### United States Environmental Protection Agency

Office of Wastewater Management Washington, DC 20460



# Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharge

EPA ‐ 800

‐ R

‐ 11

‐ 005
November 2011Fish Hold Effluent and Fish Hold Cl eaning Wastewater Discharges CONTENTS

i CONTENTS

Page

E XECUTIVE S UMMARY

.................................................................................................................... III

S ECTION 1 I NTRODUCTION ............................................................................................................... 1

S ECTION 2 F ISHING V ESSEL T YPES

, F ISHERIES

, G EOGRAPHIC D ISTRIBUTION

, AND F ISH
H OLD D ISCHARGE P RACTICES ............................................................................................. 3

2.1 Lobster/Crabber ...................................................................................................... 3

2.2 Scallop Dredge ........................................................................................................ 4

2.3 Fish Tender ............................................................................................................. 4

2.4 Gillnetter ................................................................................................................. 5

2.5 Longliner ................................................................................................................. 5

2.6 Purse Seiner ............................................................................................................ 6

2.7 Trawler .................................................................................................................... 6

2.8 Troller ..................................................................................................................... 6

S ECTION 3 W ATER Q UALITY C HARACTERISTICS OF F ISH H OLD E FFLUENT AND F ISH H OLD
C LEANING W ASTEWATER .................................................................................................... 8

S ECTION 4 V OLUMES AND R ATES OF D ISCHARGE OF F ISH H OLD E FFLUENT AND F ISH H OLD
C LEANING W ASTEWATER .................................................................................................. 10

S ECTION 5 W ASTE D ISPOSAL P RACTICES FOR F ISH H OLD E FFLUENT ............................................ 12

S ECTION 6 E STIMATED C OST OF F ISH H OLD E FFLUENT AND F ISH H OLD C LEANING
W ASTEWATER W ASTE T REATMENT AND D ISPOSAL .......................................................... 14

S ECTION 7 R EFERENCES ................................................................................................................. 15

Attachment A: Summaries of Informa tion Gathered In Telephone ConversationsFish Hold Effluent and Fish Hold Cl eaning Wastewater Discharges CONTENTS

ii LIST OF TABLES

Table 1. Fish Hold Storage and Discharge Practices .....................................................................11

Table 2. 2007 Fish Hold Effluent Treatment and Disposal Costs .................................................14

The EPA technical contacts for this document are Robin Danesi (202) 564-1846 and Ryan Albert (202) 564-0763.Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Executive Summary

iii 

## EXECUTIVE SUMMARY

Commercial fishermen store the fish and shel lfish they catch in some form of chilled condition on board their fishing ve ssels, to keep their catch fresh until delivery to an onshore seafood processor

. Most seafood is either dead when brought onboard or is killed shortly thereafter, before being stored in a refrigerated seawater ho lding tank, with the exception of certain shellfish (e.g., crab, lobster), which must be kept alive. The two most common methods of cooling seawater are by mechan ical refrigeration or by adding ice (or ice slurry or ice chips). In general, refrigerated seawater (RSW) systems are used aboard purse se iners, tenders and some trawlers, while ice is used aboard gillnetters, longliners, trollers and some trawlers. Other vessels (e.g., large shrimping vessels in the Gulf of Mexico) use dry fr eezers to preserve their catches,

while lobster and crab boats have seawater flow -through tanks used to keep their catch alive.

Fish hold effluent includes RS W, ice and melted ice that remains in the fish hold after the catch has been off-loaded at the seafood processo r. The water that is drained as the ice melts during the fishing expedition is al so considered to be fish hold effluent. Common practice aboard commercial fishing vessels is to discharge th e fish hold effluent overboard immediately following off-loading of the catch at the onshore seafood processor. Following evacuation of the catch, the fish hold may be cleaned; any fish hold cleaning wastewaters are also discharged

overboard. The fish hold effluent and fish hold cleaning wastewater are discharged in the water body adjacent to the vessel, with only a few ex ceptions. At least one port was identified that captures fish hold effluent along with dock and pier runoff and tr ansports it into the municipal

sewer system.

The water quality characteristics of fish hold effluent reflect contri butions from various

sources: vessel and fish hold ma terials and coatings, ambient wa ter, potable/service water, and the seafood product itself. EPA collected fish hold effluent discharge samples from 31 commercial fishing vessels, and fi sh hold cleaning discharge samp les from 9 vessels for their Study of Discharges Incidental to Normal Opera tion of Commercial Fishing Vessels and Other NonRecreational Vessels Less Than 79 Feet (USEPA, 2010). Elevated con centrations of certain total and dissolved metals, as well as many of other po llutants, were measured in fish hold effluent and fish hold cleaning wastewater. Elevated me tals concentrations were found for total iron, dissolved and total copper, total arsenic, dissolv ed zinc and selenium. BOD, TSS, turbidity, and nutrient parameters (NH3-N, TKN, and TP) were found at elevated concen trations that were often higher than those typical ly found in domestic sewage.

The volume of fish hold effluent discharged by a fishing vessel depends on the size of the vessel, the number of fish holds and their volumes, the method used for keeping the catch fresh (RSW, ice, etc.) and the frequency at which the catch is off-loaded. These discharges are not continuous, but occur periodically when the fish ing vessel is in opera tion during the fishing season. Fish hold cleaning wastewater discharges also occur on a periodic basis; however, the volumes are considerably smaller.

To date there has been little regulation of fish hold effluent discharges. Discharges “incidental to the normal operation of a vessel” were excluded from the National Pollutant Discharge Elimination System (NPDES; 40 CFR 122.3) . That exclusion did not apply when theFish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Executive Summary

iv discharges were due to operation of the vesse l “in a capacity other than as a means of transportation . . . such as when used as . . . a seafood processing facility.” Of five states with significant commercial fishing in dustries surveyed, only one (V irginia) was found to have a NPDES permit for fishing vessel operations.

Although the most common practice for commercia l fishing vessels is to discharge their

fish hold effluent and fish hold cleaning wastewater overboard afte r unloading their catch in port,

transfer of these effluents ashore for treatment and disposal may be a practical alternative for managing these wastes. This practice was en countered in two locations: San Francisco, California and Sitka, Alaska. Using average fish hold effluent BOD and TSS concentrations and average rates for industrial users of municipal wastewater treatm ent plants (WWTPs), the cost for sewage treatment and disposal of fish hold effluent was estimated to be $5.02 /1,000 gallons.Fish Hold Effluent and Fish Hold Clea ning Wastewater Discharges Section 1 - Introduction

1 

## SECTION 1

INTRODUCTION

This document addresses fish hold effluent and fish hold cleaning wastewater, two common discharges from commer cial fishing vessels. Commercia l fishing vessels are vessels that commercially engage in the catching, taking, or harvesting of fish and shellfish or an activity that can reasonably be expected to result in the catching, taking, or harvesting of fish and shellfish. Commercial fishing vessels include any vessels harvesting fish, crab, lobster, shrimp, or other aquatic organism s for commercial sale.

Commercial fishermen store the fish they catch in some form of chilled condition on board their fishing vessels, to keep their catch fresh until delivery to a seafood processor

. Most seafood is either dead when brought onboard or is k illed shortly thereafter, before being stored in a refrigerated seawater holding tank, with the ex ception of certain shellf ish (e.g., crab, lobster), which must be kept alive. The two most common methods of cooling seawater are by mechanical refrigeration or by adding ice (or ice slurry or ic e chips). In general, refr igerated seawater (RSW) systems are used aboard purse seiners, tenders and some trawlers, while ice is used aboard gillnetters, longliners, trollers and some othe r trawlers. Other vessels (e.g., large shrimping vessels in the Gulf of Mexico) use dry freezers to preserve their catches, while lobster and crab boats have seawater flow-through tanks used to keep their catch alive.

Commercial fishing vessels may employ vari ous methods of colle ction including nets, trawls, traps, or hook-and-line to capture the target spec ies. The major classes of fishing vessels are differentiated by fisheries, ge ographic distribution, and how the fi sh are stored onboard ships.

Fish hold effluent and fish hold cleaning wastewater discharge practices vary according to these differences. The type of fish usually determ ines both the method of onboard storage and the process by which catch is removed from fish holds when the vessel returns to port, as discussed in the following section of this document.

For vessels with refrigerated seawater tanks, the catch is typically extracted from fish holds by pumping the fish and the accompanying RSW out of the hold, of ten with the use of

additional ambient water called bail water. Th e RSW and bail water is often captured and

recirculated back to the hold a nd pumped multiple times, until all fish have been removed from the fish hold. Any excess RSW or ba il water that is not required to assist in fish extraction is pumped overboard pierside. Vessels that use chipped or slurry ice generally remove the seafood and then discharge the spent ice overboard pierside. Occasionally, ve ssels that store their catch in ice slurry also use vacuum filtration systems (e.g., some shrimping boats in the Gulf of Mexico).

Tanks used to keep lobster and crab catch alive, pump surrounding water into the tank continuously to maintain the highest water qualit y possible. The flow rate through these systems results in a constant discharge of fish hold e ffluent. Because the majority of the seafood product remains alive, there is little bi ological decay or degradation in the tank. Furthermore, because these tanks have reasonably rapid flushing times and a continuous discharge, there is a little accumulation of pollutants.Fish Hold Effluent and Fish Hold Clea ning Wastewater Discharges Section 1 - Introduction

2 Fish hold effluent includes RS W, ice and melted ice that remains in the fish hold after the

catch has been off-loaded. The water that is drai ned as the ice melts during the fishing expedition

is also considered to be fish hold effluent. Standard practice for disposal of fish hold effluent aboard commercial fishing vessels is to discharg e the fish hold effluent overboard immediately following off-loading at the seafood processor.

Fish holds are also often clean ed or disinfected by vessel cr ews between catches. All fish holds are evacuated (i.e., comple tely emptied) for cleaning. To rinse the fish hold tank, vessel crews use either municipal water from the pier or dock or they pump water from the surrounding ambient water. Cleaning may simp ly involve rinsing the tanks with this water, or crews sometimes add detergents or disinfectants. Crews also often use scrub brushes to clean the walls

and floor of the fish hold to maximize the re moval of organic material. Fish hold cleaning

wastewater is a combination of residual fish hold water and ambient or municipal water and often contains soaps or detergents.

The fish hold water, bail water (including bail water that is transferred with the catch to the docks of most off-loading facilities), melte d ice and/or fish hold cleaning wastewaters are typically discharged in the adjacent water body, with only a few exceptions. Two ports (San Francisco, California and Sitka, Alaska) were id entified that had methods of capturing fish hold effluent for treatment and disposal. San Francisc o’s Pier 45 conveys the fish hold effluent along with dock and pier runoff into the municipal sewer system. Some fish processing facilities, such

as the Sitka Seafood Processors Co -op, may collect the fish hold effl uent and treat it. However, most ports and processing facilities are not eq uipped to capture the high volume of water

contained in fish holds. Over board fish hold effluent and fish hold cleaning wastewater discharges are not currently regulat ed by EPA in the current VGP.Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 2 - Fishing Vessel Types, Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

3 

## SECTION 2 FISHING VESSEL TYPES, FISHERIES, GEOGRAPHIC DISTRIBUTION, AND FISH HO LD DISCHARGE PRACTICES

Commercial fishing vessels may employ vari ous methods of colle ction including nets, trawls, traps, or hook-and-line to capture the target sp ecies. This section describes the major classes of fishing vessels, including how they vary according to different fisheries and geographic distribution. It also di scusses how the fish are stored aboard ship, and how fish hold discharge practices vary according to these differences.

Approximately 70,000 commercial fi shing vessels operate in US waters, representing the largest category of vessels in the Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial Fishing Vessels and Other Non-Recreational Vessels Less Than 79 Feet (USEPA, 2010)

. The majority of commercial fishing ve ssels are relatively small compared to

other nonrecreational vessels such as barges or utility vessels, with 56 percent of commercial fishing vessels in the 26- to 50-foot range (USEPA, 2010).

In any geographic region, commercial fish ing is a highly dive rse industry. Based on personal communication with a representative of United Fishermen of Alaska, Alaska has approximately 10,000 active fishing ve ssels ranging in size from 7 f eet to 635 feet and including skiffs, gillnetters, purse seiners, trawlers, crabbi ng vessels, tenders, and trollers (see Attachment A). Of these vessels, many are equipped to fish several different species throughout the year by modifying their gear type. Gear type modification mainly involves changing deck equipment and other machinery. Almost all purse seiners, te nders, and crabbing vessels have RSW systems,

while hook and line and set-net ve ssels use ice tanks. A vessel w ith an installed RSW system

would not use the tanks as ice tanks even if their gear type changed.

2.1 L OBSTER /C RABBER

Lobster and crab (Dungeness, King, Tanner, a nd Blue) boats target their catch using twine or wire-meshed steel pots (traps). Baited po ts are left to “soak” for up to several days before retrieval. Lobster pot vessels are typical ly found in southern Ca lifornia and in the New England coastal states from Maine to Rhode Islan d. In southern California, the spiny lobster is the primary target species, while in New Engla nd the American lobster is the primary target. Lobster and crab boats vary in shape size and range from aluminum skiffs with outboard motors that fish the inside waters, to s eagoing vessels 100 or more feet in length that fish the Bering Sea and the Gulf of Alaska for king crab (U SEPA, 2010). During the 2010 Study of vessel discharges, EPA observed lobster boats with fl ow-through tanks that pump ambient sea water into the lobster tanks, and then discharged directly overboard. Flow-through tanks are used to keep lobsters alive until the lobster boat reaches the seafood processing facility.

Crab boats that fish the in-s hore waters along the East Coast and Gulf Coast range in size from approximately 24 feet to 40 feet. The Chesapeake Bay, North Carolina and Louisiana coasts support the largest blue crab fisherie s (SCDNR, 2010). Commercial fishing methods for blue crabs include crab pots and trot lines. Blue crab s are placed in a ventilated container (e.g., bushel basket) with a moist cloth covering the top, rather than in water which can suffocate blueFish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 2 – Fishing Vessel Types, Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

4 crabs when oxygen levels drop. Since blue crabs are placed in ventilated cont ainers rather than a tank of water, no effluents are disc harged from these fishing vessels.

Vessels catching Dungeness, king and snow cr abs are typically be tween 50 feet and 150 feet in length and are larger than crab boats used along the East Coast and Gulf Coast for catching blue crabs. Dungeness crabs exist in co mmercial quantities from Alaska to south of San Francisco, California. Along the Pacific coast, Dunge ness crabs live in the inte rtidal zone out to a depth of 170 meters. Dungeness crabs are stored a live in holds on boats that are filled with recirculating sea water and are delivered every few days to seafood processing plants. Once the catch is off-loaded at the processing plants, any remaining seawater in the tanks is discharged overboard pierside. King and Snow crabs are found in the waters off the Alaskan coast such as the Bering Sea. Like Dungeness crabs, King and S now crabs are stored alive in holds on boats that are filled with re-circulating sea water unt il they can be delivered to the seafood processing plant. Water in the tanks is discharged overboard as the catch is off-loaded at the processing plant.

2.2 S CALLOP D REDGE

A scallop dredge or oyster dredge, is a dre dge which is towed along the bottom of the sea by a fishing boat to collect scall ops, oysters, clams, crabs, and in some cases, sea cucumbers. Dredge boats used to collect cl ams, oysters, and crabs in near-s hore estuarine waters range from 24 feet to 50 feet long. Offshore dredge boats used to collect sea scallops can be as large as 190 feet long (USEPA, 2010). The largest wild sc allop fishery is the Atlantic sea scallop ( Placopecten magellanicus ) fishery found off the shores of the northeastern United States and eastern Canada; however, scallops are harvested along all United Stat es coastal areas as far north as Alaska. Some scallop dredging boasts process and freeze scallops at sea, while others have RSW holding tanks that off-load fresh scallops at a shore-side processing facility. Fish hold

effluent and fish hold clea ning wastewater is discharg ed overboard at the pier.

2.3 F ISH T ENDER

A fish tender vessel supports fishing vessels by providing supplies, fish products or other materials, and additional refrigerating space; stor ing the catch; and tran sporting the catch from the fishing vessels to the fish processing facilit y. During specific fishing seasons, fish tenders can also be fitted into a crabbing vessel. Fish tenders range in size from 50 to 130 feet in length. In southeast Alaska, fish tende rs are typically used to transfer chum salmon ( Oncorhynchus keta ) from offshore fishing boats to the shore-side fish processing facil ity. Fish tenders are often large vessels with large fish holds filled with RSW. In Alaska, fish and RSW are pumped into the seafood processing facility where fish are colle cted into tanks for further processing and a portion of the RSW is returned to the vessel to co ntinue the fish removal process. The remaining portion of the RSW is discharged to ambient wa ter pierside. Ultimately, all the RSW from the vessel is discharged in this manner along with any fish hold cleaning wastewater.

Due to the large size of these tender vessels , the fish hold cleani ng process lasts much longer than for other vessels. The tanks are generally rinsed and then filled with water and a mild detergent. The solution is then allowed to circul ate in the tank system for several hours before the fish hold cleaning wastewat er is discharged pierside.Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 2 – Fishing Vessel Types, Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

5 2.4 G ILLNETTER

Gillnetters catch a variety of fish, such as salmon and herring, by setting curtain-like nets perpendicular to the direction in which the fish are traveling as they migrate along the coast

toward their natal streams. Gill netting is performed in nearly all coastal waters of the United States, including the Great Lakes (MDNRE, 2010). Nets can be set in place, such as at or near the mouths of rivers, or allowed to drift freely in deep water. Gillnet vessels are usually 30 to 40 feet long and are easily recognized by the drum on either the bow or the stern on which the net is rolled (ADFG, 2008). Fish caught by gillnetters are dead when pulled aboard. Gillnetters typically gut the fish on-board, and then place the gutted fish in a hold filled with wet ice. In southeast Alaska, the wet ice is discharged overboard at the pi er after the fish have been unloaded at the seafood processor. Any wastewat er generated by fish hold cleaning is also discharged overboard at the pier.

2.5 L ONGLINER

Longliners catch fish (primarily halibut, bl ack cod, swordfish, tuna and shark) via a longline that is either laid on the bottom or su spended in the water colu mn. Long line fishing is conducted in nearly all coasta l areas of the United States (NJDA, 2010; NMFA, 2010). Each longline can be up to a mile in length and ha ve thousands of baited hooks. A longline vessel typically sets several lines for a 24 hour “soak.” Fish brought aboard long -line boats are either cleaned immediately or placed in ice in the vessels’ hold until they reach the seafood processing plant. Based on personal communication with Alaskan Longline Fishermen’s Association, almost all longliners do some amount of fish pr ocessing immediately after the fish are caught. This can includes gutting, bleeding, heading or cleaning the fish be fore stowing them into their fish holds (see Attachment A).

Longliners are typically 50 to 100 feet in le ngth (USEPA, 2010). The vast majority of longliners have fish hold tanks th at are filled with clean ice pr ior to fishing. As the tanks are filled with fish and the ice melts, any water is automatically pumped out of these tanks via the bilge pump. In southeast Alaska, the remaining i ce from the fish hold is discharged overboard, usually pierside at the seafood pr ocessor. The tanks stay relativel y clean due to the use of ice. Based on personal communication with Alaskan Longline Fishermen’s Association, some longliners clean their fish holds between each off- load (see Attachment A) while others add fresh ice to the tanks before leaving on another fishing trip and clean th eir fish holds periodically. The tanks are pressure washed with water; dish soap, biodegradable detergents, or a very mild bleach

solution is added when needed. The wastewater fr om pressure washing is discharged directly

overboard.

Based on personal communication with West ern Fishboat Owners Association, some longliners that fish for tuna in the Pacific O cean use dry blast freezing systems (see Attachment A). These dry blast vessels are similar to the trollers in the Gulf Coast used to catch shrimp in that they have no fish hold discharges but do oc casionally need to be cleaned between seasons. The fish are caught and immediatel y frozen whole, with no pro cessing on board the vessels. The

reason for this is that tuna te nd to be very clean fish and th e tuna industry prefers that all processing to be done at the processing plant clos est to where the fish is ultimately consumed. The cleaning of the fish hold aboa rd these vessels is similar to defrosting a refrigerator, and anyFish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 2 – Fishing Vessel Types, Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

6 water or condensation is discharg ed overboard. The tuna season gene rally lasts from June to late October, but there is some amount of fishing o ccurring in American Samoa during other parts of the year.

2.6 P URSE S EINER

Purse seiners catch fish that school close to the surface, such as salmon, herring, and sardines, by encircling them with a long net and drawing (pursing) the bottom closed to capture the fish. Purse seiners are used in Alaska pr imarily for salmon, while in New England and along the Gulf Coast, purse seiners are used to captu re species such as menhaden (Smith, 1991). Purse

seiner vessels in Alaska are limited to a maxi mum length of 58 feet (ADFG, 2010) to control the salmon harvest, while purse seine vessels in New England targeting me nhaden generally range from 140 to 170 feet in length (Smith, 1991). Fish caught on purse seiners are normally placed in

a RSW fish hold and are off-loaded at the seafood processing facility. Refrigerated sea water is pumped to the seafood processing facility along w ith the fish during off-loading. A portion of the

water is returned to the vessel to assist in additional fish off-loading, while the remaining water is discharged pierside. Ultimately, all of the fish hold effluent is discharged once the fish have been off-loaded. Fish holds aboard purse seiner s are cleaned by filling the tanks with water and a mild detergent and allowing it to circulate for some time before the water is discharged pierside.

2.7 T RAWLER

Trawlers, also called draggers, typically catch large quantities of mid-water species, such as pollock or pink shrimp, and bottom-fish, such as flounder, by towing a large, cone-shaped net. Trawlers are common in the New England fishery fo r bottom fish, and in the Gulf of Mexico for shrimp. Trawlers also operate along the Pacifi c Coast from California to Alaska, targeting sablefish and longspine a nd shortspine thornyheads ( Sebastolobus altivelis and Sebastolobus

alascanus ). Dover sole is generally ca ptured using deep water trawls while rockfish is caught

with midwater and bottom trawls (Gilden, 1999). Alaskan trawlers target mackerel and Pacific cod in the Bearing Sea. Trawlers range in size from small shrimp trawlers to large, 600-foot

ocean Pollock and Pacific Cod trawlers that possess onboard processing facilities (USEPA, 2010). Trawlers can either store fi sh in ice-filled hold tanks, or RSW tanks, or process, package and freeze the fish on board. As an example, a 160-foot trawler available for purchase in the

northeastern United States has four RSW tanks with a 250-ton capacity and a freezer hold that can accommodate 400,000 lbs of squid in bags ; 218,000 lbs. of mackerel (8,400 cases); or 292,000 lbs. of herring (8,400 cases). Tr awlers that preserve fish us ing wet ice or RSW discharge

the ice/water overboard when the catch is off-loaded at the se afood processing facility. Any fish hold cleaning wastewater would al so be discharged at the pier. Those that process, package and

freeze fish on board do not have a wastewater disc harge from the fish-hold. These vessels would, however, discharge wash-down waters from decks and fish processing areas.

2.8 T ROLLER

Troll vessels catch fish such as salmon and tuna by “trolling” bait or lures on lines through feeding concentrations of fish. Commercial troll fishing is conducted in Alaska primarily for salmon, while commercial troll fishing in the northeastern United States targets species such as tuna and mahi-mahi. Trolling vessels vary in size and configurati on, ranging from small,Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 2 – Fishing Vessel Types, Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

7 hand-trolling skiffs to large, ocean-going power trolling vessels of 50 feet or more in length. Troll fish are gutted after being ca ught and placed in a fish hold containing wet ice. In Alaska, the majority of the wet ice and fish hold cleaning effluent is discharged overboard after the catch

is off-loaded.Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 3 - Water Quality

Characteristics of Fish Hold Effluent and Fish Hold Cleaning Wastewater

8 

## SECTION 3 WATER QUALITY CHARACTERISTICS OF FISH HOLD

EFFLUENT AND FISH HOLD CLEANING WASTEWATER

The water quality characteristics of fish hol d effluent and fish hol d cleaning wastewater

reflect contributions from vari ous sources: vessel and fish hold materials and coatings, ambient water, potable/service water, a nd the seafood product itself (USEPA , 2010). If the seafood is not frozen, but preserved in RSW or ice slurry, small quantities of organic material from the catch (e.g., lipids, protein) will be released as the fish degrade, th ereby increasing the concentration of these constituents in the discharge. Furthermor e, different volumes of blood, mucus, and other matter can drain from the seafood into the hold, depending on how the fish is cleaned on deck. For example, salmon, when caught via gillnets on gillnetting vessels, are cut at the gills and bled and then placed into the fish hold with RSW or ice before being clea ned (USEPA, 2010). This results in their internal organs and some blood leaking into the water. In contrast, salmon caught

on trollers are cleaned while the fi shing vessel is still at sea and th e internal organs are discarded into the surrounding waters. Hence, on the salmon trollers, the organs an d most of the residual

blood are not in contact with RS W or ice and consequently, lowe r quantities of these materials are discharged when the vessel em pties and cleans its hold at dock.

EPA collected fish hold efflue nt samples from 31 commercia l fishing vessels, and fish hold cleaning wastewater samples from 9 vessels for their study of ve ssel discharges (USEPA, 2010). EPA generally collected single grab sample s from these vessels while the vessels were dockside. These samples were usually collected while the effluent was being discharged, but they were occasionally collected directly from the fish hold. The samples were analyzed for both total and dissolved metals, classical polluta nts (biochemical oxygen demand, oil and grease, sulfide, total suspended solids and other physical -chemical parameters) pathogens, and nutrients. EPA also analyzed the fish hold cleaning wast ewater samples and three fish hold effluent samples for nonylphenols (USEPA, 2010).

Section 3.4 of EPA’s Report to Congress on the Study of Discharges Incidental to Normal Operation of Commercial Fishing Vesse ls and Other Non-recreational Vessels Less than

79 Feet (USEPA, 2010) summarizes the specific analyt es detected in fish hold and fish hold cleaning effluent water. EPA’s in terpretation of the likely risks posed by these analytes to human health and the environment, relative to pollu tant loadings, background ambient and source water contaminant levels and characteristics, and other relevant information useful for this assessment, is presented in Chapter 5 of the repor t to Congress and summarized below.

Elevated concentrations of certain total and dissolved metals, as well as many other pollutants, were measured in fish hold and fish hold cleaning effluent. Elevated concentrations were found for total iron, dissolved and total copper, total arsenic, dissolved zinc and selenium.

Concentrations of total and dissolved metals in fish hold cleaning effluent were generally similar to, but lower than, those measured in fish hold effluent samples.

Several classical polluta nts found in fish hold effluent a nd fish hold cleaning wastewater may have the potential to pose risk. BOD was found at elevated concentrations in all samples and, in many instances, was found at higher concen trations than those in typical raw domesticFish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 3 - Water Quality

Characteristics of Fish Hold Effluent and Fish Hold Cleaning Wastewater

9 sewage. Concentrations of COD and TOC corre lated with BOD concentrations and were similarly elevated in all samples. The high BOD likely contributed to the pervasively low dissolved oxygen levels. Total susp ended solids (TSS) and turbidity in fish hold effluent and fish hold cleaning wastewater were also similar to levels found in typica l raw domestic sewage. Sulfide concentrations were elevated, partic ularly in samples from a New England ground fishery trawler. Nutrient parame ters, particularly NH3-N, TKN, and TP, were all measured at concentrations comparable to typical raw domes tic sewage. High pathogen concentrations were

found in a few fish hold effluent and fish hold cl eaning wastewater samples; however, the source of pathogens was likely contaminated ambient b ackground water used to clean the decks aboard these vessels (USEPA, 2010).Fish Hold Effluent and Fish Hold Cleani ng Wastewater Discharges Section 4 - Volumes and Rates of Discharge of Fish Hold Effluent and Fish Hold Cleaning Wastewater

10 

## SECTION 4

VOLUMES AND RATES OF DISCHARGE OF FISH HOLD

EFFLUENT AND FISH HOLD CLEANING WASTEWATER

The volume of fish hold effluent generated by a fishing vessel depends on the size of the vessel, the number of fish holds and their volumes, the method used for keeping the product fresh (RSW, ice, etc.) and the frequency at which the catch is off-loaded. The discharge of fish hold water is not continuous, but occurs periodica lly when the fishing vessel is in operation during the fishing season. Fish hold cleaning wa stewater discharges also occur on a periodic basis; however, the volumes are considerably smaller.

Vessels such as small salmon trollers or l ongliners that frequent Alaska waters have approximately 1,500 gallons of fish hold storage. EPA estimated this volume is occupied by approximately 50 percent fish and 35 to 40 per cent ice when the vessel off-loads at the seafood processing facility (USEPA, 2010). The ice, which is thrown overboard daily after the fish are unloaded, would result in a fish hold discharge of between 500 a nd 600 gallons per day (gpd) for these types of vessels on days they are actual ly fishing (fish hold volum es, fish hold effluent discharges, and fish hold clean ing wastewater discharges are summarized in Table 1).

EPA estimated that mid-size fishing vessels, su ch as gill netters, and purse seiners found in Alaska, and shrimp boats in the Gulf of Me xico, have fish hold volumes of between 3,000 and 5,000 gallons. Assuming these vessels have between 35 and 40 percent of i ce/water slurry in the fish hold tanks, they likely discharge between 1,000 and 2,000 gallons of fish hold water every two to three days when they are fishing. Larger fishing vessels such as offshore trawlers found off the coast of New England and tenders found in Alaska can have RS W holding tanks or ice hold tanks with capacities as large as 15,000 gallons. These ta nks, which contain 30 to 40 percent RSW or ice after the s eafood is unloaded, result in a fish hold discharge of between 4,500 and 6,000 gallons. These vessels are expected to unload their catch and discharge fish hold effluent every three to five days wh en operating during the fishing season.

Fish hold tanks are cleaned after the catch ha s been off-loaded at the seafood processing facility. Therefore, the frequency of fish hold cleaning depends on the type and amount of fish being caught. For example, offshore trawlers in New England might clean the fish hold tank every three to five days when they return to the fish processing facili ty. Small fishing vessels such as salmon trollers and longlin ers in Alaska, off-load the catc h daily and also clean the fish hold tanks daily. Fish tenders and purse seiners with RSW tanks might clean their tanks every few days when they return to the fish processing facility.

On small fishing boats such as trollers and longliners, and mid-size fishing boats such as gill netters, fish holds are typically cleaned using a garden hose at a flow rate of approximately 10 to 12 gpm (USEPA, 2010). Fish hold cleaning is completed in 15 minutes or less, resulting in a discharge of between 150 and 200 gallons each day the vessel is fi shing. Larger vessels such as offshore trawlers found in New England and large tenders in Alaska also use a garden hose to wash down the fish hold tanks; however, cleanin g these tanks takes l onger, approximately 30

minutes. EPA estimated the volume of fish hold cl eaning wastewater discharged for these vesselsFish Hold Effluent and Fish Hold Cleani ng Wastewater Discharges Section 4 - Volumes and Rates of Discharge of Fish Hold Effluent an d Fish Hold Cleaning Wastewater

11 ranges between 300 and 400 gallons per cleaning, whic h are expected to occur every three to five days during fishing season (USEPA, 2010).

Table 1. Fish Hold Storage and Discharge Practices

Vessel Size Fish Hold Storage Volume (gal.) Frequency of

Fish Hold Discharge and

Fish Hold Cleaning

Wastewater

Discharge Fish Hold Discharge

Volume

(gal.) Fish Hold Cleaning

Wastewater

Discharge

Volume

(gal.)

Small: salmon

trollers and longliners 1,500 Daily when fishing 500 - 600 150 - 200

Mid-size: gill

netters, purse seiners and shrimp

boats 3,000 – 5,000 Every 2-3 days when fishing 1,000 – 2,000 150 - 200

Larger: offshore trawlers and fishing

tenders up to 15,000 Every 3-5 days when fishing 4,500 – 6,000 300 - 400

Source: USEPA, 2010Fish Hold Effluent and Fish Hold Cleaning Wast ewater Discharges Section 5 – Waste Disposal Practices

for Fish Hold Effluent

12 

## SECTION 5

WASTE DISPOSAL PRACTICES FOR FISH HOLD EFFLUENT

To date there has been little federal regulat ion of fish hold effluent discharges (see Section 6 of EPA 2010 for an analysis of how in cidental discharges ar e currently subject to regulation under US Federal Law or a binding international obligati on of the United States). As documented in the previous sections, it is a co mmon practice for commercial fishing vessels to discharge their fish hold efflue nt and fish hold cleaning wastew ater overboard after unloading

their catch. Transfer of these effluents ashore for treatment a nd disposal may be a practical alternative for managing these wastes. This pr actice was encountered in two locations: San Francisco, California and Sitka, Alaska.

Based on personal communication with the Sa n Francisco Port Authority, the city recently finished re-engineering th e pier deck of Pier 45 at Fish erman’s Warf to capture all offloaded water, ice and fish waste (see Attachment A). The Port had been named in a lawsuit in which one of their 15 tenant fish processors wa s sued for violating thei r storm water permit for allowing fish processing wastewat er to drain into the bay. As a property owner, the Port was responsible for their tenant’s compliance. In re sponse, the Port of Sa n Francisco installed a system that captures all fish processing wast e as well as fish hold effluent. Funded by a $1.6 million grant from the Clean Water State Revolvi ng Fund, the project included installation of a pumpout manifold that allows herring boats moor ed along the west apron of the Pier 45 fish processing facility to discharge fish hold effluent and fish wast e to the city sewer system. The project also included installation of a new stormwater collection system along the west apron of Pier 45 to direct polluted stormw ater runoff from this area back to the city’s sewer system (SFPORT, 2009). The new pier deck system scre ens larger solids, which are collected and composted, and routes the separated wastewat er to the municipal sewer system. Similar collection systems have been used by seafood processing plants for some time.

Based on personal communication with the Sitka Seafood Producers Co-op in Sitka, Alaska, the facility accepts “dirty” fish hold i ce from fishing vessels (see Attachment A). This facility is permitted through the NPDES program to collect seafood processing wastewater, grind any solids (fish parts) using a macerator

, and discharge the wastewat er through their dockside outfall. The processing facility began voluntarily collecting dirt y ice in the fall of 2009 from some fishing vessels, since the pr ocessor had the means to manage it onsite. As at other ports, the ice is usually shoveled overboard, but if the ice appears to be very bloody or contain significant fish guts and slime, the Sitka Co-op facility asks that the ice be shoveled into totes (the same totes used to off-load fish) and taken into the facility. There the ice is melted, and the melt water

is then combined with the s eafood processing wastewater. The S itka Co-op operates a fleet of about 120 hook and line vessels and four gillnette rs, the majority of which use only ice tanks. RSW tanks are primarily used by purse seiners, which are not members of the co-op. The four gillnetters and a half dozen of the hook and line vessels use RSW tanks or a mixture of ice and

ambient seawater. These vessels have no means of pumping their fish hold effluent into the facility, so these vessels discha rge their fish hold effluent di rectly overboard per their usual practice.Fish Hold Effluent and Fish Hold Clea ning Wastewater Discharges Section 5- Waste Disposal Practices

for Fish Hold Effluent

13 As the San Francisco Port and Sitka Co-op examples illustrate, different methods and facilities are required to conve y ice and RSW ashore for treat ment and disposal. Based on personal communication with West Coast Seafood, in regions such as the Pacific Northwest, fish processors are generally located in secluded or rural areas wher e the local sewer or WWTPs may not have the capacity to handle large volumes of fi sh hold effluent (see Attachment A). In larger metropolitan areas (such as San Francisc o) this would not be a limitation.Fish Hold Effluent and Fish Hold Cleaning Wastewat er Discharges Section 6 – Estimated Cost of Fish Hold Effluent and Fish Hold Cleaning Wastewater Waste Treatment and Disposal

14 

## SECTION 6

ESTIMATED COST OF FISH HOLD EFFLUENT AND FISH

HOLD CLEANING WASTEWATER WASTE TREATMENT AND

DISPOSAL

The cost of treating and disposing fish hold effluent and fish hold cleaning wastewater at a publically owned treatment works was estimated using average 2007 rates for industrial users (NACWA, 2008), as shown below in Table 2. Av erage concentrations for BOD (840 mg/L) and TSS (210 mg/L) measured in fish hold effluent samples (USEPA, 2010) were used to determine surcharges for these constituents. Based on these concentrations and average rates for industrial users of WWTPs, the total cost for sewage treat ment and disposal of fish hold effluent is estimated to be $5.02 /1,000 gallons.

Table 2. 2007 Fish Hold Effluent Treatment and Disposal Costs

Rate component 2007 Average Volume charge $2.76 /1,000 gallons BOD surcharge 0.2625 /pound BOD charge $1.84 /1,000 gallons TSS surcharge 0.2421 /pound TSS charge $0.42 /1,000 gallons Total charge $5.02 /1,000 gallons

Source: NACWA, 2008

As noted above, the feasibility of onshore treatment and disposal of fish hold effluent and fish hold cleaning wastewater de pends upon the nature of the effl uent (i.e., RSW or ice), the method of conveyance from ship to shore (e.g., pu mping, fish totes), and the availability of a facility to accept, convey and treat the waste. In some cases, capital expenditure may be necessary to construct or upgrad e the facilities to allow them to accept fish hold wastewater. Costs of construction/upgrading would be highly specific to an individu al site, and no general estimates of such capital expenditures are availa ble. For example, the investment of $1.6 million for improvements made at Pier 45, which allow he rring boats to discharge fish hold effluent to the City of San Francisco sewer system, is likely to be a high estimate for such a system, because that project also included the in stallation of a new stormwater collection system. On the other hand, at some seafood processing facilities the capabil ity to accept fish hold effluent may already

exist.Fish Hold Effluent and Fish Hold Clea ning Wastewater Discharges Section 7- References

15 

## SECTION 7

REFERENCES

ADGF. 2010. Frequently Asked Questions. Alaska Department of Fish and Game, Division of Commercial Fisheries, Accessed October 10, 2010. (http://www.cf.adfg.state.ak.us/geninfo/about/faq/cf_faq.php)

ADFG. 2008. What Kind of Fishing Boat is That? Alaska Division of Fish and Game, Division of Commercial Fisheries. Juneau, AK 2008.

MDNRE. 2010. Commercial Trapnets in Central Lake Huron. Michigan Department of Natural Resources and Environment. Accessed October 6, 2010. (http://www.michigan.g ov/dnr/0,1607,7-153-10364_52259_10951_11244-69487-- ,00.html).

NACWA. 2008. Highlighting Challenges in Util ity Financing and Management; 2008 NACWA Financial Survey Summary. National Associat ion of Clean Water Ag encies. Washington,

DC.

NMFA. 2010. California-based swordfish pelagic longline fishery. National Marine Fisheries Service, Southwest Regional Office. Accessed October 10, 2010. (http://www.swr.noaa.gov/fm d/observer/wcllprog02.htm).

NJDA. 2010. New Jersey Fishing and Aquaculture : Harvesting the Garden State’s Waters. New Jersey Department of Agriculture, Jersey Seafood. Accessed October 6, 2010. (http://www.state.nj.us/s eafood/seafoodreport.pdf).

Gilden, J., editor. 1999. Oregon’s changing coastal fishing communities. Oregon State University, Corvallis, Oregon, ORESU-0-99-001.

SFPORT. 2009. Pier 45 Drainage Improvement s Project. Port of San Francisco. (http://recoverysf.org/intran et/RecoverySF/files/2009/03/pi er45drainageimprovements1.p df).

Smith, J.W.1991. The Atlantic and Gulf Menhaden Pu rse Seine Fisheries: Origins, Harvesting Technologies, Biostatical Monitoring, Recen t Trends in Fishery Statistics, and Forecasting. Marine Fisheries Review, 1991.

SCDNR. 2010. Sea Science, Blue Crabs. South Carolina Department of Natural Resources. Accessed October 6, 2010 (http://www.dnr.sc .gov/marine/pub/seascience/bluecrab.html).

USEPA. 2010. Report to Congress: Study of discharges incide ntal to normal operation of commercial fishing vessels and other non-recrea tional vessels less than 79 feet. Office of Water, United States Environmental Prot ection Agency, Washington, D.C. EPA 833-R10-005.Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-1 ATTACHMENT A:

SUMMARIES OF INFORMATION GATHERED IN TELEPHONE CONVERSATIONSAttachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-2 Project No.: 0256.03.001.004 DISTRIBUTION

Page _1 _ of __1

_

Project Name: Vessels

– Technical Support

TELEPHONE CALL RECORD

Outgoing Call Date: Aug, 12 2010 Time: 6pm

Company Name: Sitka Seafood Co-op Contact Name: Craig Shoemaker

Phone No.: 907-747-5811

Name: Kathleen Wu

GENERAL SUBJECT : Information on the Fishing Industry

TOPICS DISCUSSED AND ACTION TAKEN

Craig Shoemaker is a plant manager at the S itka Seafood Producers Co-op in Sitka, Alaska. I told Mr. Shoemaker that I had spoken with Li nda Behnken earlier and that she mentioned the Co-op was now accepting “dirty” fish hold ice from boats. He confirmed this practice and said that their facility is permitte d through the NPDES program to collect their seafood processing wastewater, send it through their pr imary grinder, and discharge it through their dockside outfall. The processing facility “felt obligated” to accept dirty ice from some fi shing vessels since the processor had the means to manage it onsite. Th e facility began this voluntary process of collecting dirty ice in the fall of 2009.

If the ice appears to be relatively clean upon inspection, the facility does not bother with collecting the ice and asks the vessel operators to shovel it overboard per their usual practices. Most of the Co-op’s vessels pr ocess their catch immedi ately after bringing it onboard and before anything enters the hold tanks, so the ice rema ins very clean. However, the cleanliness of the tanks can depend on the fish species. For example, some bottom fish species can excrete slime after processing, which influences the amount of cleaning re quired later.

99% of the fish processed at th is facility is salmon. Last year the facility processed 500,000 lbs of halibut, 1.3 million lbs of black cod, and 300,000 lbs of rockfish. Salmon and black cod are sold as whole fish so require little processing at the facility itself.

I asked if the Co-op accepts only dirty ice or also dirty refrigerated seawater from in fish holds. Mr. Shoemaker stated that the Co-op only has the ability to take ice from boats using the same

totes that are used to off load fish. The ice is collected, melted, and then sent to a sump. The vessels with refrigerated seawat er have no way of pumping their fish hold wastewater into the facility. However, the Co-op operates a fleet of about 120 hook and line vessels and 4 gillnetters and the majority of these vessels only use ice ta nks. Refrigerated seawater tanks are primarily used by purse seiners, which are not members of the co-op. All 4 of the gillnetters and about 5% of the hook and line vessels use refrigerated seaw ater tanks or a mixtur e of ice and ambient

seawater. All the fish hold wastewater from thes e vessels is discharged directly overboard per their usual practice.Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-3 Fish hold cleaning is also performed after each offload on these vessels. Any wastewater generated from this activity is also discharged directly overboard. Most vessel operators use bleach, joy dish soap, or any F DA-approved food grade cleaners.

The only other facility that also offers a similar dirty ice serv ice for their vessels is Alaska Glacier Seafood in Juneau, Alaska.Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-4 Project No.: 0256.03.001.004 DISTRIBUTION

Page _1 _ of __1

_

Project Name: Vessels

– Technical Support

TELEPHONE CALL RECORD

Outgoing Call Date: Aug, 11 2010 Time: 2pm

Company Name: Alaskan Longline Fishermen’s Association Contact Name: Linda Behnken

Phone No.: 907-747-0695

Name: Kathleen Wu

GENERAL SUBJECT : Information on the Alaskan Fishing Industry

TOPICS DISCUSSED AND ACTION TAKEN

Linda Behnken is a representative of the Al askan Longline Fishermen’s Association and an avid fisherman owning her own longliner ve ssel and fishing when she can along Alaska’s coast. Her expertise is in longliner vessels.

These longliner vessels range from 14 ft skiffs to 70 ft vessels. The majority of the longliners however range from 40 ft to 60 ft. The longliners mainly fish for salmon, halibut, rockfish, black cod, and a few other species that belong to multi-speci es fisheries, such as skates. Although the sizes of the vessels are not really species dependent , Black cod fishing longliners tend to be larger ranging from 40 ft to 70 ft, b ecause their target species are concentrated in deeper waters and require the fisherman to travel further out from shore. Almost all longliners do some amount of fish processing immediately af ter the fish are caught. This includes gutting, bleeding, heading and clean the fish befo re stowing them into their tanks.

The vast majority of longliners are ice boats. These ice boats have fish hold tanks that are filled with clean ice prior to fishing. As the tanks are filled with fish and the ice melts, any water is pumped out of these tanks via the bilge pump automatically. When the boats return to the seafood processing facility, the catch is offloa ded and any ice is shoveled out of the tanks directly overboard.

The remaining longliners have refrigerated seawater (RSW) holding tanks. Ms. Behnken estimates longliners with RSW tanks make up about less than 10% of all longliners in Alaska. She added that it is very different than purse seiners, the majority of which have RSW tank systems. These vessels also discharge their fi sh hold wastewater directly overboard after offloading their catch to a s hore side seafood processor.

Ms. Behnken also confirmed that longliners almo st always clean their tanks between each offload. Most use pressure hoses with water to keep their tanks clean, but some add mild detergents when needed. The soaps that are mo st commonly used are dish soap, biodegradable detergents, or a very mild bleach solution. She said that the fishermen are very careful to not useAttachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-5 any detergents that could affect the food grade of the fish. In other words, only soaps they felt comfortable using in a kitche n or for cleaning dishes.

When asked about any exceptions to managi ng fish hold discharges, Ms. Behnken noted that the Sitka Seafood Co-op has ju st started a new policy of colle cting visibly “dirty” ice from

fish hold tanks. Most of the time the ice is a llowed to be shoveled ove rboard, but if the ice appears to be very bloody or cont ain significant fish guts and slime, the facility asks that the ice be shoveled into totes (the same totes the fish were offloaded in) and taken into the facility. She was not sure how the facility then manages th e ice, but speculated th at they probably first allowed the ice to melt and then sent everyt hing through the facility’s macerator prior to discharged via their outfall. She also stated that this new activity was likel y a result of trying to keep their dock and shore clean and free of birds.Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-6 Project No.: 0256.03.001.004 DISTRIBUTION

Page _1 _ of __1

_

Project Name: Vessels

– Technical Support

TELEPHONE CALL RECORD

Outgoing Call Date: Aug, 12 2010 Time: 7pm

Company Name: United Fishermen of Alaska Contact Name: Mark Vinsel

Phone No.: 907-586-2820

Name: Kathleen Wu

GENERAL SUBJECT : Information on the Fishing Industry

TOPICS DISCUSSED AND ACTION TAKEN

Mark Vinsel is the Executive Director of United Fishermen of Alaska, an umbrella organization that represents 38 smaller fishing vessel associat ions in Alaska, such as District Fishermen United, Alaskan Longline Fishermen’s Associations, Alaska Trollers Association, etc. Thus their members operate the entire range of fishing vessels and fish in all the fisheries.

As discussed in the 2009 comments provided on fi shing safety (Attachment 1), there are about 10,000 permitted and active vessels in Alaska. 9, 828 vessels ranged in size from 7 feet to 635 feet and included skiffs, gillnetters, purse seiners, trawlers, crabbing vessels, tenders, and trollers. Of these vessels, many are equipped to fi sh several different species through out the year by modifying their gear type. Gear type m odification mainly involves changing on desk equipment and other machinery. The following ar e some statistics included in the report.

Vessel Size Distribution

1. 2,009 vessels (20%) are 20ft or less;

2. 2,363 vessels (24%) are be tween 21ft and 29ft;

3. 4,096 vessels (42%) are be tween 30ft and 49ft;

4. 863 vessels (9%) are betw een 50ft and 79ft; and

5. 497 vessels (5%) are over 79ft.

Age of Vessels Distribution

1. 634 vessels are over 50 years old, built befo re 1959, (two are over 100 years old);

2. 463 vessels are 40 to 50 years old, built in 1959 – 1968;

3. 2,070 are 30 to 40 years old, built in 1969 – 1978;

4. 3,626 are 20 to 30 years old, built in 1979 – 1988;

5. 2,265 are 10 to 20 years old, built in 1989 – 1998;

6. 646 are less than ten years old; and

7. 4,395 (45%) are of 5 net tons or less and not currently require d to be documented vessels.

Gear Types DistributionAttachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-7 1. 54% operate one gear type;

2. 24% operate two gear types;

3. 11% operate thr ee gear types;
4. 4% operate four gear types;

5. 2% operate 5 or more gear types;

6. Two vessels are registered under 11 different gear types; and

7. The remaining vessels did not specify gear type.

Mr. Vensel stated that larger vessels generally operate more g ear types and have more deck space to switch out equipment as needed.

Mr. Vinsel said that he was uns ure about the distribution of ve ssels that have refrigerated seawater (RSW) tanks or use ice tanks, but genera lizations can be made. For example, almost all purse seiners, tenders, and crabbing vessels ha ve RSW systems, while hook and line and set-net

vessels use ice tanks. A vessel with an installed RSW system would not use the tanks as ice tanks even if their gear type changed.

Mr. Vinsel stated that as far as he is aware, all vessels discharge their RSW tanks and ice tanks directly overboard after off load ing their catch. This includes a ny wastewater from tank cleaning as well. I told him that the Sitka Co-op was actually accepting “dirty” ic e from some of their

vessels. He said that he has ne ver heard of this, but was not su rprised to learn of voluntary practices from more progressive communities. When I asked him which other communities he would also consider progressive in Alaska, he stated that Cordova is considered more progressive, but doubted they w ould have voluntary environmental practices similar to Sitka because it is not a cruise ship community.

Mr. Vinsel also provide d the following website http://www.cfec.state.ak.us/plook/ , which has

additional Alaska vessel information and statistics. His instructions were to select the “Yearly CSV” tab, select “Vessels” under File Type, and then select the year of interest. He said that this method provides the most complete data sets.

Mr. Vinsel also offered some additional contacts, but they were all already on my contacts list.Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-8Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-9Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-10Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-11Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-12Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-13Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-14Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-15Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-16 Project No.: 0256.03.001.004 DISTRIBUTION

Page _1 _ of __1

_

Project Name: Vessels

– Technical Support

TELEPHONE CALL RECORD

Outgoing Call Date: Aug, 20 2010 Time: 2pm

Company Name: West Coast Seafood Contact Name: Rod Moore

Phone No.: 503-227-5076

Name: Kathleen Wu

GENERAL SUBJECT : Information on the Fishing Industry

TOPICS DISCUSSED AND ACTION TAKEN

Rod Moore is a representative of West Coast Seafood, a trade association that represents 12 seafood processors located in Washington, Oregon, and California. The seafood facilities process several species of tuna, 12 species of ground fish, crabs, salmon, sardines, whiting, and swordfish year round.

Mr. Moore was unsure of the type of vessels or the lengths of the fishing boats but offered the following generalization based on his knowledge of the fishing industry. Almost all crabbing vessels use live tanks that circulate seawat er to keep the crabs alive. Tuna, ground fish and swordfish are generally fl ash frozen onboard or kept in ice tanks. Sardines, however, are fished most frequently on vessels with RSW systems or ice slurry

tanks.

Mr. Moore is unaware of any seafood pro cessors, whether they are part of his association or not, that collect fish hold e ffluent or used ice from these vessels. He confirmed that all fishing vessels discharg es their fish hold effluent immediately overboard following offloading at the s eafood processor. Any fish hold cleaning discharges are managed the same way. He is unaware of any other management processes for fishing vessels or seafood processors. He st ated that the processo rs he represents are generally located in secluded or rural area s where the local sewage or POTW systems would not have the capacity to handle that volume of waste. I mentioned that San Francisco Bay may have a fish hold offloading site where vessels can discharge their fish hold effluent directly into the San Francisco sewage system. Mr. Moor e stated that he is unaware of this service offered by the Bay, but he is also unfamiliar with the processors in that area. However, if it would not surpri se him if San Francisco’s sewer system had the capacity to manage fish hold effl uent from several vessels a day.Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-17 DISTRIBUTION

Page _1 _ of __1

_

Project Name: Vessels

– Technical Support

TELEPHONE CALL RECORD

Outgoing Call Date: Aug, 13 2010 Time: 1:30pm

Company Name: San Francisco Port Authority Contact Name: John Mundy

Phone No.: 415-274-0256

Name: Michelle Moore

GENERAL SUBJECT : Information on new Pier 45 system for capture of all water and ic e discharged with catch

TOPICS DISCUSSED AND ACTION TAKEN

The Port Authority in the City of San Franci sco re-engineered the pi er and put in a pump system that captures all water and waste that had previously washed into the bay. There are 15 seafood processors on Pier 45 and their operations have had sewer service in place for some time. After being screened for solids, which ar e sent to be composted, the wastewater from these processors is routed to the city sewer. Wa ter discharged onto the Pier deck from fish holds, etc. used to wash back into the bay. This water is now captured by the new design. The seafood processors have permits and if they were to get sued for allowing gurry (the W coast term for bail water?) to go into the bay, they could get sued, and their landlord, the City of SF, would get sued as well. Three pump-out manifolds were installed for pumping out fish gurry. He said the worst offenders have been the herring operations because they just want the roe so they don’t care about the

condition of the fish.

John is retiring today. If we have additio nal questions, we should contact Jay Ach (415- 274-0562).Attachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-18 Project No.: 0256.03.001.004 DISTRIBUTION

Page _1 _ of __1

_

Project Name: Vessels

– Technical Support

TELEPHONE CALL RECORD

Outgoing Call Date: Aug, 11 2010 Time: 4pm

Company Name: Western Fishboat Owners Association Contact Name: Wayne Heikkila

Phone No.: 530-229-1097

Name: Kathleen Wu

GENERAL SUBJECT : Information on the Fishing Industry

TOPICS DISCUSSED AND ACTION TAKEN

Wayne Heikkila is a representative of the Western Fishboat Owners Association. He mainly works with trollers and hook-and-li ne vessels (longliners) that fish in the Pacific Ocean and offload along the US West Coast. These vessels primarily fish for Albacore tuna, salmon, and a variet y of crabs throughout the year.

About 50% of vessels use dry blast freezi ng systems. These systems have no fish hold discharges but do occasionally need to be cleaned between seasons. Mr. Heikkila stated that the cleaning is similar to de frosting a refrigerator and any water or condensation is discharged overboard. These dry blast vessels are similar to the trollers in the Gulf Coast used to catch shrimp, but used exclusively in the Pacific for tuna. The tuna season generally lasts from June to late Oct ober, but there is some amount of fishing occurring as far as American Samoa during ot her parts of the year. The fish are caught and frozen whole immediately with no pro cessing on board the vessels. The reason for this is that tuna tend to be very clean fi sh and are delivered whole because the industry prefers that all the processing to be done at the processing pl ant closest to where the fish is ultimately consumed. The only processing ev er performed on board is limited to gill bleeding the tuna.

About 40% of the vessels use refrigerated seawater/recirculat ed sea water/brine systems. The majority of these vessels ar e used for crabbing. The remaining 10% of vessels use ice tank systems and are used primarily for salmon. All fish hold tanks on these vessels discharge their effluent direc tly overboard following the offload of their catch. This includes any fish hold ta nk cleaning activities as well.

Mr. Heikkila also provided the following c ontacts for information gathering purposes:

Moore, Mr. Rod Executive Director, West Coast Seafood

Processors AssociationAttachment A: Summaries of Informat ion Gathered in Telephone Conversations

A-19 1618 SW First St, Ste 318 Portland, OR 97201 Telephone: 503-227-5076

Fax: 503-227-0237 Email: seafood@integra.net

Marchand, Jr., Mr. Pierre

Processor President, Jessie's Ilwaco Fish Company

PO Box 800 Ilwaco, WA 98624-0800 Telephone: 360-642-3773

Fax: 360-642-3362 Email: pierrem@ilwacofish.com

Pleschner-Steele, Ms. Diane Executive Director, California Wetfish

Producers Association

PO Box 1951 Buellton, CA 93427 Telephone: 805-693-5430

Fax: 805-686-9312 Email: dplesch@earthlink.net

Alverson, Mr. Robert Fishing Vessel Owner's Association 4005 - 20th Ave W, Room 232 Seattle, WA 98199-1290 Telephone: 206-283-7735

Fax: 206-283-3341

Email: robertalverson@msn.com

Fricke, Mr. Douglas

WA Troller Assoc

Boat Seafoods

PO Box 306 Hoquiam, WA 98550 Telephone: 360-580-3027

Fax: 360-538-0466

Email: dfricke@techline.com