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RESPONSE TO COMMENTS

General NPDES Permit for Seafood Processors

Operating Shorebased Facilities in Kodiak, Alaska

Public Comments were Received from the Following:

1 Alaska, Department of Fish and Game, Habitat and Restoration Division: C. Wayne Dolezal,

Habitat Biologist, Region II.

2. Kodiak Fishmeal Company: John T. Sullivan, President.

3. Kodiak Island Borough: Linda L. Freed, Director, Community Development Department.

4. Ocean Beauty Seafoods, Inc: Jim Yonker, Director, Corporate Quality Assurance.

5. Western Alaska Fisheries, Inc: Robert J. Thomas, Corporate Secretary.

General Comment

Kodiak Island Borough: Conceptually the Borough supports the issuance of general permits as a

method of reducing paperwork, time and expense by permittees, permitting agencies, reviewing

agencies and the public. Specifically, the Borough supports the issues of this permit since there appears

to be no reduction in regulatory oversight that might result in environmental degradation and reduces

the administrative burden associated with individual permit reviews. The Borough also relies on Alaska

Department of Environmental Conservation to insure that the technical aspects of the permit are

consistent with state water quality standards.

Ocean Dumping Site

Comment: Alaska Department of Fish and Game (ADF&G) commented that Section 3.5 while

mentioning the ocean dumping site, the site is not defined and a map was not included in the draft

permit. ADF&G also recommended that solid wastes disposed of in the ocean dumping site be ground

to 0.5 inch particle size prior to discharge to avoid the potential for creation of zones of deposit.

Response: A map of the ocean dumping site has been included in the final permit under Section 11.3

and a definition of “ocean dumping site” has been included in the definition portion of the permit in

Section 10. Also in Part 3.5, Waste Disposal Practice, a requirement that solid seafood processing

wastes to be disposed of in the ocean dumping site shall be ground to 0.5 inch particle size prior to

discharge.

Comment: Kodiak Fishmeal Company (KFC) commented that Section 3.5 prohibits the ocean dumping

except if the waste is unsuitable for processing at a by-product recovery facility. KFC proposes that
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Section 3.5 be modified to permit individual permittees to ocean dump if KFC is incapable of

transporting the excess fish waste to the ocean dumping site.

Western Alaska Fisheries also commented on Section 3.5 and stated that they would prefer having the

option to transport excess fish waste to ocean dumping site themselves.

Response: The final permit includes a new section allowing individual permittees to transport solid

seafood wastes to the ocean dumping site upon notification and approval of EPA and ADEC. The

processing wastes must be ground to 0.5 inch particle size prior to dumping and logs (as described in

Section 3.5.3) must be submitted with the monthly reports.

Grinding before Screening

Comment: KFC and Western Alaska Seafoods both stated that when KFC exceeds its capacity and is

not able to transport all of the fish wastes to the ocean dumping site, then the individual permittees need

to be able to grind the solid fish wastes before screening and transport to the ocean dumping site.

Response: Section 3.1 prohibits grinding before screening. This provision is in the permit for the

benefit of the permittees. Grinding before screening has the potential of exceeding the permit 

butchering limitations because the smaller size waste solids may go through the screens. However, in

the situation where a permittee does not have the capability of grinding after the screens and must also

transport its own solid wastes to the dumping site, grinding before screening will be allowed; this

information must be included in the notification to EPA and ADEC. Also if the grinding before

screening results in permit limitation exceedances, then the permittee must report in accordance with the

noncompliance reporting requirements in Sections 7.1.1 and 7.1.2. Visual monitoring during the period

of grinding before screening will need to be extra diligent to assure that floating solids and shoreline

accumulations do not occur.

Individual Waste Stream Flow Monitoring

Comment: Ocean Beauty commented on Section 3.2.3 which required flow measurement of the surimi

waste stream. Ocean Beauty believes that this restricts plants that do not have the physical capabilities

to monitor the water used for surimi processing only.

Response: The permit requires flow measurement of each waste stream because it is necessary to know

the flow in order to calculate the quantity of pollutants discharged into the receiving water. It is EPA’s

understanding that flow measurements in the Kodiak plants have been estimated in the past rather than

using the total 24-hour water usage measured by the city flow meters. The final permit will allow

permittees to propose a method to estimate the flow used in individual waste streams where there is no

dedicated flow meter. The explanation as to how the flow is estimated is required shall the first monthly

report submitted after the permit is effective or when the estimated flow is initiated. The sample type

column on the DMR should also be filled out to show that the reported flow value is estimated.