United States 

Environmental Protection 

Agency 

Questionnaire for 

Canned and Preserved Seafood 

Processing Facilities in 

Certain Locations of Alaska 

EPA is distributing this questionnaire under the authority of Section 308 of the 

Clean Water Act. You must return the completed questionnaire(s) to EPA 

within 45 days of receiving it. If you fail to respond, file late, or fail to comply 

with the instructions, you may be subject to criminal fines, civil penalties, and 

other sanctions, as provided by law. 

April 2010 
i 

INTRODUCTION 

The U.S. Environmental Protection Agency (EPA) is conducting an information gathering effort of nine or 

fewer corporations or entities within the Canned and Preserved Seafood Processing Category

(Seafood Processing Facilities). This effort is focused on entities with operations in certain locations in 

Alaska. These locations include: 

 Anchorage; 

 Cordova; 

 Juneau; 

 Ketchikan; 

 Petersburg; 

 Dutch Harbor; and 

 The Kenai Peninsula. 

EPA will use the information it collects from facilities in these locations (the “study area”) to respond to an 

industry petition that was submitted to EPA in 1980. This petition requested EPA to revise effluent 

limitations and standards and prohibitions for direct discharges from seafood processing facilities in 

“non-remote” locations in Alaska (see 40 CFR Part 408), including Anchorage, Cordova, Juneau, 

Ketchikan, and Petersburg. As noted in the January 9, 1981 Federal Register Notice, EPA also proposed 

to redefine the term “non-remote” for the Alaskan segment of the industry to eliminate the words 

“population center,” and to add Dutch Harbor and the Kenai Peninsula to the list of non-remote

processing centers. EPA also considered including Ward Cove as a non-remote area because of its 

proximity to the Ketchikan processing center. Ward Cove, however, has since been included in a finalized 

total maximum daily load evaluation, which does not allow discharges from seafood processing facilities, 

and so is not included in the scope of EPA’s current information gathering effort. 

EPA identified nine corporations that operate seafood processing facilities in the study area. EPA 

is requiring these corporations to complete a questionnaire for each of the seafood processing 

facilities they operate in Alaska; that is, facilities in the study area AND in any other part of Alaska, 

including shore-based seafood processing facilities operating and discharging less than one-half 

(0.5) nautical mile from shore at mean lower low water (MLLW) and near-shore seafood 

processing facilities operating and discharging from one (1) to one-half (0.5) nautical mile from 

shore at MLLW. 

EPA will use the technical data collected from each facility to characterize the facility’s operation, 

processing capacity, seafood processing waste generation in terms of fluctuation in volume, and current 

waste recycle / recovery and disposal practices. EPA will use the collected financial data to characterize 

the economic status of the industry and to estimate the possible economic impacts associated with 

alternative waste disposal practices. 

EPA is distributing this questionnaire under the authority of Section 308 of the Clean Water Act. You 

must return the completed questionnaire(s) to EPA within 45 days of receiving it. If you fail to 

respond, file late, or fail to comply with the instructions, you may be subject to criminal fines, civil 

penalties, and other sanctions, as provided by law. 
ii 

INSTRUCTIONS FOR COMPLETING THE QUESTIONNAIRE 

QUESTIONNAIRE OVERVIEW

This questionnaire is divided into two primary sections. Part A – Corporate Information requests 

corporate financial information while Part B – Facility Information requests information about the 

operations and finances of each of the facilities, including those onboard vessels, you operate in Alaska. 

You should complete Part B for the following facility or facilities: 

1. E.C. Phillips and Sons 

2. E.C. Phillips and Sons – Craig Fisheries 

3. Any other seafood processing facility you operate in Alaska. 

EPA has provided one copy of Part B for each seafood processing facility listed above that your 

company operates in Alaska. The name of each facility is listed at the beginning of each section. EPA has 

also provided a blank Copy of Part B. If you operate seafood processing facilities in Alaska that are 

not listed above, please copy the blank questionnaire and complete a copy for each additional processing 

facility not listed. 

Please include any additional comments in the comments table at the end of each Part and identify the 

question(s) for which the comment(s) apply (e.g., A-7, B-3). EPA has provided definitions for key terms at 

the end of each section. These terms are shown in bold italics as they are used throughout the 

questionnaire. 

Please complete one copy of Part A for your seafood processing company for 2005 through 2009. 

Please complete one copy of Part B for each seafood processing facility you operate in Alaska for 

2005 through 2009. Each question will specify if information is requested for calendar years or fiscal 

years. 

CERTIFICATION

After you complete this questionnaire, a responsible corporate official must sign one of the Certification 

Statements on page 1 to either (1) verify and validate the information provided, or (2) certify that the 

company no longer engages in seafood processing in the EPA study area. 

TIMEFRAME FOR COMPLETING QUESTIONNAIRE

You must return the completed questionnaire(s) to EPA within 45 days of receiving it. Please 

consider this timeline when completing Section B for individual facilities. 

QUESTIONNAIRE ASSISTANCE

If you have any questions as you complete this questionnaire, please contact EPA using the telephone 

numbers and email addresses provided below. 

Contacts for Assistance 

Part A (Corporate Information) 

Part B Questions B-42 to B-47 (Facility Financial 

Information) 

Mr. Todd Doley 

(202) 566-1160 

doley.todd@epa.gov 

Part B Questions B-1 to B-41 (Facility Technical 

Information) 

Mr. Donald F. Anderson 

(202) 566-1021 

anderson.donaldf@epa.gov 
iii 

SUBMITTING THE QUESTIONNAIRE PACKAGE TO EPA

When the questionnaire package is complete, sign the Certification Statement (page v). Assemble the 

final completed questionnaire package. Please include: 

 Certification Statement; 

 Part A - Corporate Information; 

 Part B - Facility Information (one copy for each facility you operate in Alaska); 

 Accounting Reports, and 

 Other Attachments. 

Return the completed questionnaire using the enclosed return label to the following address: 

U.S. Mail or Overnight Delivery (e.g., Federal Express, UPS, etc) 

U.S. Environmental Protection Agency 

Questionnaire for the Canned and Preserved Seafood Processing Facilities in Certain 

Locations of Alaska 

c/o Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151-1102 

(703) 633-1600 

EPA recommends that you keep a copy of the completed questionnaire for each facility, including 

attachments, in the event that we need to contact you to clarify your responses. EPA will review the 

information submitted and may ask additional, follow-up questions to complete our analyses. 

EPA sincerely appreciates the time and effort you will put into responding to this questionnaire. Your 

information is vital to EPA’s response to your industry’s petition. 
iv 

CONFIDENTIAL BUSINESS INFORMATION 

EPA provides you the opportunity to claim information as confidential. If no business confidentiality claim 

accompanies the information when it is received by EPA, EPA may make the information available to the 

public without further notice. 

Regulations governing the confidentiality of business information are contained in the Code of Federal 

Regulations (CFR) at Title 40 Part 2, Subpart B. You may assert a business confidentiality claim covering 

part or all of the information you submit, other than effluent data and information or data that is otherwise 

publicly available, as described in 40 CFR 2.203(b): 

“(b) Method and time of asserting business confidentiality claim. A business which is submitting 

information to EPA may assert a business confidentiality claim covering the information by 

placing on (or attaching to) the information, at the time it is submitted to EPA, a cover sheet, 

stamped or typed legend, or other suitable form of notice complying language such as ‘trade 

secret,’ ‘proprietary,’ or ‘company confidential.’ Allegedly confidential portions of otherwise 

nonconfidential documents should be clearly identified by the business, and may be submitted 

separately to facilitate identification and handling by EPA. If the business desires confidential 

treatment only until a certain date or until the occurrence of a certain event, the notice should so 

state.” 

You may claim as confidential all information included in the response to a question by checking the 

Confidential Business Information (CBI) box next to the question number. Note that you may be 

required to justify any claim of confidentiality at a later time. Therefore, it is strongly recommended that 

only those pieces of information that are the most sensitive (e.g., certain financial information and data) 

as described in 40 CFR Part 2, should be claimed as CBI. Other types of information and data not 

protected from public disclosure, as also noted in 40 CFR Part 2, should not be claimed as CBI. Note also 

that facility effluent data are not eligible for confidential treatment, pursuant to Section 308(b) of the Clean 

Water Act, and thus will be treated as nonconfidential even if the CBI box is checked. In addition, 

information that is publicly available should not be claimed confidential. 

Information covered by a claim of confidentiality will be disclosed by EPA only to the extent of, and by 

means of, the procedures set forth in 40 CFR Part 2, Subpart B. In general, submitted information 

protected by a business confidentiality claim may be disclosed to other employees, officers, or authorized 

representatives of the United States concerned with implementing the Clean Water Act. 

Information covered by a claim of confidentiality will be made available to EPA contractors to enable the 

contractors to perform the work required by their contracts with EPA. All EPA contracts provide that 

contractor employees use the information only for the purpose of performing the work required by their 

contracts and will not disclose any CBI to anyone other than EPA without prior written approval from each 

affected business or from EPA's legal office. 
Certification Statement Alaskan Canned and Preserved Seafood Processing 

Copy of 

1 

CERTIFICATION STATEMENT 

Please check only one applicable certification statement then sign and complete the remainder of this 

page. 

Certification Statement #1

I certify under penalty of law that the attached questionnaire was prepared under my direction or supervision 

and that qualified personnel properly gathered and evaluated the information submitted. The information 

submitted is, to the best of my knowledge and belief, accurate and complete. In those cases where we did not 

possess the requested information for questions applicable to our company, we provided best estimates. We 

have to the best of our ability indicated what we believe to be company confidential business information

as defined under 40 CFR Part 2, Subpart B. We understand that we may be required at a later time to justify 

our claim in detail with respect to each item claimed confidential. I am aware that there are significant 

penalties for submitting false information, including the possibility of fines and imprisonment as explained in 

Section 308 of the Clean Water Act.

Certification Statement #2

I certify under penalty of law that this entity or corporation does not or will no longer operate any Seafood 

Processing Facility that processes seafood in any of the following Alaskan locations: 

 Anchorage 

 Cordova 

 Juneau 

 Ketchikan 

 Petersburg 

 Dutch Harbor 

 The Kenai Peninsula 

I am aware that there are significant penalties for submitting false information, including the possibility of fines 

and imprisonment as explained in Section 308 of the Clean Water Act.

 

Signature of Certifying Official Date 

 ( ) 

Printed Name of Certifying Official Telephone Number of Certifying Official 

Title of Certifying Official 

 ( ) 

Email of Certifying Official Facsimile Number of Certifying Official 

Company Name (if different from parent company) 

Street Address 

 

City State Zip Code