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 2011
Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges CONTENTS 

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CONTENTS 

Page 

EXECUTIVE SUMMARY .................................................................................................................... III

SECTION 1 INTRODUCTION ............................................................................................................... 1

SECTION 2 FISHING VESSEL TYPES, FISHERIES, GEOGRAPHIC DISTRIBUTION, AND FISH 

HOLD DISCHARGE PRACTICES ............................................................................................. 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

SECTION 3 WATER QUALITY CHARACTERISTICS OF FISH HOLD EFFLUENT AND FISH HOLD 

CLEANING WASTEWATER .................................................................................................... 8

SECTION 4 VOLUMES AND RATES OF DISCHARGE OF FISH HOLD EFFLUENT AND FISH HOLD 

CLEANING WASTEWATER .................................................................................................. 10

SECTION 5 WASTE DISPOSAL PRACTICES FOR FISH HOLD EFFLUENT ............................................ 12

SECTION 6 ESTIMATED COST OF FISH HOLD EFFLUENT AND FISH HOLD CLEANING 

WASTEWATER WASTE TREATMENT AND DISPOSAL .......................................................... 14

SECTION 7 REFERENCES ................................................................................................................. 15

 Attachment A: Summaries of Information Gathered In Telephone Conversations 
Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges CONTENTS 

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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

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EXECUTIVE SUMMARY 

Commercial fishermen store the fish and shellfish they catch in some form of chilled 

condition on board their fishing vessels, 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 holding 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 mechanical refrigeration or by adding ice (or ice slurry or ice chips). 

In general, refrigerated seawater (RSW) systems are used aboard purse seiners, 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 freezers to preserve their catches, 

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

Fish hold effluent includes RSW, ice and melted ice that remains in the fish hold after the 

catch has been off-loaded at the seafood processor. The water that is drained as the ice melts 

during the fishing expedition is also considered to be fish hold effluent. Common practice aboard 

commercial fishing vessels is to discharge the 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 exceptions. At least one port was identified that 

captures fish hold effluent along with dock and pier runoff and transports it into the municipal 

sewer system. 

The water quality characteristics of fish hold effluent reflect contributions from various 

sources: vessel and fish hold materials and coatings, ambient water, potable/service water, and 

the seafood product itself. EPA collected fish hold effluent discharge samples from 31 

commercial fishing vessels, and fish hold cleaning discharge samples from 9 vessels for their 

Study of Discharges Incidental to Normal Operation of Commercial Fishing Vessels and Other NonRecreational Vessels Less Than 79 Feet (USEPA, 2010). Elevated concentrations of certain total 

and dissolved metals, as well as many of other pollutants, were measured in fish hold effluent 

and fish hold cleaning wastewater. Elevated metals concentrations were found for total iron, 

dissolved and total copper, total arsenic, dissolved zinc and selenium. BOD, TSS, turbidity, and 

nutrient parameters (NH3-N, TKN, and TP) were found at elevated concentrations that were 

often higher than those typically 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 fishing vessel is in operation 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 the 
Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Executive Summary

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discharges were due to operation of the vessel “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 industries surveyed, only one (Virginia) was found to have a 

NPDES permit for fishing vessel operations. 

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

fish hold effluent and fish hold cleaning wastewater overboard after 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 encountered 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 treatment 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 Cleaning Wastewater Discharges Section 1 - Introduction

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SECTION 1 

INTRODUCTION 

This document addresses fish hold effluent and fish hold cleaning wastewater, two 

common discharges from commercial fishing vessels. Commercial 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 organisms 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 killed shortly thereafter, before being stored in 

a refrigerated seawater holding 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 mechanical 

refrigeration or by adding ice (or ice slurry or ice chips). In general, refrigerated seawater (RSW) 

systems are used aboard purse seiners, tenders and some trawlers, while ice is used aboard 

gillnetters, longliners, trollers and some other 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 various methods of collection including nets, 

trawls, traps, or hook-and-line to capture the target species. The major classes of fishing vessels 

are differentiated by fisheries, geographic distribution, and how the fish are stored onboard ships. 

Fish hold effluent and fish hold cleaning wastewater discharge practices vary according to these 

differences. The type of fish usually determines 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, often with the use of 

additional ambient water called bail water. The RSW and bail water is often captured and 

recirculated back to the hold and pumped multiple times, until all fish have been removed from 

the fish hold. Any excess RSW or bail 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, vessels 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 quality possible. The flow rate through these systems 

results in a constant discharge of fish hold effluent. Because the majority of the seafood product 

remains alive, there is little biological 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 Cleaning Wastewater Discharges Section 1 - Introduction

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Fish hold effluent includes RSW, ice and melted ice that remains in the fish hold after the 

catch has been off-loaded. The water that is drained 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 discharge the fish hold effluent overboard immediately 

following off-loading at the seafood processor. 

Fish holds are also often cleaned or disinfected by vessel crews between catches. All fish 

holds are evacuated (i.e., completely 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 simply 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 removal 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), melted 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 identified that had methods of capturing fish hold 

effluent for treatment and disposal. San Francisco’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 effluent and treat it. However, 

most ports and processing facilities are not equipped to capture the high volume of water 

contained in fish holds. Overboard fish hold effluent and fish hold cleaning wastewater 

discharges are not currently regulated 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

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SECTION 2 

FISHING VESSEL TYPES, FISHERIES, GEOGRAPHIC 

DISTRIBUTION, AND FISH HOLD DISCHARGE PRACTICES 

Commercial fishing vessels may employ various methods of collection including nets, 

trawls, traps, or hook-and-line to capture the target species. This section describes the major 

classes of fishing vessels, including how they vary according to different fisheries and 

geographic distribution. It also discusses how the fish are stored aboard ship, and how fish hold 

discharge practices vary according to these differences.

Approximately 70,000 commercial fishing 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 vessels 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 fishing is a highly diverse industry. Based on 

personal communication with a representative of United Fishermen of Alaska, Alaska has 

approximately 10,000 active fishing vessels ranging in size from 7 feet to 635 feet and including 

skiffs, gillnetters, purse seiners, trawlers, crabbing 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, tenders, and crabbing vessels have 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. 

2.1 LOBSTER/CRABBER

Lobster and crab (Dungeness, King, Tanner, and Blue) boats target their catch using 

twine or wire-meshed steel pots (traps). Baited pots are left to “soak” for up to several days 

before retrieval. Lobster pot vessels are typically found in southern California and in the New 

England coastal states from Maine to Rhode Island. In southern California, the spiny lobster is 

the primary target species, while in New England 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 seagoing vessels 100 or more feet in length that fish the Bering Sea 

and the Gulf of Alaska for king crab (USEPA, 2010). During the 2010 Study of vessel 

discharges, EPA observed lobster boats with flow-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-shore 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 fisheries (SCDNR, 2010). Commercial fishing methods for 

blue crabs include crab pots and trot lines. Blue crabs are placed in a ventilated container (e.g., 

bushel basket) with a moist cloth covering the top, rather than in water which can suffocate blue 
Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 2 – Fishing Vessel Types, 

Fisheries, Geographic Distribution, and Fish Hold Discharge Practices 

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crabs when oxygen levels drop. Since blue crabs are placed in ventilated containers rather than a 

tank of water, no effluents are discharged from these fishing vessels. 

Vessels catching Dungeness, king and snow crabs are typically between 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 commercial quantities from Alaska to south of San 

Francisco, California. Along the Pacific coast, Dungeness crabs live in the intertidal zone out to a 

depth of 170 meters. Dungeness crabs are stored alive 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 Snow crabs are stored alive in holds on boats 

that are filled with re-circulating sea water until 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 SCALLOP DREDGE

A scallop dredge or oyster dredge, is a dredge which is towed along the bottom of the sea 

by a fishing boat to collect scallops, oysters, clams, crabs, and in some cases, sea cucumbers. 

Dredge boats used to collect clams, oysters, and crabs in near-shore 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 scallop 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 States 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 cleaning wastewater is discharged overboard at the pier. 

2.3 FISH TENDER

A fish tender vessel supports fishing vessels by providing supplies, fish products or other 

materials, and additional refrigerating space; storing the catch; and transporting the catch from 

the fishing vessels to the fish processing facility. 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 tenders are typically used to transfer chum salmon (Oncorhynchus keta) 

from offshore fishing boats to the shore-side fish processing facility. 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 collected into tanks for further processing and a 

portion of the RSW is returned to the vessel to continue the fish removal process. The remaining 

portion of the RSW is discharged to ambient water 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 cleaning 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 circulate in the tank system for several hours before 

the fish hold cleaning wastewater 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 

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2.4 GILLNETTER

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 pier after the fish have been 

unloaded at the seafood processor. Any wastewater generated by fish hold cleaning is also 

discharged overboard at the pier. 

2.5 LONGLINER

Longliners catch fish (primarily halibut, black cod, swordfish, tuna and shark) via a 

longline that is either laid on the bottom or suspended in the water column. Long line fishing is 

conducted in nearly all coastal areas of the United States (NJDA, 2010; NMFA, 2010). Each 

longline can be up to a mile in length and have 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 processing immediately after the fish are caught. 

This can includes gutting, bleeding, heading or cleaning the fish before stowing them into their 

fish holds (see Attachment A). 

Longliners are typically 50 to 100 feet in length (USEPA, 2010). The vast majority of 

longliners 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 automatically pumped out of these tanks via the 

bilge pump. In southeast Alaska, the remaining ice from the fish hold is discharged overboard, 

usually pierside at the seafood processor. The tanks stay relatively 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 their 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 from pressure washing is discharged directly 

overboard. 

Based on personal communication with Western Fishboat Owners Association, some 

longliners that fish for tuna in the Pacific Ocean 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 occasionally need to be cleaned between seasons. 

The fish are caught and immediately frozen whole, with no processing on board the vessels. The 

reason for this is that tuna tend to be very clean fish and the tuna industry prefers that all 

processing to be done at the processing plant closest to where the fish is ultimately consumed. 

The cleaning of the fish hold aboard these vessels is similar to defrosting a refrigerator, and any 
Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 2 – Fishing Vessel Types, 

Fisheries, Geographic Distribution, and Fish Hold Discharge Practices 

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water or condensation is discharged overboard. The tuna season generally lasts from June to late 

October, but there is some amount of fishing occurring in American Samoa during other parts of 

the year. 

2.6 PURSE SEINER

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 primarily for salmon, while in New England and along 

the Gulf Coast, purse seiners are used to capture species such as menhaden (Smith, 1991). Purse 

seiner vessels in Alaska are limited to a maximum length of 58 feet (ADFG, 2010) to control the 

salmon harvest, while purse seine vessels in New England targeting menhaden 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 with 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 seiners 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 TRAWLER

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 for bottom fish, and in the Gulf of Mexico for 

shrimp. Trawlers also operate along the Pacific Coast from California to Alaska, targeting 

sablefish and longspine and shortspine thornyheads (Sebastolobus altivelis and Sebastolobus 

alascanus). Dover sole is generally captured 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 fish 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). Trawlers that preserve fish using wet ice or RSW discharge 

the ice/water overboard when the catch is off-loaded at the seafood processing facility. Any fish 

hold cleaning wastewater would also be discharged at the pier. Those that process, package and 

freeze fish on board do not have a wastewater discharge from the fish-hold. These vessels would, 

however, discharge wash-down waters from decks and fish processing areas. 

2.8 TROLLER

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 configuration, 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 caught 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

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SECTION 3 

WATER QUALITY CHARACTERISTICS OF FISH HOLD 

EFFLUENT AND FISH HOLD CLEANING WASTEWATER 

The water quality characteristics of fish hold effluent and fish hold cleaning wastewater 

reflect contributions from various sources: vessel and fish hold materials and coatings, ambient 

water, potable/service water, and 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, thereby increasing the concentration of 

these constituents in the discharge. Furthermore, 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 cleaned (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 fishing vessel is still at sea and the internal organs are discarded 

into the surrounding waters. Hence, on the salmon trollers, the organs and most of the residual 

blood are not in contact with RSW or ice and consequently, lower quantities of these materials 

are discharged when the vessel empties and cleans its hold at dock. 

EPA collected fish hold effluent samples from 31 commercial fishing vessels, and fish 

hold cleaning wastewater samples from 9 vessels for their study of vessel discharges (USEPA, 

2010). EPA generally collected single grab samples 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 pollutants (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 wastewater 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 Vessels and Other Non-recreational Vessels Less than 

79 Feet (USEPA, 2010) summarizes the specific analytes detected in fish hold and fish hold 

cleaning effluent water. EPA’s interpretation of the likely risks posed by these analytes to human 

health and the environment, relative to pollutant 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 report 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 pollutants found in fish hold effluent and 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 concentrations than those in typical raw domestic 
Fish 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 correlated with BOD concentrations and were 

similarly elevated in all samples. The high BOD likely contributed to the pervasively low 

dissolved oxygen levels. Total suspended solids (TSS) and turbidity in fish hold effluent and fish 

hold cleaning wastewater were also similar to levels found in typical raw domestic sewage. 

Sulfide concentrations were elevated, particularly in samples from a New England ground 

fishery trawler. Nutrient parameters, particularly NH3-N, TKN, and TP, were all measured at 

concentrations comparable to typical raw domestic sewage. High pathogen concentrations were 

found in a few fish hold effluent and fish hold cleaning wastewater samples; however, the source 

of pathogens was likely contaminated ambient background water used to clean the decks aboard 

these vessels (USEPA, 2010). 
Fish Hold Effluent and Fish Hold Cleaning 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 periodically when the fishing vessel is in operation 

during the fishing season. Fish hold cleaning wastewater discharges also occur on a periodic 

basis; however, the volumes are considerably smaller. 

Vessels such as small salmon trollers or longliners 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 percent 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 and 600 gallons per day (gpd) for 

these types of vessels on days they are actually fishing (fish hold volumes, fish hold effluent 

discharges, and fish hold cleaning wastewater discharges are summarized in Table 1). 

EPA estimated that mid-size fishing vessels, such as gill netters, and purse seiners found 

in Alaska, and shrimp boats in the Gulf of Mexico, have fish hold volumes of between 3,000 and 

5,000 gallons. Assuming these vessels have between 35 and 40 percent of ice/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 RSW holding tanks or ice 

hold tanks with capacities as large as 15,000 gallons. These tanks, which contain 30 to 40 

percent RSW or ice after the seafood 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 when operating during the fishing season. 

Fish hold tanks are cleaned after the catch has 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 facility. Small fishing vessels 

such as salmon trollers and longliners in Alaska, off-load the catch 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 fishing. 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, cleaning these tanks takes longer, approximately 30 

minutes. EPA estimated the volume of fish hold cleaning wastewater discharged for these vessels 
Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges Section 4 - Volumes and Rates of 

Discharge of Fish Hold Effluent and Fish Hold Cleaning Wastewater 

11 

ranges between 300 and 400 gallons per cleaning, which 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, 2010 
Fish Hold Effluent and Fish Hold Cleaning Wastewater 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 regulation of fish hold effluent discharges (see 

Section 6 of EPA 2010 for an analysis of how incidental discharges are currently subject to 

regulation under US Federal Law or a binding international obligation of the United States). As 

documented in the previous sections, it is a common practice for commercial fishing vessels to 

discharge their fish hold effluent and fish hold cleaning wastewater overboard after unloading 

their catch. Transfer of these effluents ashore for treatment and disposal may be a practical 

alternative for managing these wastes. This practice was encountered in two locations: San 

Francisco, California and Sitka, Alaska. 

Based on personal communication with the San Francisco Port Authority, the city 

recently finished re-engineering the pier deck of Pier 45 at Fisherman’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 was sued for violating their storm water permit for 

allowing fish processing wastewater to drain into the bay. As a property owner, the Port was 

responsible for their tenant’s compliance. In response, the Port of San Francisco installed a 

system that captures all fish processing waste as well as fish hold effluent. Funded by a $1.6 

million grant from the Clean Water State Revolving Fund, the project included installation of a 

pumpout manifold that allows herring boats moored along the west apron of the Pier 45 fish 

processing facility to discharge fish hold effluent and fish waste 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 stormwater runoff from this area back to the city’s sewer system 

(SFPORT, 2009). The new pier deck system screens larger solids, which are collected and 

composted, and routes the separated wastewater 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 ice 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 wastewater through their dockside 

outfall. The processing facility began voluntarily collecting dirty ice in the fall of 2009 from 

some fishing vessels, since the processor 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 seafood processing wastewater. The Sitka Co-op operates a fleet of 

about 120 hook and line vessels and four gillnetters, 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 discharge their fish hold effluent directly overboard per their usual 

practice. 
Fish Hold Effluent and Fish Hold Cleaning 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 convey ice and RSW ashore for treatment 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 where the local sewer or WWTPs may 

not have the capacity to handle large volumes of fish hold effluent (see Attachment A). In larger 

metropolitan areas (such as San Francisco) this would not be a limitation. 
Fish Hold Effluent and Fish Hold Cleaning Wastewater 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. Average 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 treatment 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 depends upon the nature of the effluent (i.e., RSW or ice), the 

method of conveyance from ship to shore (e.g., pumping, 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 upgrade the facilities to allow them to accept fish hold wastewater. 

Costs of construction/upgrading would be highly specific to an individual site, and no general 

estimates of such capital expenditures are available. For example, the investment of $1.6 million 

for improvements made at Pier 45, which allow herring 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 installation of a new stormwater collection system. On the other 

hand, at some seafood processing facilities the capability to accept fish hold effluent may already 

exist. 
Fish Hold Effluent and Fish Hold Cleaning 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.gov/dnr/0,1607,7-153-10364_52259_10951_11244-69487--

,00.html). 

NACWA. 2008. Highlighting Challenges in Utility Financing and Management; 2008 NACWA 

Financial Survey Summary. National Association of Clean Water Agencies. 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/fmd/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/seafood/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 Improvements Project. Port of San Francisco. 

(http://recoverysf.org/intranet/RecoverySF/files/2009/03/pier45drainageimprovements1.p

df). 

Smith, J.W.1991. The Atlantic and Gulf Menhaden Purse Seine Fisheries: Origins, Harvesting 

Technologies, Biostatical Monitoring, Recent 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 incidental to normal operation of 

commercial fishing vessels and other non-recreational vessels less than 79 feet. Office of 

Water, United States Environmental Protection Agency, Washington, D.C. EPA 833-R10-005. 
 Attachment A: Summaries of Information Gathered in Telephone Conversations

A-1 

ATTACHMENT A: 

SUMMARIES OF INFORMATION GATHERED IN TELEPHONE CONVERSATIONS 
 Attachment A: Summaries of Information 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 Sitka Seafood Producers Co-op in Sitka, Alaska. I 

told Mr. Shoemaker that I had spoken with Linda 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 permitted through the NPDES program to collect their seafood processing 

wastewater, send it through their primary grinder, and discharge it through their dockside outfall. 

The processing facility “felt obligated” to accept dirty ice from some fishing vessels since the 

processor had the means to manage it onsite. The 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 process their catch immediately after bringing it onboard and before 

anything enters the hold tanks, so the ice remains 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 required later. 

99% of the fish processed at this 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 seawater 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 tanks. 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 seawater tanks or a mixture of ice and ambient 

seawater. All the fish hold wastewater from these vessels is discharged directly overboard per 

their usual practice. 
 Attachment A: Summaries of Information 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 FDA-approved food grade cleaners. 

The only other facility that also offers a similar dirty ice service for their vessels is Alaska 

Glacier Seafood in Juneau, Alaska. 
 Attachment A: Summaries of Information 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 Alaskan Longline Fishermen’s Association and 

an avid fisherman owning her own longliner vessel 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-species 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, because 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 after the fish are caught. This includes gutting, 

bleeding, heading and clean the fish before 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 offloaded 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 fish hold wastewater directly overboard after 

offloading their catch to a shore side seafood processor. 

Ms. Behnken also confirmed that longliners almost 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 most commonly used are dish soap, biodegradable 

detergents, or a very mild bleach solution. She said that the fishermen are very careful to not use 
 Attachment A: Summaries of Information 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 kitchen or for cleaning dishes. 

When asked about any exceptions to managing fish hold discharges, Ms. Behnken noted 

that the Sitka Seafood Co-op has just started a new policy of collecting visibly “dirty” ice from 

fish hold tanks. Most of the time the ice is allowed to be shoveled overboard, but if the ice 

appears to be very bloody or contain 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 the ice, but speculated that they probably first 

allowed the ice to melt and then sent everything through the facility’s macerator prior to 

discharged via their outfall. She also stated that this new activity was likely a result of trying to 

keep their dock and shore clean and free of birds. 
 Attachment A: Summaries of Information 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 associations 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 fishing 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 fish several different species through out the year 

by modifying their gear type. Gear type modification mainly involves changing on desk 

equipment and other machinery. The following are some statistics included in the report. 

Vessel Size Distribution 

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

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

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

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

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

Age of Vessels Distribution 

1. 634 vessels are over 50 years old, built before 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 required to be documented vessels. 

Gear Types Distribution 
 Attachment A: Summaries of Information Gathered in Telephone Conversations

A-7 

1. 54% operate one gear type; 

2. 24% operate two gear types; 

3. 11% operate three 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 gear types and have more deck 

space to switch out equipment as needed. 

Mr. Vinsel said that he was unsure about the distribution of vessels that have refrigerated 

seawater (RSW) tanks or use ice tanks, but generalizations can be made. For example, almost all 

purse seiners, tenders, and crabbing vessels have 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 loading their catch. This includes any wastewater from tank cleaning 

as well. I told him that the Sitka Co-op was actually accepting “dirty” ice from some of their 

vessels. He said that he has never heard of this, but was not surprised 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 would have voluntary environmental practices similar to Sitka 

because it is not a cruise ship community. 

Mr. Vinsel also provided 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 Information Gathered in Telephone Conversations

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A-9 
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A-10 
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A-11 
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A-12 
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A-13 
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A-14 
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A-15 
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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 seawater to keep the crabs alive. 

Tuna, ground fish and swordfish are generally flash 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 processors, whether they are part of his 

association or not, that collect fish hold effluent or used ice from these vessels. He 

confirmed that all fishing vessels discharges their fish hold effluent immediately 

overboard following offloading at the seafood 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 stated that the processors he represents are 

generally located in secluded or rural areas 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. Moore 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 surprise him if San Francisco’s sewer system had 

the capacity to manage fish hold effluent from several vessels a day. 
 Attachment A: Summaries of Information 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 ice discharged with catch 

 

TOPICS DISCUSSED AND ACTION TAKEN 

The Port Authority in the City of San Francisco re-engineered the pier 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 are sent to be composted, the 

wastewater from these processors is routed to the city sewer. Water 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 additional questions, we should contact Jay Ach (415-

274-0562). 
 Attachment A: Summaries of Information 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-line 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 variety of crabs throughout the year. 

About 50% of vessels use dry blast freezing 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 defrosting 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 October, but there is some amount of fishing 

occurring as far as American Samoa during other parts of the year. The fish are caught 

and frozen whole immediately with no processing on board the vessels. The reason for 

this is that tuna tend to be very clean fish and are delivered whole because the industry 

prefers that all the processing to be done at the processing plant closest to where the fish 

is ultimately consumed. The only processing ever performed on board is limited to gill 

bleeding the tuna. 

About 40% of the vessels use refrigerated seawater/recirculated sea water/brine 

systems. The majority of these vessels are 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 directly overboard following the offload of their 

catch. This includes any fish hold tank cleaning activities as well. 

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

Moore, Mr. Rod 

Executive Director, West Coast Seafood 

Processors Association 
 Attachment A: Summaries of Information 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