# / UNITEDSTATES ENVIRONMENTAL PROTECTION AGENCY

DATE: SUBJECT: Comments on Seafood Guidelines ftt> •• .,...-,.....'........--.,'"-..,... '.' ",**~**

FROM:

TO: THRU: Dianne

# SOderlu~~~ Alaska Operations Office Harold Geren M/S 521

___ ,; _ii'**/~** W. James Sweeney,**Dir~~~o~** A1asKa Operations**Offl~** 

# lWlf©**~IT W~V\'t** **~MAR**0 91981 :.1) PERMITS BRANCH EPA

- REGION 10 /

The following comments are submitted for your review as Region XiS input to the Effluent Guidelines Division proposed response to the Alaskan seafood industries petition to modify and amend BPT for nonremote Alaska seafood processors. (Excluding Kodiak). Comments Region X, EPA supports the proposed decision to deny the petition for Anchorage. Cordova, Ketchikan and Petersburg. The Alaska Operations Office has reconfirmed statements made in the city-by-cityanalysis regarding reduction costs and capabilities for both Anchorage and Petersburg. In the Anchorage city-by-cityanalysis itwas confirmed that Seward Fisheries is presently serving five processors in Anchorage. Further more, the company has purchased two vacuum trucks, one ofwhich will be used in Anchorage to transfer seafood waste from plant storage bins to the hauling truck. (The other vacuum truck will be located in the Homer/Kenai area). The company 1s also planning on purchasing two large three axle tankers (9-10 thousand gallons each) which will be used to haul waste from Anchorage to Seward. The company is hopeful they will have these trailers on lineby the herring season in April, oratthe latestby the onset ofthe salmon season. The contract haulerwill be used until the new trailers are in use. During the 1981 processing season prices could go up to $24/ton (from $20.00). The $8.00 to $10.00 creditwould probably remain constant. The increased pricewould be due to fuel costs. In regard to possible imposed load restrictions on the Seward Highway. our office submits the following information. According to the StateDepartment ofTransportation, weight restrictions are imposed on the Seward Highway occurring, atthe earliest, inmid March and run toJune 1. (June 15 at the latest) The restriction is generally 75% ofthe normal axle loading, which relates to about a 50% loss in cargo capacity. An employee ofSeward Fisheries stated that weight restrictions have not caused hauling problems in the past. and he did not anticipate this becoming a problem in the future. Seward Fisheries does suggest to theirclients thatthey have holding bins capable ofhandling waste from two peak operating days. The employee stated thatwith the new larger tankers this should be even less ofa Ii**p~** for", U7!)·'tRr.v, ;',16\**~-** ......**-~~-**problem, as they would not have to haul atcapacity to handle waste loads. Furthermore, the company is anxious to get the waste as fresh as possible to improve product quality. He confirmed that Seward Fisheries is prepared to handle all Anchorage processors waste. In regard to Petersburg, there was a slightdiscrepancy under Part C, city-by-cityanalysis. The total waste generated by the petitioner is reported as 53,000 pounds, which could not be handled by three round trips ofa five ton flatbed truck (holding 6tons) as reported. However, review of the 1/11/80 petitionerapplication for an NPDES permit identifies maximum waste per day of 36,000**I~S** of salmon and 20,000 lbs ofhalibut. Alaska Fish and Game for Southeast Alaska reports that the halibut season only extends from June 7 to 14 and July 12-19 for 1981. or 16 days. They report this is a typical season length. The peak ofthe salmon run is June, July and August. Acertain amount ofthis waste is allowed to be discharged in the screened effluent as total suspended solids and oil and grease. With 36,000 lbs ofsalmon waste this discharge would be 5550 lbs, orover 2 1/2 tons per day. Because oflow halibut effluent limits, the value for halibut is negligible. Therefore, the maximum waste volume to be dealtwith is closer to 50,000 lbs. It is unlikely that the petitionerwould be processing maximum amounts of salmon and halibut simultaneously. but ifthey were required to do so for amaximum of 14 days during the season they would possibly need to make four trips with the flatbed truck. Our office has confirmed the other information provided in the Petersburg city-by-cityanalysis is correct. The Alaska Operations Office strongly supports altering the definition ofnon-remote to reflect the concept ofprocessing centers rather than population centers. We believe this provides for a more reasonable means ofregulating the Alaskan seafood industry. Aprime example in support ofthis decision is Dutch Harbor. In 1979. the fishery landing in the Dutch Harbor/Unalaska area totaled 136.4 million pounds, with a value of $92.7 million, the highest for any major U.S. port. Yet this area is presentlyclassified as remote, and as such the BPT for this area is grinding to 1/2 inch prior to discharge. This possibly allows the highest volume ofseafood waste discharge ofanywhere in Alaska or the contiguous United States. The Alaska Operations Office supports classifying the Kenai Peninsula and Dutch Harbor areas as non-remote, as such requiring that the effluentbe screened and the solids be collected. Anumber of studies have been done in the Dutch Harbor area over the last several years. Although the Agencies primary concern 1s the cost ofwaste abatement technology in relation to the effluentreduction benefits achieved. the reports cited below address the issue ofwater qualityand the waste impacts on the marine environment. In the Dutch Harbor area, where atleast 15 processors operate, it 1s our beliefthat the effluent reduction benefits derived from screening and collection of solids, primarily shellfishwastes, and the subsequent improvement in the bottom habitat and possiblywater quality offsetthe costoftreatment.