/ UNITED STATES 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-city analysis regarding reduction costs and capabilities for both Anchorage and Petersburg. 

In the Anchorage city-by-city analysis it was confirmed that Seward 

Fisheries is presently serving five processors in Anchorage. Further 

more, the company has purchased two vacuum trucks, one of which 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 line by the herring season in April, or at the latest by the onset 

of the salmon season. The contract hauler will 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 credit would probably remain constant. 

The increased price would 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 State Department of Transportation, weight restrictions 

are imposed on the Seward Highway occurring, at the earliest, in mid 

March and run to June 1. (June 15 at the latest) The restriction is 

generally 75% of the normal axle loading, which relates to about a 50% 

loss in cargo capacity. An employee of Seward 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 their clients that they have holding bins 

capable of handling waste from two peak operating days. The employee stated that with the new larger tankers this should be even less of a 

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problem, as they would not have to haul at capacity 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 slight discrepancy under Part C, city-by-city analysis. The total waste generated by the petitioner is reported 

as 53,000 pounds, which could not be handled by three round trips of a 

five ton flatbed truck (holding 6 tons) as reported. However, review of 

the 1/11/80 petitioner application for an NPDES permit identifies maximum 

waste per day of 36,000 I~S of salmon and 20,000 lbs of halibut. 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 of the salmon run is 

June, July and August. A certain amount of this waste is allowed to be 

discharged in the screened effluent as total suspended solids and oil 

and grease. With 36,000 lbs of salmon waste this discharge would be 

5550 lbs, or over 2 1/2 tons per day. Because of low halibut effluent 

limits, the value for halibut is negligible. Therefore, the maximum 

waste volume to be dealt with is closer to 50,000 lbs. It is unlikely that the petitioner would be processing maximum amounts of salmon and 

halibut simultaneously. but if they were required to do so for a maximum 

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-city analysis is correct. 

The Alaska Operations Office strongly supports altering the definition 

of non-remote to reflect the concept of processing centers rather than 

population centers. We believe this provides for a more reasonable 

means of regulating the Alaskan seafood industry. A prime example in 

support of this 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 presently classified 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 of seafood waste discharge of anywhere 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 effluent be screened and the solids be collected. 

A number of studies have been done in the Dutch Harbor area over the 

last several years. Although the Agencies primary concern 1s the cost 

of waste abatement technology in relation to the effluent reduction 

benefits achieved. the reports cited below address the issue of water 

quality and the waste impacts on the marine environment. In the Dutch 

Harbor area, where at least 15 processors operate, it 1s our belief that the 

effluent reduction benefits derived from screening and collection of 

solids, primarily shellfish wastes, and the subsequent improvement in 

the bottom habitat and possibly water quality offset the cost of treatment.