to is described on the previous page (page 10).
The fuel cannot be analyzed until it is produced.
Because of the nature of the operation, the fuel analysis varies
with product mix. Emission figures were calculated from the
best estimate of what the fuel analysis would be.
30. See comment on page 119 of the draft EIS where it is stated that
the worst anticipated limited mixing height conditions (100 m
mixing height with stability F) was given consideration.
31. Low level emissions of hydrocarbons will amount to about 1000 lb/day
according to ECA's permit application to the Alaska Department of
Environmental Conservation. This is roughly equivalent to the
hydrocarbon losses from retail gasoline pumping operations totaling
83,000 gallons per day.
32. The statement was meant to say that cleaner fuels could be made
available to consumers to reduce emissions from sources external
to the topping plant.
33. The statement on page 77 does not indicate that such truck delivery
to the individual consumer will involve additional truck traffic in
the area. It merely points out the fact thatthe distance which
v/ould need to be covered, either by truck or rail would be short.
Since individual consumers in the area are already currently served
by trucks there will not be "increased tanker traffic" due to the
facility in Fairbanks municipality.
34. The description of the existing air quality in the area as "good"
was included in order to point out that the expected increase in
pollutants would not be adding to an already unacceptable situation.
Certainly if air quality was presently in violation of National
Ambient Air Quality Standards, the 2% to 15% increase in pollutants
for the operational phase would represent a significant impact. We
recognize that any increase in pollutants will add to deterioration
of air quality. Any type of activity or growth brings this effect.
The key to determining acceptability of resultant air quality is
302
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whether or not the ambient air quality standards are in jeopardy
and whether or not the air quality undergoes a considerable change
for the worst. It is important to consider present air quality in
making conclusions about the impact of the parking lot. It is not
however the only basis for the conclusion which was stated, as can
be determined by reading the entire paragraph.
35. Degradation need not be "obviously significant." The extent to
which it is significant depends on the capacity of the airshed to
handle the incremental increase in pollution and the area's
ambient air quality. See also response to comment #34.
36. As population increases, there usually is a need for additional
supportive facilities and service industries (i.e. service
stations, restaurants, motels, grocery stores, larger road
maintenance crews, shopping centers, etc.). These are future
facilities which may not be even conceived of at this time.
it is therefore impossible to state where they are located.
37. The statement was not intended to imply that EPA recommends or
condones industrial expansion on lands currently undeveloped.
We have always contended that land use and growth issues must be
decided locally.
The EIS points out that much land is available for expansion and
development for several reasons: (1) it is intended to reflect the
nature and extent of the vacant land which will be subject to
increased development pressure (as required by Section 6.910(b),
40 CFR Part 6 and as required by CEQ guidelines) and (2) it is
intended to emphasize that the presence of the topping plant can
be highly influential in determining future land use patterns.
EPA has never stated that "the topping plant should determine
North Pole's growth potential."
38. Parts of the EIS,may read as if the plant were approved simply
because the EIS discusses those impacts that may result if the
the permit is granted.
39. These figures represent potential savings that may result from
the topping plant (as proposed) and the addition of a Hydro Treater
and Reformer. See revisions on page 137.
40. Financing for these projects will come from taxes, Federal agencies,
and, hopefully, from State Impact funds.
41. Many of the schools in the Borough have been severely impacted.
The extent to which this has occurred is attributable to the
fact that the Borough population has grown from 31,000 1n 1970
to over 63,000 1n 1975. The Borough's comprehensive plan
accurately predicted that the elementary schools would be ffiost
heavily impacted.
303
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42. We agree that this option is open to the planners and decision-
makers in the Borough. To date however, EPA has not received
such a recommendation.
This statement is appropriate because it depicts what might occur
in the future. The topping plant will be an influential factor
in the development of future land use patterns.
43. On-site runoff will be contained in holding ponds.
44. See revised text page 154. Promulgated EPA regulations for oil
pollution prevention for non-transportation related onshore and
offshore facilities (40 CFR Part 112, Federal Register Volume
38, No. 237, Part 11, December 11, 1973) do not address transporta-
tion-related facilities such as the tie line. Regulations for the
non-transportation related facilities state that SPCC plans (such
as the topping plant including the tank storage) must be completed
within six months after commencement of operations and implemented
as soon as possible but not later than one year after operations
begi n.
45. Spill prevention methods and procedures include diking, valving
tie-in lines at both ends, and other preventive methods as
described on pages 99a and 100. The Tanana River is protected
since the Corns of Engineers levee runs between the facility
site and the river.
46. Refer to response to comment #35. Also, determination of whether
or not an action is significant depends on the assimilation capacity
of the affected resources or systems. North Pole is already
impacted by the Alyeska Pipeline construction. In the past 3-5
years the town population has approximately doubled. As it exists,
North Pole is not free from development influences.
47. Comment considered and appropriate changes made.
48. After additional study it has been discovered that even with
tertiary treatment AWQS cannot be met in the effluent. A mixing
zone, is required.
304
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John Becker
Advanced Planning §
Special Projects Eng.
Juneau Headquarters
Andy Zahare L-c- s
District Pre-Construction
Engineer
Interior
j
date : November 26, 1975 i
subject! Comments on Draft EIS for
ECA Topping Plant North
Pole, Alaska by EPA,
Region X, Seattle
4
In a general sense this statement does a commendable job of evaluating
the impacts from the proposed action. In more specific sections we would,
like to point out some minor inconsistencies which can be eliminated
in the FEIS.
The EPA has done a good job in utilizing the readily available informa-
tion for an air and water quality evaluation in the Fairbanks-North
Pole area,, Additional information was presented by various agencies
and individuals at the hearing- Judging from the work done in the
draft, we're sure this additional information will be adequately analized.
Specific. Comments:
On page 67 the DEIS states that the New Richardson. Highway "caused"
traffic increases. It would be extremely difficult to substantiate
that the new facility "caused" traffic increases. We suggest "caused"
is a complicated issue, and unless it is significant to your project,
can be omitted altogether.
I Page 67 should show that the Badger - Chena Hot Springs Road
I connector is completed rather than pending. ADTs up to 450 were
I recorded in September of this year.
Page 69 includes cost of living comparison for the area with reference
to the lower 48. An up to date and possibly more accurate comparison
could be obtained from the Pipeline Impact Reports, prepared by the
Fairbanks North Star Borough, which document the costs and area wide
trends.
foil page 135 the Fairbanks North Star Borough population is estimated
[at 32,000. Our latest information shows this to be 63,350. This
[figure should be confirmed by the North Star Borough.
[The information presented under site selection is more suited for
[discussion under alternative to the proposed project. The last
[sentence on page 75 needs to be substanciatcd or omitted.
The impact of clearing the refinery site is suggested to be insigni-
ficant. A stronger case might be built by comparing the 40 acres
to be cleared, with the thousands of identical acres located across
the Tanana River which is not likely to be developed for scores of
years. The loss of ] jitat is only a fraction of a percent of the
305
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*
can't
available habitat, arid the loss will not be noticed by Natures
inefficient system, (approximately ± 51.).
It appears to us that, the thorough discussion of aquatic impacts
under Alternative to the Proposed .Action would lie better located
if placed under the Impacts section.
[Several references arc made to noise in the DHIS. The LTA has
I concluded that there will not lie significant noise impacts. We
CK I suggest the reviewer be furneished with a comparison between the
¦/ I accepted standard and anticipated noise levels described in
I decibels.
Thank you for allowing us this review. 'Ve would appreciate a copy of
the final statement to use as reference material.
AZ/BT/kt
306
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ESPOf^E TO IMPORTATION
PLAfHING DIVISION ALASKA
EEPARUEJT OF HIGHWAYS
1. Various government agencies and citizen groups have helped greatly
in providing us with up-to-date information on the existing
conditions in the Fairbanks-North Pole area. The EIS has served
as a useful guide in bring to light those anticipated critical
impacts which need(ed) to be more fully mitigated or evaluated.
2. Comment considered and appropriate changes made on page 67.
3. Comment considered and appropriate changes made on page 67.
4. Comment considered and appropriate changes made on page 69.
5. Comment considered and appropriate changes made. This figure has
been confirmed.
6. EPA elected to discuss site selection in the "Description of
Proposed Project" for two reasons: (1) the applicant has applied
for a new source NPDES permit to discharge at a specific proposed
site and (2) the alternatives to the proposed action focuses on
the issuance or denial of the permit at the proposed site.
This comment is a well taken one however. We will consider this
format change for future EIS's on new source NPDES permits.
7. Comment considered.
8. Comment considered and appropriate changes made.
307
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mII ®F MSP
DEPARTMENT OF NATURAL RESOURCES
Division or LAUDS
JAY S. HAMMOND, GOVCRHOR
4420 AlllPORT WAY - FAIRBANKS 39701
December 19, 1975
Walter D. Jaspers, Director
Office of Federal Affairs M/S 623
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Jaspers:
P
r
-
y
In reviewing the draft Environmental Impact Statement for the Energy Company of
Alaska Topping Plant at North Pole, Alaska, we note an omission under Required
Permits, page 19. Pursuant to AS 46.15.040 and 11AAC 72.050, a permit is re-
quired-to appropriate the process water pumped from on-site wells.
The draft EIS does not adequately address the effect of the topping plant on
the growth of a petrochemical industry and associated developments in the
North Pole area. Because of this, it is difficult for the Division of Lands
to predict and evaluate the effect of the proposed Topping Plant on state
waters and lands, including the unnamed, unsurveyed islands of the Tanana River.
We would appreciate a chance to comment on this section when this deficiency has been
corrected.
Sincerely,
William H. Copeland
District Manager
cc: Gary Johnson
Planning and Classification
raitsntm
ma Qf FEQBIN. JlFMNt
308
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RESPONSE TO ALASKA
DEPARTIOT OF NATURAL RESOURCES
1. Comment considered and appropriate changes made,
2. Comment considered and appropriate changes made.
309
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Advisory Council
On Historic Preservation
I 522 K Street N.W.
Washington, D.C. 20005
November 25, 1975
Mr. Walter D. Jaspers, Director
Office of Federal Affairs, M/S 623
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Jaspers:
This is in response to your request of October 1975 for comments on the
draft environmental statement (DES) for the Energy Company of Alaska
Topping Plant, North Pole, Alaska. Pursuant to its responsibilities
under Section 102(2)(C) of the National Environmental Policy Act of
1969, the Advisory Council on Historic Preservation has determined that
the DES demonstrates evidence of compliance with Section 106 of the
National Historic Preservation Act of 1966, but that it does not demonstrate
adequate compliance with the provisions of Executive Order 11593, "Protection
and Enhancement of the Cultural Environment" of May 13, 1971, as implemented
through the Advisory Council's "Procedures for the Protection of Historic
and Cultural Properties" (36 C.F.R. Part 800). However, it appears that the
Environmental Protection Agency (EPA) is aware of its responsibilities. The
Advisory Council wishes to remind EPA that if the archeological and historical
survey mentioned on page 147 of the DES locates cultural resources that EPA
should determine the eligibility of such properties for inclusion in the
National Register of Historic Places, and, if determined eligible by the
Secretary of the Interior, afford the Council an opportunity to comment on
the undertaking in accordance with the "Procedures.''
Should you have any questions or require any additional assistance, please
contact Brit Allan Storey of the Advisory Council staff at P. 0. Box 25085,
Denver, Colorado 80225, telephone number (303) 234-4946.
Sincerely yours,
Louis S. Wall
Assistant Director, Office
of Review and Compliance
cc:
Sheldon Meyers-EPA:FLO
310
The Council is an independent unit of the Executive Branch of the Federal Government charged by the Act of
October 1 5, 1966 to advise the President and Congress in the field of Historic Preservation.
-------
RESPONSE TO THE
ADVISORY CaTICIL ON
HISTORIC PRESERVATIfTI
The Environmental Protection Agency is aware of its responsibilities
and has taken appropriate steps to ensure adequate compliance with the
provisions of Executive Order 11593. The Agency has informed the Alaska
State Historic Preservation Officer of its intentions in regards to a
subsurface archaeological survey and has made appropriate changes in the
EIS to reflect this.
311
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
204 East 5th Avenue, Room 217, Anchorage, Alaska 99501
December 1, 1975
Mr. Walter D. Jaspers, Director
Office of Federal Affairs, M/S 623
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Jaspers:
The draft environmental impact statement for the proposed issuance of a
new source NPDES permit for discharge of wastewater from the Energy
Company of Alaska's proposed topping plant into tne Tanana River, sent
to the Soil Conservation Service, Washington, D. C., was referred to the
Soil Conservation Service, Anchorage, Alaska, for review and comments.
This response represents all comments of the Soil Conservation Service.
GENERAL COMMENTS
The statement represents considerable effort in the assembly of available
data and in effective presentation of pertinent facts throughout the
report. The statement appears to candidly appraise the effects of the
proposed action.
SPECIFIC COMMENTS
The soil data is good and the findings of the drilling program are typical
of the area. The permafrost will probably disappear after clearing, nor-
mally without soil subsidance. The area is very flat, has high permea-
bility, and is of low erosion hazard. The site is excellent for the pur-
pose proposed.
Tn the discussion of unavoidable impacts, there is note of the removal of
natural vegetation on 40 acres. It is suggested that following construction,
the consideration be given to mitigating the unpleasant aesthetic results
of the installation by planned use (landscaping) of adaptive plant species.
iThe "Vegetative Guide for Alaska", attached, may be of value should you
[follow this suggestion.
Tn the discussion of the "short time use of the environment", note is made
of the urbanization expected in the area. We suggest that the Fairbanks
area soil survey and interpretations will provide a good guide to the
planning and development of urban areas associated with the proposed topping
plant.
-------
Mr. W. D. Jaspers
2
The section on Irreversible and Irretrievable Committments of Resources
acknowledges 40 acres of "muskeg vegetation" to be converted to the
facility and the loss of habitat for the small mammals and birds which
presently occupy the area. It should likewise be noted that the land
converted to the facility is good agricultural land (prime for the area)
that is lost for future farming activities. The same section states,
"If the availability of cheaper fuel leads to increased industrial and
commercial development, the trend in North Pole may be away from a rural
community toward an urban/industrial city". It should be acknowledged
that cheaper fuel will benefit both present and future agriculture and
agri-business activities.
We appreciate the opportunity to comment.
Sincerely,
Weymeth E. Long
State Conservationist
enclosure
cc: Council on Environmental Quality (5 copies)
Office of Coordinator of Environmental Quality Activities
R. M. Davis, Administrator, SCS, Washington, D. C.
K. L Williams, Director, WTSC, SCS, Portland, Oregon
District Conservationist, SCS, Fairbanks, Alaska
313
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RRPfJJSF TO
\m\ SOIL OOiJSERVATIQJ SERVTfF
1. This letter from the Soil Conservation Service, Anchorage, Alaska,
has aided ECA and EPA greatly as a guide to mitigate impacts on
the soil and vegetation of the area.
2. This information has been incorporated into the text. See page 150-A.
3. EPA has recommended to ECA that the "Vegetative Guide for Alaska"
be utilized for the revegetation of cleared areas. Discussion of
this recommendation is included on page 156.
4. Your suggestion should be helpful to local planners, therefore a
copy of your letter has been forwarded to the Mayor of North Pole
and the Fairbanks North Star Borough Planning Director.
5. Comment considered and appropriate changes made. See page 162.
314
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November 17, 1975
TO:
FROM:
William Aron
U.S. DEPARTMENT OF COMMERCE
iya'ianal QcsertSc and Atmospheric Administration
ENVIRONMENTAL DATA SERVICE
Washington, D.C. 20235
Dx61/DLEC „
3 I J3/5
CV4
vDirector,,Office_of Ecology and Environmental Conservation, EE
Special Projects
SUBJECT: EDS Review of DEIS 7510.43 (Energy Company of Alaska Topping
Plant)
The EDS has reviewed the subject DEIS and offers the following comments:
General
The description of the local climate and the potential for impact upon the
I climate and air quality is complete and pertinent. There are some minor
[errors, however, which should be corrected.
Specific
"™ 3
On p. 39 the primary standard for carbon monoxide is given as 10,000ug/m
for ^ hours and 40ug/m for 1 hour. The 1 hour standard should be 40,000
ug/m .
On p. 43, 2nd paragraph, "persistent cover" is blamed for extremely cold
temperatures. Apparently, snow cover is being referred to. This should
be made explicit.
|0n p. 43, 4th paragraph, the growing season is defined in terms of "frost"
I dates. It should be defined in terms of "freeze" dates. This is the
| basis for the growing season information presented here.
On p. 45, 4th paragraph, calm winds are defined to be 5.0mph or less.
Calm winds are actually less than Imph.
On p. 45, 4th paragraph, last sentence, "south-southwest" should read
"west-southwest."
On p. 50, 2nd paragraph, it is stated that the National Climatic Center
issues air stagnation advisories. This is not so. The National Weather
Service performs this function and it is not part of the National Climatic
Center.
|On p. 125, bottom line, the figure referred to should be "23." Figure 22
is a wind rose.
315
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RESPONSE TO NATIONAL OCEANIC & ATMOSPHERIC ADMINISTRATION,
ENVIRONMENTAL DATA SERVICE
1,
Comment
considered
and
appropriate
changes
made.
2.
Comment
considered
and
appropriate
changes
made.
3.
Comment
considered
and
appropriate
changes
made.
4.
Comment
considered
and
appropriate
changes
made.
5.
Comment
considered
and
appropriate
changes
made.
6.
Comment
considered
and
appropriate
changes
made.
7.
Comment
considered
and
appropriate
changes
made.
8.
Comment
considered
and
appropriate
changes
made.
316
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0EC 3 1 197c
U.S. DEPARTMENT OF COMMERCE Of ft
National Oceanic and Atmospheric Administration
ENVIRONMENTAL RESEARCH LABORATORIES
Silver Spring, Maryland 20910
December 10, 1975
TO: Director, Office of Ecology and Environmental
Conservation
FROM: Isaac Van der Hoven
Air Resources Laboratories
SUBJECT: Comments on EPA DEIS #7/10.43
Energy Company of Alaska Topping Plant, North
Pole, Alaska
In view of the fact that the surface wind characteristics of the two
nearest instrument locations (Fairbanks and Eielson AFB) are so decidely
different, it would seem that onsite measurements are required to
assess the air pollution impact. Measurements should be taken near
the surface (10 m) and at the elevation of the effective stack height.
317
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RESPONSE TO NATIONAL OCEANIC & ATMOSPHERIC ADMINISTRATION,
AIR RESOURCES LABORATORIES
R. W. Beck, consultants for ECA, considered it fortunate to
have two meteorological stations as close as the stations at Eielson
and at the Fairbanks International Airport with the proposed site
located in between. Meteorological conditions at the site were
estimated based on the data from these two stations, in the absence
of extensive data at the site. Meteorological measurements made at
the site during the background study generally confirmed the assump-
tions made, at least for the period of site study. The method of
estimating meteorological conditions at a site used by R. W. Beck is
commonly used but only in full recognition of the fact that complex
local meteorological conditions might cause actual conditions to vary
somewhat from those estimated by this method.
The conclusions reached with respect to wind speed and direction
were intended to describe prevailing wind speed and direction and
were not intended to imply that other wind speeds and directions will
not occur since the data contained in the tables do indicate otherwise.
Refer also to response to comment #4 from the Fairbanks Environ-
mental Center.
318
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D£c 3 1 1975
OpA
UU3xl
pec 10 1975
TO: Jr. William Aron, Director
Office of Ecology and Environmental Cone
-------
RESPONSE TO NATIONAL OCEANIC a AUDSPHERIC ADMINISTRATION,
NATIONAL WEATHER SERVICE
1. Comment considered and appropriate changes made.
2. Comment considered and appropriate change made.
3. Comment considered and appropriate change made.
320
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U.S. D2PAa7M2NY AF CQtf MS3CE
National Ccaante ana AtmonpiierJc Administration
National Marine Fisheries Servias 1
P. 0. Box 1668, Juneau, Alaska. 99802 ^ z ! 1$?S
Ofi\
Date December 12, 1975 Reply to Attn, of: FAK21 /TH
Director, Office of Ecology and Environmental Conservation, EE
to Through: Associate Director for Resource Management, F3
From ^ ' Q&rry L. Rietze
Director, Alaska Region
Subject: Comments on Draft Environmental Impact Statement - Energy Company of
Alaska Topping Plant, North Pole, Alaska (EPA), DEIS 7510.43
The draft environmental impact statement for Energy Company of Alaska
Topping Plant at North Pole, Alaska', that accompanied your memorandum of
October 31 , 1975 has been received by the National.Marine Fisheries
Service for review and comment.
The statement has been reviewed and the following comments are offered
for your consideration.
Specific Comments
II. DESCRIPTION OF THE ENVIRONMENT
F. Flora and Fauna
2. Fauna
"Paqe 56, Paragraphs 3 and 4; page 57, Table 6. According to the Ameri-
r.-.u—•.» i n,.10 -t-ic "a 1 ~-c
can Fisheries Society's Special PublTcatTonNo. 6, "A List of Common and
Scientific Names of Fishes from the United States-and Canada" (R.M.
Bailey et al, 1970), the following corrections should be made: Oncorhynchus
keta is the "chum," not "king," salmon; 0. tshawytscha, the "chinook,
not "chum," salmon; and <3. Kisutch, the "coho," not "silver," salmon.
The scientific name for the broad whitefish is Coregonus nasus.
Page 56, Paragraph 5. With regard to the statement that, "There is
_ i * * 1 < '1 Ji? • _ .• r . • • ^ it « « 1 J I
speculation...however specific information is meager," it would be
helpful if any specific information, however meager, indicating that
salmon spawn in the sloughs along the Tanana were presented in the final
EIS. Perhaps this information could be obtained from the Alaska Depart-
ment of Fish and Game, 1300 College Road, Fairbanks, Alaska 99701
(telephone, 907/452-1531).
cc: F34 (3)
321
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RESPONSE TO NATIONAL OCEANIC & ATOPHERIC AMINISTWION,
NATIONAL MARINE FISHERIES SERVICE
1. Comment considered and appropriate changes made. Coho salmon is
the same as silver.
2. This information regarding the paucity of data was obtained from
the Alaska Department of Fish and Game in Fairbanks (Reference #12).
Comment #13 by J. S. Grundy, Regional Supervisor, Habitat Pro-
tection Section, Fairbanks, indicates that salmon do not spawn in
Piledriver Slough.
322
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HON!
DEPARTMENT OF TRANSPORTATION
MAILING ADDRESS
UNITED STATES COAST GUARD COMMANDER (dpi)
17TH COAST GUARD DISTRICT
FPO SEATTLE M77I
5922
21 NOV 1975
Walter D. Jaspers, Director
Office of Federal Affairs, M/S 623
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA., 98101
Dear Mr. Jaspers:
The draft environmental impact statement for the Energy Company of Alaska
Topping Plant - North Pole, Alaska, has been received and reviewed. The
U. S. Coast Guard has the following comments to offer:
I pg. 19 - The final statement should mention whether or not ECA has ar-
Iranged to obtain state royalty oil from the State of Alaska.
pg. 56 - Information on the life histories and even the presence of
various species of fish in the Tanana River is sorely lacking. Salmon
spawning habits in the area are virtually unknown, and much study is needed
on the non-commercial species present (Least Cisco, Lake Chub, and Slimy
Sculpin).
pg. 98 - The statement mentions that some fish are attracted to warner
water. It should also be mentioned that some fish are repelled by increased
temperature. More information on effluent temperatures and effects should
be provided, particularly the possibility of increased temperature causing
a reduction of the already low dissolved oxygen content of the river in
winter months.
pg. 100 - Groundwater impacts are discussed insufficiently. The draft
statement says "To restrict movement of any surface contamination of oil
towards the relatively shallow water table the applicant plans to provide
relatively impermeable compacted earth fill (approximately 12 inches thick)
at the site where there is a spill potential". EPA regulations (40 CFR 112.7)
state that onshore facilities should have as a minimum "dikes, berms, or
retaining walls sufficiently impervious to contain spilled oil". We assume
this to mean the containment of all spilled oil, in which case "relatively
impermeable" fill seems insufficient. We suggest you change "restrict
movement" to "prevent movement" and "relatively impermeable compacted earth
fill (approximately 12 inches thick)" to "concrete or a similarly imper-
meable material". We would also like more information on locations of sites
with the greatest spill potentials.
§pg. 153-154 - We would like more information on "soil sealants". How
fective are they compared to a concrete or similar barrier? Again, exactly
ere do these leaching possibilities exist?
323
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pg. 166 - The statement admits that grayling, chum, silver, and king
salmon may be more sensitive to oil in salt water than pink salmon. Yet
the EPA intends to use the maximum limit determined compatible with pink
salmon in marine water as the proposed downstream limitation for the
fresh water of the Tanana. Further justification is indicated. The effect
of oil on non-commercial species is not even mentioned. More studies are
needed related to the effects of small amounts of oil on all species present
in the Tanana River.
We hope these questions will be cleared up in the final statement. If so,
the Coast Guard has no further objections to the proposed action. Thank
you for the opportunity to comment.
Sincerely
rd
i District
324
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RfZSPO; !SE TO
DEPARTTEjr OF TPA iSFORWIO*;
U.S. COAST GUARD
1. As stated on page 19, ECA has registered an interest with the
State of Alaska to secure State royalty oil. On May 22, 1975
ECA received a formal solicitation from the Commissioner of
Natural Resources for a proposal to purchase crude oil. ECA
submitted a proposal on May 30, 1975. The State Royalty Board
has not yet made any decision regarding the sale of Royalty Oil.
ECA has, however, consummated a contracted for crude with a
major North Slooe producer.
2. Additional information on fisheries resources has been added.
3. Additional information on temperature has been included in the
final EIS. For the estimated effluent temperature, 60°F, no
significant impacts on the water quality of the Tanana are
expected outside the mixing zone.
4. Impacts on groundwater as a result of spills of oil would depend
on such factors as the proper construction and uokeen of soill
control systems, climatological variables (snowmelt, temperature,
etc.} as well as the magnitude and frequency of spills. Additional
information has been provided in the revised EIS.
Areas such as the process units and rail and truck loading racks
will be covered with a reinforced concrete deck that will be
curbed and drained to the sewer system. Smaller spills are
normally anticipated in such areas, primarily due to maintenance.
In the storage tank area, losses of oil are not normally exoected
and would probably be due orimarily to equioment failures. An
impermeable membrane (such as neoprene) will be placed directly
beneath each storage tank. It will not extend beneath the entire
surrounding diked area. Prevention of groundwater contamination
in the event of a spill will rely on downward flow restriction
by a mechanically compacted layer of suitable soil (12" to 18"
thick) and the capability for rapid withdrawal of spilled material
into a closed piping drainage system. ECA states that spills may
be routed to tank storage above ground, or, if necessary, returned
to the trans-Alaska Pipeline.
Tests for soil permeability to oil and water will be made nrior to
installation of the compacted layer and bentonite (or other material)
will be added to improve impervious qualities if necessary. A cover
layer may also be installed. Inspections to determine maintenance
of compaction will be made.
325
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Sufficient capacity will exist within the dikes to contain a
major spill. ECA states that rupture of the dikes from oil
spills under pressure is considered highly improbable since
tank storage will be at atmospheric pressures and sDacing
between dikes will be according to Oil Insurance Association
spacing requirements.
Stormwater retention ponds will be lined with a compacted soil
layer (similar to the diked area) or an impermeable membrane.
5. Compacted soil will be used rather than an additional sealant,
near the storage tanks. As discussed in the previous response,
areas where minor spills are routinely expected will be concrete
decked, curbed, and drained to a diversion tank for testing and
further treatment if required.
6. Because it is unknown whether the grayling, chum, silver, king
salmon and other species in the Tanana River may be more or less
sensitive to oil in fresh water than the pink salmon in salt
water, the discharge from the refinery was evaluated based on the
criterion established for the sides of the mixing zone at Valdez.
In the absence of definitive studies on the impacts of oil on the
biota of the Tanana, a cold, freshwater river, this apnroach was
chosen. Additional studies would assist in determining a more
appropriate criterion.
326
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DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
December 18, 1975
Mr. Walter D. Jaspers, Director
Office of Federal Affairs, M/S 623
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Jaspers:
ALASKAN REGION
632 SIXTH AVENUE
ANCHORAGE, ALASKA 99501
TELEPHONE 272-5561
*!
!WI|
DEC 2 2 1975
,0fsIC£ OF FEDERAL AFFAIRS
i
We have completed our review of the Draft EIS on The Energy Company
of Alaska Topping Plant to be located at Morth Pole, Alaska.
The followinq comments are offered for your consideration as you prepare
your Final EIS.
(Tigure §3: We have added three other airports to your map of North Pole
^ land vicinity (copy attached). Bradley Sky Ranch had a total of 36 aircraft
[parked at the airport during our inspection, made in August 1975.
Environmental Impact of Proposed Project: The Draft EIS speaks of the
proponent's ability to prevent ice fog formation (under ideal conditions)
in the range of 0.2 to 2.0 Km downwind of the unassisted stack. Since
you are aware that the area is susceptible to patchy ice fog (see
figure 21) at present, we feel that you must in someway deal with the
plant's potential for increasing the frequency and intensity of ice fog
formation in the area beyond the 2.0 Km range. If the plant's operation
will contribute to increasing the intensity and frequency of ice fog
formation in the North Pole area, we feel that it should be described in
the Summary of Unavoidable Impacts, due to its negative effect on aircraft
operations.
Thank you for the opportunity to review and comment on your Draft EIS.
Sincerely,
WILLIAM T. MULLALY
Chief, Planning Staff
Enclosure
327
-------
RESPONSE TO
FEDERAL AVIATION ADMINISTRATION,
DEPARTMENT OF TRANSPORTATION
1. Comment considered and appropriate changes made.
2. Comment considered and appropriate changes made.
328
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
ER-7 5/1085
m i 9 1976
Off]
Dear Mr. Jaspers:
Thank you for your letter transmitting copies of the
Environmental Protection Agency's draft environmental
statement for the Energy Company of Alaska Topping Plant,
North Pole, Alaska.
Our comments are submitted according to the format of the
statement or by subject.
GENERAL COMMENTS
We are generally in agreement with EPA's analysis of the
potential impacts of waste water discharge from the plant
into Tanana River and the data supplied on the power needs
of the area. However, we believe that secondary impacts
and the possibility of future facility expansion should be
more candidly discussed.
AIR QUALITY
The technical analysis of impacts on air have not been
translated into a meaningful explanation for the average
citizen. The statement does not indicate whether or not
plant operation will increase the severe ice fog and air
pollution problems already in existence in the Fairbanks
jarea.
It appears that the discharges into the air from the plant
will be relatively clean; however, the physical aspects of
ice fog such as disruption of visibility should be more
carefully assessed. At the current time, air service to
Fairbanks is being disrupted due to ice fog conditions.
Ground traffic in the Fairbanks vicinity, along the
Richardson Highway, and at the airfields in the vicinity
is also affected.
"On page 12 5, the second paragraph indicates that
(theoretically) there will be no ice fog formation in the
range of 0.2 to 2.0 km. downwind of the unassisted stack.
On page 113, it is indicated that the plume would be
^e-1916
329
-------
2
dispersed away from present ice fog areas. In still air
conditions, however, or under the conditions as shown in
Figures 2 3a, b, c, and d, it appears there will be some
occasions when the plant will contribute to the ice fog
problem from Fairbanks to Eielson Air Force Base. The
frequency and severity of such a problem should be presented
in the final statement.
ARCHEOLOGICAL AND HISTORIC SITES
On page 147, it is stated that an archeological and
historical survey of the project area will be conducted prior
to construction. Such surveys should be conducted sufficiently
early in the planning and design process to enable proper
impact evaluation and the incorporation of necessary measures
to avoid or mitigate impacts. The results of the surveys and
a discussion of impact avoidance or mitigative measures should
be contained in the final statement. The final statement
should also discuss those mitigating measures that will be
employed if significant cultural resources, which are not
located during surveys, are discovered during construction.
OUTDOOR RECREATION
Additional information is necessary to fully evaluate the
project's impact on recreation. This is especially true in
regard to the project's impact on the recreational attributes
of the Tanana River. The document notes on page 32, that
recreation constitutes a use of the Tanana. Recreation uses
of the Tanana River should be detailed in the final statement
and the impacts of each use discussed.
The discussion of recreational facilities on page 142, should
indicate what specific recreation areas would be expected
to receive the greatest impact from the project. A map
depicting recreation sites within a 20-mile radius of the
project would be most helpful. It should be included in the
final statement.
TANANA RIVER IMPACTS
The specific location for the point of discharge into the
Tanana River should be shown on a map in the final statement.
Data on winter flow characteristics of the Tanana River at
330
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the point of discharge should be provided. During winter,
the reduced flow of the Tanana assumes a more braided pattern
and is often divided into many small channels. Under these
conditions, dilution of discharge wastes may be far less
than anticipated in the draft statement, which assumes a
minimum of 3100 cfs to be available, without indicating that
this will be spread out into numerous small flows.
The final statement should provide information describing
the stream environment below the point of discharge. The
Tanana is believed to be a major overwintering area for many
fish populations inhabiting its vast network of tributaries.
Specific temperature data for the discharge wastes are needed
to assess possible impacts to fish which might be attracted
.to the effluent.
Without the information referred to above, the discussions
of mixing zones in the draft statement do not accurately
describe impacts to fish populations and water quality.
The final statement should describe how water quality will be
monitored during the six-month period when the river is
covered with ice. The fact that visual observations will be
limited should be stated. Accurate sampling will also become
more difficult.
The possibility of pollutants accumulating in the ice with
subsequent release during breakup should be explored. This
could occur downstream for long distances and might possibly
_affect resources quite distant from the discharge point.
The extent of environmental damage that might occur from a
200-year flood overtopping the Corps of Engineers levee
(page 32) should be discussed. Oil spill contingency plans
should be designed to take into account the possibility of
flood destruction, even if this is remote.
The information given is inadequate to assess impacts of the
feeder line on fish resources at the Chena slough crossing.
331
-------
We hope these comments will be helpful to you.
Mr. Walter D. Jaspers
Director
Office of Federal Affairs, M/S 623
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Sincerely yours,
p«r»-tv Assistant Secretary of the Interior
332
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RESPONSE TO THE U.S.
DEPARlfer OF INTERIOR
1. Comment considered and appropriate changes made.
2. Comment considered. Refer, in particular, to "Summary Sheet" in
the draft EIS and final.
3. In terms of direct air quality impacts (resulting from stack emissions),
the operation of the refinery will not significantly add to the ground
level ice fog and air pollution problems in Fairbanks. Because ground
level ice fog is largely the result of people and cars, the extent to
which the refinery will aggravate ice fog conditions depends on the
magnitude of the facility's "multiplier" effect.
4. Comment considered.
5. Comment considered.
6. Comment considered.
7. Comment considered. Because the refinery (i.e. 80 additional people
and their families) is not expected to significantly affect recreation
resources in the area, EPA submits that while a map of recreation sites
within the 20 mile radius of the facility might be instructive,
the expenditure of time and resources to create such a map cannot be
justified unless it could prove to be useful in future recreation planning.
We have instead included a listing of the sites which will be affected.
As indicated in the EIS, the prospects for new recreational developments
appear favorable at this time.
8. The final discharge configuration will be selected after further
studies on winter flow in the channels of the Tanana near the ECA
site if a mixing zone is included in the final permit. If no mixing 2one
is defined in the final permit, ECA1s discharge must meet Alaska
Water Quality Standards at the end-of-the pipe.
9. Additional information has been included in the EIS.
10. Permit conditions will ensure that water quality standards (which
provide for protection of fish populations) will be met.
11. Sampling through the ice is difficult but would be necessary during
the winter months.
12. Permit conditions will require adequate mixing during winter months
to reduce the probability of pollutants accumulating in the ice
in concentrations that might prove detrimental. When break-up
occurs, much greater dilution would be available.
13. Evaluation of environmental damage from the 200-year flood was not
included in the final EIS. It would be necessary to determine flood
333
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water elevations behind the levee for the 200-year flood.
14. Additional information has been provided in the final EIS.
334
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CHAPTER »
COMMENTS RECEIVED
ON THE DESIRABILITY
OF THE PROJECT
-------
STORY OF COMMENTS RECEIVED ON THE DESIRABILITY OF THE PROJECT
EPA received a number of letters from residents of the North Pole-
Fairbanks area voicing opinions on the proposed topping plant. Although
these letters did not specifically comment on the draft EIS, we thought
it worthwhile to include copies of them here because they reflect local
citizen response regarding the overall desirability of the project.
Table 23 summarizes these letters.
Supporters of the proposed plant most often cited energy needs,
economic development, adequate environmental controls, and enhancement
of the quality of their lives as the reasons for their support. They
were optimistic about what the plant could mean to the area in terms
of economic growth but also expressed the need for planned and con-
trolled growth. They felt that the plant would satisfy a definite
need and that its construction would result in desirable, planned
growth of the North Pole-Fairbanks area.
Citizens who wrote opposing the project expressed the concern that
the plant might increase air quality problems, have an undesirable
effect in terms of population growth, and change the rural, small-town
character of the area.
Petitions in support of and opposition to the project were also
received by EPA during the comment period and after the public meeting
(164 people signed the support petition and 107 signed the opposition
petition). The petitions are not included in this final statement but
are available for review at the EPA Region X office. Copies of the
petitions were sent to the Mayor, City of North Pole; Mayor, Fairbanks
North Star Borough; Governor of Alaska; and Commissioner, Alaska Depart-
ment of Environmental Conservation for their information and possible
use in determining alternative futures for the North Pole-Fairbanks
area.
336
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-------
TABLE 27
COMMENTS RECEIVED ON THE DESIRABILITY OF THE PROJECT
-338-
Air Quality
Water Quality/Supply
Energy Needs/Fuel Costs
Wi 1 dl i fe
Recreation
0)
•»->
CO
3
"O
•r-
O
Aquatic Fauna
Mitigation/Controls
Population Pro.iecti on/Growth
Historic Preservation
Land Use, Planning
Agriculture
Alternatives
Quality of Life
Economi cs/Employment
Sludge Disposal
Health and Sanitation
Noise
Industrial Expansion
Overtaxing of Existing Facilities
No Specific Reason Cited
Oate
Received
From
General
Tone
12/10
Ray Kohler
Supportive
X
X
12/10
6. A. Seeliger
Supportive
X
X
X
12/11
Michael Harter
Supportive
X
12/16
Chris Stephens
Supportive
X
X
12/16
Robert J. Mitchell
Supportive
X
X
X
12/16
Vernon H. Boyles
Supportive
X
X
12/16
R. W. Groff
Supportive
X
12/17
William I. Waugaman
Supportive
X
X
12/19
Gregory C. Mitchell
Supportive
X
12/22
Rynnieva Wescott
Supportive
X
X
X
X
-------
-------
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_ m ¦ ¦ a w t i n m. i * r»r* i _ uiri rv r l i /\VJ
125 ADAK STREET
HAMILTON ACRES
P.O. BOX 1193
TELEPHONE 452-17!,
December 3, 1975
FAIRBANKS. ALASKA 997Q7
Director of Public Affairs
U. S. Environmental Protection Agency
1200 Sixth Avenue M/S 605
Seattle, Washington 98101
Dear Sir:
I am writing in regard to the proposed North Pole oil refinery to be
located just outside Fairbanks. There seems to be a fair amount of
local opposition to the project.
I would like to go on the record as being in favor of the North Pole
refinery. As I am sure you are well aware, the refinery is quite
acceptable on any environmental grounds.
The environmentalists seem to be mounting their typical hysteria
campaigh: "Polution" Rah!, "Ecology" Rah!, "Nature" Rah! The real
question seems to be, whether Industrial Development should be
allowed in Alaska or any other part of the U.S.?
To conclude, I am simply saying that there are Alaskans in favor
of the refinery, industrial growth in general. I do, admittedly,
have a "vested interest" as our letter head makes clear, but I have
been an Alaskan since the year I was born, something I doubt any of
the opposition can say.
Sincerely yours,
GREER TANK $ WELDING, INC.
David Greer
Vice President
DG/ba
347
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&
{
December 3, 1975
Director of Public Affairs
U. S. Environmental Protection Agency
1200 Sixth Ave., M/S 605
Seattle, Washington
Subject: North Pole Refinery
Gentlemen:
It is my understanding that the design and proposed operation
of the North Pple Refinery by the Energy Company of Alaska will
fully comply with EPA requirements and standards.
I am an Alaskan of nearly thirty years residence in Fairbanks
and I heartily endorse this development as it will enhance further
private industrial growth so that our economy may become less de-
pendent on Government payrolls of the various Federal and State ag-
It is hoped that the large majority of true Alaskans who favor
orderly growth and development, will he adequately represented in
correspondence you may receive so that a very small but- very vocal
minority of pseudo Alaskans will not create the absolutely false
impression that great numbers are opposed to the Refinery and other
potential industrial development.
The project as proposed truly meets with the goals of EPA as
stated by Mr. Russell Train and I hope it will be a model to which
your office may point with pride.
Yours very truly,
North Pole, Alaska
encies.
Conrad G. B. Frank
Box 80805
College, Alaska 99701
CGBF/mh
348
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f
F
PHONE : 4 5 2-! 1 S 1
P. O. BOX 288
508 TWELFTH AVENUE
FAIRBANKS. ALASKA 9970 1
December 1, 1975
Director of Public Affairs
U.3.Environmental Protection Agency
12QC Sixth Ave., m/3 605
Seattle, tesh. 98101
Dear Sir:
Regarding the j^orth Pole Refinery we urge you to apprcve same.
We are certain those involved will do the utmost to meet all SPA
State requirements. Because of the energy shortage locally and nationally
it is imperative this Refinery be built as soon a;: possible.
I have been a resident of Alaska for fifty years and my wife
was born in Fairbanks so we are well informed of the needs and the
future of this area.
Sincerely,
"S t i' /* -
Leo A. Schlotfeldt,
Chairman of Board
349
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10
ROM
U.S. ENVIRONMENTAL PROTECTION AGENCY
E. CMILTCN kt:3S A!® SHARON D. HINE3
DEPT • I OCA HON
DEPT.-IOC A HON
Mo
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SUBJFC:LppORT OF THE PROPOSED NORTH POLS REEIKERY
-
| DATE / /
DSG3MBER 6, /l97 5/
DEAR SIRS:
VE WOULD LIKE TO EXPRESS OUR FULL SUPPORT OF THE PROPOSED NORTH POLE REFINERY
NEAR NORTH POLE, ALASKA.
' V. Ef; Cw THIS iNE
¦5 jNtl
<.v
¦ iOC-i On
S^GNf D
Date j
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SEND PARTS 1 AND 3 WITH CAR&ON INTACT - PART 3 Will BE RETURNED WITO REPIY.
350
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December 4, 1975
Director of Public Affairs
U. S. Environmental Protection Agency
1200 Sixth Ave. M/S 605
Seattle, Washington
Re: North Pole Refinery
North Pole, Alaska
Gentlemen:
I was present at the hearing held in the North Pole School
a short while ago. The hearing was scheduled and chaired by your
agency.
The consensus was quite strongly in support of the Refinery
with the most notable opposition coming from a group of Univer-
sity students that had been bussed to the hearing for their com-
bined presentations.
If I understand it correctly, the plant does meet EPA stan-
dards, and that it is a first for this type of undertaking.
We have all been made more aware of the dangers to our coun-
try and community with the increase in local population and ac-
tivity. The uncontrolled air and area pollution by individual
bouses and household members seems quite a bit more a matter to
worry about rather than a project that is controlled by owners,
architects, investors, taxpayers, Borough and Council elected
officials, and various State and Federal agencies from the very
inception of the project.
Please let me go on record as being very much in favor of
the North Pole Refinery. As a resident of the Fairbanks area
for 50 years, I can recall much change and many reasons along
the way for not changing, nevertheless, what we have today is
considerably better for the majority of residents. Let us hope
it will continue.
Thank you for this opportunity to be heard, it is a bit diff-
icult to compete vocally and in particular against the more ar-
ticulate and younger members.
Yours very truly,
665 10th /
Fairbanks, Alaska 99701
HWM/mh
351
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December 5, 1975
Director of Public Affairs
U. S. Environmental Protection Agency
1200 Sixth Ave. M/S 605
Seattle, Washington
Re: North Pole Refinery
North Pole, Alaska
Gentlemen:
As an Alaskan whose quality of life covers the spectrum of getting
by in 1929 to enjoying the conveniences and comforts of todays Fair-
banks, I support the establishment of a small refinery at North Pole.
The change of the life style of people in the Fairbanks area has
not been free of changes or inconveniences to our life. In spite of
these changes and inconveniences, 1 wouldn't wish to return to yes-
teryears quality of life. Nor would the majority of the people wish
to return to yesteryears quality of life.
As an Alaskan and a business man it has always been hoped that
cheap fuel and electricity for transportation, heating and light-
ing might be a reality in Fairbanks. There is no question that this
represents a sizeable slice of the consumers dpllar in the Interior
of Alaska. This is all the more evident when compared with the same
costs in the other major Alaskan cities and with cities in the Low-
er 48. Consequently, projects which could have the impact of re-
ducing the consumer cost of living and the business community's cost
of doing business are welcomed.
The hearing held at North Pole, which I attended, raised a few
minor questions on the Environmental Impact Statement which may
need clarification or correcting, but nothing so substantial as to
necessitate a change in the conclusion on being in favor of pro-
ceeding with the refinery. It is difficult to rationalize the con-
cept of no growth that some of the proponents to the Refinery pro-
pose against a project th^t will affect everyone in savings and ben-
efits.
Yours very truly,
Clyde W. Geraghty
210 Bonnifield
Fairbanks, Alaska
/
CWG/mh
352
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A1 Cory
21 Mile Richarson Hwy
North Pole, Alaska 99501
Telephone: 488-9403
December 3, 1975
Director of Public Affairs
U.S. Environmental Protection Agency
1200 Sixth Ave, M/S 605
Seattle, Washington 98101
Dear Sir:
1 am the owner of a small business located on 21 Mile Richardson
Hwy. and I own considerable property in the area.
I want it to go on record as being wholeheartedly in favor <&f the
Refinery proposal for construction at North Pole. Having been a
resident of that area for 15 years, I have watched the problems
with unemployment and the lack of an Industry of any type, that
furnishes year around employment, which is sorely needed for this
area.
I sincerely hope, that construction of this project will commence
and reach completion at the earliest possible date.
Yours truly,
/
vT
A1 Cory /
353
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RAY KOHLER & CO.
CERTIFIED PUBLIC ACCOUNTANTS
P. O. BOX 607
FAIRBANKS. ALASKA 99707
\Vp
IJecember 5, 1975 < Oo
Director of Public Affairs
U. S. Environmental Protection Agency
1200 Sixth Avenue, M/S 605
Seattle, Washington 98101
Dear Sir:
^ vV
\ ^
I believe the application for a permit for construction of a refinery
at North Pole, Alaska should be given favorable consideration.
I understand the refinery as proposed would fully meet all of the en-
vironmental requirements and that there is no technical reason why it should not
be built. We have been assured that petroleum prpducts will be made available
to the area and within the state at prices substantially below those now prevail-
ing. Certainly in an area that has been plagued by high living costs, this should
be welcomed by all.
As a forty year resident of Fairbanks, I welcome the economic base that
will be provided by this installation. Too long haye we been dependent, directly
or indirectly, on government payrolls.
I urge your favorable consideration.
Ray Kohler
gmf
354
MEMBERS AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS
-------
lillilllil TANANA VAlle? M€t>iCAL~SURQiCAL QROUp
1001 NOBLE STREET • FAIRBANKS. ALASKA 99701 • PHONE 452-1611
November 28, 1975
Regional EPA Office
1200 6th Avenue M/S 605
Seattle, Washington 98101
SUBJECT: North Pole Refinery Project
Gentlemen:
Though I attended the public hearing recently held at
North Pole, Alaska concerning the subject, I did not get an
opportunity to testify. I hope, therefore, that you will accept
my statement in writing in lieu of personal testimony.
So that I may qualify myself as a person who has a long
term interest in the Fairbanks-North Pole area I would like to
state that I have been a resident of this area for thirty-three
years; I am married, have children and grand-children residing
here. The public has thought enough of me to elect me to the
Fairbanks School Board, the North Star Borough Assembly, the
Fairbanks City Council, to the Presidencies of the Chamber of
Commerce and the Fairbanks Rotary Club. In the past, I have
received two public citations for outstanding community service.
I am now serving as a director of the Town and Village Assocui-
tion for Development and on the Governor's Commission for Land
Though I thought the hearing was well run, considering the
difficult conditions under which the hearing officers worked, I do
not feel that enough of the people having substantial and long term
interests spoke in support of the North Pole refinery.
From what I heard, it seemed that environmental considera-
tions had been very carefully thought out and adequate provisions
made to meet standards. I was dismayed to hear people who
obviously had but a tenuous short term concern, heap scorn on
the studies and people who supported the project. My observations
seemed to detect a concerted effort by the project's detractors to
stall the refinery to death.
Use.
STAFF MEMBERS
OBSTETRICS a GYNECOLOGY surgery pediatrics
ORTHOPEDIC SURGERY
general practice a family medicine
LAWRENCE) DUNLAP. M D
FJCOG
ANCEL EARP JR . M.D WILLIAM H JAMES. M.D
PACS WAYNE W. MYERS. M.D.
WALDO H HANNS. M D
RADIOLOGY
JAMES S. FUZZARD. M.D.
355
G. A. SEELIGER, MGR.
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Page Two
The importance of the North Pole Refinery to the Interior of
Alaska can scarcely be over-estimated. In this land where trans-
portation costs arc sky-high and petroleum supplies are perilously
limited (I cite the current shortage of fuel oil to fire the GVEA
turbines) we need a refinery to assure ourselves that homes will
be heated at an acceptable cost to our citizens.
The economic history of the area has been most uncertain
up to this time due to our reliance on government spending. The
operation of a refinery in this area would go a long way toward
stabilizing our economy, provide jobs for people already here and
who incidentally have a right to stay here.
The people who want to build the North Pole Refinery undoubtedly
have a critical schedule to follow due to ihe difficulty ul scv,-ring
financing and equipment. An>; delay would, I feel. f>teb£e a grave and
unnecessary threat to the project. I, therefore, urge early consid-
eration and speedy approval of the North Pole Refinery Project.
Respectfully,
G.A, Seeliger
GAS,. nlw
356
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Greater Fairbanks
P.O. BOX 1791
FAIRBANKS, ALASKA 99707
FAIRBANKS PROGRESSES WITH REALTORS ^
'JnitPu '.n ^riviro?:r.".:t,il Protectior A^'-'-cy
1200 6th Avenue
~ t - £ r\ f-
n-~
battle, ,va?hirigtoi'. .
Jear ;,irn:
"he ?>\i ?.;•> 30\:O "r> FC.1. voul" " ;j j - ,7l
in fur of !>:•» "C?.T" PC 1 liE'I^SHY yco^ ,
Thin'; you.
"'.lliATTR ?W?.~^Tl 3C\X>
/ / ? / — >
;//
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CfA
DEC 1 6 W5
alaska/national
banK
of the north
Main Office
Alaska National Bank Buildinq
Fairbanks, Alaska 99701
December 9, 1975
Director of Public Affairs
U.S. Environmental Protection Agency
1200 Sixth Avenue, M/S 605
Seattle, WA 98101
Dear Sir:
This is a statement from the Alaska National Bank of the North urging your
approval of the construction of the Refinery at North Pole, Alaska. This
refinery is vitally needed in the interior and will have significant positive
benefit for all Alaskans.
The cost of fuel in the interior is one of the major factors causing a 50%
higher cost of living here than in the lower 48. For example, the high cost
of stove oil (currently at 54tf per gal.) combined with severe winter temperatures
produces home heating bills of over $200 per month. The cost of transportation
is also excessively high when the cost of gasoline at 80£ per gallon is combined
with 6 and 7 miles a gallon gasoline usage for 6 cylinder cars during winter.
The North Pole Refinery will provide, for the first time in the interiorof
Alaska, a relatively inexpensive source of fuel. This will cause a significant
reduction in the cost of living in interior Alaska.
A lower cost of living deferential $s compared to the lower 48 will help the
interior to develop the sound economic base it desperately needs. It will
demonstrate to outside firms that business can be operated at reasonable cost
in Alaska. (Note, transportation is one of our major industries and one of
its major cost of operation is fuel.) The growth of industry will provide jobs
and add to our economic base.
Perhaps more Importantly, the refinery will signal to outside investors and
sources of funds that the Interior of Alaska is not on a boom and bust cycle.
Instead, it 1s taking meaningful steps to develop sound economic growth. This
will do much to inhence the attraction of the interior as a place to do business
and invest funds.
358
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Page 2
December 9, 1975
If the refinery Is not built it will indicate that the people of the
interior don't really want to improve their economy and are not really
Interested in economic development. That is not the desire of the
people of Alaska and such an indication would do lasting economic harm
to all of Alaska.
Alaska needs to break away from its past boom and bust economy and
develop a sound economy with steady growth. Construction of the refinerv
at North Pole will be a ma.ior step toward achieving that goal. We urge
your speedy approval of the refinery.
& Development
CS/sh
359
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UiOfii
DEC 1 •
December 12, ]975
Director of Public Affairs
IJ. 3. Environmental Protection Agency
1200 Sixth Ave., Il/S 60$
Seattle, Washington
Subject: North Pole Refinery
North Pole, Alaska
CJontlericn:
I fully endorse the building of the refinery at Morth Pole, .Uv.^k-.
Having been born and raised'in Fairbanks, L'7 years n-^o, T h^v.
watched this area grow and the refinery will be a real far*to" in keeping
the cost of living down. It will make fuels readily available the
lowest nossible price, a real factor in these inflationary times.
I don't believe the refinery will create an./ -1 pui-ition profti
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IfxsWert kit (0
DEC 1 «
VERNON H. BOYLES
417 HAINES AVENUE - FAIRBANKS. ALASKA 99701
PHONE 452-1792
December 10, 1975
Director of Public Affairs
U.S.Environmental Protection Agency
1200 Sixth Avenue, M/5 605
Seattle, Washington, 98101
Re: North Pole Refinery
Gentlemen:
I would like to take this opportunity to state my support for the
above referenced project.
I have been a resident of Fairbanks for 21 years, in the mechanical
contracting business for the last 10 years. I have raised my family
here and plan on living here the rest of my life. I feel that sound
growth and development in our area is very important to the livlihood
of the residents living here.
I understand the EPA requirements are being met on the proposed refinery
and feel that the Refinery would be a good beginning for our area to
promote and attract industry.
Thanks.
Sincerely,
VHB/s
361
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B&A
REALTORS
ANNA GROFF, BROKER
CUSHMAN & 9th ST.
P O. BOX 927, FAIRBANKS, ALASKA 99707
Phone 452-1811
December 10, 1975
Director of Public Affairs
U.S. Environmental Protection Agency
1200 6th Avenue M/s 605
Seattle, Washington 98101
Dear Sir:
Having been a resident of Alaska since 1957 and engaged in
Financing most of this time, I have been closely associated
with many Economic Problems which have confronted Alaska in
the years past.
The Development of any Frontier Country such as ours, depends
heavily on two things, transportation and Finance. To sell a
long term mortgage in the years past to an outside Mortgage
Company, has been virtually impossible for a lack of year-
around Economy. At least with the building of the Pipeline
and the coming of a gasline and the necessary By-Products
line in the future, these serious economic problems can be
greatly reduced.
The location of the Refinery on the banks of the Tanana River,
is an ideal location. There is very little population in the
immediate area and no population to the Southwest across the
river, as it is a Military Reservation.
I have personally witnessed the operation of Refineries in
downtown Tulsa, Oklahoma, in fact I was greatly surprised to
find that some of these huge buildings were engaged in the
Refining Business, as there was no expulsion of smoke or
Re.: Earth Resources Refinery,
North Pole, Alaska
362
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December 10, 1975
Director of Public Affairs
U.S. Environmental Protection Agency
steam, as used to be the case in years past.
With the great deposits of raw material, which Alaska containes,
and a permanent industry so sorely needed in this area, many
of us sincerely hope, that the findings of the Environmental
Protection Agency will be highly in favor of construction
of the above described refinery.
Yours truly,
Ro W. Groff
Vice President
RWG:kms
cc: Dr. William C. Wood
363
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Branch Office
P.O. Box 847
Telephone 456-5005
Fairbanks, Alaska
Usibelli Coal Mine, inc.
270 ILLINOIS ST. * FAIRBANKS, ALASKA 99701
December 12, 1975
U. S. Environmental Protection Agency
1200 - 6th Avenue
MF 605
Seattle, Washington 98101
Dear Sir:
It is the consensus of opinion of Alaskas T.iners that
the Oil Refinery at North Pole be constructed forwith0
If Alaskas resources are to be developed and if Alaskans
in the interior are to live in a comparative life style as the
Uo S« citizens of other ar«as then we are entitled to cheaper
petroleum products,, The only way we are going to enjoy cheaper
oil products is to have a refinery near the source of crude.
Based on our knowledge of the area the environnental
damage of a refinery would be rrdninal..
Sincerly,
Willian I, ¦Jaugaman
: OFFICE OF FEDERAL AFFAIRS
I ••
364
-------
December 3, 1975
Director of Public Affairs
U. S. Environmental Protection Agency
1200 Sixth Ave., M/S 605
Seattle, Washington
Subject: North Pole Refinery
Gentlemen:
It is my understanding that the design and proposed operation
of the North Pole Refinery by the Energy Company of Alaska will
fully comply with EPA requirements and standards.
I am an Alaskan of nearly thirty years residence in Fairbanks
and I heartily endorse this development as it will enhance further
private industrial growth so that our economy may become less de-
pendent on Government payrolls of the various Federal and State ag-
It is hoped that the large majority of true Alaskans who favor
orderly growth and development will be adequately represented in
correspondence you may receive so that a very small but very vocal
minority of pseudo Alaskans will not create the absolutely false
impression that great numbers are opposed to the Refinery and other
potential industrial development.
The project as proposed truly meets with the goals of EPA as
stated by Mr. Russell Train and I hope it will be a model to which
your otfice may point with pride.
Yours very truly,
North Alaska
encies.
365
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RYNNIEVA-ALASKA
Vegetable Seeds
Varieties recommended by the
University of Alaska Extension Service
ALASKA-YUKON
Plant & Seed Co.
Specialists in Alaskan & Canadian Seeds
P.O. Box 2829 — Fairbanks, Ala«ka 99707
Phona 1907)488-6658
December 12, 1975
Mr. W. D. Jaspers
Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington
0EC22 1375
ffrlCE OF FEDERAL AFFAIRS
Dear Sir:
We endorse construction of the refinery at North Pole, Alaska by the Energy
Company of Alaska.
The Alaska-Yukon Plant £- Seed Co. Is financed by long-time Alaskans who have
agrarian interests for Alaska. Since developing Alaska's anricultura1 poten-
tial will help the environment more than any other source, we are concerned
with planned development of natural resources.
Controversy resisting the refinery is blindly justified. If preservationists
respect growth effects to Interior Alaska's environment, they would welcome
ECA 1 s ref i nery.
ECA is designing the refinery to serve the neecfs of Interior Alaska, creating
a competitive market enabling the consumer to purchase fuel oil at a cost
comparable to Anchorage prices.
ECA's major contribution to Interior Alaska will be the necessary stimulation
to extend the agricultural industry. The refinery will supply bulk fertilizer
to interior farmers. Steam emission from the refinery and the GVlA power
plant can be utilized to dry vegetable seed, grain and hay crops, sterilize
soil, and heat large food-producing greenhouses.
Another possible utilization of escaping heat is aquaculture (fish farming).
With the steady decline of commercial fishing harvests, aquaculture is an
industry that will develope as the necessary energy is supplied. Steam
unused by agriculturally-oriented production will be fed back into the GVEA
power plant leaving little emission to the atmosphere.
We share Fairbanks Growth Council's concern about the growth of Interior
Alaska but we choose, however, to favor industries for Alaska that provide
productive labor and essential factors to better living conditions.
A major factor for the impact arising in Interior Alaska from the trans-Alaska
pipeline construction is a lack of "groundwork" required for our existing
population: FOOD PRODUCTION and a stabilized COST OF LIVIMG. Alaska's increased
population cannot be maintained without a food producing economy. Whereas food-
366
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Environmental Protection Agency
December 12, 1975
Page - 2 -
production was a necessary prerequisite in all past cultures^ the pipe and
concrete appeared in Alaska before the agricultural foundation.
We are not newcomers to Alaska trying to destroy, but we wish to retain
"our way of life". My partners have each spent more than thirty years in
Alaska. I have lived here all of my adult life. All of us Intend to con-
tinue living here, regardless of the hardship, providing existence is
poss i ble.
ECA is sincere in its efforts to cooperate with community planning. The
North Pole refinery can improve conditions and circumstances surrounding
the development of the community. To rephrase this, ECA's refinery will
improve Interior Alaska's ecosystem.
EPA's concern is protecting our environment. Preservationists appear to
be against all EPA reports favorable to development. The few against
good usage of our natural resources are depriving long-time and new Alaskans
of improved livelihood.
Thank you for allowing us to voice our preference on the refinery issue.
We feel approval of the Environmental Impact Statement is warranted and
EPA should issue ECA an environmental permit without further delay.
Sincerely yours ,
RW/cg
Enc: "Beginnings of Domestication", ANTHROPOLOGY TODAY excerpt.
367
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"BEGINNINGS OF DOMESTICATION"
Excerpt from:
ANTHROPOLOGY TODAY; CRM Books, Del Mar, California, 1971 Second Printing;
Richard L. Roe, Publisher; Pages 235 & 236. Chapter 16.
Shortly after the close of the Pleistocene, around 9000 B.C., human groups
in several different parts of the world underwent a cultural revolution whose
effects were as great and far reaching as those of any other event in man's history.
The archaeological stage represinting the emergence of this life way was first
called the Neolithic, or New Stone Age. As the name implied, this epoch witnessed
many changes in stone tool technology. And the people at this new level of cult-
ural development in fact made great contributions in several areas of technology,
ranging from pottery and the use of metals to many of the structural elements
that are to be found in architecture today. Nevertheless, these and many other
material advances that accompanied them were only secondary expressions of a
much more important and fundamental change in human life, for this new level
represent not only a period of elaboration but a basic reorientation of the direction
of cultural evolution and man's place in nature.
The key was the shift in subsistence economies. Paleolithic man lived by
hunting wild animals and gathering wild plants, an economy that could produce
remarkable achievements in areas where food resources were especially abundant.
Even under the best conditions, however, hunting and gathering imposes severe
restrictions upon man's numbers and his opportunities for cultural development.
locked in an «laborate network of ecological checks and balances.
s
dependent upon wild food, man remains merely one o£ several
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-2-
should reproduce and flourish at the expense of others. And domestication re-
sulted in farming and herding, which form the basis of what anthropologists
call a food-producing economy. In gaining this control over his food supply,
man ultimately found that he could produce food with almost the same degree of freedom
that he could produce other necessities of life, such as tools.
The effects of food production were far reaching. Tied to their crops and
herds, men usually found it necessary to settle down in more-or-less permanent
villages and towns. Just as the shift in economics required new tools and skills,
so group life in permanent settlements required new forms of social and political
organization and, no doubt, new ethical and religious principles as well. At the
same time, village life fostered the development of many new arts and crafts,
which in turn promoted the formation of trading networks for distributing both
raw materials and finished products.
The change in man's condition as a level of food production became truly
effective was quantitative as well as qualitative. Food production eventually
led into an increase in human numbers that was similar to -- and indeed the
ultimate cause of -- the population explosion of modern times. This was in large
part due to a relaxation of natural restrictions upon human breeding that came
about once man had relatively assured supplies of food during even the leanest
months of the year. But it probably reflected as well the loss of such practices
ai infanticide and the abandonment of the aged, which must have been common
in Paleolithic times when food was often scarce and men had to cover great dis-
tances to find it. When people settle down in villages and make their living
by farming and tending animals, however, old people and children also can make
economic contributions.
Food production proved to be so successful that within a few millenniums
of its appearance — in all the separate regions of the world where it did
independently appear -- the new life way had spread to westieated plants and
369
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-3-
animals could survive. It is for this reason that hunters and gatherers today
are found almost exclusively in marginal areas such as arctic wastes, deserts,
and the depths of tropical forests. In addition to providing a means of existence
for the overwhelming majority of men born since the close of the Pleistocene,
food production was a necessary prerequisite for the still higher forms of culture
known as civilization, which ultimately expanded the village-farming level to that
of literacy and urbanism in many parts of the world.
No civilization has been or ever could be developed by hunters and gatherers.
All the key features of civilization -- social classes, specialists, political
states, writing systems, and great engineering projects -- ultimately must be
viewed as cultural responses to the needs created by dense human populations.
And, given the limited wild food resources available to men in even the most
favorable natural environments, really large groups cannot develop or be maintained
without food-producing economies. Thus, although the early village farmer no
doubt considered himself merely to be making a living, we view him as the pioneer
who built the bridge leading from savagery to life as we know it today. Without
the Paleolithic we could not have been men, but without the achievement of food
production we could not have been civilized.
** Anthropology Today is a collegiate textbook edited by
3*» Ph. D Consultants from leading colleges and universities
in the United States.
370
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m
I
CULFABCO INC.
() CULVERT FABRICATING COMPANY ~)
n *fi
DEC 2 2 1975
.OFFICE OF FEDERAL AFFAIR®
' i
Director of Public Affairs
U S Environmental Protection Agency
1200 Sixth Avenue M/S 605
Seattle, Washington 98101
15 December 1975
* «*'
907/452-4464
BOX 3025 • 3605 PEGER ROAD
FAIRBANKS, ALASKA 99701
Dear Sir:
This letter is to inform you that my family and I consider it critical
that there be no delay or obstruction to the construction of the North
Pole Refinery.
My wife and children were born in Fairbanks, Alaska, and we operate
a business here. We are convinced that the program outlined for the
construction of the refinery will not degrade our environment.
We feel that it is more important that Fairbanks have good industrial
growth than it is to maintain a 'log cabin community' where electricity,
transportation, and the modern aspects of society are beyond economic
capability. We want Fairbanks to continue the growth we have seen over
the past 25 years so that we can enjoy large, warm, modern homes; good
availability of food, and recreation. Obviously, none of these are
available unless there is a source of reasonably priced fuel for elec-
tricity and transportation.
Please support the early construction of this facility. We understand
it meets all EPA and State requirements, which we feel provides all
safety of our air and water to maintain it in an acceptable standard.
KWC/s
371
-------
F I DC
DR. WILLIAM R.WOOD FAIRBANKS INDUSTRIAL DEVELOPMENT CORPORATION
EXECUTIVE VICE PRESIDENT Phone 907 452-5400 or 452-5752 619 Eleventh Avenue Fairbanks, Alaska 99701
December 17, 1975
Director of Public Affairs
U.S. Environmental Protection Agency
1200 Sixth Avenue, M/S 605
Seattle, Washington 98101
Dear Sir:
While I write as an individual in strong support of the
North Pole Refinery Project, I do express the "community" view
of the organization of which I am the non-salaried Executive
Vice President.
The Fairbanks Industrial Development Corporation is a
group of leading business and professional firms in the Interior
of Alaska, now numbering ninety-six active members and growing.
It was organized on a non-profit community service basis to seek,
through orderly resource utilization in our region, a sound stable,
diversified economy. Quite definitely it does not advocate growth
for growth's sake. It believes in the development of new wealth
through combining wisely the energy, skills, and creativity of
the human resource with the natural resource base. It seeks to
avoid exploiting or despoiling either. New wealth makes possible
improvement in social, economic, and cultural conditions of people.
Historically, almost endless attempts to redistribute exisiting
wealth have not achieved such improvement.
The FIDC, therefore, advocates thorough investigation and
use of the "value added by people concept" before committing an
Alaskan natural resource to development. The full opportunity for
local use and processing of renewable and non-renewable natural
resurces is the resource birthright of all Alaskans.
The North Pole Refinery Project, small scale as it is,
emerges as a "break through" opportunity for the residents of
Interior Alaska to do something significant for themselves that
will improve living conditions through relative reduction of fuel
and energy costs.
As you well know, in the past Alaska has been the victim
of exploitation of its prized resources: fur, fish, timber,
copper, and gold. In the absence of strong Alaska resource
utilization policies in territorial days, the rape of the colonials
was the name of the game. The cycle of employment and business
372
Fairbanks
Interior Alaska's S ervice, O perations &S upply Center
-------
Director of Public Affairs
-2-
December 17, 1975
activity, particularly for Interior Alaska, has been boom and
bust.
We are weary of that cycle. Surely we can do better. In
the last two years the population throughout Interior Alaska has
almost doubled and continues to grow because of the huge manpower
requirements of the oil pipeline construction project. Many of
the workers want to remain in Alaska. They join others who seek
the type of secure future that only permanent employment opportunities
can bring after the construction build-up something in addition
to government jobs, service and supply work.
In a relatively small but very significant way the North Pole
Refinery Project would provide such permanent employment opportunities,
a meaningful outlet for the energies, talents, and skills of our
people.
Let it be understood without doubt that our first concerns
are WHAT is to be done with Alaska's natural resource wealth?
WHY? FOR WHOM?
The issues are moral and social as well as economic and
budgetary. For resource production, processing, and utilization
activities, when wisely conceived and managed, contribute directly
to the dignity and self-respect of the individual and his community.
They provide for a sturdy, diversified, and balanced economy, as
well as a means of insuring quality in social and cultural affairs
of the people and the State. The issues here are above and beyond
partisan political considerations, trivialities, and frivolousness.
Alaska needs to break away from its past boom and bust
economy. Construction of the North Pole Refinery Project would
be a major step toward achieving that goal.
Sincerely yours,
WRW/kb
2 /?. UJ-trrA
William R. Wood
Executive Vice President
...
ov
373
-------
THE ORGANIZATION FOR THE MANAGEMENT OF ALASKA'S RESOURCES, INC.
MT. McKINLEY MUTUAL BANK BUILDING, 5271/2 3rd Avenue, Fairbanks
MAIL: P.O. Box 132, Fairbanks, Alaska 99707
Telephone (907) 452-8323
Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Gentlemen;
The Fairbanks Chapter of the Organization for the Management
of Alaska's Resources supports the ECA refinery at North Pole,
Alaska.
We feel that it is imperative that all possible techniques
utilized to date, and the techniques utilized in the refineries
recently built in Texas and Washington states to decrease all
pollution factors and excess moisture emissions into the atmos-
phere must be followed.
We hope that the EPA will not only permit but will encourage
North Pole to develop this refinery since carefully chosen and
engineered industrial development will help Alaska to become
s elf-s uffic i ent.
December 19,1975
build an
ALL AMERICAN
TRANS ALASKAN
gas line
374
-------
WILLIAM R. TOWSLEY
821 GLACIER AVENUE
FAIRBANKS. ALASKA 90701
DEC30197S
OFFICE OF FEDERAL AFFAIRS
December 22, 1975
The Director,
U.S. Environmental Protection Agency
1200 Sixth Avenue,
Seattle, Washington 98101
Dear Sir:
For just over 20 years, I have been working in
Fairbanks and feel qualified to judge on some of the
aspects of the rudimentary facilities available when
I first came here and the improvements currently en-
joyed. We now have a city sewer and water system in
my neighborhood and I no longer suffer the dangers
of an inadquate cesspool and drinking water system.
(I have my own well which I now use to water our lawn
and flower and vegetable gardens.)
When I first came here, raw sewage was being
dumped into the Chena River - this condition is now
almost completely eliminated.
Our streets, where I live, were not paved but
just this summer were chipped and tarred and the dust
is reduced.
Our City Manager has put in one-way traffic and
thereby has sped up the movement of vehicles through
the city - concurrently reducing the incidence of carbon
monoxide.
We are going to get an oil refinery near North
Pole which will enable us to have a better source of
energy and at less cost than our previous operations.
That is, we hope to have an oil refinery at North Pole.
I think most of us here are for controlled progress -
which we have. There are some, in my viewpoint, who
will resist progress regardless of its benefits and
regardless as to whether or not there is even a meas-
urable unfavorable impact.
375
-------
I believe that it's just a relatively few people
who for reasons of their own - not understandable from
their protestations - wish to keep a status quo or even
to return to our previous conditions of outdoor toilets,
unsanitary night soil dumping, contaminated wells for
drinking water. I say this because that seems to be
the way they live.
Lets continue our controlled growth. The North
Pole area refinery will add to the growth.
376
-------
r
i'A r Coi. p
ujO^^jcL +c> ki^auJ
\/y\'^ ffivd ^ QJ=, (JU^v- AicL^(ca^_ £e£?
"r- r^ot rc^ -yjc s '-^Jj-^J(vj~y- ~\ a ' 'Y '.J-:TOh c+— -Qr, S?Ur>:^ ^
l\ "j© t- rKa>w/ ''! -u:
OL ¦— c>t
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- - ¦ /v9£/
?mi©lWE[jj)
DEC 2 91975
OFfSCE OF FEDERAL AFFAIRS
i
i . --^fj*„*l'."'»*¦'»
377
-------
JAN 61976
"»T1CE OF FEDERAL AFFAIRS
5 Kile Chena Hot Sprgs Rd
SR 50488
?airbarks, Ak., 99701
28 December 1975
Director of Public Affairs
U.S. Environmental Protection Agency
1200 Soxth Ave.
Seattle, '//ash., 96101
Gentleffien:
I ur£e you to disapprove the issuance of
a permit for the refinery at Xorth Pole, Ak .
There are many other areas in the North Star
Borough in which a refinery and some related
industries could be located which would still
benefit the area economically and not increase
the air pollution in the Tanana Valley. 'What-
ever pollutants are put into the air of the
valley tend to stay until ore of our infre-
quent winds blows them away.
Scientists at the University of Alaska
prepared a study of a refinery in the Tanana
Valley ahich stressed the very d-jtiri:".ental
effects of locating it rear North ?ole and
advised that it be located on one of the hills
near Fairbanks where winds would disperse the
air. Big Delta, which is on the pipeline and
a very v.indy area, would also be a ^ood loca-
tion; I'm sure there are many more in the
Borough.
378
-------
The air pollution in the valley is not
confined to cold weather. Today, which is rel-
tively mild and above zero, as I look from
our homestead north of Fairbanks I can see
the gray-brown smog stretching from the base
of our hill south towards the Alaska F.ange,
enclosing the city of North Pole about ten
miles from here. Even in summer the air in
the valley is no longer clear.
Some industrial growth is inevitable
and if controlled will be beneficial to all
residents of this area. Powever, industries
seeking to locate here should be compelled
to place consideration of possible environ-
mental damage first in choosing a site,
instead of choosing the site first for econ-
omic reasons and then attempting to justify
it environmentally.
Sincerely,
379
-------
JJac\e. S'.jbL.
. 7 ^ 75" ^tc*.cL
355.5 V/Y. • • /pbfes '^y-
n C! si f-f^toA^t-s qr"="
!.fl
u'eiSJWAl
X <^ k^op.+U ""PoIt. ,
T>( tcibt. ^£coi/\$'d£fc cp(*A/'c>^\
A.bocVt" £Xw\ tx &£rCG ~~
gtiAfe.te.cc4-ioiA /kas?fcaio, 6is^.uLCif^_ of
LcxS^At^op 5ds\cx>f O^d lAau£
H^ia. ci. of" A , in
•R>to. . X, am v-jo-f- ^ad.< coi/
£irvO vOi^\ lO«*fl/\ou+
o^t-+frn^| ^c^.cL H-V)^occl- i© -
FceoA\ pL\b fistafce^ t/v^fo^vrvs^o^
X 'of- K-fc_a_cL Cc {£. u3oa^
onl^ uvialsfe. SMfc- ^c/e. pe~ob(t^iA^
iJ&oiL&Z, . IL fed. (i'SaJL, b£-Cc^U&€- 31'u*-
tu\ a^vd cWaIjc.
(3'ifc COai^S&.S' r I/VKcl^L.
-------
REFERENCES
-------
REFERENCES
1. Guinn, H.C., Zoning Administrator, Fairbanks North Star Borough,
Letter to K. Andree, Golden Valley Electric Association, Inc.
April 24, 1975.
2. "Soil Survey, Fairbanks Area, Alaska", U.S.D.A., Soil Conservation
Service/Alaska Agricultural Experiment Station, Series 1959. No. 25.
September 1063.
3. "Environmental Resource Inventory, Chena River Lakes Flood Control
Project", U.S. Army Corps of Engineers, Alaska District. March 1975.
4. "Subsurface Investigation - New Turbine Generating Facility,
North Pole, Alaska", Shannon and Wilson, Inc., Geotechnical
Consultants for GVEA. April, 1975.
5. "Chena River Lakes Project - Interior Drainaae Facilities", U.S.
Army Corps of Engineers, Alaska District. March 1974.
6. "Earthquake History of the United States", U.S. Department of
Commerce, National Oceanic and Atmospheric Administration. 1973.
7. "Resources of Alaska, A Regional Summary", Joint Federal-State
Land llse Planning Commission for Alaska. July 1974.
B. "Chena River Lakes Project - Alaska, Design Memorandum No. 5",
Corps of Engineers. February 25, 1972.
9. Childers, J.M., J.P. Meckel, and G.S. Anderson. Floods of August
1967 in East - Central Alaska, U.S.G.S. Water Supply Paper 1880A,
USGPO, Washington, D.C. 1972.
10. Herrin, George. Flood Insurance Administration, Seattle, Washington.
Personal communication with C.B. Wilson, EPA, Region X. July 1975.
11. State Water Quality Standards, Alaska. October 1973.
12. Alaska State Department of Fish and Game, "Fishery Resources of the
Tanana", Memorandum from Stephen L. Tack to George Van Wyhe.
Fairbanks, Alaska. July 1, 1975,
13. Gordon, Ronald C. "Winter Survival of Fecal Indicator Bacteria in
a SubArctic Alaskan River", EPA-R2-72-013, U.S. Environmental
Protection Agency, NERC-Corvallis, Oregon. August 1972.
14. Shallock, E.W. and F.B. Lotspeich. "Low Winter Dissolved Oxygen in
some Alaska Rivers", EPA - 660/3-74-008. U.S.EPA-Corvallis, Oregon.
April 1974.
382
-------
15. U.S. Environmental Protection Agency. Unpublished Data, Arctic
Environmental Research Laboratory, Fairbanks, Alaska. July 1970.
16. Kelso, W., Senior Engineer, R.W. Beck and Associates. Written
communication to C.B. Wilson, USEPA, Region X, Seattle, Washington.
May 29, 1975.
17. Tryck, Nyman and Hayes, "Resources for Planning-Comprehensive
Development Plan", Fairbanks North Star Borough. Adopted 1975.
18. Meckel, J.P. U.S.G.S., Fairbanks, Alaska. Personal communication
with C.B. Wilson, EPA, Region X, Seattle, Washington. July 1975.
19. Environmental Protection Agency, "Technical Assistance-North Pole
Wastewater Treatment Facility, North Pole, Alaska", Water Operations
Branch, Region X, Seattle, Washington. March 1975.
20. Engineering Science, Inc., "Air Quality Profile for Fairbanks
Borough Primary Abatement Area", July 8, 1975.
21. The American Society of Mechanical Engineers Publication, "Recom-
mended Guide for the Prediction of the Dispersion of Airborne
Effluents". Library of Congress, No. 68-31123. May 1968.
22. Pasquill, F. "The Estimation of the Dispersion of Windborne
Material", Meteorological Magazine. 90 (1063): 1961.
23. Benson, C.S. and Gunter Weller, "A Study of Low Level Winds in the
Vicinity of Fairbanks, Alaska". 1970.
24. Lewis, Carl eta, Mayor of North Pole. Personal communication with
F.K. Coleman, EPA, Region X. July 31, 1975.
25. Alaska Department of Highways/Federal Highway Administration,
"Environmental Interchanges on the Richardson Highway." November, 1974.
26. General Services Administration, "Final Environmental Impact
Statement, Federal Building and Parking Facility-Fairbanks, Alaska."
EIS No. EAK 75001. Auburn, Washington. April 2, 1975.
27. Pipeline Impact Information Center Report No. 9. November 13, 1974.
28. Kupiszewski, Dan, Economist, State Department of Labor, Northern
Region, Personal communication with F.K. Coleman, EPA, Region X.
August 1, 1975.
383
-------
29. Bouchard, E.R., Vice President, Energy Company of Alaska. Personal
Communication with C.B. Wilson, EPA, Region X. July 25, 1975.
30. Tack, Stephan L., Alaska Department of Fish and Game, Fairbanks,
Alaska. Personal communication to C.B. Wilson, EPA, Reoion X.
July 9, 1975.
31. National Academy of Sciences-Ilational Academy of Engineering:
Committee on VJater Quality Criteria. Water Quality Criteria 1972,
EPA-R3-73-033, USGPO, Washington, D.C. 1972.
32. USEPA, Proposed Criteria for Water Quality, Volume 1, Washington,
D.C. 20460. October, 1973.
33. USEPA, "Primary Drinking Water: Proposed Interim Standards",
40 CFR Part 141, Federal Register, 40(51): March 14, 1975.
34. USEPA, "Proposed Toxic Pollutant Effluent Standards", 40 CFR, Part 129,
Federal Register, 38(247): December 27, 1973.
35. USEPA, "Development Document for Effluent Limitations Guidelines and
New Source Performance Standards for the Petroleum Refining Point
Source Category", Effluent Guidelines Division, EPA, Washington, D.C.
April 197.
36. USEPA, "Compilation of Air Pollution Emission Factors", Second
Edition as revised.
37. Environmental Research Laboratories, "Plume Rise From Multiple
Sources", Oak Ridge, Tennessee. March 1974.
38. Turner, D. Bruce, "Workbook of Atmospheric Dispersion Estimates",
USEPA AP-26. March 1972.
39. Estes, Floyd, City Administrator, North Pole, Personal communication
with Susan LJedgle,R.W. Beck Consultants. November, 1974.
40. Larry Smith and Company, Inc., "The Economic Impact of an Oil
Refinery on the Fairbanks North Star Borough". August 1972,
41. Boulette, John, City Councilor, North Pole, Personal communication
with F.K. Coleman, EPA, Region X. July 9, 1975.
42. Pipeline Impact Information Center Report Number 14. March 19, 1975.
43. Pipeline Impact Information Center Report Number 18. July 16, 1975.
44. Daily News-Miner, Fairbanks, Alaska. Friday, August 8, 1975.
384
-------
45. Creighton, William, Division of Parks and Recreation, Fairbanks
North Star Borough, Personal comnunication with S. Wedgle, R.W. Beck.
November 1974.
46. Clements, Frank, "The Role of Industrial Development." Small Town.
6(1): July 1975.
47. Reger, Douglas, State Archaeologist, State of Alaska Department of
Natural Resources, Personal communication by letter to Walter D. Jaspers,
Office of Federal Affairs, EPA, Region X, August 4, 1975.
48. U.S. Environmental Protection Agency, "Petroleum Refining Point
Source Category Guidelines and Standards", 40 CFR, Part 419,
Federal Register, 38(91): May 9, 1974.
49. U.S. Environmental Protection Agency, "Petroleum Refining Point
Source Category Effluent Guidelines and Standards Amendments",
40 CFR, Part 419, Federal Register, 40(98): May 20, 1975.
50. Benson, Carl S., and 5ue Ann Bowling, "Condensation of Exhaust
Plumes from Jet Turbines Operating in Cold Air," 1975.
51. Holmgren, B., L. Spears, C. Wilson and C. Benson, "Acoustic Soundings
of the Fairbanks Temperature Inversions," 1973.
52. Benson, C. S., and S. A. Bowling, "The Sub-Arctic Urban Heat Island
as Studied at Fairbanks, Alaska," 1973.
53. Holty, Joseph G., "Air Quality in a Subarctic Community - Fairbanks,
Alaska," 1973.
54. Bigler, S. G., K. Mackenzie and R. A. Willis, "Air Pollution
Conditions in Fairbanks, Alaska," 1973.
55. CRREL, "Accumulation of Atmospheric Pollutants Near Fairbanks,
Alaska During Winter," 1975.
56. Pipeline Impact Information Center, Special Report No. 3, "Questions
and Answers About the Cost of Living in Fairbanks," December 12, 1975.
57. Pipeline Impact Information Center Report No. 21, October 15, 1975.
58. Goodwin, James. Alyeska, Anchorage, Alaska. Personal communication
with C. B. Wilson, EPA, Seattle, January 19, 1976.
59. Fedeler, Robert. Alaska Department of Fish and Game, Fairbanks,
Alaska. Personel communication with C. B. Wilson, January 21, 1976.
385
-------
60. Short, Jeffrey W., S. D. Rice, and D. L. Cheatham. Comparison of
the Standard Method for Oil and Grease Determination with an Infra-
red Spectrophotometric Method on Known Toxic Water-Soluble Fractions
of Oils, Northwest Fisheries Center, Auke Bay Fisheries Laboratory,
National Marine Fisheries, Auke Bay, Alaska. (In Proceedings of
Port and Ocean Engineering under Arctic Conditions Conference, 1975.)
61. Bouchard, Rod, Vice-President, Energy Company of Alaska. Personal
communication with C. B. Wilson, U. S. EPA, Seattle, WA. January
15, 1976.
62. Schetz, Dr. Joseph A., Virginia Research Assoc., 607 Rainbow Ridge
Drive, Blacksburg, VA 24060, December 1975.
63. Gedney* Larry. Geophysical Institute, University of Alaska. Personal
communication with F. K. Coleman, January 26, 1976.
64. Gloyna, E. F. and J. F. Maline, Jr. Petrochemical Wastes Effects on
Water, Parts 1-4, Water & Sewage Works Reference No. 110;R262-R285,
1963.
65. Ruggles, W. L. Basic Petrochemical Processes as Waste Sources,
Sewage and Industrial Wastes, 3_T_:274-281 , 1959.
66. U. S. Environmental Protection Agency, Unpublished data from 1969-
1970 study. Available from Region X, Alaska Operations Office,
Anchorage, Alaska (Keith Stewart).
67. LeResche, Robert E., "Wildlife Management in a Growing Alaska,"
Alaska Conservation Review, 15(3):4-6;1974.
68. Energy Company of Alaska, North Pole Refinery Site, Tanana River
Channel: Flow, Dilution and Mater Quality Study, February 6, 1976,
R. W. Beck & Associates (Consultants to ECA), Denver, Colorado.
69. Pavitt, R. W. R. W. Pavitt and Associates, Juneau, Alaska.
Personal Communication with F. K. Duncan, EPA, Seattle, Washington.
February 20, 1976.
70. Pavitt, R. W. R. W. Pavitt and Associates, Juneau, Alaska. Personal
Communication with F. K. Duncan, EPA, Seattle, Washington.
December 16, 1975.
71. Resources Planning Associates, Incorporated. Evaluating the Use
of North Slope Natural Gas in Alaska. (Prepared for Federal Power
Commission).October, 1975.
386
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APPENDIX
EXHIBIT 1
-------
WATER QUALITY STANDARDS FOR WATERS OF THE STATE OF ALASKA
For the State of Alaska, water quality standards issued in
October 1973 (18 AAC 70.010 through 18 AAC 70.020) established water
use classifications and criteria for each classification. These apply
to man-made alterations of waters of the state, including groundwater.
If waters have more than one classification, the most stringent cri-
terion applies.
Waste discharge permits issued by the State will define a mixing
zone that must not be so large as to damage the ecosystem through
interference with the biota nor so large as to diminish other bene-
ficial uses disproportionately. Secondary treatment is required for
domestic sewage, and best practicable control technology currently
available is required for industrial wastes. If these are inadequate
to achieve water quality criteria, a higher level of treatment is
required. The State may issue certification of reasonable assurance
that a proposed permitted discharge will not violate State water quality
standards.
Groundwaters are classified as A, B, F and G. Other fresh waters
of the state, being essentially in their natural conditions, are con-
sidered suitable to serve all classifications (with the exceptions of
the lower Chena River near Fairbanks and lower Ship Creek near Anchorage).
This includes the Tanana River.
The water use classifications and criteria established by the
Alaska water quality standards are summarized in Table 1. Table 2
expands on the water quality criteria specific to Class A waters;
these generally represent the most stringent applicable criteria for
the Tanana River and groundwater.
1 -a
-------
table 1
f« AAC 70.020 HATER QUALITY CRITERIA FOr HATERS OF THE STATE OF ALASKA
««'»tcr duality
^^^Pinmcteri
Vitcr Uses
Total Collforn, 1
Organisms (see note 1) ,
Mssolvcd
3xygen mg/1
or I Satura-
tion
pK T
(see note 3)
, r
Turbidity, measured in
Jackson Turbidity Units
(JTO)
Tempirature, as measur.
ed in degrees
Fahrenheit (*F)
Dissolved V,organic
substances
A. Water supply, drink-
fnj, culinary jnd food
processing withoot the
need far treatrent
oth»r thin sirple disin-
fection and simple re-
ucvsl of naturally
present 1">«nirlt1cs.
detr of b or wire
saircptes (n any month
ray not exceed SO per
100 ml, exceot around
water shall contain
zero per 100 m!.
Greater than
752 satura-
tion or
5 mg/1.
Between 6.5
and 8.5
Lest than 5 OTU
ociow CO'F
Total dissolved solids
from atl sources r*y
not exceed 500 rg/1.
b. Valcr supply, crlnli-
i nc, cull wry an1 feed
processing with th» need
for treatment equal to
coagulation, sedimenta-
tion, filtration, disin-
fection and any other
treatirsnt processes
necessary to re~ove
naturally present
irpurilies.
t'can of b or more
jacyOfj in »ny noilth
cay net exceed 1CCQ per
IPO ml t and not irore I
than 205 of samples
during one r.onth ir.4y ¦
exceed 2400 per 100 al,
except ground water
shall contain zero
per 100 ml.
Greater than
BK Si turj - .
tion or
5 mg/,1.
Between 5,g"
aruf &.$ ,
"Less than 5 0R| above
r?,t •i'.'J,1 conditions.
Below 60*F.
liucerlcai value 1s
intpp)ictble.
jC» Usttr <.ontict
Recreation
5trc &s B-l
Greater than
5 mg/1,
Between 6vy
and B.S
Hclo* 25 jrU except «hcfl
natural ecndititns ex-
ceed this figure efflu-
ents nay not Increase
the turbidity,
^«^^lr.e^1ca'! vulue M tn-
appllcable.
?!ur,*rlc»i vnue iv 1n-
appl icable.
n. Grvw;h Arid pnopa-
gatlon of fish and
other aquatic life,
including vjterfowl
and furbeafers.
Sox ss 3-1 to pro-
tect associated
recreational
values.
Sre/ter tfn/r
6 mg/1 in
salt water
and greater
than 7 mg/1
in fresh
viater.
Sctnesn 7,~J~
and 8.5 f()r
salt water-.
Between 6^
and 8.5 fftr
fresh wat*>r
' lest (hjn Hi JTV mm
attributable to solids
which result from other
than natural origin.
day not exact! mcurn
tnipt by mare tt>an 2*F
for salt water. Kay not
excetd natural temp, by
w>re than A'F for fresh
water, ito change shall
be Permitted for tenp.
over 60*F. Hii*iiruci
rate of chanoe per-
mrtted is O.gt per hr.
' k'itMn rtn:*s to tvtrii
chronic toxicity or
significant ecological
charge.
I. 5hei11i jh growth
and propagation tn-
cltiding natural and
ceracrctal growing
trcas.
riot to exceed limits
specified in National
Shellfish Sanitation
Vroqran fTini:a! of
Operations, Part 1.
'JSPHS. (sec note
Greater than
6 mg/1 1n the
larval stage.
Greater than
5 mn/1 1n the
arii^t Stan*.
Between 7
and 8.5
Same *s U-4.
"less than 6BLK
Uithin ranges to avoid
chronic toxicity or
significant ecolojical
change.
F. hgrleu!tur«l water
sup»!y, ^ciuding ir-
rigation, stock water-
ing, and tuick farming.
Kc.m of b or rare sam-
ples nny not encc$g/l for
surface water
Betwcjn 675"
ind B.S
llo Inposed turlidity
that My interfere with
established levels of
water supply treatment.
Less than
f.o anountj itove natural
conditions vhich ny
cause undue corrosion
scaling, or proceit
problens.
-------
TABLE 1 (cont.)
70.021
\j
hater (juf.i try criteria r0R
^esuJutj including Oils,
' lojtir.5 Sol ids, Sludijc
Ccposits and Other Wastes
:Sj~e as B-7
I
Sclll io'iifs
suspends.-; sol its
(includes sedi-
nent ?• t!:*nt!tjc
Delow nor,"ally
detectable
anounts
Toxic or 0L!if-r Deleterious
Substances, Pesticides and
Felated Ornanic and
lroryani c X.: tCMd1 s
MILKS Or 111[ STATE CF A',.ASl".A
(.1.1)...
UiiJ 1 n.i c L i v i ty
['0)
. L... 1 ,
! ^c. : :jr , 0 J .
il'CiijIII'td J
in col or '
Uili'.j
LW
• Acs'.' ¦-•tic
I Considerations
;;.itcr Gu;l i ty
! Parameters
i.'jUC tiL-S
Residues n."ty not naV.c the re-
'ccivir.r Kjier unfit. or unsafe
|for tne etc; of this classi-
fication; r.cr cause a film or
jsheen cp&n, or siscelora lion
Of, the S;irf
cc of the v.*(jtor
or adjoining shoreline; r.cr
cento u il«•;';« or trulsion
Wd i'f;.os;i.rJ beneath or
.jpc'i the lurfjce of the
i.-ater, within tr.e water col-
!i;~n, on tr.c totf.m or up on
,"'-¦^'1 sh-.r°1ir.pe jC-10
tainting fish, less tnan
or chronic problen levels a:,
r^voalpd by hir.r,f.y c* oin^r
apprcoriate r:Othods ard bel ;v/
concentratior.s affecting tho
ecolOjical balance.
Secchi
i/fjc ; fs-
il.li; at
r.iI n. d':|il!
cf J_Bint^-_r
barie'ls
id)
The concentration of
rtiiJiojctivc materials in
v:.i!i:rf. r.h,ill lie loss
| LhCni tiMS'.- required to
inert the liadi("ilion Pro-
tection Guides 'or maxi-
mum exposure of critical
hur.an organs recoxr.ended
by the former Federal
Rori1.il inn Council in the
case of foodstuffs harvest-
j cd from these wHers for
human eonMiir.plion. Te-
i cause any hu.'ian exposure
• !n
-------
TABLE 2
WATER QUALIir CRITERIA CLASS A WATERS - STATE Of ALASKA
lis* Water supply, drinking, culinary and food processing without the need for treatment
other thin simple disinfection and simnle removal of naturally present Impurities.
Total Coll fori Mean of 5 or more samnles In anv month may not exceed 50 organisms per 100 ml, except
Organisms groundwater shall contain zero ber I'M ml.
Dissolved Oxygen Greater than 751 saturation or f rog/l.
pH Between 6.S and 8.5.
Turbidity Less than S Jackson Turbidity Units.
Temperature, *F Below 60*F.
Dissolved Total dissolved solids from all sources may not exceed 500 mg/1.
Inorganic
Substances
Residues Including Residues may not make the receiving water unfit or unsafe for the uses of thf*
oils, floating classification; nor cause • film or sheen unon, or discoloration of, the surface
solids, sl-udgt of the water or adjoining shoreline; nor cause a sludge or emulsion to be deoosited
deposits Dr other beneath or \ioon the surface of the water, within the vater column, on the bottom or
wastes upon adjoining shorelines.
Settle able solids Below normally detectable amounts,
suspended solids
Toxic or other Carbon chloroform extracts less than 0.1 mg/1 and other chemical constituents mv
deleterious not exceed USP»S Drinking Water Standards.
substances,
pesticides and
related organic
and inorganic
materials
Color True color less than IS color units.
Radioactivity The concentrations of radioactivity shall not;
¦) Exceed 1/30 of the NPCW values given for continuous occupational
exoosure in the National Bureau of Standards Handbook No. 69.
*
b) Exceed the concentrations specified In the 1962 U.S. Public Health
Service Drinking Water Standards for waters used for domestic supplies.
c) Have a demonstrable detrimental effect on aouatic life.
d) The concentration of radioactive materials in these waters shall be less
than those required to meet the fladlatfon Protection Guides for maxfmum
exposure of critical human organs recomended by the former federal
Radiation Council 1n the case of foodstuffs harvested from these waters
for human consurntIon. Because any hunan exposure to Ionizing radiation
Is undesirable, the concentration of radioactivity In these waters shall
be maintained at the lowest practicable Jevel.
Aesthetic
Considerations
Hay not be Impaired by the oresence of materials or their effects viilcti are
offensive to the slgiit, smell, taste or touch.
-------
EXHIBIT X
-------
TABLE 1-A. WATER QUALITY- OF THE TANANA NEAR NORTH POLE, ALASKA - EPA STUDY
SOME WATER QUALITY PARAMETERS OF THE TANANA RIVER NEAR NORTH POLE, ALASKA DURING A\ 11-DAY INTERVAL BEGINNING
LATE FEBRUARY 1975
Total Solids Total Volatile Total Suspended Volatile Suspended Turbidity
(ng/1) Solids (mg/1) Solids (i:ig/l) Solids (rr.g/1) pH (JTU)
180-200 60-110 3-6 1 6.7-7.4 2.0-3.3
19-'. 87 4.2 1 7.2 2.4
1S0-2C0 64-120 3-5 1 7.3-7.7 2.2-3.3
120 84 3.4 1 7.5 2.6
Conductivity COO (rrg/l) CI (rg/l) Ca (mg/1) Ag (rr.g/1) H3 (ppb) Na (mg/1)
(iimlios)
C20-:91 1-C 1.7-2.0 42 <0.01 <0.1 3.C-4.0
244 5.6 1.8 42 <0.01 <0.1 3.9
T-^30**
220-27 j 1-6 1.7-3.4 42 <0.01 <0.1 3.-8-4.0
Avc;y.wT ?A 5 4.C 2.3 42 <0.01 <0.1 3.9
1-900*
Rang 2
Avccjgct
T-£0j**
-I *« H rt
Averagct
Average
Kg (no/") K (rcg/l) C'J (mg/1} Total Carbon Total Crganic ?iH3-r; kg 3
C^S/l) Carbon (r.r/l) (~c/T) (rrg/1)
Aivaracfi
14-15
14. S
2.0-2.1
2.1
<0.01
<0.01
27-30
23.8
15-25
21.2
0.01
-0.C1
.ca-." :•
nvcri"C,
13-15
14.2
1.9-2.1
2.0
<0.01
<0.01
•27-31
29.2
15-26
22.0
0.02-0.05
0.03
.10-. 13
.13
C-?3, (~g/l) SiO, (rr.g/1) Total Nitrogen (;rg/l) Total Phosphorus (rr.g/1)
T M-
T-90C+
R'r.90
Averace?
.002-.005
.004
13-14
13.8
.04-.06
0.05
.007-.014
0.010
T*Fr+
Avc-ra:
.002-.012
.004
14-15
14.2
.03-. 13
0.10
.007-.013
0.011
*A??roxir.-.at2ly 3 miles upstrean frcn the Topping Plant site,
roxirrately 15 rr.iles downstream from the Topping Plant site.
j. • >
I
NOTE: Samples were collected by the Arctic Environmental Research Laboratory during an 11 day
interval beginning late February 1375 and analyzed by that EPA laboratory.
2-a
-------
TABLE 1-B. TANANA WATER QUALITY
Upstream Downstream
Element (Sample No. 2) (Sample No. 1)
(ppm) (ppm)
Calcium 25 23
Si Iver <(0.01 <(0.01
Magnesium 10 11
Lead 20 ppb 25 ppb
Barium <0.1 <0.1
Cadmium <0.01 <(0.01
Hexavalent Chromium 32 ppb 19 ppb
Chromium <0.1 <^0.1
Fluoride 130 ppb 150 ppb
pH 7.1 units 7.2 units
Alkalinity 123 43
Phosphate 100 ppb 70 ppb
Sulfate 36 37
Suspended Solids 1 1
Dissolved Solids 184 147
Samples consisted of five-day composites collected upstream and
downstream of the proposed ECA refinery site on February 25, 26,
28, and March 3 and 7, 1975. (Data submitted by ECA)
2-b
-------
TABLE 1-C. TANANA WATER QUALITY^ - FEBRUARY 6, 1976, EPA ANALYSES
Parameter Concentration, ing/1
Total Suspended Solids 3.6
Chemical Oxygen Demand 1.3
Total Kjeldahl Nitrogen .016
Ammonia (as Nitrogen) .11
Nitrate-Nitrite (as Nitrogen) .16
Total Phosphorus .042
Calcium 26
Fluoride < 1
Sulfide < .02
Phenolic Compounds < .002
Oil and Grease .2b/
Cadmium .003
Chromium < .001
Copper .004
Iron .480
Nickel .015
Zinc .002
Lead .02
Manganese .13
a/ Samples collected in a channel (140 cfs) of the Tanana
River near ECA's site.
b/ Gravimetric method of analysis (American Society of Testing
and Materials). The reported value is essentially at the
detection level.
2-c
-------
TABLE 1-D. TANANA WATER QUALITY^/ - FEBRUARY 6, 1976, ECA ANALYSES
Parameter
Cyanide
Oil and grease
Sulfides
Total suspended solids
Zinc
Manganese
Chromi um
Iron
Cadmi um
Arseni c
Lead
Copper
Total phosphate
Nitrate
Phenols
Concentration, mg/1
Less than 0.01
Less than 1.0
Less than 0.1
2.4
Less than 0.1
0.09
Less than 0.01
0.2
Less than 0.01
Less than 0.01
0.02
Less than 0.1
Less than 0.1
0.2
Less than 0.001
a/ Samples collected in a channel (140 cfs) of the Tanana River
near ECA's site.
2-d
-------
TABLE 2. NORTH POLE WELL-ENVIRONMENTAL REPORT DATA*
Constituents Parts per Million
Carbonates, C03 0.0
Bicarbonates, RCO3 141.5
Chlorides, CI 5.7
Sulfates, SO4 24.0
Sulfides, S 0.0
Ammonia, NH3 Trace
Nitrites, NO2 0.0
Nitrates, NO3 Trace
Calcium, Ca 40.0
Magnesium, Mg 7.8
Sodium, Na 7.8
Iron, Fe (total) 0.52
Iron, Fe (dissolved) 0.00
Fluorides, F 0.33
Manganese, Mn 0.74
Potassium, K 1.8
Hardness as CaC03 ....132.0
Total Solids @ 105°C 156.1
pH Value @ 25°C 7.5
Conductivity:Mhos /cm x 10^ @ 25°C 27.0
Color : Water White
Odor : None
Turbidity: Clear
Theoretical Analysis (ppm)
Calcium Bicarbonate 162.1
Magnesium Bicarbonate 23.4
Magnesium Sulfate 19.3
Sodium Sulfate 12.8
Sodium Chloride 9.4
*Analyzed by Hornkohl Laboratories, Bakersfield, CA.
(Data submitted by ECA) Sampled April 1970.
-------
TABLE 3. NORTH POLE WELL-ENVIRONMENTAL REPORT DATA*
Parameter Parts per Million
Total Iron 0.60
Suspended Solids 4.0
Dissolved Solids 172.4
Total Solids 176.4
Analysis on filtered sample:
Calcium, calculated as Ca 40.8
Magnesium, " " Mg 8.3
Sodium, " " Na 6.5
Potassium, " 11 K 3.2
Iron, " " Fe 0.32
Aluminum, " " A1 0.0
Chloride, " " CI 2.5
Sulphate, " " S04 14.1
Silica, " " Si02 15.0
Total alkalinity,calculated as CaC03 136.0
Hydroxide " " " " 0.0
Carbonate " " " " 0.0
Bi-carbonate " " " " 136.0
Total hardness calculated as CaC03 136.0
Carbonate hardness " " " 136.0
Non-carbonate " " " " 0.0
Free carbon dioxide (CO2) 7.5
Pounds per 1000 Gallons
Incrusting solids 1.218
Non-incrusting solids 0.220
Probable Approximate Composition of dissolved Solids:
Parts per Million
Calcium carbonate (CaC03) 101.9
Magnesium carbonate
-------
TABLE 4. QUALITY OF NORTH POLE WATER SUPPLY
December 12, 1974 - EPA DATA
Parameter
Turbidity (JTU)
Color (SU)
Total Dissolved Soli
Chloride
Sulfate
Ni trate
Bari um
MBAS
Arsenic
Selenium
Fluoride
Cyanide
pH (SU)
Total Chromium
Si 1 ver
Copper
Manganese
Lead
Iron
Cobalt
Cadmium
Zi nc
Ni ckel
Mercury
Concentration, mg/1
1
2
.77
.45
3.0
3
. 182.0
182
<10.0
<10
26
26
<
1
< 1
<
.5
< .5
<
.25
< .25
<
0.005
< .005
<
0.005
< .005
0.2
.2
<
0.02
< 0.02
6.9
7.2
<
0.01
< 0.01
<
0.01
< 0.01
<
0.5
.23
0.7
.7
<
0.05
<0.05
<
0.61
.12
<
0.01
<0.01
<
0.006
<0.006
0.4
.01
<
0.01
<.01
<
0.0005
<0.0005
1962
USPHS Drinking Water Std
5
15
500
250
250
45
1.0*
0.5
0.01, 0.05*
0.01*
1.4 to 2.4*
0.01, 0.2*
.05* (Cr+6 only)
.05*
1.0
.05
.05*
.3
.01*
5.0
* Denotes mandatory limits; Others are recommended limits
Note: Two samples analyzed by EPA as reported in
Technical Assistance North Pole Wastewater Treatment Facility,
USEPA, Water Operations Branch, Region X, Seattle, WA. March
1975.
-------
TABLE 5. AUXILIARY NORTH POLE
CITY WELL
April
21, 1975
Parameter
mg/1
Parameter
mg/1
a/
Total suspended solids
LT 1
Lead
0.1
Total dissolved salts
280
Fluoride
0.19
Oil and Grease
LT 5
Selenium
0.007
a/
Sulfides
LT 1
Bari um
2
Ammonia - Nitrogen
LT 0.1
Silver
LT 0.1
Total Chromium
0.1
Calcium
45
a/
Chromium VI
0.1
Magnesium
11
b/
c/
Arsenic
0.03
Hardness
158
Cyani de
LT 0.02
ALKALINITY
a/
Carbonates
LT 1
Cadmium
0.03
Bicarbonates
53
pH (units)
8.3
Total Phosphates
LT .05
Phenols
LT .00'
LT= Less Than
a. Exceeds 1962 U.S. Public Health Service Drinking Water Stds
Mandatory Limits
b. Exceeds Recommended Limit
c. Calcium Carbonate equivalent
Data from a report by R.W. Beck, Assoc.,"ECA North Pole Refinery
Site, Background Data Study", March-April 1975
-------
TABLE 6. G.V.E.A. G-2 WELL- SHANNON & WILSON DATA
Parameter Concentration Range (mg/P*
Iron 0.05
Barium 0.1
Silica 0.1
Suspended Solids 0.1
Sodium 68-106
Potassium 10
Calcium 4
Magnesium 6-7
Sulfate 22-26
Chloride 8-10
Hydroxi de
Carbonate
Bicarbonate 195-281
Total Dissolved Solids 214-297
pH 6.5-6.6
Total Hardness (As CaCOg) 39
Total Alkalinity (As CaCOg) 160
Coliform Bacteria/ 100 ml
* Except pH is in standard units
Note: Samples were obtained from a shallow well (20 ft) at
Station G-2 on May 26, 1975. Data from: Subsurface Investigation:
New Turbine Generating Facility, North Pole, Alaska b.y Shannon &
Wilson, Inc. (Consultants to GVEA), Fairbanks, AK. April 1975.
2-i
-------
EXHIBIT 3
-------
KNOTS
1-3 4-6 7-10+
FAIRBANKS
SEASONAL WINDROSE
DEC-JAN-FEB
3-a
-------
KNOTS
1-3 4-6 7-10+
FAIRBANKS
SEASONAL WINDROSE
MARCH-APRIL-MAY
3-b
-------
N
S
KNOTS
1-3 4-6 7-10 +
FAIRBANKS
SEASONAL WINDROSE
JUNE-JULY-AUGUST
3-c
-------
N
KNOTS
1-3 4-6 7-10 +
FAIRBANKS
SEASONAL WINDROSE
SEPT-OCT.-NOV.
3-d
-------
N
S
KNOTS
1-3 4-6 7-10 +
FAIRBANKS
ANNUAL WINDROSE
3-e
-------
EXHIBIT 4
-------
N
S
KNOTS
1-3 4-6 7-10 +
EIELSON
SEASONAL WINDROSE
DEC.-JAN.-FEB.
4-a
-------
N
S
KNOTS
1-3 4-6 7-10*
EIELSON
SEASONAL WINDROSE
MARCH-APRIL-MAY
4-b
-------
N
S
KNOTS
1-3 4-6 7-10 +
EIELSON
SEASONAL WINDROSE
JUNE-JULY-AUG.
4-c
-------
KNOTS
1-3 4-6 7-10 +
EIELSON
SEASONAL WINDROSE
SEPT. - OCT.-NOV.
4-d
-------
N
S
KNOTS
1-3 4"6 7-10 +
EIELSON
ANNUAL WINOROSE
4-e
-------
EXHIBIT 5
-------
Permit No. AK-002546-1
Application No. AK-002546-1
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Federal Water Pollution
Control Act, as amended, (33 U.S.C. 2151 et seq; the "Act"),
Energy Company of Alaska
is authorized to discharge from a facility located at
North Pole, Alaska
to receiving waters named the Tanana River and Chena Slough
in accordance with effluent limitations, monitor imi rc-f|u i i">j;!Lt:n ts and
other conditions set forth in Parts I, II, and III hereof.
This permit shall become effective on
This permit and the authorization to discharge shall expire at
midnight, April 30, 1981.
Signed this day of
Director, Enforcement Division
5-a
-------
PART I
Page 2 of 16
Permit No. AK-002546-1
A.
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
1.
During the period beginning on the effective date and lasting through the expiration date the
permittee is authorized to discharge process wastewater from outfall serial number 001.
a. Such discharges shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTIC
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
kg/day(lbs/day)
kg/day (lbs/day)
Other Units
(Specify) Measurement
Sample
Process Water
Daily Avg
Daily Max
Daily Avg
Daily Max
Frequency
Type
Flow-m3/Day (MGD)
N/A
N/A
N/A
220
Continuous
__ _
(.058)
recording
BOD5
N/A
26(57)
N/A
N/A
1/week
24 hr. comp.
Total Suspended Solids
N/A
11.5(25)
N/A
N/A
1/week
24 hr. comp.
COD
cn
N/A
155(340)
N/A
N/A
1/week
24 hr. comp.
^Oil & Grease
N/A
2.2(4.8)
N/A
10 mg/1
1/week
4 grabs in
24 hours
Phenolic compounds
N/A
0.02(0.05)
N/A
0.1 mg/1
2/month
24 hr. comp.
Ammonia as N
N/A
4.6(10)
N/A
N/A
2/month
24 hr. comp.
Sulfide
N/A
0.09(0.2)
N/A
.4 mg/1
2/month
24 hr. comp.
Total chromium
N/A
0.004(0.01)
N/A
0.02 mg/1
2/month
24 hr. comp.
Hexavalent chromium
N/A
0.004(0.01)
N/A
0.02 mg/1
2/month
24 hr. comp.
b. The pH shall not be less than 6.5 standard units nor greater than 8.5 standard units and
shall be monitored by a grab sample once daily.
c. There shall be no discharge of floating solids or visible foam in other than trace amounts.
d. Samples taken in compliance with the monitoring requirements specified above shall be taken
at the following locations: in the effluent stream after treatment and prior to mixing with
other effluent streams.
-------
PART I
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Page 3 of 16
Permit No. AK-002546-1
2. During the period beginning on the effective date and lasting through the expiration date,
during the period of May 1 to October 31 of each year, the permittee is authorized to
discharge storm runoff from process areas from outfall serial number 001.
a. Such discharges snail be limited and monitored by the permittee as specified below:
1/
EFFLUENT CHARACTERISTIC
F1ow-r*;3/Day (MGD)
BGDr
3
Total Suspended Solids
COD
Oil and Grease
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
kg/day'lbs/day)
Daily Ava
N/A
N/A
kg/day (lbs/day) Other Units (Specify) Measurement
Daily Max Daily Avg Daily Max Frequency
N/A
At h
N/A
N/A
N/A
N/A
N/A
N/A
26 mg/1
21 mg/1
190 mg/1
8 ipq/l
246 Continuous
(0.065) recording
48 mg/1 1/week when
discharge
occurs
33 mg/1 1/week when
di scharge
occurs
370 mg/1 1/week when
discharge
occurs
Sanplt
Type
24 hr. co-
24 hr. cc
24 hr. cc
N/A N/A 8 ipg/l 15 n;g/l 1/week when 4 grabs i
discharge 24 hours
occursj^^
1/ If the dischciye limitations can not be achieved, the permittee shall treat the storm rfm^f from
process areas in the main treatment system as specified in Part I.A.3.
b. The pH shall not be less than 6.5 standard units nor greater than 3.5 standi^ units and
snail be monitored by a grab sample once daily.
-------
PART I
Page 4 of 16
Permit No, AK-002546-1
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be
taken at the following locations: in the effluent stream after treatment and prior
to mixing with any other effluent streams.
t
<1
-------
PART I
Page 5 of 15
Permit ^o. AK-002546-1
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
3. If storm water is routed through the main treatment system, during the period beginning on the effective
date and lasting through the expiration date, during the period of May 1 to October 31 of each year,
the permittee is authorized to discharge process waste water and storm runoff from outfall serial number 001.
a. Such discharges shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTIC
Process Water
Flow-m3/Day (MGD)
BOD5
Total Suspended Solids
COD
V"0i7 & Grease
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
1
(9
Phenolic compounds
Ammonia as N
Sulfide
Total chromium
Hexavalent chromium
kg/day (lbs/day)
Daily Avg
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
kg/day (lbs/day)
Daily Max
N/A
33(83)
20 (43)
245(540)
4.7(10.3)
0.05(0.1)
9.8(21)
0.2(0.4)
0.01(0.02)
0.01(0.02}
Other Units
Daily Avg
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
(Specify).
Daily Max
465
(0.123)
N/A
N/A
N/A
10 mg/1
0.1 mg/1
N/A
0.4 mg/1
0.02 mg/1
0.02 mg/1
Measurement
Frequency
Continuous
recording
1/week
1/week
1/week
1/week
2/month
2/month
2/month
2/month
2/month
Sample
Types
24 hr. comp.
24 hr. comp.
24 hr. comp.
4 crab in
24
24 hr. comp.
24 hr. comp.
24 hr. comp.
24 hr. comp.
24 hr. comp.
b. The pH shall not be less than 6.5 standard units nor greater than 8.5 standard units and shall
be monitored cy a crab sample once daily.
c. There shall be no discharge of floating solids or visible foam in other than trace amounts.
d. Samples taken in compliance with the monitoring requirements soecified above shall be taken at
the following locations: in the effluent stream after treatment and prior to mixing withi^^
other effluent streams. AJ
#
-------
A.
PART I
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Page 6 of 16
Permit No. AK-002546-1
4. During the period beginning on the effective date and lasting through the expiration date, during the
period of May 1 to October 31 of each year, the permittee is authorized to discharge storm runoff
from non process areas and tank fields to a drainage ditch which flows to the Chena Slough.
a. Such discharges shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTIC
Flow-m3/Day (MGD)
Oil and Grease
TOC
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
kg/day (lbs/day)
Daily Avg Daily Max
N/A
N/A
N/A
N/A
N/A
N/A
Other Units
Daily Avg
N/A
N/A
N/A
(Specify)
Daily Max
N/A
15 mg/1
35 mg/1
Measurement
Frequency
Sample
Type
Continuous
recording
1/week when 4 grabs in
discharge occurs 24 hours
1/week when 4 grabs in
discharge occurs 24 hours
tn
(
b. The pH shall not be less than 6.5 standard units nor greater than 8.5 standard units and shall
be monitored by grab sample once daily when discharge occurs.
c. There shall be no discharge of floating solids or visible foam in other than trace amounts.
d. Samples taken in compliance with the monitoring requirements specified above shall be taken at
the following locations: in the effluent prior to discharge to the drainaqe ditch.
>
-------
PART I
Page 7 of 16
Permit No. AK-002546-1
EFFLUENT LIMITATIONS AMD MONITORING REQUIREMENTS
5. During the period beginning on the effective date and lasting through the expiration date the
permittee shall 1) discharge all sanitary wastes to a treatment facility which provides secondary
treatment as specified in (40 CFR 133) or 2) totally contain sanitary wastes or 3) discharge
to the Tanana River as specified below:
a. Such discharges shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTIC
DISCHARGE LIMITATIONS
Effluent Concentrations
Other Units (Specify)
Effluent Loadings
kg/day (lb/day)
Measurement
Frequency
Dai ly
Average
Weekly
Average
Daily
Average
Weekly Daily
Average Maximum
Flow - m3/day (MGD)
N/A
N/A
N/A
N/A
11
(.003)
daily
B0D5
171
1
(£>
Suspended Solids
30 mg/1
45 mg/'l
0.34
(0.75)
0.5
(1.1)
N/A
1/week
30 mg/1
45 mg/1
0.34
(0.75)
0.5
(1.1)
N/A
1/week
Fecal Coliform Bacteria
200 counts/
400 counts/
N/A
N/A
N/A
1/week
MONITORING REQUIREMENTS
Sample
Type
continuou
100 ml
100 ml
grao
grab
b.
c.
d.
The pH shall not be less than S.b stands>
be monitored daily with a grab sample.
^ v-H
units nor greater than 8.5 standard units and shall
There shall be no discharge of floating solids or visible foam in other than trace a^^ts
Samples taken in compliance with the monitoring requirements specified above shal
at the following locations: After treatment and prior to discharge.
aken
-------
PART I
Page 8 of 16
Permit No. AK-002546-1
B. MONITORING AND REPORTING
1. Representative Sampling
Samples and measurements taken as required herein shall
representative of the volume and nature of the monitored discharge.
2. Reporting
Monitoring results obtained during the previous one month
shall be summarized and reported on a Discharge Monitoring Report Form
(EPA No. 3320-1), postmarked no later than the 28th day of the month
following the completed reporting period. Monitoring shall commence at
the time of facility start-up. Duplicate signed copies of these, and
all other reports required herein, shall be submitted to the Director, Enforce-
ment Division and the State at the following addresses:
United States Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Attn: Water Compliance and Permits Branch M/S 521
Alaska Department of Environmental Conservation
State of Alaska
Pouch 0
Juneau, Alaska 99801
3. Definitions
a. The "daily average" discharge other than for fecal coliform
bacteria, means the total discharge by weight during a calendar month divided
by the number of days in the month that the production or commercial facility
was operating. Where less than daily sampling is required by this permit,
the daily average discharge shall be determined by the summation of the measured
daily discharges by weight divided by the number of days during the 'calendar
month when the measurements were made. The daily average for fecal coliform
bacteria is the geometric mean of samples collected during a calendar month.
b. The "weekly average" discharge, other than for fecal coliform
bacteria, means the total discharge'by weight during a calendar week divided by
the number of days in the week that the production or commercial facility was
operating. Where less than daily sampling is required by this permit, the
daily average discharge shall be determined by the summation of the measured daily
discharge by weight divided by the number of days during the calendar week when
the measurements were made. The weekly average for fecal coliform bacteria is
the geometric mean of samples collected during a calendar week.
c. The "daily maximum" discharge means the total discharge by
weight during a calendar day. 5_h
-------
PART 1
Page ? of 16
Permit No.: AK-002546-1
Test Procedures
Test procedures for the analysis of pollutants shall conform
to regulations published pursuant to Section 304(g) of the Act,
under which such procedures may be required.
Recording of Results
For each measurement or sample taken pursuant to the requirements
of this permit, the permittee shall record the following informa-
tion:
a. The exact place, date, and time of sampling;
b. The dates the analyses were performed;
c. The person(s) who performed the analyses;
d. The analytical techniques or methods used; and
e. The results of all required analyses.
Additional Monitorlng by Permittee
If the permittee monitors any pollutant at the location (s)
designated herein more -frequently than required by this
permit, using approved analytical methods as specified above,
the results of such monitoring shall bt included in the cal-
culation and reporting of the values required in Lhe Discharge
Monitoring Report form (EPA Mo. 3320-1). Such increased
frequency shall also be indicated.
Records Retention
All records and information resulting from the monitoring
activities required by this permit including all records of
analyses performed and calibration and maintenance of instru-
mentation and recordings from continuous monitoring instrumentation
shall be retained for a minimum of throe (3) years, or longer if
requested by the Director, Enforcement Division or the State Water
Pollution Control Agency.
5-1
-------
PART II
Page 10 of 16
Permit No. AK-002546-1
A. MANAGEMENT REQUIREMENTS
1. Change in Discharge
: witlM
All discharges authorized herein shall be consistent
terms and conditions of this permit. The discharge of any
pollutant identified in this, permit more frequently than or
at a level in excess of that authorized shall constitute a
violation of the permit. Any anticipated facility expansions,
production increases, or process modifications which will
result in new, different, or increased discharges of pollutants
must be reported by submission of a new NPDES application or,
if such changes will not violate the effluent limitations
specified in this permit, by notice to the permit issuing
authority of such changes. Following such notice, the permit
may be modified to specify and limit any pollutants not pre-
viously limited.
2. Noncompliance Notification
If, for any reascr, the permittee does not comply with or will
be unable to comply with any daily rraxiimjm effluent limitation
specif-led in this permit, the permittee shal 1 provide the
Director, Enforcement Division and the State with the following
information, in writing, within five (5) days of becoming
aware of such condition:
a. A description of the discharge and cause of noncompliance;
and
b. The period of noncompliance, including exact dates and
times; or if not corrected, the anticipated time the
noncompliance is expected to continue, and steps being
taken to reduce, eliminate and prevent recurrence of the
noncomplying discharge.
3. Facilities Operation
The permittee shall at all times maintain in good worki ig order
and operate as efficiently as possible all treatment or control
facilities or systems installed or used by the permittee to
achieve compliance with the terms and conditions of this permit.
S-J
-------
Page 11 of 16
PART II
Permit No. AK-002546-1
4. Adverse Impact
The permittee shall take all reasonable stops to minimizWIfe^^ ^
adverse impact to navigable waters resulting from norcompl
with any effluent limitations specified in this permit, including m
such accelerated or additional monitoring as necessary to deter-
mine the nature and impact of the noncomplying discharge.
5. Bypassing
Any diversion from or bypass of facilities necessary to maintain
compliance with the terms and conditions of this permit is pro-
hibited, except (i) where unavoidable to prevent loss of life or
severe property damage, or (ii) where excessive storm drainage
or runoff would damage any facilities necessary for compliance
with the effluent limitations and prohibitions of this permit.
The permittee shall promptly notify the Director, Enforcement
Division and the State in writing of each such diversion or
bypass.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed
from or resulting from treatment or control of wastewaters shall
be disposed of in a manner such as to prevent any pollutant from
such materials from entering navigable waters, except as limited
in Part I-A.
7. Power Failures
In order to maintain compliance with the effluent limitations
and prohibitions of this permit, the permittee shall either:
a. In accordance with the Schedule of Compliance contained in
Part I, provide an alternative power source sufficient to
operate the wastewater control facilities;
or, if no d^te for implementation for an alternative power source
appears in Part I,
b. Halt, reduce or otherwise control production and/or all
discharges upon the reduction, loss, or failure of one
or more of the primary sources of power to the wastewater
control facilities.
5-k
-------
Page 12 of 16
PART II
Permit No. AK-002546-1
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the head of the State Water PolltMoj^
Control Agency, the Director, Enforcement Division, and/or their
authorized representatives, upon the presentation of credentials:
a. To enter upon the permittee's premises where an effluent
source is located or in which any records are required
to be kept under the terms and. conditions of this permit;
and
b. At reasonable times to have access to and copy any records
required to be kept under the terms and conditions of this
permit; to inspect any monitoring equipment or monitoring
method required in this permit; and to sample any discharge
of pal li/tants.
2. Transfer cf Ownership or Control
in the evert of any change in control or ownership cf facilities
from which the authorized discharges emanate, the permittee shall
notify the succeeding owner or controller of the existence of
this permit by letter, a copy of which shall be forwarded to the
Director, Enforcement Division and the State Water Pollution
Control Agency.
3. Availability of Reports
Except for data determined to be confidential under Section 308
of the Act, all reports prepared in accordance with the terms of
this permit shall be available for public inspection at the
offices of the State Water Pollution Control Aanecy &nd the
Director, Enforcement Division. As required by the Act, effluent
data shall not be considered confidential. Knowingly making
a false statement on any such report may result in the imposition
of criminal penalties as provided for in Section 309 of the Act.
4. Permit Modification
After notice and opportunity for a hearing, this permit may be
modified, suspended, or revoked in whole or in part during its
term for cause including, but not limited to, the following:
5-1
-------
Part II
Pa«ie 13 of 16
Permit No. AK-002546-1
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to
disclose fully all relevant facts; or
c. A change in any condition that requires either a temporary
or permanent reduction or elimination of the authorized
discharge.
Toxic Pollutants
Notwithstanding Part II, B-4 above, if a toxic effluent standard
or prohibition (including any schedule of compliance specified in
such effluent standard or prohibition) is established under
Section 307(a) of the Act for a toxic pollutant which is present
in the discharge and such pollutant in this permit, this permit
shall be revised or modified in accordance with the toxic effluent
standard or prohibition and the permittee so notified.
6. Civil and Criminal Liabi1ity
Except as provided in permit conditions on "Bypassing" (Part II,
A-5) and "Power Failures" (Part II, A-7), nothing in this permit
shall be construed to relieve the permittee from civil or criminal
penalties for noncompliance.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from
any responsibilities, liabilities, or penalties to which the
permittee is or may be subject under Section 311 of the Act.
8. State Laws
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee fron
any responsibilities, liabilities, or penalties established
pursuant to any applicable State law or regulation under
authority preserved by Section 510 of the Act.
5-m
-------
PART II
Page 14 of 16
Permit Wo. AK-002546-1
9. Property Rights
The issuance of this permit does not convey any property r
in either real or personal property, or any exclusive privileg
nor does it authorize any injury to private property or any
invasion of personal rights, nor any infringement of Federal,
State or local laws or regulations.
10. Severability
The provisions of this permit are severable, and if any provision
of this permit, or the application of any provision of this permit
to any circumstance, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit
shall not be affected thereby.
5-n
-------
Page 15 of 16
PART III
Permit No. AK-002546-1
OTHER REQUIREMENTS
A. Analytical Quality Control
The permittee shall submit to the Director, Enforcement Division
a summary of the analytical quality control program it proposes to use
within 30 days of the effective date of this permit. Such summary shall:
1. Specify the appropriate analytical methods and quality
control techniques the permittee proposes to use. The latter are to
be taken from EPA publication "Handbook for Analytical Quality Control
in Water and Wastewater Laboratories", June 1972;
2. Describe the sample stations locations, method and
frequency of collection along with the flow measuring techniques and
their level of accuracy;
3. Outline the procedures to be employed in preparing
analytical results for reporting purposes and subsequent storage.
B. Mixing Zone
Alaska Water Quality Standards must be achieved outside the
boundaries of the mixing zone defined below:
1. The boundaries in the vertical plane shall extend from
the bottom to the receiving water surface.
2. The lateral boundaries shall not exceed 10 feet upstream
of the outfall or 200 feet downstream of the outfall.
3. The longitudinal boundaries shall not exceed 50 feet
measured on either side of the outfall terminus.
C. Receiving Water Study
Tfie permittee shall discharge in such a manner as to achieve
the requirements of the permit as specified in Part III.B.
To insure that water quality is met at the mixing zone boundaries
the permittee shall undertake the following study:
a. At least once during each of the months of December,
January, February, and March the permittee shall inject dye at a constant
rate into his effluent.
b. Samples shall be collected at locations 200 feet downstream
of the discharge location at 20 foot intervals between samples.
5-o
-------
PART III
Page 16 of 16
Permit No. AK-002546-1
c. The minimum dilution of any of these samples collected
must be at least 200 to 1. If this level of dilution is not achieved,
the permittee shall notify the Director, Enforcement Division and State
as specified in Part II.2. and shall immediately curtail or eliminate
discharge to insure that dilution of 200 to 1 is achieved.
d. If the permittee finds that discharge to the proposed
location is not feasible and that discharge to another location is possible
which would meet a dilution of 200 to 1, the discharge location can be
moved to that location with the concurrence of the Director, Enforcement
Division and the State.
e. Reports of dye studies (including all assumptions, methods,
and instrumentation) shall be submitted within ten (10) days after the
study is completed to the Director, Enforcement Division and the State.
5~P
-------
EXHIBIT 6
-------
EXHIBIT 6.
DIFFUSION ANALYSIS
EPA analyzed the dilution characteristics for the ECA discharge
to the Tanana River, Alaska, to determine what minimum river flows
could provide 200 to 1 dilution at 200 feet downstream. Information
and assumptions for this analysis are listed below:
1. River channel configuration as measured by USGS in the branch
containing 140 cfs on February 6, 1976 (see attached report
submitted by ECA).
2. Treated effluent is discharged at 40 gpm (0.089 cfs or 58,000
gpd) for Case I and 80 gpm, Case II.
3. Mid-channel discharge through a single port outfall.
4. Buoyancy and momentum of jet are dissipated in discharge
through a rock rubble pile.
5. The effluent is well vertically well mixed.
6. Dilution of the plume occurs through longitudinal advection
and lateral diffusion. Effluent concentrations, C, can be
calculated at any point in the river from
- v2
C = Qd 1
Co 2D yny xu e X ^
where
Co = the initial concentration
Op « the effluent discharge rate, cfs
D = the average water depth, feet
>fy = the lateral coefficient of eddy diffusion, feet^/sec.
x ¦ distance downstream from the discharge, feet
y ¦ the distance, laterally, from stream centerline, feet
u = the average stream velocity, feet/sec.
6-a
-------
The minimum dilution, SQ» occuis along the centerline (y=o) and
can be obtained from equation (1).
(2)
7. The diffusion coeffient, V(y> w^s calculated from:
= 2.3 Du#
(3)
where
u# = the shear velocity, feet/second, assumed to be
approximately 0.1 times the average velocity
Equation (3) results in diffusion coefficients which give
results similar to those obtained from the dye study, con-
ducted by EPA on February 6, 1976.
8. Stream flow and cross-sectional characteristics were determined
from the equation for uniform flow:
R = the hydraulic radius, feet
S = the bottom slope of the river, feet/feet
n = Manning's friction coefficient
Data collected by the USGS on February 6, 1976, was used to
define the quantity, $, where:
Q =149 A R 2/3 S 1!2
n
where
Q = the river flow, cfs
2
A = the river cross sectional area feet
n
6-b
-------
Results of this analysis (Table 1) indicate that a minimum
dilution of approximately 200 to 1 (calculated value 198:1) could
be attained within 200 feet downstream from the 40 gptn (0.89 cfs)
discharge for a river flow of about 59 cfs. For a discharge of 80 gpm,
the corresponding river flow required would be about 110 cfs for
approximately 200:1 dilution (calculated value 197:1).
TiHTTT 1
SUMMARY OF RESULTS
Qw
Effluent
Flow, cfs
Area,ft
®max
Maximum
Depth, ft
Hydraulic
Badius, ft
Q
Channel
Flow, cfs
u
Average
Velocity
Diffusion
Coefficient
C/C0
Min. Dilu-
tion at 200 ft
6-C
-------
ENERGY COMPANY OF ALASKA
NORTH POLE REFINERY SITE
TANANA RIVER CHANNEL
FLOW. DILUTION AND WATER QUALITY STUDY
February 6, 1976
Prepared By: R.W. Beck & Associates
Denver, Colorado
-------
General Information
On Thursday, February 5, 1976, Jeff Maxwell of R, W. Beck
and Associates arrived in Fairbanks for the purpose of measuring the
flow of a channel on the Tanana River (immediately adjacent to Energy
Company of Alaska's proposed topping plant site), taking water quality
samples from this channel, and performing a dye study of the dilution
characteristics of this channel. This information is to be used by Region
X EPA personnel in validating (or changing) the NPDES permit conditions
for ECA's treated wastewater discharge.
An informal meeting was held Thursday evening with Keith
Stewart of EPA - Anchorage and Jim Meckel and Bruce Parks of USGS -
Fairbanks to discuss study techniques and coordination for the field work.
On Friday, February 6, 1976, the four above-mentioned individuals (with
the aid of a USGS snow machine and miscellaneous other equipment from
USGS, EPA and RWB) made the discharge measurement, took the water
quality samples and performed the dilution study. Photographs of the work
in progress and of the general area were taken on Friday and on Sunday
February 8, 1976 (available at a later date).
On Monday, February 9, 1976, USGS calculations of channel dis-
charge were obtained and reviewed, and the fluorescence of samples taken
during the dilution study were measured. These results follow.
Flow Study
The configuration of the channel as observed is represented in the
General Location and Blow-up figures. USGS data sheet and calculations
are also attached. The general location of the field study was characterized
as mostly ice-covered (totally ice-covered on Sunday when the ambient temp-
erature was approximately -40 F), with few open areas. As indicated the
Blow-up, three channels were found of flows: 140 cfs, 18 cfs, and 0. 1 cfs,
respectively, from the western to eastern sides of the area.
Dilution Study
Dye (Rhodamine B) was released at a steady rate from a surface
discharge point on the main flow subchannel (140. cfs) suggested by Keith
Stewart. After steady-state conditions were achieved (10-15 minutes), two
sets of samples were taken at five cross-river points, 200 feet downstream.
These sampling points were equally spaced across the subchannel, and
samples were vertically-integrated.
-------
-*5^^
MtAUt tt niT
GENERAL tOCAftO# Wmm 9TODY *
6-f
-------
83ft-
BOTfOM PROFILE ©
DEPTH (ft)
I'
44 ft
BOTTOM PROFILE 0
/^--PROPOSED
Vs S discharge
POINT
SCALE IN FEET
BLOW-UP OF FLOW STUDY SITE
6-g
-------
•-S7B-K-WI'
(May ItfflU)
Su.No..
UNITED STATES
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
watoi nrsounco division
DISCHARGE MEASUREMENT NOTES
Mtu. N*. .Cf/.5.9_
C~.p. t>y
CWLkI by
CAGE READ1NC5
Date 19.7.A Party
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Date rated Used ratine
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Spin before meat. —— after .*?/£!.._.
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conditions: Cross section
FW SY*e.&c/y Weather —
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-------
2.
The relative fluorescence of the two sets of samples, as measured
on an EPA - Fairbanks laboratory fluorometer (Turner Model III) were:
Set A
Sample # Fluorescence*
1 11
2 20
3 34
4 19
5 2
Set B
1 15
2 66
3 98
4 43
5 5
* units arbitrary, dye concentration proportional to value.
The instrument was zeroed on water withdrawn from the river before dye
was released. The results show that 200 feet downstream of the release
point, the dye had not diffused completely, and was concentrated toward the
center of the stream. The greater fluorescence values of Set B may result
from a greater rate of dye release at that time. Control of dye release was
crude, at best.
Dye Study figures have been plotted to show the approximate
cross-river variation in dye concentration, and can be related to dilution.
As noted, perfect mixing did not show a "top-hat" profile, i. e., no
variation with cross-river distance. Integration techniques have been used
to determine the average relative concentration denoted by the horizontal
lines through the bell-shaped curves on the figures. Taking the ratio of the
average fluorescence value to the centerline peak value gives the fraction
of perfect-mixing dilution accomplished within 200 feet ( 15/34 -A, 41/100
-B, or approximately 41%) This technique does not require determination
of the absolute concentrations of dye at either discharge or sampling sites.
Nor does the discharge rate need to be specified (providing it is less than
approximately 1% of the dilution flow). Theoretical dilution available is
simply the ratio of dilution flow (in the channel of the Tanana River) to dis-
charge (treated waste water from ECA).
6-j
-------
DYE STUDY A
-------
OYE STUDY B
-------
3.
Therefore, the expected dilution available for ECA's discharge
(slightly less than 0. 1 cfs) in this main flow portion of the adjacent channel
(140 cfs) is approximately 500: 1 to 600: 1.
Water Quality Study
Two identical sets of water quality samples were taken, one re-
tained by EPA - Anchorage and one returned to Denver for analysis by
RWB. Both sets were preserved according to "Standard Methods" for the
appropriate analyses. Parameters for analysis include; oil and grease,
phenols, sulfides, TSS, nutrients and trace metals. The results of these
analyses and specification of technique will be supplied at a later date.
In-situ measurements by RWB included:
D. O. - 14. 0 ppm, pH - 7. 6, temperature - OC.
6-m
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APPENDIX B
APP LI CAT ION F 0 R_A_D E PAR TMENT 0 FT HE ARMY PER MIT
One set of originat drawings and two copies which show the location and character of the proposed activity must be
attached to this application (see sample drawings and checklist).
1. Application number (To be assigned by Corps).
2. Date.
Day
Mo.
Yr.
3. For official use only.
4. Name and address of applicant.
Telephone number JL
Mr. E. R. Bouchard, Vice President
Energy Company of Alaska
One Energy Square
Suite 1200
Dallas, TX 75206
Social Security No.
5. Name, address, and title of applicant's authorized agent for permit application coordination.
None
Telephone Number.
6. Describe the proposed activity, its purpose and intended use, including a description of the type of structures, if any
to be erected on litis, or pile or float-supported platforms, and the type, composition and quantity of materials to be
discharged or dumped ai\d means of conveyance.
Treated water discharge pipe and outfall from petroleum refinery. Pipe to b
buried, discharging into Tanana River below minimum level of river. Aver-
age treated water flow indicated on attached table. Quality described in
attached Environmental Report. Treated water to be pumped from waste-
water treatment plant. Air purge to be used if shutdown occurs in winter.
7. Proposeduse.
PrivjteD
Public ~
Commercial
Other ~ (Explain in remarks)
8. Name and addresses of adjoining property owners whose property also adjoins the waterway.
1. State of Alaska
2. Clarence Holt, 15 Mile, Old Richardson Highway North Pole, Alaska
99705
3. Grace Ford and Others, Box 218 North Pole, Ala,ska 99705
9. Location where proposed activity exists or will occur.
Sec.
16
¦ Twp..
2 So.
Rge_. ^ Ea.
Ala ska
Stat*
Fairbanks Meridian
Fairbanks No._Siar Borough
County City or Town
(Where applicable)
North Pole»
Nor C«ty Or Town
^Refinery property in process of being annexed into City of North Pole
10. Name of waterway at location of the activity. Tanana JRiver -¦ —
FORM REPLACES ENG FORMS 4345 AND A3«5-1 (PART Al. MAY 71
ENG j Apfl74 4345 ^NO 4345-1 (PART Bl. JUN 71, WHICH ARE OBSOLETE.
{BP 114S-2-H
B-I
n • t* - t
6-n
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11. Date activity is proposed to commence. . ^ 76
Date activity is expected to be completed. ..Sept, , . 1977
12. Is any portion of the activity for which authorization is sought now complete? Yes ~ No 25
If answer is "Yes" give reasons in the remarks section. Month and year the activity
was completed . Indicate the existing work on the drawings.
13. List all approvals or certifications required by other Federal, interstate, state or local agencies for any structures,
construction, discharges, deposits or other activities described in this application.
Issuing Agency
EPA
Alaska DEC
F airbanks
North Star
Borough
Type Approval
Identification No.
NPDES
Air & Water
Permits to Construct
and Operate
Land Use Approval for
Hearing Industrial Zoning
Date of Application Date of Approval
March 31, 1975
March 31, 1975
14. Has any agency denied approval for the activity described herein or for any activity directly related to the activity
described herein? Yes ~ No 13 (If "Yes" explain in remarks)
15. Remarks (see paragraph 3 of Permits Pamphlet for additional information required for certain activities).
a. Treated water discharge pipe will cross Tanana River levee
b. No petroleum products will be handled, stored or transported on
riverward side of levee.
c. Environmental Impact Statement is being prepared by EPA Region X
d. Copy of Environmental Report and site survey attached.
16. Application is hereby made for a permit or permits to authorize the activities described herein. I certify that I am
familiar with the information contained in this application, and that to the best of my knowledge and belief such
information is true, complete, and accurate. I further certify that I possess the authority to undertake me proposed
activities.
Signature of Applicant
18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or
agency of the United States knowlingly and willfully falsifies, conceals, or covers up by any trick, scheme, or device
a material fact or makes any false, fictitious or fraudulent statements or representations or makes or uses any false
writing or document knowing same to contain any false fictitious or fraudulent statement or entry, shall be fined not
more than $10,000 or imprisioned not more than five years, or both.
The application must be signed by the person who desires to undertake the proposed activity; however, the application
may be signed by a duly authorized agent if accompanied by a statement by that person designating the agent and
agreeing to furnish upon request, supplemental information in support of the application.
If the activity includes the discharge of dredged or fill material in navigable waters or the transportation of dredged
material for the purpose of dumping it in ocean waters, the application must be accompanied by a fee of S100 for
quantities exceeding 2500 cubic yards and S10 for quantities of 2500 cubic yards or less. Federal, State and local
governments are excluded from this requirement.
B
B-2
6-o
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TREATED WATER DISCHARGE
TO TANANA RIVER
Estimated Discharge 37 gpm
from first phase of refinery-
Estimated Additional Discharge 6 gpm
from refinery when completed
Total Estimated Discharge from Refinery 43 gpm
Note:
Waste water treatment facilities designed to allow process
area storm water drainage to be collected, held, arid run through
complete treatment plant if required to meet water quality discharge
regulations. Discharge pipe designed to accommodate flow of two
times normal flow or 86 gpm.
6-p
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1
fe)*®
23"TREATED WATER
DISCHARGE PIPELINE
1SLffl
o
WASTEWATER I[I I0F^^a== —
t~catucut rArn 1'I PLANT PRO"
TREATMENT FACIL •¦¦cess AREA
PETROLEUM
PRODUCTS
TANK FARM
\k. "n,;
»¦*
N
\ PROPERTY LINfL,
PLAN
100 0 200 4OO *CO GOO
SCALE IN FEET~
O
_is
"I
from: USGS-FAIRBANKS(C-I), A' Acf
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RIVERWARD SIDE
SURFACE OF
EXISTING LEVEE
LANDWARD SIDE
GRAVEL FILL COVER 3*MIN.
2-1/2" TREATED WATER DISCHARGE
* PIPELINE
10
20
30
40
SCALE 1H FEET
DETAIL NO. I
GROUND
SURFACE
GRAVEL COVER
SURFACE OF EXISTING LEVEE -
SCALE IN f EET
SECTION A-A
3Z-
MEAN LOW WATER ELEV. 487.2
DETERMINED BY ICE ELEV., APRIL 1970
TANANA RIVER
RIP RAP OR GA33l0N^Dh°O°,y
PROTECTED DIS-
CHARGE
DISCHARGE ELEV. 483 i
SCALE IN FEET
DETAIL NO. 2
PURPOSE! TREATED WATER DISCMARGE FROM
PETROLEUM REFINERY (COMMERCIAL)
DATUM MEAN SEA LEVEL
TO TANANA RIVEft
NEAR NORTH POLE
30R0UQH OF NORTH STAR STATE ALASKA
APPLICATION BY ENERGY COMPANY OF
ALASKA
SHEET 2 OF 2 DATE
6-r
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EXHIBIT 7
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NORTH POLE REFINERY SITE
Date:
Time:
Weather:
DAYTIME AMBIENT
SOUND LEVEL
15 April
1975
10:00 a.
m.
Sleet/rain, 0-5 mph wind
, 38°F
•Band Frequency
High
Low
Hz
db
db
31.5
44
34
63
41
35
125
44
37
250
43
36
500
44
35
IK
40
36
2K
39
34
4K
36
24
8K
26
18
16K
20
17
A
47
41
B
52
45
C
55
50
Flat
13
11
Equipment: GR1933 Sound Analyser, Uher 4200 recorder, GE1562-A
Calibrator, 1" mic, 40' cord
Cal ib rati on:
125 Hz
250
500
IK
2K
116 db
116 db
115 db
114 db
113 db
Attenuator setting 100-120 db
7-a
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NORTH POLE REFINERY SITE
NIGHTTIME AMBIENT SOUND LEVEL
Date: 17 April 1975
Time: 10:30 p.m.
Weather: Snow, 5_7 mph wind, 20°F
Mid-Band Frequency High Low
Hz db db
31.5 58 48
63 48 43
125 41 31
250 33 25
500 25 22
IK 20 18
2K 14 13
4K 15 14
8K 16 15
16K 17 16
A 30 25
B
C
Flat
Equipment: GR1933 Sound Analyser, Uher 4200 recorder, GE-1562-A
Calibrator, 1" mic, 40' cord
Calibration: 125 Hz : 117 db
250 : 117 db
500 : 117 db
IK : 117 db
2K : 117 db
Attenuator setting 100-120 db
7-b
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GLOSSARY
-------
Glossary of Petroleum Industry Terms
Asphalt: Black to brown solid or semi-solid cementitious material
which gradually liquifies when heated and in which the predominating
constituents are bitumens. It occurs in nature or is obtained as a
residue from cracked stocks or from the distillation of certain crude
oils.
ASTM: American Society for Testing Materials. A national technical
society which has among its functions the standardization of specifi-
cations and methods of testing. The organization is widely recognized
as the authority on methods of testing petroleum products.
Atmospheric Pressure: 1. Air pressure; more specifically, the
pressure of the air at sea level. 2. As a standard, the pressure at
which the mercury barometer stands at 760 millimeters or 30 inches
(equivalent to approximately 14.7 pounds per square inch).
Barrel: U.S. Petroleum industy uses 42 gallon barrel as a unit of
measure. (Do not confuse this measurement with a "Drum" which is
usually 55 gallons).
BP or BCD: Barrels per day or barrels per calendar day. Expression
for operating capacity of a refinery, generally with an allowance over
a period for downtime.
Blending: 1. Mixing refinery products to suit market conditions.
T. Mixing on-specification fuel with off-specification fuel to bring
the latter within use limits (a method of reclamation). 3. Mixing an
interface with either or both adjacent products, or with a third product,
without degrading any of them beyond use limits.
Branded Distributor: One who purchases the major portion of his require-
ments from a branded oil company and who is authorized to use his trade-
mark.
Bulk Petroleum Products: Those products normally transported by
pipeline, rail tank car, tank truck, barge, or tanker and stored in
tanks, as opposed to packaged petroleum products.
Butane: Referred to as LPG - a liquid under pressure that turns to a
gas when released to atmosphere (vented). Usually channeled into the
manufacture of petrochemicals, etc.
Clean Product: Products such as aviation and motor gasolines, jet
fuel, diesel fuel, kerosens, and other distillate fuels; contrasted with
black oil (dirty cargoes).
G-l
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Catalytic Cracking ("Cat-Cracking"): A process or cracking in which
the catalyst supplements heat and pressure.
Cracking: A refining process by which the original physical pattern
of oil is disintegrated by heat and pressure, with or without a catalyst,
so that the resulting fragments rearrange into new combinations differ-
ing from the originals in physical characteristics. In the practical
sense, it is a form of heat treatment under high pressures often using
a catalyst. The net result of cracking is the production of considering
increased yields of gasoline of higher anti-knock quality than can be
produced by ordinary distillation process.
Crude (Crude Mineral Oil, Crude Oil, Mineral Oil, Petroleum, Rock Oil):
A liquid of geological origin which comes from the earth, consisting of
hydrocarbons and relatively small amounts of sulfur, nitrogen, and oxygen
in the form of derivatives of hydrocarbons.
Diesel Fuel: The petroleum fraction used as a fuel in diesel or
compression ignition engines. The most important characteristic of diesel
fuel, particulate 1-D and 2-D, is its ignition quality, since this con-
trols its performance in the engine. Ignition quality is determined in
an engine as the "Cetane number". Volatility also affects engine perfor-
mance and is generally controlled by the distillation range. Most diesel
fuels fall in the range of 30 to 65 in cetane numbers. The three grades
of diesel fuel and their applicability for use in diesel engines are
broadly indicated in the following classification.
Grade 1-D. This grade comprises the class of volatile fuel oils
from kerosene to the middle distillates. Fuels of this grade are applic-
ably for use in high-speed engines involving frequent and relatively wide
variations in loads and speeds, and where abnormally low temperatures
are encountered.
Grade 2-D. Included in this grade are distillate gas oils of
lower volatility. These fuels are applicable for use in high-speed
engines involving relatively high loads and uniform speeds, or in engines
not requiring fuels having the higher volatility specified for Grade
No. 1-D.
MOTE. Grade 2-D is the type of diesel fuel most commonly en-
countered. A common mistake made by a complainant is to refer to "Ho. 2
diesel", which, as can be seen from the above descriptions, does not
exist. The caller is actually referring to No. 2 fuel oil, sometimes
sold at filling stations to truck operators, but which is not suitable
for diesel operation. It may perform for a short period, but then the
truck or bus will stall, especially if the weather is cold. Mo. 2 heat-
ing oil does not have the proper volatility and, more importantly, does
have the cetane value for diesel engine operation.
G-2
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Grade 4-D. This class covers the more viscous distillates
(middle distillates) and blends of these distillates with residual
fuels oils. These fuels are applicable for use 1n low - and medium -
speed engines Involving sustained loads at constant speed, such as
large, heavy, stationary type diesel engines.
Distillate: A product of distillation, or the liquid condensed from
the vapor driven off in the still. Gasoline, naptha, solvents, kerosene,
No. 1 and No. 2 heating oil, diesel fuels, jet fuels, propane, butane
and lubricating oils are all examples of distillates since they are
the result of distillation of crude oil. Middle distillates are the
intermediate ranges of fuel such as kerosene, home heating oils, range
and stove oil, and diesel fuel.
Distillation: The process in which the crude oil is heated to a temp-
erature at which a portion of the crude oil is vaporized and in which the
vapors formed are cooled so that they return to the liquid state.
Distribution - Retail: The largest segment of retail distribution is
the service station, primarily the local gas station, garages, repair
shops and chain and general country stores. The next largest segment
is the fuel oil dealer. In some areas, he maintains no large storage
facilities of his own but operates out of the bulk plant of his supplier
and sells directly to the consumer. Other fuel oil dealers maintain
their own bulk plant installations.
Distribution - Wholesale: Wholesale distribution refers primarily
to bulk plant operations. The main job of the bulk plant operators is
to receive shipments in large quantities by pipeline, tanker, barge,
tankcar and truck, and deliver them to resellers and other customers.
Bulk plants are located close to consuming centers; storage tanks and
handling and transportation equipment are their marketing tools.
Customers supplied by bulk plants or marine terminals include service
stations, commercial customers, public utilities, transportation com-
panies, manufacturing plants and factories.
Fossil Fuels: Substances which have a geological origin, are composed
of hydrocarbons and used as fuel. Examples include oil, natural gas,
coal, and lignite.
Fractions or Cuts: Products secured by fractional distillation.
Gasoline fraction or gasoline cut, and kerosene fraction or kerosene
cut, etc.
Fractional Distillation of Crude^Oil: Separating the crude oil into
fractions by a progressive distillation process, separating the compo-
nents 1n the order of their boiling points. Propane, butane, naptha,
gasoline, kerosene, No. 2 heating oil, lubricating oil stocks and
residuals - all separated as a result of heating to vaporization and
condensing.
G-3
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Fuel Oil:
No. 1 Fuel Oil - A heavier distillate intended for use in burners
of the vaporizing type in which the oil is converted to a vapor by con-
tact with a heated surface or by radiation. High volatility is necessary.
Straight run kerosene is a generally good description of the product
which is predominantly used in space heaters.
No. 2 Fuel Oil - A heavier distillate than Grade No. 1. It is
intended for use in atomizing-type burners which spray the oil into a
combustion chamber where the tiny droplets burn while in suspension.
This grade of oil is used in most home burners that have central heat-
ing and in many medium capacity commercial industrial burners where its
ease of handling sometimes justifies its higher cost over the residual
fuels.
No. 4 Fuel Oil - Usually a light residual but it sometimes is
a heavy distillate. It is intended for use in burners equipped with
devices that atomize oils of higher viscosity than home burners can
handle. In all but extremely cold weather it requires no preheating
for handling.
No. 5 Fuel Oil (Light) - Residual fuel of intermediate viscosity
for burners capable of handling fuel more viscous than Grade No. 4 without
preheating. Preheating may be necessary in colder climates.
No. 6 Fuel Oil - Sometimes referred to as "Bunker C". A high-
viscosity oil used mostly in commercial and industrial heating. It
requires preheating in the storage tank to permit atomizing. The extra
equipment and maintenance required to handle this fuel usually does not
permit it to be used in small installations.
NOTE. No. 1, No. 2, and sometimes No. 4 are distillate fuels,
sometimes called "clean fuels". Residual fuels, often referred to as
"dirty fuels" are No. 6, No. 5 (light and heavy) and sometimes No. 4,
which is classified as a light residual. Starting with No. 6 fuel, it
is diluted or "cut back" with required amounts of No. 2 fuel to make
both grades of No. 5 and No. 4.
Gases: When in the context of refinery operations, consist of methane,
ethane, propane and butane. The first two are used as refinery fuel gas
or may be supplied, together with other refinery gases, for making
cooking gas or natural gas. Propane and butane may be liquefied by com-
pression and marketed as petroleum gases (L.P.G.). Butane may also be
incorporated in blending motor gasoline.
G-4
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Hydrocarbons: Compounds containing only a combination of carbon
with hydrogen. There are a very large number of these compounds and
they form the basis of all petroleum products. These compounds may
exist as gases or liquids or as solids. A number of hydrocarbons are
also contained in bituminous coal, oil shale, and tar sands.
Hydrogenation: The chemical addition of hydrogen to a material. The
procedure has come into prominence in refining to change the character-
istics of a petroleum product by adding hydrogen.
Jet Fuels: ASTM designates 3 types of commercial jet fuels, Jet A,
a relatively high flash point distillate of the kerosene type; Jet A-l,
a kerosene type similar to Jet A, but incorporating special low tem-
perature characteristics for certain operations; and Jet B. Jet A
requires a freezing point of -36 degrees Fahrenheit, while Jet A-l has
a maximum freezing point of -54 degrees Fahrenheit. Type Jet A is used
for short and medium range flights, while Jet A-l is designed for long
range flights. Jet B is a relatively wide boiling range distillate with
a freezing point of -56 degrees Fahrenheit and is a blend of gasoline
and kerosenes. Volume demands for Jet A and A-l are large, but small for
Jet B. Jet B corresponds to the Military JP-4 fuel, discussed below.
Military jet fuels include JP-1, still sometimes used, which has a
low freezing point of -76 degrees Fahrenheit is a kerosene made from
selected crudes (naphthenic). However, the most often used is JP-4
jet fuel, a blend of 25 to 35 percent kerosene and 65 to 75 percent
gasoline components (naphtha). This has proved quite satisfactory for
military requirements. There are other specially designed jet fuels,
such as JP-5 for Navy carrier operation, which is a mixture of special
kerosenes and aviation gasoline.
Jet fuel quality may be improved through the use of additives such
as antioxidants, corrosion inhibitors, antistatic additives, and anti-
icing additives.
The components of the jet fuels may overlap into the light distill-
ate range, but mostly they come from the range of middle distillates.
Kerosene; The general name applied to the group of refined petroleum
fractions, distilling after gasoline, and overlapping into the light
distillates and middle distillates. It is colorless, low. in sulfur,
does not burn with a smoky flame, and boils over the range of 350 degrees
to 525 degrees Fahrenheit. Different kerosenes are called upon to burn
under different conditions, so that variations in the properties can be
expected. This means that, after being distilled, the kerosene is sep-
arated into different fractions according to boiling point and subjected
to further refining and treatment in order to remove all the undesirable
constituents.
G-5
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Loading Rack: A structure with one or more risers, loading valves,
arms, and drop tubes, built alongside railroad tracks for the purpose
of loading railroad tankcars. Also, a structure built in a tank vehicle
loading area for the purpose of transferring product into tank trucks;
often referred to as fill stand or loading stand.
Marketing - Petroleum: Distribution and marketing of petroleum pro-
ducts include their physical transportation, storage, handling and
delivery. Many petroleum products are manufactured far from centers
of consumption. Therefore, to avoid delivery pile-ups and delays, the
wholesaler must maintain substantial inventories of products for ultimate
sale to consumers and resellers.
In addition to the refiner who distributes directly, there is the
distributor who sells under the brand name of the supplier, one who sells
under his own brand, and the unbranded distributor. They buy from re-
fineries in bulk quantities, and usually are local merchants who dis-
tribute products at the wholesale level. They perform the same function -
i.e., they take care of the intermediate distribution phase between the
refinery and the terminal on the one hand, and the-consumer and resellers
on the other.
Naptha: A light liquid obtained by distillation of petroleum. The
word is now used in a general sense rather than to describe a particular
product. Naptha in one form or another is used in the manufacture of
paints, etc., and as a cleaning fluid.
Octane Rating: A rating derived from the antiknock test of gasoline
in a special engine. The percentage of iso-octane in a blend with normal
heptane required to match the characteristics of the gasoline being tested
is assigned as the octane number of that gasoline.
Petrochemicals: Chemicals made from components of crude oil and/or
natural gas. the cracking process for the manufacture of gasoline
produces large quantities of gaseous hydrocarbons which were at one
time waste products used only as illuminants and fuels in the refinery.
They are used in industry to manufacture plastics, detergents, solvents,
synthetic rubber, paint, medicines, fertilizer and other agricultural
chemicals.
Petroleum: Crude Oil. A mixture of gaseous, liquid, and semi-solid
hydrocarbons varying widely in gravity and complexity, capable of being
removed as a liquid from underground reservoirs of accumulation, and
capable of being separated into various fractions by distillation and
recovery. Petroleum burner fuels include those fuels burned under
boilers or in furnaces for power or heat. Petroleum disti11ates
include the groups of hydrocarbons yielded by distillation, or gasolines,
napthas, kerosenes, gas oils, fuel oils, and lubricating oils. Petroleum
gases include butane, propane natural gas and manufactured gas.
G-6
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Petroleum 1ubricants include lubricating oils and greases. Petroleum
Products is a general term that includes all petroleum fuels, lubri-
cants, and specialties.
Propane: A liquid that turns to gas when vented to atmosphere. It
is present in most natural gas and is the first product refined from
crude petroleum. It is used as fuel for mobile equipment and in heat
treating. Used extensively in agriculture for crop drying - heat for
incubators, brooders, sterilization of milk, dehydrate fruits and veg-
etables, and frost prevention. Also used in curing tobacco and smoking
meats.
Tank Farm: Bulk storage installation composed of storage tanks and
related facilities such as loading racks, and pumping units.
Throughout: Capacity: quantity transported per unit of time; barrels
per day or gallons per minute.
Yield: In petroleum refining, the percentage of product or inter-
mediate fractions based on the amount charged to the processing operation.
Yields from a Barrel of Crude Oil (Variable Depending on Type of Crude):
Gallons per Percent
Barrel Yield
Gasoline 18.5 44.1
Kerosene 2.1 5.1
Gas Oil and Distillates 10.0 23.9
Residual Fuel 011 3.7 8.7
Other Products and Losses 7.7 18.2
TOTAL 42.0 100.0
~ GPO 699-616
G-7
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