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 Westward Seafoods, Inc.

Plant Address Kodiak, Alaska

NPDES Permit # AKG528825

Date of Visit Wednesday, August 18, 2010 People Contacted Chris Sannito 1 , Quality Assurance Manager

Seafood processed Pollock

Cod

Rockfish

Crab Salmon (<10% of production)

Products Fresh and Frozen Whole (round) fish (H&G)

Fillets

Roe

Surimi Range of annual production vol ume 40 million pounds per year Months of operation January through November Discharge type Screened solids are trucked to Kodiak Fishmeal Company Screened wastewater is discharged through NPDES permitted outfall, meets O&G and TSS limits. Company Website www.westwardseafoods.com

Westward Seafoods, a wholly owned subsidia ry of Mahura Nachiro Holding Company, operates a large seafood processing plant in K odiak. The plant operate s ten months of the year, slowing down in the fall and stopping operations sometime between the end of October and the end of November, at end of trawling season. Westward has sent its screened processing wastes to the Kodi ak Fishmeal Company plant since 1996. Westward is a co-owner of the plant [ information claimed CBI was removed from this

report ]. Mr. Sannito explained that all the co-owners [ information claimed CBI was removed from this report ]. The plant can store three to four days of waste, and so does not run continuously in November and Decem ber, when Kodiak processing volume is

low.

[ information claimed CBI was removed from this report ] The meal plant cuts operating costs by recovering and burning white fish oi l instead of diesel . Also, although their salmon oil is not food grade, they sell it to a nother company for refining and it is sold as a

1 Maricar Mangampo provided comments on this report after Chris Sannito left Westward Seafoods.2 nutraceutical. Bone is also recovered, and so ld for use in organic farming because of its high phosphorus content.

Westward produces fresh and frozen whole fish (H&G), fillets, and surimi. They do not have a canning line and salmon makes up less than 10% of their typical 2 40 million pounds/year of production. Pollock is the main species Westward processes. They process a small amount of crab harvested near Kodiak (they do not process crab harvested in the Bering Sea). The rockfish fishery was open in 2010 for the first time in years, as a pilot program. Mr. Sannito thought it was unlikely that the rockfish fishery would be open in 2011 3

.

Water use varies considerably with plan t operations. When they are making surimi, Westward uses 2 MGD of city water. Water use falls to 0.4 MGD or less when they are processing groundfish into H&G or fillets. Westward pays $1,100/MG for city water, a major production expense.

Operations. During the August 18, 2010 visit, West ward was receiving pollock and rockfish. Fish are pumped from the traw ler holds, weighed, and conveyed to holding

tanks or totes. Figure 1 shows the fish transfer hose of a fish pump used to empty a

trawler hold. Figure 2 shows Pacific rockfish on a conveyor and Figure 3 shows the fish

in totes.

Mr. Sannito explained that until 2003 Westwa rd allowed melting ice and other transfer wastewater to drip through gaps in their wooden dock. The dock is now surfaced in

concrete and all wastewater is routed to th e plant sumps for eventual discharge through the permitted outfall.

Fish are placed in totes and moved through th e plant with fork lifts because Westward has few conveyors. Figures 4 and 5 show the different variety of fish in totes waiting for processing.

Westward produces #1 grade surimi from fillets and #2 grade from frame meat. The meat is minced, washed and dewatered with screw presses. The dewatered mince is packed in boxes and frozen on a contact plate freezer ( Figure 6). Westward also operates air blast freezers. The surimi line was not operating at th e time of the visit, sc heduled to re-start September 1.

Fresh product is shipped by Air Alaska air fr eight. Frozen products are shipped by sea.

Labor Force. Westward employs a seasonal labor fo rce that enters the country on J-1 visas. Westward does not pay for their tr ansportation, but supp lies lodging in a bunk house or apartments.

2 During her review of this report, Maricar Mangampo indicated that production varies from year to year.

3 During her review of this report, Maricar Mangampo indicated that the rockfish fishery was open for

2011.3 Waste Management. Westward freezes and sells parts of the cod that other processors waste. These include heads, gills, st omachs, and livers, but not frames.

In general, waste is sluiced through flumes throughout the plant into the main sump channel that is under Buildings A and B. A level-controlled 10” pump lifts the wastewater to rotary screens located on an upper level of the plant. Westward bought the screens from IPEC, Vancouver, BC in 1998. They were a replacement for hydrosieve screens, needed because Westward’s waste volume had increased and they wanted to produce a drier waste. The screens are equipp ed with a 0.5 mm mesh (1 mm is typical in Kodiak). The rotary screen is shown in Figure 7 . Waste discharged from the rotary screens drops into a ho lding bin (shown in Figure 8 ). From the holding bin, waste is loaded into dump trucks for transport to the Kodiak Fishmeal Company plant. Some waste is placed directly into totes that ar e taken to tote dumper near the waste truck loading area.

Westward, unlike the other processors in Kodiak, does not contract with a 3 rd party waste hauler to take its waste to the fishmeal pl ant. Instead, Westward owns and operates two trucks. Trucking is a big expense.

Westward also has a concrete boat ramp on its property that trucks carrying waste from other processors can use to load a barge for o ff sea disposal, in the event that the fishmeal plant cannot operate. The meal plant leases a Cape Douglas barge as a contingency. Mr. Sannito recalls only one time that the meal plant did not operate during busy pollock

season.

Birds that try to feed on the waste are a nuisa nce and can be harmed. In the winter, eagles congregate around the processing plants.

Wastewater that passes through the rotary screens is discharged through Westward’s NPDES permitted outfall. Figure 9 shows the wastewater sampling tap. Westward

contracts with Kodiak Seafood Laboratories to analyze samples of the wastewater for O&G, TSS, SS, and pH. Mr. Sannito is the technician who analyzes the samples. Mr. Sannito says Westward has never had a problem meeting their permit limits.4 Figure 1. Fish transfer hose5 Figure 2. Pacific rockfish

Figure 3. Transfer to totes6 Figure 4. Fish in totes

Figure 5. Fish in totes7 Figure 6. Block freezers

Figure 7. Rotary screen8 Figure 8. Waste for meal plant

Figure 9 Effluent sampling point