DISCLAIMER The full text of certain NPDES permits and the asso ciated fact sheets has been made available to provide online access to this public information. EPA is making permits and fact sheets available electronically to provide convenient access for inte rested public parties and as a reference for permit writers. The ownership of these documents lies with the permitting authority, typically a State with an authorized NPDES program. While EPA makes every effort to ensure that this web site remains current and contains the final version of the active permit, we cannot guarantee it is so. For example, there may be some delay in posting modifications made after a permit is i ssued. Also note that not all active permits are currently available electronically. Only permits and fact sheets for which the full text has been provided to Headquarters by the permitting authority may be made available. Headquarters has requested the full text only for permits as they are issued or reissued, beginning November 1, 2002. Please contact the appropriate permitting authority (either a State or EPA Regional office) prior to acting on this information to ensure you have th e most up-to-date permit and/or fact sheet. EPA recognizes the official version of a permit or fact sheet to be the version designated as such and appropriately stored by the respective permitting authority. The documents are gathered from all permitting au thorities, and all documents thus obtained are made available electronically, with no screening for completeness or quality. Thus, availability on the website does not constitute endorsement by EPA.Date: September 14, 2001 NPDES Permit Number: AK-000027-2 

## The U.S. Environmental Protection Agency (EPA) Plans To Reissue A Wastewater Discharge Permit To:
Alyeska Seafoods, Inc. (the "permittee") 303 NE Northlake Way

Seattle, WA 98105

EPA Proposes NPDES Permit Reissuance. EPA proposes to reissue a National Pollutant Discharge Elimination System (NPDES) permit to Alyeska Seafoods, Inc. The proposed permit sets conditions on the discharge of pollutants from the Alyeska Seafoods - Unalaska facility to Unalaska Bay and Iliuliuk Harbor, Alaska. In order to ensure protection of water quality and human health, the permit places limits on the types and amounts of pollutants that can be discharged and places other conditions on the facility.
This Fact Sheet includes:

- the tentative determination of EPA to issue the permit,

- information on public comment, public hearing, and appeal procedures,

- a description of the facility and proposed discharge,

- a map and description of the discharge location,

- a listing of past and proposed effluent limitations, schedules of compliance, and other

conditions, and

- technical material supporting the conditions in the permit. EPA Invites Comments on the Proposed Permit. EPA will consider all substantive comments before issuing a final NPDES permit. Those wishing to comment on the proposed permit may do so in writing by the expiration date of the Public Notice. After the Public Notice expires and the public comments have been considered, EPA Region 10’s Office of Water Director will make a final decision regarding permit reissuance. If no substantive comments are received, the tentative conditions in the proposed permit will become final and the permit will become effective upon issuance. If comments are received,Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 2 of 31

EPA will respond to the comments and the permit will become effective 30 days after its issuance date, unless a request for an evidentiary hearing is submitted within 30 days.
Documents Are Available for Review. The proposed NPDES permit and related documents can be reviewed at EPA’s Regional Office in Seattle between 8:30 a.m. and 4:00 p.m., Monday through Friday. To request copies and other information, contact the NPDES Permits Unit at: United States Environmental Protection Agency, Region 10 1200 Sixth Avenue, O W-130 Seattle, Washington 98101 (206) 553-1214 or 1-800-424-4372 (from Alaska, Idaho, Oregon and Washington) The fact sheet and proposed permit are also available at: Alaska Department of Environmental Conservation Attn: Division of Wastewater Discharge 555 Cordova Street Anchorage, Alaska 99501 (907) 269-7500
and Alaska Department of Environmental Conservation Attn: Division of Wastewater Discharge 410 W illoughby Avenue, Suite 303 Juneau, Alaska 99801 (907) 465-5302.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 3 of 31

TABLE OF CONTENTS
page
1 APPLICANT

........................................................... 5
2 TYPE OF FACILITY AND ACTIVITY

......................................... 5 2.1 Facility Location and Description

........................................ 5 2.2 Process Description

................................................. 5 2.3 Facility History and Performance

........................................ 6
3 PROPOSED DISCHARGE

................................................ 6 3.1 Nature, Amount, and Composition of Discharge

............................ 6 3.2 Treatment of Wastewater Prior to Discharge

.............................. 7
4 RECEIVING WATER

..................................................... 7 4.1 Nature of Unalaska Bay, Iliuliuk Bay and Iliuliuk Harbor

...................... 7 4.2 Beneficial Uses of Unalaska Bay, Iliuliuk Bay and Iliuliuk Harbor

............... 7 4.3 Climate

........................................................... 8 4.4 Water Column

...................................................... 8 4.5 Seafloor

.......................................................... 9
5 BASIS FOR EFFLUENT LIMITATIONS AND MONITORING

..................... 10 5.1 General Approach

.................................................. 10 5.2 Summary of Effluent Limitations, Past and Proposed

....................... 11 5.3 Technology-based Evaluation

......................................... 12 5.4 Mixing Zone and Other Variances to State Water Quality Standards

........... 12 5.5 Water Quality-based Evaluation

....................................... 13 5.6 Summary of Effluent Monitoring

....................................... 14
6 BASIS FOR BEST MANAGEMENT PRACTICES PLAN

......................... 16
7 BASIS FOR ENVIRONMENTAL MONITORING

............................... 16
8 BASIS FOR ANNUAL REPORT

........................................... 17
9 PERMIT CONDITIONS FOR COMPLIANCE, RECORDING, REPORTING, AND OTHER GENERAL PROVISIONS

................................................ 17
10 OTHER LEGAL REQUIREMENTS

......................................... 18 10.1 State Water Quality Standards and Certification

........................... 18 10.2 Endangered Species Act

............................................. 18 10.3 Fishery Conservation and Management Act

.............................. 19 10.4 Coastal Zone Management Act

........................................ 19 10.5 Pollution Prevention Act

............................................. 19 10.6 Oil Spill Requirements

............................................... 19Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 4 of 31

11 MODIFICATION OF PERMIT LIMITS OR OTHER CONDITIONS

.................. 20
12 PERMIT EXPIRATION

................................................... 20
13 GLOSSARY OF TERMS AND ACRONYMS

.................................. 20
14 REFERENCES

........................................................ 25
APPENDIX A - Location of the Alyeska Seafoods - Unalaska facility

................... 26
APPENDIX B - Diagram of the Alyeska Seafoods - Unalaska facility

................... 27 APPENDIX C - Synopsis of Modeling the Discharge of Settleable Solid Seafood Residues

.. 28Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 5 of 31

1 APPLICANT Alyeska Seafoods, Inc. [Business Office] 303 N.E. Northlake Way Seattle, WA 98105 (206) 547-2100
and Alyeska Seafoods, Inc. [On-site Management Office] 551 West Broadway Avenue P.O. 530 Unalaska, AK 99685 (907) 581-1211 Alyeska Seafoods, Inc., requested the reissuance of NPDES permit no. AK-000027-2 for its Unalaska onshore seafood processing facility on November 27, 2000.
2 TYPE OF FACILITY AND ACTIVITY
2.1 Facility Location and Description Alyeska Seafoods owns, operates, and maintains the Alyeska Seafoods - Unalaska facility, a facility which conducts seafood processing and seafood meal reduction. Alyeska Seafoods - Unalaska facility is located in the City of Unalaska, Alaska. The facility lies at 53 o 52'44" N, 166 o 32'25" W, in Unalaska Island of the Fox Island group in the easternmost Aleutian Islands, USGS hydrologic unit number 19030102. The map in Appendix A shows the location of the Alyeska Seafoods - Unalaska facility. The diagram of the grounds of the facility in Appendix B shows the lay of the building, docks and outfall lines. The facility consists of (1) a large onshore facility which houses crab, finfish and surimi processing lines and a meal reduction facility, (2) product warehouses, (3) residential buildings, (4) a power house, (5) a tank farm, and (6) docks.
2.2 Process Description Alyeska Seafoods - Unalaska facility processes surimi, minced and filleted pollock, headed/gutted and filleted Pacific cod, frozen crab (king, bairdi, and opilio) sections, frozen (bait) herring, black cod, and miscellaneous rockfish. Alyeska takes receipt of the seafood catch from fishermen along its dock, offloading the catch in large vacuum lines or baskets. Seafood is butchered by machine and by hand in any of several processing lines throughout the facility. Processing wastes (i.e., heads, offal, unusable tissue parts) are flumed to dewatering conveyors where they are transported to the meal plant for reduction to fish meal, a marketable secondary product. Water used in butchering, processing, and fluming is collected before final discharge and passed through a screening process to recover residual tissue pieces. Screened solids are returned to the meal reduction plant. Wastewater is discharged without further treatment through a subsurface outfall. TheAlyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 6 of 31

facility processes in excess of 140 million pounds of raw seafood annually, of which over 90% is pollock.
2.3 Facility History and Performance The Alyeska Seafoods - Unalaska facility’s NPDES permit expired May 31, 2001. Alyeska Seafoods bought the facility in 1985 and began operations in 1986; a seafood processor has operated on-site since the 1950s or earlier. The facility’s screening treatment of its effluent was installed in 1992 in order to capture finfish and crab offal for reduction to meal thereby both producing a marketable by-product and decreasing discharges of biochemical oxygen demand (measured as BOD5 and affecting the amount of dissolved oxygen, or DO , in the receiving water), total suspended solids ( TSS ), settleable solid seafood residues, and floating process residues to south Unalaska Bay. Alyeska Seafoods also installed a multi-port diffuser on its outfall in 1992 to improve initial dilution of the discharge. Alyeska Seafoods has contracted with vessels for the conveyance and at-sea disposal of stickwater and surimi wastewater (effluents which do not contain screenable solids) in order to meet its effluent limits during high-volume summer fisheries. The facility processes in excess of 140 million pounds of raw seafood annually. A review of the facility’s discharge monitoring reports shows that the facility’s average flow is as much as 6.5 million gallons per day (MGD), of which 120,000 gal/day is stickwater and 3 MGD is non-contact wastewater. Sanitary wastewater is discharged to the City of Unalaska’s sewage collection system. The effluent discharge ranges in temperature from a low of 6°C in the winter to a high of 17°C in the summer; pH ranges from 6.6 to 7.8. The discharge monitoring reports indicate that the facility has reported full compliance with its permit effluent limits for the period of permit issuance to the present. The facility has reported an average monthly discharge of 33,837 lbs TSS/day and a maximum daily discharge of 81,625 lbs TSS/day based upon 86 analyses. The facility has reported an average monthly discharge of 17,195 lbs oil and grease/day and a maximum daily discharge of 39,731 lbs oil and grease/day based upon 40 analyses. The facility has reported a monthly average discharge of five-day biochemical oxygen demand for the period July through October of 62,711 lbs BOD5/day and a maximum daily discharge of 124,595 lbs BOD5/day. The facility has not detected total residual chlorine (TRC) in its effluent discharge.
PROPOSED DISCHARGE
3.1 Nature, Amount, and Composition of Discharge Alyeska Seafoods - Unalaska facility discharges seafood processing wastewater consisting of relatively high levels of biochemical oxygen demand (BOD5), total suspended solids (TSS), settleable solid processing residues, floating residues, fish oils, and scum. The effluent discharge may also contain traces of disinfectants. These wastewater streams can be several degrees warmer than the receiving waters. The plant also discharges various non-contact cooling wastewaters from an air treatment scrubber, electrical 3Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 7 of 31

generators and refrigeration condenser units which may be as much as 5°C above ambient temperatures and may contain trace amounts of other pollutants.
3.2 Treatment of Wastewater Prior to Discharge The Alyeska Seafoods - Unalaska facility treats its final effluent wastewater with 1 x 10 millimeter slotted wedgewire screening, recovering all residual waste particles to one millimeter width prior to discharge. This screening and meal reduction reduces the facility’s effluent discharges of BOD5 (estimated decrease of more than 70%), TSS (estimated decrease of more than 95%), settleable solid process residues (estimated decrease of more than 97%), and floating solid process residues (estimated decrease of more than 95%).
RECEIVING WATER
4.1 Nature of Unalaska Bay, Iliuliuk Bay and Iliuliuk Harbor Unalaska Bay is located on the north, or Bering Sea side, of Unalaska Island in the eastern Aleutian Islands. It lies at roughly 54°N latitude, 166°30' W longitude. The bay is the foremost safe harbor and anchorage in the eastern Aleutian Islands and shelters both fishing and cargo vessels. It is about 790 air miles southwest of Anchorage and supports a national airport along its limited coastal bench. Greater Unalaska Bay, consisting of a number of contiguous subsidiary bays, is 10.4 nautical miles (nm) wide at its mouth from Cape Cheerful on the west to Cape Kalekta on the east. It is roughly 11.6 nm from the mouth of the bay to its head at the south end of Captains Bay. Greater Unalaska Bay is approximately 87 square nm in area and has roughly 50 nm of shoreline. Iliuliuk Bay is a contiguous and subsidiary bay on the southeast side of Unalaska Bay. It is approximately 1.4 miles wide and 2.7 miles long. Iliuliuk Bay is a steep-sided fjord bay with up to 80% of its width consisting of a relatively flat seafloor deeper than -100 ft, bordered by the mainland of Unalaska Island on the east, Dutch Harbor and Amaknak Island on the west, a convergence of these two islands separated by the entrance to the harbor on the south, and a relatively shallow sill of approximately -45 ft depth on the north. Iliuliuk Harbor is a small, highly sheltered harbor approximately 500 yds across with narrow passage to Iliuliuk Bay through a reefed east channel and to Captains Bay through a hazardous south channel.
4.2 Beneficial Uses of Unalaska Bay, Iliuliuk Bay and Iliuliuk Harbor Designated beneficial uses for Alaska’s marine waters are established by regulation and are found in the State of Alaska Water Quality Standards [18 AAC 70]. For marine waters of the state, these designated uses include: (1) water supply, (2) water recreation, (3) growth 4Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 8 of 31

and propagation of fish, shellfish, other aquatic life, and wildlife, and (4) harvesting for consumption of raw mollusks or other raw aquatic life [18 AAC 70.020(a)(2)].
4.3 Climate The eastern Aleutian Islands are characterized by a maritime climate. Low-lying fog, overcast skies, rain, and drizzle dominate weather conditions along the islands. Average annual precipitation in the area is estimated to be about 58 inches, some of which falls as snow. Fog occurs frequently in the summer. Normal summer air temperatures range from 50 to 60 o F while normal winter air temperatures range from 25 to 35 o F. Unalaska weather data indicate moderate to strong winds throughout the year (CH2M-Hill 1994, Evans-Hamilton 1993). W inds in winter and during storms are usually strong. Average wind speeds range from 10 to 22 mph between October and April and range from 6 to 9 mph between May and September. W ind velocities greater than 25 mph occur in every month of the year and velocities of more than 50 mph are not uncommon. Most gales originate from the north and east in the fall and winter. Local topography plays a major role in determining wind speed and direction.
4.4 Water Column The waters of greater Unalaska Bay are both marine (outer) and estuarine (inner). Surface salinity ranges from around 20 ppt to nearly 33 ppt. Bottom water salinity is less variable, ranging from 25 ppt to 33 ppt. Water temperatures in the bay range from 3° to 10° C near the surface and from 3° to 7° C near the seafloor. Vertical gradients of temperature and salinity which cause stratification of marine and estuarine waters are strongly seasonal, forming in May and June, becoming more pronounced in July through middle-to-late September, and then rapidly returning to an unstratified condition in October. Tides in greater Unalaska Bay are relatively small. The mean tidal amplitude (vertical distance from mean high water to mean low water) is approximately one meter. The maximum tidal amplitude is about two meters. The circulation study of greater Unalaska Bay (CH2M-Hill 1994) indicated that the water circulation with the bay is driven primarily by winds ( . 90%) and secondarily by tides ( . 10%). This results in currents which are strongly seasonal and weakly semi-diurnal in direction and velocity. It is only during periods of low-speed winds that tidal currents might dominate the circulation patterns of the bay.On a large scale, the modeling of circulation in greater Unalaska Bay indicates that winddriven currents are 5 to 15 cm/sec along the western shores of Amaknak Island, the eastern shore of Hog Island and through the pass between the two islands, through the easternAlyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 9 of 31

mouth of Captains Bay and Iliuliuk Harbor, and along the northeastern shores of Unalaska Bay proper. In other areas in the bay, the wind-driven currents range between 1 and 5 cm/sec. Currents in the deep basins of Captains Bay and Dutch Harbor-Iliuliuk Bay may be less than 1 cm/sec during much of the year (CH2M-Hill 1994; Evans-Hamilton 1993; SAIC 1992). The major difference between summer and winter wind-driven circulation patterns is the changes in current direction in many sections of the bay. The circulation study of greater Unalaska Bay suggests that the flushing time required for 95% of the water at a given location in the bay to be replaced by ocean water from outside of the bay ranges from 20 days in central Unalaska Bay to 70 days at the head of Captains Bay. No appreciable differences in flushing times appear to result from changes in wind patterns between summer and winter over most of the year. Captains Bay and Iliuliuk Bay-Dutch Harbor are the exceptions to these generalizations on flushing time. The replacement of the water in Captains Bay 113 meter-deep basin below a 29 meter deep sill requires the development of a pronounced hydraulic pressure head at the south end of the bay during the unstratified conditions of winter. Flushing of this deep basin occurs intermittently during strong, persistent winds or storms from the north. Similar processes constrain and renew Iliuliuk Bay-Dutch Harbor. Three large freshwater streams enter greater Unalaska Bay, the Makushin River of Broad Bay, the Shaishnikof River at the head of Captains Bay, and the Iliuliuk River which drains Unalaska Lake east of Iliuliuk Harbor. All three streams are utilized by salmon for spawning. At least five other streams flow into greater Unalaska Bay year-round and more than thirty other streams seasonally flow into the bay.
4.5 Seafloor Greater Unalaska Bay's subsurface topography, or bathymetry, is complex, consisting of five prominent sills (i.e., pronounced elevations in the seafloor) and four water basins (i.e., pronounced depressions). The northernmost basin is established by Chelan Bank in the north and extends from the Bering Sea into the mouth of Unalaska Bay. The second basin, in Unalaska Bay proper, extends from the mouth adjacent Eider Point along the western portion of the bay and divides into Nateekin Bay to the southwest and south Unalaska Bay (a.k.a. "Processor Bay"). Captains Bay is a very separate and distinct basin enclosed by steep coast on three sides; it is separated by sills across the west and east entrances of this bay. Iliuliuk Bay and Dutch Harbor constitute a single basin bordered by a sill extending from the Dutch Harbor spit east to Unalaska Island on its north side and by the convergence of Amaknak Island and Unalaska Island and the shallower Iliuliuk Harbor to the south. This information suggests that the bays are typical of deep, steep-sided fjords with sills across their entrances. Circulation in the deep basins of such bays may be restricted seasonally due to a stratified water column and decrease bottom currents. Such basins may act as traps for settleable solids and nutrients and experience seasonal oxygen depletion.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 10 of 31

5 BASIS FOR EFFLUENT LIMITATIONS AND MONITORING
5.1 General Approach
EPA followed the Clean Water Act, state regulations, and EPA’s 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the proposed effluent limits. In general, the Clean Water Act requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based or water quality-based limit

. This proposed permit includes both technology-based and water quality-based limits. Technology-based limits are established based upon the level of treatment that is achievable using available technology. Water quality-based limits are designed to prevent exceedance of the Alaska Water Quality Standards (A WQS) in the receiving water. Appendix C contains more detail about how EPA established these water quality-based limits on settleable solid seafood residues.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 11 of 31

5.2 Summary of Effluent Limitations, Past and Proposed


### Table I: Comparison of Permit Limits
Parameter 1996 Permit Limits Proposed Limits Seafood Processing Wastewater BOD5, lbs/day Monthly Average 90,000 (May 1 to Oct. 31) 90,000 (June 1 to Oct. 31) Daily Maximum 144,000 (May 1 to Oct. 31) 144,000 (June 1 to Oct. 31) Settleable Solids Maximum particle size 0.5 mm (process residues) 1 mm (finfish wastes) 0.5 inch (crab wastes) Settleable Solids Annual load - 1 acre zone of deposit no limit 2,700,000 lbs/yr @ 1mm 10,800,000 lbs/yr @ 0.5 in pH, standard units Range 6.5 to 8.5 6.5 to 8.5 Non-contact Scrubber, Condenser and Evaporator Wastewater TSS, lbs/1,000 lbs Monthly Average 1.5 no limit Daily Maximum 3.7 no limit Oil and Grease, lbs/1,000 lbs Monthly Average 0.76 no limit Daily Maximum 1.4 no limit BOD, lbs/1,000 lbs Monthly Average 3.8 no limit Daily Maximum 6.7 no limit pH, standard units Range 6.5 to 8.5 no limit Non-contact Cooling Wastewater Temperature, °C Daily Maximum no limit 20 °C Proposed permits limits for settleable solids are based on the proposed zone of deposit of one acre. The proposed permit requires that finfish processing wastes shall be screened to approximately one millimeter (1 mm) in width and that crab processing wastes shall be ground to one half inch (0.5 in) width prior to discharge through on-site outfalls. The proposed permit further provides that all seafood processing solid waste residues shall be ground to one half inch (0.5 in) width prior to discharge at sea in depths greater than 120 ft MLL W and at a distance of one mile from shore. The proposed permit also prohibits discharges of waste streams that are not part of the normal operation of the facility, as reported in the permit application.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 12 of 31

5.3 Technology-based Evaluation
Section 301 of the Clean Water Act requires particular categories of industrial dischargers to meet technology-based effluent limitation guidelines. The intent of a technology-based effluent limitation is to require a minimum level of treatment for industrial and municipal point sources across the country based on currently available treatment technologies while allowing a discharger to choose and use any available pollution control technique to meet the limitations. Where EPA has not yet developed guidelines for a particular industry, EPA can establish permit limitations using Best Professional Judgment (BPJ; 40 CFR §§ 122.43, 122.44 and 125.3). EPA has determined that discharges of seafood processing wastes shall not exceed one half inch (0.5 in) width when processed and discharged in remote Alaskan locations. In the case of seafood processors discharging large quantities of solid seafood waste residues which produce persistent deposits of more than one acre on the sea floor, EPA has made a BPJ determination that finfish wastewater must be screened to approximately one millimeter (1 mm) width prior to discharge. In order to reduce the pollutant load, solid residues must be either screened, collected, and reduced to meal or transported for disposal from an underway vessel to offshore waters as designated by EPA and the State of Alaska. EPA has previously required in-plant technology-based limits for individual process lines based upon national effluent guidelines for bottomfish, salmon, and herring processing. In administering the permit EPA has found that the separation, collection, and on-site utilization and burning of fish oils and the commingling of the various effluent streams for screening and final discharge through a single outfall support the use of more stringent water quality-based limits for biochemical oxygen demand (BOD5) and waste residues.
5.4 Mixing Zone and Other Variances to State Water Quality Standards The State of Alaska, through ADEC, can authorize a number of site-specific variances to the Alaska Water Quality Standards. Variances to A WQS include site-specific water quality criteria (18 AAC §§ 70.220 and 70.235), a mixing zone wherein A WQS may be exceeded (18 AAC § 70.240), a zone of deposit wherein the A WQS criteria for settleable residues may be exceeded (18 AAC § 70.210), and short-term variances from the anti-degradation policy standard or the water quality criteria (18 AAC § 70.200). In addition, ADEC may exercise enforcement discretion in determining whether to initiate an enforcement action on a water quality violation (18 AAC § 70.900). In the case of this permit, Alyeska Seafoods is applying for (1) mixing zones of 100 ft radius around the outfalls of Discharges 001 and 002 for temperature, color, turbidity, floating and suspended residues, and pH, (2) a mixing zone 230 ft wide and 12,200 ft long for the at-sea Discharge 004, and (3) a one acre zone of deposit on the sea floor around outfall 001 for settleable solids seafood processing residues. ADEC has indicated that it will approve such areas in its State certification of the NPDES permit. No mixing zone is required for Discharge 002.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 13 of 31

5.5 Water Quality-based Evaluation Water quality-based limits are derived from the Alaska Water Quality Standards to protect the water quality and beneficial uses of Alaskan waters. The NPDES regulation at 40 CFR § 122.44(d)(1) requires that permits include limits for all pollutants or parameters which “are or may be discharged at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above any state water quality standard, including state narrative criteria for water quality.” The limits must be stringent enough to ensure that Alaska water quality standards are met, and must be consistent with any available wasteload allocation established in the assessment of a total maximum daily load of pollutant discharges to a receiving water. Based upon Alyeska Seafoods’ monitoring of its effluents and its receiving waters, water quality-based limits are justified for four pollutants: biochemical oxygen demand (BOD5), settleable solid seafood processing residues, temperature, and pH (a measure of the acidity or alkalinity of the wastewaters). EPA Region 10 completed an assessment of the TMDL for settleable solids seafood processing residues for south Unalaska Bay, predicting wasteloads which would produce waste piles of different sizes on the sea floor around an outfall (EPA 1998). This TMDL provides the foundation for water quality-based limits of residues in this permit. Alyeska Seafoods has requested that the permit limits for settleable solid residues provide for a discharge of a combination of both screened finfish wastes and ground crab wastes. EPA has completed an assessment of allowable discharges of both screened and ground wastes for a zero acre, one acre and two acre zone of deposit (Table 1, above; Appendix C). At the publication of this draft permit, ADEC has tentatively approved a one acre zone of deposit. The permits limits are based on modeling results for a one acre zone of deposit, allowing for a safety factor. EPA previously completed TMDL determinations for the discharge of biochemical oxygen demand into south Unalaska Bay and developed appropriate water quality-based limits on discharges of BOD5 at the facility. The facility has been able to meet these limits and water quality monitoring of south Unalaska Bay indicates that these limits have been protective of the Alaska Water Quality Standard for dissolved oxygen. The average monthly and maximum daily limits on BOD5 have been sustained in the current permit reissuance. The most stringent State criteria for pH are those for the growth and propagation of fish, shellfish, and other aquatic life: pH may not be less than 6.5 or greater than 8.5, and may not vary more than 0.1 pH unit from natural conditions in the receiving water. Based on these criteria, the permittee may not discharge effluents for which the pH is less than 6.5 or greater than 8.5. The most stringent State criteria for temperature are that the temperature of a discharge may not exceed 15°C or cause the weekly average to increase by more than 1°C. State criteria exist for color, turbidity, and floating residues... pollutants characteristic of the wastewater plume of seafood processors. It is EPA’s best professional judgment that the Alaska water quality criteria for temperature, color, turbidity, and floating residues will be met outside of the mixing zones. The EPA is proposing a maximum temperature limit of 20°Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 14 of 31

C for non-contact cooling water, based on a past 401 Certification from ADEC for a similar type discharge. Antidegradation of Water Quality

. In proposing to reissue this permit, EPA has considered the State’s antidegradation policy [18 AAC 70.015]. This policy states, in part, that in Alaska: “the existing water uses and the level of water quality necessary to protect the existing uses must be maintained and protected (and), if the quality of a water exceeds levels necessary to support propagation of fish, shellfish, and wildlife and recreation in and on the water, that quality must be maintained and protected unless the department (ADEC)... allows the reduction in water quality...”. The permit, as stated above, allows and limits effluent discharges of temperature, pH, and residues. The limits in the draft permit are consistent with and protective of the State water quality standards and the water quality of the receiving water. EPA believes that the draft permit is consistent with the State’s antidegradation policy.
5.6 Summary of Effluent Monitoring
The Clean Water Act requires that monitoring shall be included in permits to determine compliance with effluent limitations. Monitoring may also be required to gather data for future effluent limitations and to monitor effluent impacts on the receiving water. The Permittee will be responsible for conducting the monitoring and for reporting the results to EPA. Table II presents the proposed monitoring requirements based on the minimum sampling necessary to adequately monitor the facility’s performance. For comparison purposes, the table also shows the monitoring requirements in the past permit.

TABLE II. Comparison of Monitoring Requirements Parameter 1996 Permit Frequency and Sample Type Proposed Permit Frequency and Sample Type Seafood Processing Water - Summer Monitoring Months August, September, October July, August, September, October Flow (mgd) daily, record daily, meter BOD5 (mg/L; lbs/day) 2/week, 24-hr composite 2/week, grab or composite TSS (mg/L; lbs/unit) 2/week, 24-hr composite 1/week, grab or composite Settleable Solids (mg/L; lbs/day) 2/week, 24-hr composite 1/week, grab or composite
Oil and Grease,(mg/L; lbs/unit) 1/week, grab no monitoring pH 1/week, grab 1/week, grab Seafood Processing Water - Winter Monitoring Months January, February, March February Flow (mgd) daily, record daily, meterAlyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 15 of 31

TABLE II. Comparison of Monitoring Requirements Parameter 1996 Permit Frequency and Sample Type Proposed Permit Frequency and Sample Type BOD5 (mg/L; lbs/day) 1/week, 24-hr composite 1/week, grab or composite TSS (mg/L; lbs/unit) 1/week, 24-hr composite 1/week, grab or composite Settleable Solids (mg/L; lbs/day) 1/week, 24-hr composite 1/week, grab or composite
Oil and Grease,(mg/L; lbs/unit) 1/month, grab no monitoring pH 1/month, grab 1/week, grab Non-contact Scrubber, Condenser and Evaporator - Summer and Winter Monitoring Months January, February, March, August, September, October no monitoring
Flow (mgd) daily, record no monitoring Production Levels daily, record no monitoring BOD5 (mg/L; lbs/day) 1/week, 24-hr composite no monitoring TSS (mg/L; lbs/unit) 1/week, 24-hr composite no monitoring Oil and Grease,(mg/L; lbs/unit) 1/month, grab no monitoring pH 1/month, grab no monitoring Non-contact Cooling Wastewater - Summer and Winter Monitoring Months no monitoring February, July, August, September, October Flow (mgd) no monitoring daily, record Temperature no monitoring daily, grab or probe The permit requires weekly effluent monitoring of pollutant parameters for which a limit or condition exists within the permit (40 CFR §§ 122.41 and 122.44). Monitoring is conducted during five of the twelve months per year as sufficient to collect representative samples which quantify both concentrations and mass loading for the facility; the sampling months coincide with fishing seasons and attendant high levels of pollutant discharge. Representative Sampling

. The proposed permit requires sampling whenever a bypass, spill, or non-routine discharge of pollutants occurs, if such a discharge could cause a violation of an effluent limit.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 16 of 31

6 BASIS FOR BEST MANAGEMENT PRACTICES PLAN
The Clean Water Act and federal regulations authorize EPA to require best management practices , or BMPs, in NPDES permits. BMPs are measures for controlling the generation of pollutants and their release to waterways. For many facilities, these measures are typically included in the facility Operation & Maintenance plans (O&M) plans. BMPs are important tools for waste minimization and pollution prevention. EPA encourages facilities to incorporate BMPs into their O&M plans and to revise them as new practices are developed. The proposed permit requires Alyeska Seafoods to develop and implement a BMP plan within 180 days of permit issuance. The Permittee must develop a materials balance assessment (i.e., a flow diagram) of its process, treatment and discharge lines and quantify the input and output streams of water and pollutants. The Permittee must consider the optimization of product recovery and chemical use, staff training aimed at controlling the discharge of pollutants to the receiving waters, spill prevention and control, and water conservation. The Permittee must document this assessment as a working document known as a BMP plan in accordance with the requirements of the permit.

7 BASIS FOR ENVIRONMENTAL MONITORING The proposed permit requires Alyeska Seafoods to monitor the receiving water for the discharge and accumulation of residues on the sea floor, sea surface and shoreline and for the degradation of dissolved oxygen concentrations in the water column. The purpose of this monitoring is to verify the assumptions made in developing permit limits regarding receiving water conditions and the effectiveness of permit limits. Based on the results of this study, EPA will determine whether or not to revise these permit limits when the permit is renewed. Ambient monitoring of the residues on the sea surface and sea floor and of dissolved oxygen within the water column are important in monitoring the effect of the Alyeska Seafoods plant on the receiving waters. Daily surveys and records of the sea surface and sea shore for scum and other residues are required in the permit. Monitoring of settleable residues on the sea floor is required as an annual sea floor survey in the area around the outfall. Water quality monitoring of the receiving waters is required in the second and fourth years of the permit, and will verify the continue protection of the State water quality standard for dissolved gases in the bay and the efficacy of permit limits. The proposed permit requires the Permittee to submit study plans to EPA and ADEC for approval. The plan must address issues such as appropriate sampling location, variability in the receiving water, appropriate sampling and analytical methods, analytical variability, and quality assurance/quality control for sampling and analysis.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 17 of 31

8 BASIS FOR ANNUAL REPORT The proposed permit requires the Permittee to complete and submit an annual report which compiles effluent and environmental monitoring data and reports permit violations, upset conditions, by-pass conditions, plant or process changes, and corrective actions undertaken to improve wastewater treatment and pollution prevention at the facility. The annual report provides a comprehensive record of wastewater discharge at the facility and its effect on the receiving water. The annual report supports improved understanding and management of the discharges and discussion of these discharges by the applicant and government representatives. Title 40 of the Code of Federal Regulations provides the regulatory basis for this requirement at sections 122.41 (“Conditions applicable to all permits”), 122.44(i) (“Monitoring requirements”), and 122.48 (“Requirements for recording and reporting of monitoring results”).
9 PERMIT CONDITIONS FOR COMPLIANCE, RECORDING, REPORTING, AND OTHER GENERAL PROVISIONS Sections § VI through VIII of the draft permit contain standard regulatory language that is required to be in all NPDES permits. The following sections of the permit are based largely upon 40 CFR Part 122, subpart C, “Permit Conditions” and on other referenced laws and regulations.

- Duty to Comply from 40 CFR § 122.41(a),

- Proper Operation and Maintenance from 40 CFR § 122.41(e),

- Duty to Mitigate from 40 CFR § 122.41(d),

- Toxic Pollutants from 40 CFR § 122.41(a)(1-2), § 122.44(b, e), and § 125.3,

- Removed Substances from 40 CFR § 122.41(a)(1) and (o) and C WA § 405(A),

- Need to Halt or Reduce Activity not a Defense from 40 CFR § 122.41(c),

- Bypass of Wastewater Treatment from 40 CFR § 122.41(m),

- Upset Conditions from 40 CFR § 122.41(n),

- Inspection and Entry from 40 CFR § 122.41(i),

- Penalties for Violations of Permit Conditions from 40 CFR § 122.41(a)(2-3),

- Duty to Provide Information from 40 CFR § 122.41(h),

- Records Contents from 40 CFR § 122.41(j)(3),

- Submittal of Reports from 40 CFR § 122.41(h, j, and l),

- Retention of Records and Reports from 40 CFR § 122.41(j)(2),

- On-site Availability of Records and Reports from 40 CFR § 122.41(i)(2),

- Availability of Reports for Public Review from 40 CFR § 122.1(e) and § 122.7(1) and 40 CFR § 2.101,

- Planned Changes from 40 CFR § 122.41(l)(1),

- Changes in the Discharge of Toxic Substances from 40 CFR § 122.42(a),

- Anticipated Noncompliance from 40 CFR § 122.41(l)(2),

- Reporting of Noncompliance from 40 CFR § 122.41(l)(6-7) and § 122.44(g),

- Permit Actions from 40 CFR § 122.44(c) and 40 CFR § 122.61 - § 122.64,

- Duty to Reapply from 40 CFR § 122.41(b),

- Incorrect Information and Omissions from 40 CFR § 122.41(l)(8),Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 18 of 31

- Signatory Requirements from 40 CFR § 122.41(k),

- Property Rights from 40 CFR § 122.41(g),

- Severability from 40 CFR § 124.16,

- Transfers from 40 CFR § 122.41(l)(3),

- Oil and Hazardous Substance Liability from 40 CFR § 125.3, 40 CFR part 300, 33 CFR § 153.10(e), and section 311 of the Act,

- State Laws from 40 CFR § 122.1(f) and section 510 of the Act, and

- Reopening of the Permit from 40 CFR § 122.41(f) and § 122.44(c).
10 OTHER LEGAL REQUIREMENTS
10.1 State Water Quality Standards and Certification EPA is requesting State officials to review and provide appropriate certification to this NPDES permit pursuant to 40 CFR § 124.53. Since State waters are involved in the draft permit, the provisions of Section 401 of the Clean Water Act apply, requiring EPA to seek State certification that the permit is protective of the State Water Quality Standards before issuing a final permit. This certification by the State ensures that federally issued permits are in compliance with the laws of the State ( see 40 CFR § 124.55). In particular, ADEC must provide written stipulation for a water quality study of the receiving water and authorization of mixing zones and a zone of deposit in its certification of the permit. In accordance with 40 CRF §124.10(c)(1), public notice of the draft permit has been provided to the State agencies having jurisdiction over fish, shellfish and wildlife resources, and over coastal zone management plans.
10.2 Endangered Species Act Endangered species found in the vicinity of the discharge include Eskimo curlew ( Numenius borealis ), American peregrine falcon ( Falco peregrinus anatum ), Aleutian shield-fern or Aleutian holly-fern ( Polystichum aleuticum ), short-tailed albatross ( Diomedea albatrus ), humpback whale ( Megaptera novaeangliae ), right whale ( Eubalaena glacialis ), and blue whale ( Balaenoptera musculus ). Threatened species found in the vicinity of the discharge include Spectacled eider ( Somateria fischeri ), Steller's eider ( Polysticta stelleri ), Aleutian Canada goose ( Branta canadensis leucopareia ), and Steller sea lion ( Eumetopias jubatus ). Pursuant to 40 CFR § 122.49(c), EPA has concluded that, with the exception of the Steller's eider, the localized effluent discharges authorized by this permit will have no effect on the continued existence of these endangered or threatened species and will not adversely affect their critical habitat. The EPA has concluded that the localized effluent discharges authorized by this permit are likely to adversely affect Steller’s eiders. EPA has initiated consultation with USF WS on the potential effects of this permit action on Steller’s eiders, and is applying the conclusions and reasonable and prudent measures developed in the Service’s biological opinion on the permitting of seafood processors throughout Alaska (USF WS 01/17/01; Attachment A to draft permit). EPA will initiate additional consultation with NMFS or USF WS should new information reveal impacts not previously considered, should theAlyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 19 of 31

activities be modified in a manner beyond the scope of the original opinion, or should the activities affect a newly listed threatened or endangered species. The draft permit, fact sheet and consistency determination will be submitted to the U.S. Fish and W ildlife Service (USF WS) and the National Marine Fisheries Service (NMFS) for review at the time of public notice. EPA is requesting concurrence from USF WS and NMFS on the draft permit, and will consider their comments in the final permit decision.
10.3 Fishery Conservation and Management Act The Magnuson-Stevens Fishery Conservation and Management Act requires EPA to consult with NMFS with respect to the reissuance of this NPDES permit concerning its impacts on any essential fish habitat and to provide a description of the measures proposed to avoid, mitigate, and offset the impact of this permitted discharge on such habitat. EPA finds that the permitted discharge will comply with Alaska Water Quality Standards outside of the authorized zones of variance, that decreases in marine life within these zones will be compensated by increases in the abundance of marine life in surrounding zones of organic enrichment, and that issuance of this permit is not likely to adversely affect any species in the vicinity of the discharge. EPA provides this fact sheet to describe the discharge, the draft permit, and the permit’s limits, conditions, and measures of mitigation.
10.4 Coastal Zone Management Act The applicant has certified that the activities authorized by this draft permit are consistent with the Alaska Coastal Management Plan. The draft permit, fact sheet and consistency determination will be submitted to the State for review at the time of public notice. Pursuant to 40 CFR § 122.49(d), requirements for State coastal zone management review and approval must be satisfied before the permit may be issued.
10.5 Pollution Prevention Act It is national policy that, whenever feasible, pollution should be prevented or reduced at the source, that pollution which cannot be prevented should be recycled in an environmentally safe manner, and that disposal or release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner. The Permittee will discharge at the facility in accordance with best management practices which will address the provisions of the Pollution Prevention Act.
10.6 Oil Spill Requirements
Section 311 of the Clean Water Act prohibits the discharge of oil and hazardous materials in harmful quantities. Discharges specifically controlled by the draft permit are excluded from the provisions of Section 311 because these discharges are limited to amounts and concentrations which are deemed to be protective of State water quality standards. However, this permit does not preclude the institution of legal action or relieve theAlyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 20 of 31

Permittee from any responsibilities, liabilities, or penalties for other unauthorized discharges of toxic pollutants which are covered by Section 311 of the Act.
11 MODIFICATION OF PERMIT LIMITS OR OTHER CONDITIONS
When EPA receives information that demonstrates the existence of reasonable cause to modify the permit in accordance with 40 CFR § 122.62(a), EPA may modify the permit. “Reasonable cause” includes alterations or additions to the facility or activity, new federal regulations or standards, new state water quality standards, the completion or modification of total maximum daily loads or wasteload allocations for the receiving water of the facility (also, see 40 CFR § 122.44(d)((1)(vii)(B)), failure of the permit to protect state water quality standards, a change in a permittee’s qualification for net limits, any relevant compliance schedule, the need to incorporate or revise a pretreatment or land application plan, when pollutants which are not limited in the permit exceed the level which can be achieved by technology-based treatment, the correction of technical mistakes and legal misinterpretations of law made in determining permit conditions, and the receipt of new information relevant to the determination of permit conditions. Minor modifications to a permit may be made by EPA with the consent of a permittee in order to correct typographical errors, change an interim compliance schedule, allow for a change in ownership, change a construction schedule, or delete an outfall. Pursuant to 40 CFR § 122.63, such minor modifications may be made without public notice and review.
12 PERMIT EXPIRATION This permit will expire five years from its effective date. In accordance with 40 CFR § 122,6(a), the conditions of an expired permit continue in force under 5 U.S.C. § 558(c) until the effective date of a new permit when a permittee submits an application for permit reissuance 180 days before the expiration of the permit. Permits which are continued because EPA has not reissued a new permit remain fully effective and enforceable.
13 GLOSSARY OF TERMS AND ACRONYMS § means section or subsection.
AAC means Alaska Administrative Code.
ADEC means Alaska Department of Environmental Conservation. Average monthly discharge means the average of “daily discharges” over a monitoring month, calculated as the sum of all daily discharges measured during a monitoring month divided by the number of daily discharges measured during that month. It may also be referred to as the "monthly average discharge." Best management practices (“BMPs”) means schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the pollution of “waters of the United States.” BMPs also include treatmentAlyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 21 of 31

requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.
BOD5 means biochemical oxygen demand, five-day. Bypass means the intentional diversion of waste streams from any portion of a treatment facility.
°C means degrees Celsius.
CFR means Code of Federal Regulations. Cooling water means once-through non-contact cooling water.
CWA means the Clean Water Act, (formerly referred to as the Federal Water Pollution Control Act or Federal Water Pollution Control Act Amendments of 1972) Public Law 92-500, as amended by Public Law 95-217, Public Law 95-576, Public Law 96-483 and Public Law 97-117, 33 U.S.C. 1251 et seq. Daily discharge means the discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for purposes of sampling. For pollutants with limitations expressed in units of mass, the "daily discharge" is calculated as the total mass of the pollutant discharged over the day. For pollutants with limitations expressed in other units of measurement, the "daily discharge" is calculated as the average measurement of the pollutant over the day. Daily maximum discharge means the highest allowable "daily discharge" and is also referred to as the "maximum daily discharge." Discharge of a pollutant means any addition of any "pollutant" or combination of pollutants to "waters of the United States" from any "point source" or any addition of any pollutant or combination of pollutants to the waters of the “contiguous zone” or the ocean from any point source other than a vessel or other floating craft which is being used as a means of transportation. Discharge Monitoring Report (“DMR”) means the EPA uniform national form, including any subsequent additions, revisions, or modifications for the reporting of self-monitoring results by permittees. DMRs must be used by “approved States” as well as by EPA.
DO means dissolved oxygen.
Effluent limitation means any restriction imposed by the Director on quantities, discharge rates, and concentrations of “pollutants” which are “discharged” from “point sources” into “waters of the United States,” the waters of the “contiguous zone,” or the ocean.
EPA means U.S. Environmental Protection Agency.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 22 of 31

ESA means the Endangered Species Act.
°F

means degrees Fahrenheit. Facility or activity means any NPDES “point source” or any other facility or activity (including land or appurtenances thereto) that is subject to regulation under the NPDES program.
lb

means pound.
Maximum means the highest measured discharge or pollutant in a waste stream during the time period of interest. Maximum daily discharge limitation means the highest allowable “daily discharge.”
MGD means million gallons per day. mg/L means milligrams per liter. Mixing zone means the zone of dilution authorized by ADEC under 18 AAC 70.032 wherein pollutant concentrations may exceed the criteria of the Alaska Water Quality Standards for the proscribed pollutants.
MLLW means mean lower low water. mg/L means milligrams per liter.
ml means milliliter.
NMFS means National Marine Fisheries Service. National Pollutant Discharge Elimination System (“NPDES”) means the national program for issuing, modifying, revoking and reissuing, terminating, monitoring and enforcing permits, and imposing and enforcing pretreatment requirements, under sections 307, 402, 318, and 405 of C WA.
OW means EPA’s Office of Water.
P.L. means (U.S.) Public Law.
Point source means any discernible, confined, and discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, landfill leachate collection system, vessel or other floating craft from which pollutants are or may be discharged. This term does not include return flows from irrigated agriculture or agricultural storm water runoff.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 23 of 31

Pollutant means dredged spoil, solid waste, incinerator residue, filter backwash, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural waste discharged into water.
Process wastewater means any water which, during manufacturing or processing, comes into direct contact with or results from the production or use of any raw material, intermediate product, finished product, byproduct, or waste product.
QAPP means quality assurance project plan. Schedule of compliance means a schedule of remedial measures included in a “permit'', including an enforceable sequence of interim requirements (for example, actions, operations, or milestone events) leading to compliance with the C WA and regulations.
sp. means species. Sanitary wastes means human body waste discharged from toilets and urinals.
Seafood means the raw material, including freshwater and saltwater fish and shellfish, to be processed, in the form in which it is received at the processing plant. Seafood process waste means the waste fluids, organs, flesh, bones, and chitinous shells produced in the conversion of aquatic animals and plants from a raw form to a marketable form. Settleable solid process residues means process waste solids that gravimetrically settle out of the process wastewater and accumulate on the bottom of a wastewater discharge collection sump (which typically has a residence time of 15 minutes). Severe property damage means substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production.

Technology-based limitmeans a permit limit or condition based upon EPA’s technologybased effluent limitation guidelines or EPA’s best professional judgment.
TSS means total suspended solids.
USFWS or FWS means U.S. Fish and W ildlife Service. Upset means an exceptional incident in which there is unintentional and temporary noncompliance with permit effluent limitations because of factors beyond the reasonable control of the permittee. An upset does not include noncompliance to the extent causedAlyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 24 of 31

by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.
Variance means any mechanism or provision under section 301 or 316 of C WA or under 40 CFR part 125, or in the applicable ``effluent limitations guidelines'' which allows modification to or waiver of the generally applicable effluent limitation requirements or time deadlines of C WA. This includes provisions which allow the establishment of alternative limitations based on fundamentally different factors or on sections 301(c), 301(g), 301(h), 301(i), or 316(a) of C WA. Water depth means the depth of the water between the surface and the sea floor as measured at mean lower low water (0.0). Water quality-based limit means a permit limit derived from a state water quality standard or an appropriate national water quality criteria.
Waters of the United States or waters of the U.S. means: (a) All waters which are currently used, were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide; (b) All interstate waters, including interstate wetlands; (c) All other waters such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds the use, degradation, or destruction of which would affect or could affect interstate or foreign commerce including any such waters: (1) Which are or could be used by interstate or foreign travelers for recreational or other purposes; (2) From which fish or shellfish are or could be taken and sold in interstate or foreign commerce; or (3) Which are used or could be used for industrial purposes by industries in interstate commerce; (d) All impoundments of waters otherwise defined as waters of the United States under this definition; (e) Tributaries of waters identified in paragraphs (a) through (d) of this definition; (f) The territorial sea; and (g) Wetlands adjacent to waters (other than waters that are themselves wetlands) identified in paragraphs (a) through (f) of this definition. Zone of deposit (ZOD) means an area of the bottom in marine, coastal, or estuarine waters in which ADEC has authorized the deposit of residues in exceedence of the water quality criteria of 18 AAC 70.020(b) and the antidegradation requirement of 18 AAC 70.0101(c).Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 25 of 31

14 REFERENCES
ADEC. 1994. Waterbody Recovery and Pollution Prevention Plan for Unalaska Bay, Alaska. Alaska Department of Environmental Conservation, 410 W illoughby Avenue, Juneau, Alaska. Enviro-Tech Diving. 1998. Diver survey of the Alyeska Seafoods outfall, 1998. EnviroTech Diving, Inc., 1127 N W 45 th Street, Seattle, Washington.
USEPA. 1991. Technical support document for water quality-based toxics control. Office of Water, Washington, D.C. EPA/505/2-90-001.
USEPA. 1993. Guidance manual for developing best management practices (BMP). Office of Water, Washington, D.C. EPA/833/2-93-004.
USEPA. 1996. NPDES permit writers’ manual. Office of Wastewater Management, Washington, D.C. EPA/833/B-96-003.
TetraTech. 1996. Total maximum daily load (TMDL) for seafood residues in the waters of Alaska. USEPA Region 10, Office of Water, 1200 Sixth Avenue, Seattle, Washington. September 30, 1996.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 26 of 31

APPENDIX A - Location of the Alyeska Seafoods - Unalaska facilityAlyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 27 of 31

APPENDIX B - Diagram of the Alyeska Seafoods - Unalaska facilityAlyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 28 of 31

APPENDIX C - Synopsis of Modeling the Discharge of Settleable Solid Seafood Residues
TECHNICAL BRIEF FOR EXPANDED SEAFOOD MODEL RUNS Gary Braun, Senior Scientist Tetra Tech, Inc, 15400 NE 90 th Street, Suite 100, Redmond, WA, 98052 September 30, 1996.

In support of the development of a general NPDES permit for shore-based, near shore, and offshore seafood processors, Tetra Tech prepared an ocean discharge criteria evaluation (ODCE) report in July 1994. The report concentrated on characterizing the effluent being discharge from the covered facilities and its potential effect on receiving waters. The report also developed preliminary modeling predictions for the deposition of solid seafood waste residues on the sea floor. Technical directive No. 12 directed Tetra Tech to expand the modeling assessment of the deposition of settleable solid seafood waste residues from processors using different particle size assumptions. Tetra Tech was also directed to determine endpoints for maximum discharges which produce deposition areas of zero, one, and two acres using the case scenarios defined in the previous ODCE. To accomplish this task, three general cases were modeled (i.e., 0.5 inch, 0.38 inch, and 0.04 inch maximum particle size) and the results are presented in Tables 1, 2, and 3, respectively. No changes in the WASP5 model were required to perform these model simulations, however, the input files used for each model run were modified as needed and are described below. Results of the predicted areal coverage of solid wastes for both the WASP output, based on the number and area of grids, and SURFER, based on contours of depth accumulation, are reported. In general, the determination of the endpoints for maximum discharges that produce zero, one, and two acre waste piles are based on the areas estimated by SURFER, the 3-dimensional contouring software. Table 1 depicts the area and thickness of a waste pile which results from discharging seafood waste solids that have been ground to a maximum particle size of 0.5 inch. The assessment assumes that 60% of the loading mass of particles is 0.5" in diameter, 20% is 0.25", and 20% is 0.125". Table 2 depicts the area and thickness of a waste pile which results from discharging seafood waste solids that have been ground to a maximum particle size of 0.375 inch. The assessment assumes that 60% of the loading mass of particles is 0.375" in diameter, 20% is 0.188", and 20% is 0.094". Table 3 depicts the area and thickness of a waste pile which results from discharging seafood waste solids that have been ground to a maximum particle size of 0.04 inch (= 1 mm). The assessment assumes that 100% of the loading mass of particles is 0.04" in.Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 29 of 31Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 30 of 31Alyeska Seafoods - Unalaska facility AK-000027-2 Fact Sheet page 31 of 31

### Reissuance of NPDES Permits for Three Major Alaskan Seafood Processors in the Aleutian Islands

Response to Public Comments

The EPA provides the following responses to the public on the reissuance of three National Pollutant Discharge Elimination System (hereafter, “NPDES”) permits: (1) AK-000027-2 to Alyeska Seafoods, Inc., for its Unalaska Bay on-shore seafood processing facility; (2) AK-002865-7 to UniSea, Inc., for its Unalaska Bay on-shore seafood processing facility; and (3) AK-003730-3 to Trident Seafoods Corporation, for its Akutan Harbor on-shore seafood processing facility. Some of these responses include and explain changes to the draft NPDES permits for the above facilities that were noticed and released for public comment on September 21, 2001. In addition, EPA has revised the draft permits in accordance with conditions presented by the State of Alaska in its Clean Water Act (hereafter, “CWA”) § 401 certification of the permits and its consistency determination pursuant to the Coastal Zone Management Act (hereafter, “CZMA”) and by the National Marine Fisheries Service (hereafter, “NMFS”) and the U.S. Fish and Wildlife Service (hereafter, “FWS”) in their conservation reviews accorded by the Endangered Species Act (hereafter, “ESA”), the Marine Mammal Protection Act (hereafter, “MMPA”), and the Fishery Conservation and Management Act (hereafter, “FCMA”).

Comment : UniSea and Trident Seafoods request a discussion with EPA on the identification of their facilities’ outfalls. (Cover page) Response : The EPA discussed the identification of the permitted facilities’ many outfall lines and developed a revised numbering system to identify outfalls and discharges. The EPA has revised the permits to designate outfalls and discharges accordingly.
Comment : Trident Seafoods comments that the new permit requires screening of live-tank water and boat-hold transfer water which was previously authorized for untreated discharge. Trident Seafoods objects to this new screening requirement. Screening live-tank water and boat-hold transfer water would require a significant investment in the revision of plumbing, pumps and building in order to treat the increased flow of wastewater. (Section I.A.1)Response to Comments page 2 of 15



### Response : Trident Seafoods-Akutan has previously been permitted to discharge live-tank water and boat-hold transfer water without screening or other treatment in its previous NPDES permits that ADEC has certified. Other large pollock processors have been required to screen their live-tank water and boat-hold transfer water and have done so for the past decade. Trident reports that dive surveys of the seafloor along and beneath the dock indicate that the discharge of unscreened live-tank and boat-hold transfer water has produced a range of depositional effects from a small, intermittent deposits of fish scales measuring less than 100 sq. ft. to no distinguishable deposit. Yet the discharge produces a visible plume along the dock face at the point of discharge, joining discharges of similar wastewater from off-loading fishing vessels to create an impact area along the facility’s dock-face. The costs and benefits of screening this wastewater discharge provide arguments for both alternatives... and the requirement to screen out fish scales and other solid residues rests on the regulatory judgment of ADEC.
The ADEC has determined that Trident Seafoods shall screen its live-tank water and boathold transfer water prior to discharge and has required this treatment in its § 401 certification of the NPDES permit. No provision has been made for a mixing zone or zone of deposit. If the permittee is not satisfied with ADEC’s determinations, then the permittee must resolve this issue with ADEC during the 30-day appeal period following the re-issuance of the permit. In consideration of ADEC’s certification of the permit, EPA has determined that no change in the permit is necessary on the basis of this comment.
Comment : Alyeska Seafoods comments that the facility screens all of its seafood processing wastes, will not discharge ground or whole wastes, and requires no limits for grinding crab wastes. (Sections I.A.1.b and I.E) Response : The ADEC has determined that Alyeska Seafoods, Trident Seafoods-Akutan and UniSea shall screen all seafood processing wastes to 0.5 mm width prior to on-site discharge. In consideration of ADEC’s certification, EPA has revised the permits to eliminate limits on the mass of settleable solid seafood processing residues that can be discharged on-site into south Unalaska Bay at each of these facilities. The EPA has provided further that solid seafood processing waste residues ground to one-half inch may be discharged at-sea.
Comment : Trident Seafoods comments that there is occasionally a “foam, film, or sheen” near our live-tank return water, and though this dissipates within an acceptable mixing zone, there is no mixing zone established for the live-tank water and boat-hold transfer water. The permit should identify and establish a mixing zone for the live-tank water and boat-hold transfer water. (Section I.A) Response : The EPA has revised the permit to incorporate ADEC’s specific authorization of a mixing zone.Response to Comments page 3 of 15



### Comment : UniSea and Trident Seafoods comment that previous permits authorized the barging of seafood wastewater (including surimi), stickwater, and scrubber / evaporator wastewater. The draft permit re-characterizes these wastewaters as fish and crab waste solids and unground calcareous shells. The draft permits should be revised to identify seafood processing wastewater as previously allowed. (Section I.B and Section I.D 1 

### or I.G 2 

### ) Response : The EPA agrees that seafood processing wastewater, which includes stickwater as one form among many, is a legitimate and important at-sea discharge. The EPA has revised the permits to provide for authorization of at-sea discharges of seafood processing wastes and wastewaters.
Comment : Alyeska Seafoods comments that settleable solid residues screened to 0.5 mm width and having no limits should not be monitored. (Section I.E) Response : The EPA believes that it is important to learn more about the discharge and effects of discharges of seafood processing waste residues. Each of the permitted facilities is one of the ten largest processors of seafood in the United States. The EPA finds it entirely appropriate and in accordance with both the CFR [e.g., 40 CFR § 122.43(a)] and the AWQS to require monitoring of flow, five-day biochemical oxygen demand (hereafter, “BOD5"), total settleable solids (TSS), settleable solids, and pH in the discharges of these very large seafood processors. The EPA has determined that no change in the permit s is necessary on the basis of this comment.
Comment : Trident Seafoods comments that there is a limitation on BOD5 from June through October but the effluent monitoring is required from July through October. The limitation should be from July 1 to October 31. (Section I.E 1 

### or I.H 2 

### and Section I.A.2 ) Response : The EPA agrees that effluent limits must be supported appropriately by effluent monitoring. In view of the expansion of the pollock fishing and processing season pursuant to the American Fisheries Act ( see Figures 1 and 2 below), EPA has determined that it is necessary to limit discharges to south Unalaska Bay and Akutan Harbor during June. Rather than reduce the time period during which effluent limits on BOD5 apply, EPA will extend the duration of effluent monitoring to include June. The EPA has revised the permits to extend monitoring to cover the period June 1 through October 31.

1 Permit section references for Alyeska Seafoods and UniSea reflect four numbered outfalls.

2 Permit section references for Trident Seafoods reflects seven numbered outfalls.Response to Comments page 4 of 15



### Insert Pollock Catch Figures on This PageResponse to Comments page 5 of 15



### Comment : Trident Seafoods finds the requirement to incorporate the results of all monitoring not required by the permit into the Discharge Monitoring Report (hereafter, “DMR”) calculations is unreasonable. The applicant should be required to submit the additional test results but not incorporate them into the DMR. (Section I.E.2 1 

### or I.H.2 2 

### ) Response : The EPA has included this provision in accordance with 40 CFR § 122.41(l)(4)(ii). The EPA has determined that no change in the permit is necessary on the basis of this comment.
Comment : Alyeska Seafoods comments that the mixing zone for its processing wastewater discharge should be an oval extending 100 ft around its 150 ft multi-port diffuser rather than a circle of 100 ft radius and requests that the permit reflect this change. (Section I.F.2.a) Response : The EPA agrees with the view that a mixing zone should accommodate the size and shape of an outfall diffuser. The EPA has conferred with ADEC concerning this issue. As authorized in the State of Alaska’s certification of NPDES permit no. AK-000027-2 for Alyeska Seafoods’ Unalaska on-shore seafood processing facility, the mixing zone for the facility’s multi-port diffuser is oval in shape and its perimeter is 100 ft from the diffuser. The EPA has revised the Alyeska Seafoods permit at Section I.F.2.a to incorporate the State-authorized mixing zone for Alyeska Seafoods’ Discharge 001.
Comment : Trident Seafoods comments that “week” should be replaced with “month” in the sentence beginning “The annual report shall...” The current permit reads month and there is no discernable advantage we can decipher for changing the presentation of the information to a weekly format. It would require considerably more effort to produce in this format. (Section I.F.3) Response : The EPA agrees that the date and time of monitoring are sufficient and that the week is unnecessary. The EPA has revised the permits to replace “week” with “month.”
Comment : Alyeska Seafoods comments that its multiport diffuser extends 150 ft in length from a depth of -50 ft to -60 ft MLLW. The repositioning and rebuilding of the diffuser is a costly modification. Alyeska Seafoods requests that EPA reconsider the proposed condition in view of this expense and remove the -60 ft MLLW requirement. (Section I.F.4) Response : In consideration of the nature, environmental result, and terminal depth of the diffuser at -60 ft MLLW, EPA finds that Alyeska Seafoods’ outfall diffuser meets the intent of the permit condition to protect the quality of the receiving water. The EPA has revised the Alyeska Seafoods permit to authorize the historic location and depth of Alyeska Seafoods’ Discharge 001.Response to Comments page 6 of 15



### Comment : UniSea comments that the draft permit requires that non-contact wastewater must be discharged at mean lower low water (hereafter, “MLLW”) or deeper. This waste stream is currently being discharged above MLLW and no deleterious impact has been noted to date. It is estimated that it would cost $50,000 to make the necessary structural modifications for compliance with this permit condition. UniSea requests that this requirement be removed from the permit. (Section I.F.4 1 

### or I.I.4 2 

### ) Response : The EPA has reconsidered the proposed permit requirement in view of the permittee’s report that (1) the discharge does not create persistent foam and (2) the extension of the outfall will cost $50,000. The EPA has reviewed the sea surface monitoring reports of UniSea, Alyeska Seafoods and Trident Seafoods to confirm that the discharges do not cause the formation of persistent foam on the receiving water. The EPA relies upon the permittee’s estimates of the costs of extending outfall pipes and upgrading pump pressure. The EPA has revised the permits to allow discharges of non-contact wastewaters at a height of three feet or less above high water.
Comment : Trident Seafoods comments that the sanitary wastewater outfall should have a mixing zone as described in the Fact Sheet. (Section I.I.2) Response : The EPA has revised the permit to incorporate ADEC’s specific authorization of a mixing zone.
Comment : Trident Seafoods comments that not all utilidors discharge at MLLW or deeper. It would like to continue its historic discharges through utilidors off the dock face approximately two feet above the sea surface. (Section I.F.4 1 

### or I.I.4 2 

### ) Response : The EPA recognizes the difficulty and expense of installing and extendingpipes for the concrete discharge raceways that exit the facility as open utilidors with bargrates. The EPA has revised the permits to require that non-contact wastewater outfalls discharge no more than three feet above high water.
Comment : Trident Seafoods comments that its ADEC C-Plan and US Coast Guard/US EPA Facility Response Plan specify that it call ADEC at (907) 269-3063 or (800) 478-9300 and call the Coast Guard’s National Response Center at (800) 424-8802 or the Dutch Harbor number of (907) 581-3466. The numbers given in the draft permit are the Juneau Office of the Coast Guard and the 800 number for ADEC. Both of these are good numbers for after-hours reports, but are less useful than the telephone numbers we have for reports during office hours. The 800 number given for ADEC is, in fact, a number manned by the Alaska State Troopers, and there will be a delay in the report to ADEC if this number is called. The draft permit should be revised to simply state that we should “immediately notify the U.S. Coast Guard and ADEC as is required in the facility’s “Oil Spill Response Plan.” (Section I.F.5 1 

### or I.I.5 2 

### )Response to Comments page 7 of 15



### Response : The EPA recognizes that telephone numbers can change and accepts the permittees’ suggestion that the permits simply state that the permittee shall immediately notify the U.S. Coast Guard and ADEC. The EPA has revised the permits to require notification of proper federal and state authorities as required in a facility’s “Oil Spill Response Plan.”
Comment : Trident Seafoods comments that the permit needs to include a statement clarifying that the BMP plan is not required to address the accidental discharge of petroleum products already regulated under the facility’s “Oil Spill Response Plan.” (Section II.A) Response : The EPA agrees that a facility’s “Oil Spill Response Plan” can be referenced in lieu of including this same text addressing petroleum hydrocarbons in the facility’s BMP plan, so long as the “Oil Spill Response Plan” is present and available at the facility. The EPA has revised the permits to provide for cross-referencing the “Oil Spill Response Plan” within a BMP plan.
Comment : Alyeska Seafoods, UniSea and Trident Seafoods comment that the effects of pH should be minimized rather than the pollutant itself and requests that EPA correct and clarify the condition. (Section II.A.1) Response : The EPA agrees that the language of the draft permits can be improved to clarify the intent to control the effect of the discharge of pH upon the receiving water quality. The EPA has revised the permits to eliminate pH from the list of pollutants to be minimized.
Comment : Alyeska Seafoods, UniSea and Trident Seafoods comment that the estimated discharge should not be calculated as the raw product minus the finished product when fish meal is one of the finished products in this calculation. The permittees request that the parenthetical explanation of the calculation be eliminated. (Section III.B.3.d-e) Response : The EPA agrees that the parenthetical explanation is inappropriate for seafood processing facilities with meal reduction capabilities. The EPA has revised the permits to eliminate the parenthetical explanation.
Comment : Alyeska Seafoods comments that discharges of seafood processing wastewater do not adversely affect the threatened Steller’s eider and requests the removal of all conditions pertaining to Steller’s eiders from the permit. (Sections III.B.4, IV.B.2.a(3), IV.B.2.c, IV.B.5 and Attachment A) Response : The FWS’ study of Steller’s eider distributions in Unalaska Bay has indicated that Steller’s eiders will leave the immediate vicinity of seafood processing outfalls whenResponse to Comments page 8 of 15



### effluent discharges commence and will return to these areas when the discharges end. It is the opinion of FWS biologists that Steller’s eiders are, at a minimum, displaced by active discharges of seafood processing effluents. Since the Alaskan population of Steller’s eiders is listed as a threatened species under the ESA, FWS has provided terms and conditions in its biological opinion pertaining to this federal permit action. The EPA has incorporated appropriate monitoring requirements and other conditions into the NPDES permits for seafood processors in Unalaska and Akutan, both of which have large documented over-wintering populations of Steller’s eiders. The EPA has determined that no change in the permits is necessary on the basis of this comment. The EPA notes that the permittees may negotiate with FWS to undertake independent study of the effect of seafood processing discharges on Steller’s eiders at their facilities in lieu of a FWS study.
Comment : UniSea, Alyeska Seafoods and Trident Seafoods comment that the draft permit requires that the dive survey include surveying the waste pile down to 1⁄2” in thickness. Upon consultation with the professional diver who services the seafood industry for dive surveys, he advised that this will result in erroneous waste pile size determinations. He advised that 10 cm (approximately four inches) is the pile thickness that will result in the estimation of waste pile size that is scientifically defensible. UniSea requests that the 1⁄2” thickness requirement be removed. (Section IV.A.1.a) Response : The purpose of the such seafloor monitoring is to assess the impact area within which deposition exceeds the AWQS for the deposition of residues (i.e., no deposit). The EPA believes that it is important to develop assessments of the area of seafloor that does not meet the State’s standard for residues. The permits therefore provide that the monitoring of waste deposits on the seafloor shall include an assessment of the areas of the waste pile that are (1) thicker than ten centimeters and (2) thicker than one-half inch. The lateral distance between the ten centimeter deposit and the one-half inch deposit may, in some depositional areas, extend from 10 to 30 radial feet, amounting to 30% or more of the total deposit of offal. This apron of thin deposition is more important in view of the increases in pollock processing demonstrated in Figures 1 and 2 (above). The EPA will maintain its requirement that the area of waste deposits shall be measured out to a depositional thickness of one-half inch in spite of the difficulty and uncertainty of this level of detection. The EPA has determined that no changes in the permit s are necessary on the basis of this comment.
Comment : Alyeska Seafoods comments that the seafloor monitoring program should be focused upon determining compliance with the area of deposition of residues rather than the thickness, volume and effects of the deposition. Monitoring of characteristics beyond the area of the waste pile significantly increases the expense of seafloor monitoring and, in particular, the observation and characterization of marine life extends beyond the ability of Alaska’s divers. Alyeska Seafoods requests that the requirement to measure the thickness and volume of the offal deposit and its effects on marine life be removed from the permit. (Section IV.A.2)Response to Comments page 9 of 15



### Response : The EPA has designed a seafloor monitoring program that measures the area of burial of the bottom, the volume of a waste pile of decomposing offal, the tapering of a waste pile at its periphery, and the gross effects of the decomposing offal on marine life in the seafloor adjacent to an offal waste pile. The EPA believes that understanding these aspects the piles of decomposing seafood processing waste residues is necessary in the application of the AWQS for residues which provides that there shall be no deposit of residues on the seafloor. The EPA also believes that understanding these aspects of seafood processing waste piles is valuable to environmental protection and that developing such estimations and elementary biological information is reasonable given the impact of offal waste piles on the marine environment. Alaska has technical divers who are capable of making informative observations of the limited number of large fish and invertebrates that are found on the seafloor around seafood processing outfalls; EPA expects its permittees to utilize technical divers in seafloor monitoring. Regardless of a diver’s ability to identify marine life to the genus or species level, all divers conducting a survey of seafood processing deposits can take identification-photographs of organisms observed on, above and around the deposit. The EPA has determined that no change in the permits is necessary on the basis of this comment.
Comment: Alyeska Seafoods comments that the purpose of seafloor monitoring is to determine the measure of their offal deposit’s compliance with a zone of deposit issued by the State. Please clarify if this compliance survey is for new deposition under the 2002 reissuance of the permit or inclusive of the total offal deposit, including historic waste piles from previously permitted discharges as well as the new deposition. (Section IV.A.2) Response : The ADEC has not authorized a zone of deposit for the discharge of seafood processing residues under these permits. Nonetheless, the permits require the survey of deposits of seafood processing waste residues discharged by a facility in support of the AWQS. Both government and commercial divers who monitor the deposition of offal on the seafloor indicate that it is difficult to precisely distinguish between discharges of settleable solids seafood processing wastes and seafloor sediments and between new and old screened offal discharges. Hence, the seafloor surveys required in the current permit reissuances do not provide for a distinction between new and old offal deposits. Permittees, however, may request that their divers make distinctions between new and old deposition of settleable solids seafood processing waste residues where possible and support their observations with a photographic record. The EPA has determined that no change in the permit is necessary on the basis of this comment
Comment : Alyeska Seafoods comments that bi-annual can be misunderstood to mean twice per year rather than every two years and suggests that the frequency of such monitoring be clarified as during the second and fourth year of the permit. (Section IV.A.2) Response : The EPA intends that the seafloor surveys of seafood processors that apply screening treatment to all of their seafood processing residue discharge shall conductResponse to Comments page 10 of 15



### surveys every other year. The EPA has revised the permits at Section IV.A.2 to clarify the frequency of seafloor monitoring.
Comment : Trident Seafoods comments that Trident personnel do not have the knowledge or ability to exercise oversight of the diver’s compliance with OSHA requirements. Trident would expose itself to significant liability if any accident could be attributed to an employee’s erroneous interpretation of the Occupational Safety and Health Administration’s (hereafter, “OSHA”) regulations. Trident should be required only to notify their divers that they need to meet OSHA safety requirements. (Section IV.A.4) Response : The EPA agrees that a seafood processor’s obligation to the safe conduct of its diver-based seafloor surveys is limited to notifying the divers that surveys at its facility must be conducted in accordance with the safety requirements specified for such work by OSHA. A seafood processor should meet this obligation by informing any contracted diver verbally, in writing and through the contractual agreement for services of his or her obligation to conduct seafloor surveys on behalf of the permittee and its facility in accordance with OSHA regulations for diving. The EPA has revised the permits to reflect the permittee’s obligation to notify its contracted divers of the need to comply with appropriate OSHA regulations.
Comment : Alyeska Seafoods comments that the requirement for an assessment of the far-field effects of the seafood processing waste discharges should be removed as there is no compliance basis for the measurement of organic enrichment around the outfall. What is the compliance benefit of knowing the sediment physicochemistry and structure, and the diversity and health of the infaunal community of the far-field area? Even if differences are found, there would be no way to determine the cause of these changes; whether caused by one processor or another, shore-based processors or processors anchored in the bay, or even by natural conditions. We request that the entire section pertaining to the study of far-field seafloor effects be removed from the permit. (Section IV.A.9) Response : The EPA notes that south Unalaska Bay and Akutan Harbor were included on the State of Alaska’s Clean Water Act § 303(d) list [hereafter, 303(d) list] of impaired water bodies and that assessments of total maximum daily load (hereafter, “TMDL”) were completed to provide a basis for the recovery of the water body. South Unalaska Bay and Akutan Harbor remain water bodies of concern meriting monitoring, in this case, of the effects of discharges of seafood processing residues from three of the state’s and the nation’s largest seafood processors. The far-field seafloor study is necessary to evaluate the potential effects of the settlement of seafood processing residues outside of the immediate vicinity of the outfall. The far-field seafloor study conducted to date has suggested that the seafloor may be affected at a distance of one-quarter mile and does not appear to be affected at a distance of one mile. Some of data collected at the intermediate stations was indeterminate due to lost samples and atypical station depths. This potential for far-field deposition and degradation is greater with the increases inResponse to Comments page 11 of 15



### pollock processing demonstrated in Figures 1 and 2 (above). The EPA looks to the forthcoming studies as further establishing the impacts of seafood processing discharges on the seafloor and its benthic communities beyond the visible edge of offal wastepiles. The EPA has determined that no changes in the permit s are necessary on the basis of these comments.
Comment : Trident Seafoods comments that there is no definition of the meaning of “during the facility’s operation and discharge.” One might assume that this would relate to only times of processing, as the former permit did, but since the sewage treatment plant and some of the non-contact condenser and cooling wastewater discharge 365 days a year, another interpretation might be that this monitoring should be done year-round. Clarify by specifying the discharge of “seafood waste.” (Section IV.B.2.a-b) Response : The EPA notes that the monitoring of the sea surface and shoreline is intended to insure that seafood processing residues do not collect on either the sea surface or shoreline. The EPA agrees that this intention can be clarified by establishing that such monitoring is limited to periods of seafood processing and concomitant discharge. The EPA has revised the permits to specify that sea surface and shoreline monitoring for residues is a requirement applicable only to those times when a permitted facility is processing
Comment : Alyeska Seafoods comments that there should be no required monitoring around its docks and piers as its seafood processing wastes are discharged only through Outfall 001 in south Unalaska Bay. (Section IV.B.2.a) Response : The EPA holds a permittee responsible for the discharge or spill of pollutants at a permitted facility that may violate the AWQS. In the case of seafood processing facilities, EPA is particularly concerned about the discharge of the floating, suspended, settleable and beached residues at its discharge outfall and adjacent its docks and piers. The EPA has therefore provided for monitoring of the sea surface and sea shore around a permitted seafood processing facility and its various discharge portals. The EPA has determined that no change in the permit s is necessary on the basis of this comment.
Comment : Alyeska Seafoods comments that monitoring frequency is listed twice in the condition pertaining to modification of the sea surface monitoring program and should be corrected for redundancy. (Section IV.B.7) Response : The EPA has revised the permits at Section IV.B.7 to eliminate redundancy and to clarify the condition.
Comment : Alyeska Seafoods comments that the AWQS applicable to south Unalaska Bay are “ coastal ” marine rather than “ estuarine ” marine and that the criterium for dissolved oxygen (hereafter, “D.O.”) should be 4 mg/L rather than 5 mg/L. (Section IV.C and IV.C.4)Response to Comments page 12 of 15



### Response : The AWQS for dissolved oxygen to protect the beneficial use of seafood processing in coastal marine waters below one meter depth is 5 mg/L D.O. The AWQS for estuarine marine waters is also 5 mg/L D.O. The criterion of 5 mg/L D.O. remains. However, EPA has found that its characterization of south Unalaska Bay as a fjord-type estuary has created unnecessary disagreement. The EPA has revised the permits to eliminate the characterization of the receiving waters as either estuarine or coastal marine waters.
Comment : Alyeska Seafoods requests that the sampling frequency for ambient water quality monitoring be changed from weekly to twice monthly. Of over 20,000 data points collected during the ambient water quality of the last five years, 100% of its measurements of ambient dissolved oxygen concentrations have been above 6 mg/L. This historic data suggests that water quality is being protected and that the expensive and time-consuming ambient monitoring should be reduced. Alyeska Seafoods notes that provision is made in the permit for an increase in the frequency of monitoring and that this could be tied to a specific threshold measurement, such as a D.O. level of less than 6 mg/L, for a reduction in the frequency of monitoring to every two weeks if the ambient D.O. level is 6 mg/L or greater. Response : EPA recognizes that ambient water quality monitoring is an expensive and time-consuming activity. Alyeska Seafoods’ and UniSea’s combined ambient water quality data for 1995-2001 indicate that more than 99.8% of the D.O. measurements for south Unalaska Bay meet or exceed the AWQS. The EPA agrees that the frequency of monitoring D.O. in the receiving water can be reduced to every other week. The EPA also believes that the level of monitoring can be reduced by decreasing the total number of monitoring stations within south Unalaska Bay. The EPA believes that the two major dischargers could collaborate to develop and conduct a single, integrated ambient water quality monitoring program that meets the requirements of each permittee’s NPDES permit. The EPA encourages UniSea and Alyeska Seafoods to work together towards this end and their mutual benefit. The EPA has revised the permits to provide appropriate changes in the ambient water quality monitoring programs of the facilities.
Comment: Alyeska Seafoods comments that the ambient water quality monitoring includes parameters listed as D.O., temperature, salinity, density, and depth. The purpose and objectives seek to study the effects of seafood processing on D.O. and temperature only. Alyeska Seafoods requests the removal of salinity and density from the measured parameters. (Section IV.C.1.b) Response : It is essential to determine the density structure of the water column if we are to understand the underlying basis for the distribution of D.O. concentrations in the receiving water. Temperature and salinity provide the basis for the density structure of the seawater and are therefore collected along with density. To the best of EPA’s knowledge, the modern field equipment available for monitoring water quality profiles is an instrumentResponse to Comments page 13 of 15



### array that measures the standard oceanographic parameters of temperature, salinity, density, depth and dissolved oxygen. The EPA has determined that no change in the permit is necessary on the basis of this comment.
Comment : UniSea comments that the draft permit requires that bay monitoring for exceedances in D.O. and temperature be reported. UniSea does not believe that it is possible to determine temperature exceedances since it is not possible to determine what the ambient temperature would normally be for every monitored location. (Section IV.C.1.c) Response : The EPA agrees that it is inappropriate to require the permittee to interpret its ambient temperature monitoring data in the context of the AWQS that is presented as a weekly average temperature and a maximum hourly rate of change in temperature. It is sufficient that the permittees monitor, record and report the data. The EPA has revised the permits to eliminate the reporting of noncompliance with the AWQS for temperature.
Comment : Alyeska Seafoods, Trident Seafoods and UniSea comment that the requirement for a four-week summer study and a one-week winter study of “potential” temperature effects of non-contact cooling water discharges is unnecessary. It is unlikely that the discharge will violate temperature limitations outside of the mixing zone. (Section IV.C.2.b) Response : EPA agrees that a summer study of the potential temperature effects of the non-contact cooling water discharge should be sufficient to demonstrate the extent of its effect on the receiving water. Alyeska Seafoods, Trident Seafoods-Akutan, and UniSea conducted temperature effect studies of non-contact cooling water discharges and reported negligible effects on the receiving waters at distances greater than 30 ft from the outfalls, well within the mixing zones authorized by ADEC. The EPA has revised the permits to eliminate the ambient monitoring of non-contact cooling water discharges.
Comment : Alyeska Seafoods and UniSea comment that an annual petroleum spill summary report is not appropriate for their facilities because there is no refueling conducted at their dock or piers and requests that the requirement be removed from the permits. (Section IV.D) Response : The EPA agrees that the daily monitoring of refueling activities and potential spills is unnecessary at a seafood processor which does not refuel vessels at its facility and does not allow private vendors to refuel vessels at its facility. The EPA does hold a permitted seafood processing facility responsible for reporting oil spills in waters belonging to the citizens of the State of Alaska that are adjacent to the facility and that occur in association with the operation of a vessel which is approaching, secured to, or leaving the facility. The EPA has revised the Alyeska Seafoods and UniSea permit s to require the monitoring of petroleum sheens and spills occurring adjacent to a permittedResponse to Comments page 14 of 15



### seafood processing facility in association with vessels that are either in the process of docking or are moored at the facility.
Comment : Alyeska Seafoods comments that the references to ambient sediment monitoring and sediment compositing are unclear and requests that these requirements be removed from the permit. (Section V.B.2.c) Response : The EPA agrees that the language of the requirement is unclear. EPA has revised the permit s to require that the QAP specify procedures combine sediment samples as composite samples in a case where compositing occurs.
Comment : Trident Seafoods comments that it should not have to notify EPA and ADEC of any changes to the processing line unless such changes would result in an increase in the level of pollutants discharged. (Section VII.H) Response : The EPA is concerned with the nature, amount and location of all discharges at the facility; it is also concerned with process changes as they affect such discharges. The EPA has determined that no change in the permit is necessary on the basis of this comment.
Comment : Alyeska Seafoods comments that there is no reason to believe that there may be adverse effects by seafood processing wastewater on or to collect information on threatened and endangered species around the discharges of this wastewater. Alyeska Seafoods requests that all permit conditions pertaining to threatened or endangered species be removed. (Attachment A and Sections IV.B.1, IV.B.2.a(3), IV.B.2.c, and IV.B.5) Response : The FWS has observed that Steller’s eiders avoid active discharges of seafood processing wastes. In other parts of Alaska, FWS and tribal biologists have observed and verified that sea otters are attracted to and feed on seafood processing wastes discharges, and that some of these sea otters become sick and die as a consequence of these discharges. Scientists, seamen and citizens alike have observed that Steller sea lions are attracted to both seafood processing discharges and discards of seafood and seafood offal from vessels. The EPA agrees with other interested agencies and citizens that it is valuable to record general observations of the interactions of marine species listed as threatened and endangered with seafood processing wastes. The EPA has determined that no change in the permits is necessary on the basis of this comment.
Comment : Trident Seafoods objects to the requirement to the seabird monitoring requirements. Though field observations of endangered species in remote locations may appear to have merit on paper, the reality is that species-identifications by non-specialists would be nearly worthless. There are at least 158 species of birds that could be called seabirds (including eagles) in the Southwestern Alaskan region, and 74 of these species are identified as commonly found. Differences in coloration due to sex, stage of life, or breeding cycle can cause confusion even for experts. We believe that this requirementResponse to Comments page 15 of 15



### would require considerable time and expense and produce questionable data. (Attachment A, condition 3) Response : The EPA understands the permittee’s concerns regarding the amount of time and effort and the degree of expertise required to conduct a meaningful survey of Steller’s eiders and other sea ducks and sea birds. In consideration of the difficulty in identifying sea birds as to type from a distance, EPA has revised the permit to limit the extent of the weekly survey to within a 300 ft radius of the facility and its outfalls. The permits require a weekly survey that should take no more than one hour per week for a total of no more than 52 hours per year. Considering that this seabird survey can be conducted in conjunction with other monitoring of the sea surface and shoreline, EPA finds no reasonable basis for eliminating a permit condition developed by the FWS pursuant to its authority under ESA.
Comment : Alyeska Seafoods and UniSea comment that some conditions of Attachment A are not appropriate since their facilities doesn’t refuel fishing vessels; these vessels refuel at the docks of one of the several fuel suppliers in the area. These conditions should be removed. (Attachment A, conditions 3, 5 and 6) Response : Under the condition that refueling does not occur at the Alyeska Seafoods and UniSea seafood processing facilities, EPA agrees that conditions 3, 5 and 6 of Attachment A do not apply to these permitted facilities. The EPA has revised the Alyeska Seafoods and UniSea permit s to prohibit refueling of vessels at this facility and to eliminate the conditions in Attachment A that pertain to refueling at the permitted facility.
Comment : UniSea, Alyeska Seafoods and Trident Seafoods comment that condition 4 of Attachment A, requiring the contribution of $5,000/yr toward a study of the spatial effects of seafood processing effluent plumes on the distribution of Steller’s eiders, is arbitrary, capricious, and inappropriate and should be removed from the permit. The ADEC does not believe that requiring funds from the permittees for additional studies beyond the observations of Steller’s eiders and Steller sea lions in the sea surface monitoring is within the scope of NPDES permits. (Attachment A, condition 4) Response : The EPA has revised the Alyeska Seafoods and UniSea permit s to eliminate the requirement that each facility contribute to the study of the effects of their pollution discharges on Steller’s eiders.