1 Site Visit Report Alaska Seafood Processing Industry Petition Response

Lindsay Guzzo Environmental Engineer U.S. Environmental Protection Agency Region 10 Permits Division guzzo.lindsay@epa.gov

206-553-0268 Betsy Bicknell Senior Environmental Engineer Eastern Research Group, Inc. (ERG) betsy.bicknell@erg.com

703-633-1612

Plant Name Copper River Seafoods

Plant Address Cordova, Alaska

NPDES Permit # AKG520524

Date of Visit Thursday, August 19, 2010 People Contacted Chris La Croix (with additional information provided by Pip Fillingham)

Seafood processed Salmon (All Species)

Halibut

Cod Products Fresh and frozen (H&G, Fillet)

Smoked salmon Salmon roe (ikura an sujiko) Range of annual production vol ume [Confidential Business Information (CBI), removed from this document] Months of operation May 15 – September 15 Discharge type Grind and discharge Company Website www.copperriverseafood.com

In 1996, Copper River Seafood took ownership of a 70-year old processing plant in Cordova. This plant processes salmon [CBI removed from this document] halibut, and cod. The buildings are not insulated, so the plant does not operate in cold weather. The plant produces fresh and frozen whole fish (headed and gutted). Fresh fish, predominantly salmon, is shipped to Anchorag e. Frozen fish is exported [CBI removed from this document].

Copper River also processes salmon roe into ikura and sujiko. Ot her products include fillets, which are frozen and vacuum packed and shipped to Anchorage; and smoked

salmon.

Waste Management. Waste is sluiced from butchering machines to floor drains. Waste also accumulates on the floor ( Figure 1 ) and is then hosed into the floor drains. Figure 2

shows waste in the floor drain. From the drains, waste flows to a central sump and is then ground and discharged through Copper River’s NPDES permitted outfall, 300 to 400 feet off shore. Waste is sampled prior to discharg e to verify that it meets the 1⁄2 inch grind requirements ( Figure 3 , red handle).2 In 2009 Copper River Seafood delivered most of the salmon heads, [CBI removed from this document] to Trident for their new by- products plant. Trident picked up the heads twice a day. Copper River estimated they delivered a few hundred thousand pounds in total. About 30 – 35%, by weight of the raw salmon ends up as waste. Fish heads account for about 10% of the weight of the fish, so Trident took less than 1/3 of Copper River’s waste in 2009. Copper River did not mention if Trident had offered to take the remainder of Copper River’s waste so lids (tails and guts).

Copper River and Trident had no formal agr eement about this arrangement Copper River said he had expected Trident to take Coppe r River waste heads agai n in 2010, but Trident never contacted him to set up the program. C opper River noted that in 2009 they had a little difficulty finding space to store the iced totes while they were accumulating waste, but would be agreeable to working with Tr ident again, if they provide the totes.

Mr. La Croix mentioned that Copper River had investigated manu facturing by-products at their Anchorage facility but decided ag ainst it due to incredibly poor return-oninvestment.

Labor. Copper River employs [CBI removed fr om this document] seasonal employees who are mostly foreign students in the c ountry on J-1 visas. Copper River houses the employees, charging them a nominal amount fo r room and board. The students pay their way to Cordova. [CBI removed from this document].

Operations. Cranes unload totes from the fishing vessels. Each tote is weighed, iced, and

stacked. Figure 4 shows totes on the dock. A vacuum fish pump is used to remove fish

from tender holds. The fish are dewatered and packed in totes with ice. Copper River has no fish storage tanks. Fish totes are dumped at the head of the butchering line. Heads are removed with a guillotine cutter. Bellies are slit by hand, guts and roe removed and sluiced to a separating station. Figure 5 shows workers hand-separating the guts from the roe, which is dropped into a tote for transpor t to the egg room. The gut cavity is cleaned and the fish are separated by species a nd graded after head ing and gutting.

Fish are packed into plastic trays and th en block frozen [CBI removed from this document]. Block frozen fish are glazed and pa cked for shipping [CBI removed from this document]. Fish are also frozen whole, hand glazed, and bagged.

In the egg room, roe is proce ssed into ikura (individual eggs) and sujiko (roe skeins). The ikura is frozen in plate freezers.

In addition to the bulk processing of frozen salmon, Copper River prepares fillets for custom orders and for smoking. The fillets are cold smoked, hot smoked, and packed into pouches or jars. Pouches are cooked in a small-scale retort. The smoker is shown in Figure 6 and the retort is shown in Figure 7

.3 Figure 1. Waste in sluices and accumulating on the floor

Figure 2. Waste in floor drain4 Figure 3. Waste Sampling Point Follows Grinder Pump

Figure 4. Wooden dock with plastic totes.5 Figure 5. Separating roe

Figure 6. Smoker6 Figure 7. Mini retort for smoked salmon