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 N ame 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 volume 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 subsidiary of Mahura Nachiro Holding Company, operates a large seafood processing plant in Kodiak. The plant operates ten months of the year, slowing down in the fall and stopping operations som etime between the end of October and the end of November, at end of trawling seas on. Westward has sent its screened processing wastes to the Kodiak Fishmeal Company p lant 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 December, 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 oil instead of die sel. Also, although their salmon oil is not food grade, they sell it to another company for refining and it is sold as a

1 Maricar Mangampo provided comments on this report after C hris Sannito left Westward Seafoods.2

nutraceutical. Bone is also recovered, and sold for use i n organic farming because of its high phosphorus content.

Westward produces fresh and frozen whole fish (H&G), fil lets, 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 Westw ard processes. They process a small amount of crab harvested near Kodiak (t hey 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 unli kely that the rockfish fishery would be open in 2011 3

.

Water use varies considerably with plant operations. Whe n 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, Westward was receiving pollock and rockfish. Fish are pumped from the trawler holds, weighe d, and conveyed to holding

tanks or totes. Figure 1 shows the fish transfer hose of a fish pump used to em pty 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 Westward allowed meltin g ice and other transfer wastewater to drip through gaps in their wooden dock. The do ck is now surfaced in concrete and all wastewater is routed to the plant su mps for eventual discharge through the permitted outfall.

Fish are placed in totes and moved through the plant with fork lifts because Westward has few conveyors. Figures 4 and 5 show the different variety of fish in totes waiting fo r 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 dew atered 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 the time of the visit, scheduled to re-start September 1.

Fresh product is shipped by Air Alaska air freight. Frozen pr oducts are shipped by sea.

Labor Force. Westward employs a seasonal labor force that enters the country on J-1 visas. Westward does not pay for their transportation, b ut supplies lodging in a bunk house or apartments.

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

3 During her review of this report, Maricar Mangampo indic ated 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, stomachs, 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-controlle d 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 re placement for hydrosieve screens, needed because Westward’s waste volume had inc reased and they wanted to produce a drier waste. The screens are equipped with a 0.5 m m mesh (1 mm is typical in Kodiak). The rotary screen is shown in Figure 7 . Waste discharged from the rotary screens drops into a holding bin (shown in Figure 8 ). From the holding bin, waste is loaded into dump trucks for transport to the Kodiak Fishmeal C ompany plant. Some waste is placed directly into totes that are taken to tote dumper near the waste truck loading area.

Westward, unlike the other processors in Kodiak, does not co ntract with a 3 rd party waste hauler to take its waste to the fishmeal plant. Instea d, Westward owns and operates two trucks. Trucking is a big expense.

Westward also has a concrete boat ramp on its property t hat trucks carrying waste from other processors can use to load a barge for off sea dispos al, in the event that the fishmeal plant cannot operate. The meal plant leases a Cape Dougl as barge as a contingency. Mr. Sannito recalls only one time that the meal plant did n ot operate during busy pollock

season.

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

Wastewater that passes through the rotary screens is dis charged 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