Greg Peters 

<Petersg@arctic.net> 

02/15/200805:19 PM 

To Kai Shum/R1 O/USEPAlUS@EPA, Michael 

Lidgard/R10/USEPAlUS@EPA 

cc "Roche, Frances E (DEC)" <fran.roche@alaska.gov> 

bcc 

Subject Re: Alyeska Seafoods Permit Renewal 

I received the rest of the data from the lab a few minutes ago, so 

attached is the corrected data forms you requested that includes the 

missing analysis. The Total Ammonia was below detectable levels for all 

outfalls. 

If you need anything else from me, 'please let me know. 

Greg Peters 

Alyeska Seafoods, Inc. 

Greg Peters wrote: 

> Per your letter dated January 7, 2008, Alyeska is submitting the 

> attached data on its outfalls for the permit renewal application. 

> Your letter requested all data to be submitted by February 15th. 

> 

> Alyeska began pollock production on the evening of January 25th and 

> thus that is when our discharges began for the year. Samples Were 

> collected as soon as full production was reached and rushed to 8GB 

> environmental lab in Anchorage for analysis. All analysis has been 

> completed except for the total ammonia as N for outfall 001. The 

> laboratory has assured me again and again that the results will be 

> available soon, but they have had the samples for nearly 3 weeks now 

> and still have not provided the results of all the analyses. This 

> long time to provide results is not acceptable to us, but is outside 

> our control. We do not have the necessary laboratory equipment to 

> perform the analysis ourself. I talk to the laboratory manager on a 

> daily basis trying to get the results done, but there is always some 

> reason why the analysis isn't performed and it will be done within the 

> next day or two. So, I am submitting what I have and will provide you 

> with the remaining one item when I receive the analysis from the lab. 

> I talked with the lab manager again today, and they think the results 

> will be available this afternoon, but I thought I'd better send what I 

> have. 

> 

> For outfalls 002 and 003, the BOD, TOe, and Ammonia as N all were 

> below detectable limits of the test so I put ND (not detected) on the 

> sheets. 

> 

> Please let me know if there is any additional information you require 

> to complete the process for our NPDES renewal application. 

> 

> Best Regards, 

> 

> Dr, Greg Peters, Ph.D. 

> Director of Environmental Compliance 

> Alyeska Seafoods, Inc. 

> 

> Shum.Kai@epamail.epa.gov wrote: 

> 

» 
FinalN PD E S 

~ dalaF orm2C. pdf 
~ 

i?ec<?,,,,,') .2PS:/o-'t. 

~~_ ... _ .. _~,,_ .. ~ AK-OOOO27-2 

OUTFALL NO V. INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 Of Fonn 2-C) ()DJ. 

PART A-You must provide the results of at least one analysIS for every pollutant In thIS table Complete one table for each outfall See mstructlons for additional details. 

3. UNITS 4. INTAKE 

2. EFFLUENT (specifY if blank) (oplionafj 

h. MAXIMUM 30 DAY VALUE c. LONG TERM AVRG. VALUE a LONG TERM 

a. MAXIMUM DAllY VALUE (ifovailabie) (if available) AVERAGE VALUE 

(1) (1) d. NO. OF a. CONCEN- (1) b. NO. OF 

1. POLLUTANT CONCENTRATION (2) MASS CONCENTRATION (2) MASS (1) CONCEN:rRATION (2}MASS ANALYSES TRAT10N b. MASS CONCENTRATION (2) MASS ANALYSES 

a. Biochemical Oxygen 3245 88386 1921559 2177 48419 26 mg/l lbs. 8 mg/l 1 Demand (BOD) 

b. Chemica! Oxygen 6150 167000 3450000 3910 86200 26 mg/l lbs. Demand (COD) 

c. Total Organic Carbon 1330 36116 1 mg/l Ibs. (TOC) 

d. Total Suspended 

Solids 1945 53500 715247 1069 21300 26 mg/l Ibs. (TSS) 

e. Aplmonia (as N) ND 0 1 mg/l Ibs. 

VALUE VALUE VALUE VALUE f.Flow 3.362 75_56B 37.414 195 MG 

g. Temperature VALUE VALUE VALUE VALUE 

(<<,infer) 8.7 5.8 a.6 <6 'C 

h. Temperature VAlUE VAlUE VAlUE VALUE 

(summer) 13.8 10.7 8.6 97 ·c 

MINIMUM MAXIMUM MINIMUM MAXIMUM i. pH 6.90 7.19 26 STANDARD UNITS 

PART B- Mark 'X" in column 2--afor each pollutant you Icnow or have reason to believe is present MarlcAX" in column 2-bfor each pollutant you believe to be absent ffyou mark column 2ator any pollutant which is limited either 

directly, or indirecUy hut expressly, in an effI-uent limitations guideline, you must provide the results of at least -one analysis for that pollutant For other ponutants for which you mark column 2a, you must provide 

quantitative data or an explanation of their presence iO your dlschar:ge. Complete one table for each outfall. See the instructions fur additional details and requirements. 

2. MARK "X" 3. EFFLUENT 4. UNITS 5. INTAKE (optioilaf) 

1. POLLUTANT b. MAXIMUM 30 DAY VAlUE c. LONG TERM AVRG. VALUE , a.LONG TERM AVERAGE 

AND a b. 3. MAXIMUM DAlLY VALUE (if Ol'aifahJe) (if availahle) VALUE 

CAS NO. BELIEVED BELIEVED (1) (1) (') d.NO.OF a CONCEN· (1) b. NO. OF 

(if available) PRESENT ASSENT CONCENTRATION (2) MASS CONCENTRATION (2) MASS CONCENTRAnON (2) MASS ANALYSES TRATfON b. MASS CONCENTRATION (2) MASS ANALYSES 

, 

a Bromide 

(24959-57-9) X b. Chlorine. Total X 0.03 Q.66 0.001 0.02 112 mg/l Ibs.- Residual 

c. Color X d. Fecal Coliform X 

I;. Fluoride 

(16984-4B-8) X 

f. Nitrate-Ni1rlte 

(aiM) X EPA Form 3510-2C (8-90) PAGEV-1 CONTINUE ON REVERSE 
~ 

'Keco·,"'.,! 2/15/ v& 

AK-OOOO27-2 --- - -- - ._. OUTFALL NO 

V INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 of Form 2-C) 002 

PART A -You must provide the results of at least one analysIs for eNery pollutant In thiS table. Complete one table for each outfall See instructions for addJtionaL details. 

3, UNITS 4. INTAKE 

2. EFFLUENT (specify ifblollk) (optional) 

b. MAXIMUM 30 DAY VALUE c. LONG TERM AVRG. VALUE a. LONG TERM 

a. MAXIMUM DAilY VAlUE (if available) {if availnblt:} AVERAGE VALUE 

(1) , (1) d. NO. OF a. CONCEN- (1) b. NO.OF 

1. POLLUTANT CONCENTRATION {2}MASS CONCENTRATION (2) MASS (1) CONCENTRATION (2) MASS ANALYSES TRATION b. MASS .CONCENTRAnON (2) MASS ANALYSES 

a. Biochemical Oxygen ND 0 1 mg/I Ibs. Demand (BOD) 

b. Chemical Oxygen 173 1003 1 mg/I Ibs. Demand (COD) 

c. Total Organic Carbon 4.51 26.1 1 mg/l Ibs. (TOC) 

d. Total Suspended 

Solids ND 0 . 1 rug/I Ibs. (188) 

e. Ammonia (as N) ND 0 1 mg/l ibs. 

VALUE VALUE VALUE VALUE f.Flow 0.83 23.843 0.70 245 MG 

g. Temperature VALUE VALUE VALUE VALUE 

(Wimer) 11.7 4.3 2"5 ·c 

h. Temperature VALUE VALUE VALUE VALUE 

(summer) 19.4 12.2 245 'C 

MINIMUM MAXIMUM MINIMUM MAXIMUM 0 

1. pH 7.99 8.12 2 STANDARD UNITS 

- PART B - Mark "X· in column 2-a for each pollutant you know or have reason In believe is present Mark ·X" in column 2-b for each pollutant you believe to be absent Jfyou mark column 2a for any pollutant which is limited either 

directly, or indirectly but expressly, in an effluent limitations guiderlOe, you must provide the results of at least one analysis for that pollutant For other pollutants for which you mark column 2a, you must provide 

quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additional details and requirements. 

2. MARK"X~ 3 .. EFFLUENT 4. UNITS 5./NTAKE (optionaT) . 

1. POLLUTANT b. MAXIMUM 30 DAYVA~UE c. LONG TERM AVRG. VALUE a. LONG TERM AVERAGE 

AND a b. a. MAXIMUM DAILY VALUE (if available) (ifavai!able) VALUE 

CAS NO. BEliEVED BELIEVED (1) (1) (1) d. NO. OF a'. CONCEN- (1) b. NO. OF 

(if avai/able) PRESENT ABSENT CONCENTRAnON (2) MASS CONCENTRATION (2) MASS CONCENTRATION (2) MASS ANALYSES TRAnON b. MASS CONCENTRATION (2) MASS ANALYSES 

a. Bromide 

(24959-67~S) X b. Chlorine, Total 

Residual X c. Co/or X d. Fecal Colifonn X e. Ruoride 

(16984-48-8) X If. Nitrate-Nilrite 

i(asN) X , 

EPA Fonn 3510-2C (8-90) PAGE V-1 CONTINUE ON REVERSE 
'i{Qcei"'ol ::zl/~/(}t 

~~~ ... ~ .. ,~~ .. ~ .. ~. 

~ 

AK-OOOO27-2 

OUTFALL NO. 

V. INTAKE AND EFFLUENT CHARACTERISTiCS (continued from page 3 of Form 2-C) 

'" PART A-You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details. 

3. UNITS 4. INTAKE 

2. EFFLUENT (specifY ifblollk) (QP/fonal) 

b. MAXIMUM 30 DAY VALUE c. LONG TERM AVRG. VALUE a.lONGTERM 

a. MAXIMUM DAILY VALUE (ifovoilable) (if available) AVERAGE VALUE 

(j) (1) d. NO. OF a. CDNCEN- (1) b, NO. OF 

1. POLLUTANT CONCENTRATION (2) MASS CONCENTRATION (2)MAS$ (1) CONCENTRATION (2) MASS ANALYSES TRATION b. MASS CONCENTRATION (2) MASS ANALYSES 

a Biochemical Oxygen ND 0 l mg!l Ibs. Demand (BOD) 

b. Chemical Oxygen l66 83l l mg/l Ibs. - Demand (COD) 

c... Total Organic Carbon 3.66 18.3 l mg/l Ibs. (TOq 

-d. Total Suspended 

Solids ND 0 l mg/l .lbs. (1SS) 

e. Ammonia (as N) ND 0 l mg/l Ibs. 

VALUE VALUE VALUE VALU,E f. Flow 0.6 0.6 l MG Ibs. 

g. Temperature VALUE VALUE VALUE VALUE 

(winter) 6.l 3 ·c 

h. Temperature VALUE VALUE VALUE VALUE 

{summer} 12.2 2 ·c 

MINIMUM MAXIMUM MINIMUM MAXIMUM i. pH 8.02 8.08 2 STANDARD UNITS 

PART 8- Mark ~X"in column 2-a for each po!lutantyou know or have reason to believe is present Mark ~X" in column 2-b for each pollutant you believe to be absent !fyou mark column 2a for any pollutant which is limited either 

directly. or indirectly but expressly, in an effluent limitations guideline. you must .provide the results of at least one analysis for that pollutant For other pollutants for which you mark colunm 2a, you must provide I 

quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additional details and requirements. 

2. MARK~XP 3. EFFLUENT 4. UNITS 5. INTAKE (optional) , 

1. POLLUTANT b. MAXIMUM 30 DAY VALUE c. LONG TERM AVRG. VAlUE a. LONG TERM AVERAGE 

AND a b. a. MAXIMUM DAILY VAlUE (if OVa/table) (if available) VALUE 

CAS NO. BELIEVED BEL1EVED (1) (1) (1) d.NO_OF a. CONCEN- (1) b. NO. OF 

(ifal'Uilable) PRESENT ABSENT CONCENTRATION (2}MASS CONCENTRAT1ON (2) MASS CONCENTRATION (2}MASS ANALYSES TRATION b. MASS CONCENTRATION (2) MASS ANALYSES 

a. Bromide 

(24959--67-9) X b. Chlorine, Total 

Residual X o Colo, X d. Fecal Coliform X e. Ruoride 

(16984-48-8) X 1. Nitrate-Nitrite 

(~N) X . EPA Form 3510-2C (8-90) PAGE V-1 CONTINUE ON REVERSE 
Reply to 

Attn Of: OWW-130 

Dr. Greg Peters 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 10 

1200 Sixth Avenue 

Seattle, WA 98101 

January 7, 2008 

Director of Environmental Compliance 

Alyeska Seafoods, Inc. 

P.O. Box 31359 

Seattle, W A 98103 

Re: Renewal of National Pollutant Discharge Elimination System (NPDES) Permit 

For Alyeska Seafoods, AK-0000272 

Dear Dr. Peters: 

This letter responds to your e-mails dated December 24th and 31st, 2007. The 

Environmental Protection Agency (EPA) has previously received the above referenced 

NPDES application materials dated September 11, 2007. We completed our review of 

the application in a letter dated December 5, 2007, and in which EPA has determined that 

the application was incomplete with explanations of missing items. . 

EPA understands the following explanations from your e-mails. Outfall 001 will 

be restarted in January 2008, at which time, samples can be taken to fill-in the missing 

portions of the application. EPA also understands that Outfalls 002 and 003 discharge 

non-contact cboling water (seawater) that should not contain any added. contaminant and· 

material other than heat. EPA also understands that Outfall 004 has never been used and 

no data has been collected from this outfall. 

It is necessary to perform the required sampling requirements for Outfalls 001, 

002, and 003 as detailed in EPA's letter dated December 5, 2007. It is necessary to 

conduct the sampling f(jfdischarges of non-contact cooling water because they are 

required in the permit application, and because EPA has found from past experience that 

. there were examples of discharges of non-contact cooling water that actually contained 

substantial amounts of unexpected contaminants. 

Given these circumstances, by February 15, 2008, please submit the missing 

information for Outfalls 001, 002, and 003 that had previously been detailed in EPA's 

letter of December 5th, 2007. When the missing information is submitted, the application 

will be deemed complete. According to the federal regulation at 40 CFR 122.6(a), when 

a timely and complete application is received by EPA, and through no fault of the 

permittee, EPA does not reissue a new permit prior to the expiration date of the· existing 

permit, then the permit remains fully effective and enforceable. Therefore, your existing 

permit will remain effective and enforceable until a new permit is issued to your facility. 
2 

Please note that EPA may request additional information during the development 

of the draft pennit to clarify, modify, or supplement previously submitted material. If you 

have any questions, please contact Mr. Kai Shum at (206) 553-0060. 

Sincerely, 

'171 ~d! c:<~:~/ ~ Michael J. Lidgard, ager 

NPDES Pennits Unit 

cc: Frances Roche (ADEC) 

Greg Peters 

<Petersg@arctic.net> 

12/31/2007 02:33 PM 

To Kai Shum/R10/USEPNUS@EPA 

cc "Roche. Frances E (DEC)" <fran.roche@alaska.gov>. 

Michael Lidgard/R10/USEPNUS@EPA, Lindsay 

Guzzo/R10/USEPNUS@EPA . 

bcc 

Subject Re: Alyeska Seafoods Permit Renewal 

The outfall 001 will start up in January and I can take samples then and 

mail them out for the parameters we have never measured nor been 

required to measure before. We do not have the capability to measure 

these parameters in our industria~ lab because we do not have the 

necessary equipment. Outfalls 002 is just seawater which is used to cool 

our generators and is running all the time. There is nothing added 

besides heat, so there is nothing different chemically than the seawater 

we take iu, but if EPA thinks this necessary to test for all the 

parameters, I'll send the seawater out for analysis. Outfall 003, 

likewise is pretty much seawater used for,non-contact scrubbing and 

condensing and· I can do the same thing with that outfall if EPA thinks 

it is necessary. 

I am assuming that since you didn't mention outfall 004 for which there 

has been no discharge, you will not require parameters for this outfall? 

I am still unsure why EPA now needs the requested information that has 

never been required nor requested before in over 20 years of operation 

and several permit cycles, but I will do my best to gather the requested 

information as soon as possible. 

Greg Peters 

Alyeska Seafoods, Inc. 

Shum.Kai@epamail.epa.gov wrote: 

>Dr. Peters, 

> 

>With regards to your e-mail below, when does the company plan to 

>re-start outfalls 001, 002 and 003? Also, when will it be possible to 

>submit the required data? This information needs to be obtained as 

>required by the application, 

> 

>Kai Shum 

>NPDES Permits Unit 

>U.S. EPA Region 10 

> 

> 

> 

> 

> 

> 

> 

> 

> 

> 

> 

> 

> 

Greg Peters 

<Peter-sg@arctic. 

net> 

12/24/2007 11:33 

AM 

To 

Kai Shum/R10/USEPA/US@EPA 

cc 

Michael Lidgard/R10/USEPA/US@EPA, 

HMcKerney, Mary Kate (DEC) 11 

<katy.mckerney@alaska.gov> 

. Subject 
> 

> 

> 

> 

> 

> 

> 

> 

> 

> 

> 

Alyeska Seafoods Permit Renewal 

>Alyeska received your letter of December 5, 2007 stating that our 

>permit renewal was incomplete pert~ining to 40 CFR 122.21. 

> 

>I have a few comments/questions about your list of requested 

>information. 

> 

>For requests 1 through 3, EPA is requesting data from Outfalls 001, 002, 

> 

>and 003 that it has never collected, is not part of the current permit, 

>and has never been included on any permit application in the past. 

>Information such as chemical oxygen demand, total organic carbon, and' 

>ammonia has never been a required part of our monitoring program. Other 

> 

>information such as Biochemical oxygen dern0nd, total suspended solids, 

>pH, and temperature have never been part of certain outfalls so no data 

>18 available. If EPA considers this information necessary to renew the 

>permit, we can send samples to an outside lab for analysis once 

>production begins again, but we don ' t understand the necessity for the 

>information that is not part of the permit requirements and has never 

>been required before. 

> 

>My second comment is related to your request 4 and 5 for information on 

>outfall 004. This outfall is for at-sea discharge of processing 

>wastewater, seafood waste, or stickwater. We have not used this 

>discharge so there is no way we could collect data on the effluent 

>characteristics. This outfall is a permitted back-up in cas,e we 'have a 

>problem with our meal plant or another outfall, or if we need to barge 

>waste to meet permit limitations. This has not been necessary so far sO 

> 

>there has been no discharge. I am unsure as to how to provide the 

>requested effluent information on non-existent discharges. Will you 

>please advise on what specifically I should do regarding this request? 

>1 can't really put together what could be discharged because it would 

>depend on what the problem would be. If our meal plant breaks down, the 

> 

>outfall would include ground fish waste. If our main outfall has a 

>leak, 004 will contain screened processing wastewater. If the ambient 

>water conditions develop low oxygen conditions, outfall 004 will be 

>stickwater. I am unsure how to proceed with this request. Please 

>advise. 

> 

>Thanks. I would like to provide EPA with the necessary information it 

~>requires for Alyeska ' s permit renewal, but I am unsure about how to 

>proceed. 

> 

>Best Regards, 

> 

> 

>Dr. Greg Peters, ph.D. 

>Director of Environmental Compliance 
>Alyeska Seafoods, Inc. 

> 

> 

> 

> 

> 
Greg Peters 

.<Petersg@arctic.net> 

12/24/2007 11 :33 AM 

To Kai Shum/Rl0/USEPAlUS@EPA 

cc Michael Lidgard/Rl0/USEPAlUS@EPA, "McKerney, Mary 

Kate (DEC)" <katy.mckerney@alaska.gov> 

bCG 

Subject Alyeska Seafoods Permit Renewal 

Alyeska received your letter of December 5, 2007 stating that our 

permit renewal was incomplete pertaining to 40 CFR 122.21. 

I have a few comments/questions about your list of requested information. 

For requests 1 through 3, EPA is requesting data from Outfalls 001, 002, 

and 003 that it has never COllected, is not part of the current permit, 

and has never been included on any permit application in the past. 

Information such as chemical oxygen demand, total organic carbon, and 

ammonia has never been a required part of our monitoring program. Other 

information such as Biochemical oxygen demand, total suspended solids, 

pH, and temperature have never been part of certain outfalls so no data 

,is available. If EPA considers this info~mation necessary to renew the 

permit, we can send samples to an outside lab for analysis once 

production begins again., but we don!t understand the necessity for the 

information tha~ is not part of the permit requirements and has never 

been required before. 

My second comment is related to your request 4 and 5 for information on 

outfall 004. This outfall is for at-sea discharge of processing 

wastewater, seafood waste, or stickwater. We have not used this 

discharge so there is no way we could collect data on the effluent 

characteristics. This outfall is a permitted back-up in case we have a 

problem with our meal plant or another outfall, or if we need to barge 

waste to meet permit limitations. This has not been necessary so far so 

there has been no discharge. I am unsure, as to how to provide the 

requested effluent information on non-existent discharges. Will you 

please advise on what specifically I should do regarding this request? 

I can!t really put together what could.be discharged because it would 

depend on what the problem would be. If our meal plant breaks down, the 

outfall would include ground fish waste. If 'our main outfall has a 

leak,' 004 will contain, screened processing wastewater. If the ambient 

water conditions develop low oxygen conditions, outfall 004 will be 

stickwater. I am unsure how to proceed with this request. Please advise. 

Thanks. I would like to provide EPA with the necessary information it 

requires for Alyeska's permit renewal, but I am unsure about how to proceed. 

Best Regards, 

Dr. Greg Peters, ph.D; 

Director 'of Environmental Compliance 

Alyeska Seafoods, Inc. 

" . 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 10 

Reply to 

Attn Of: OWW-130 

Mr, Sinclair Wilt 

Vice President 

Alyeska Seafoods, Inc, 

P,O, Box 31359 

Seattle, W A 98103 

1200 Sll<1h Avenue 

Seattie, WA 98101 

December 5, 2007 

Re: National Pollutant Discharge Elimination System (NPDES) Permit Application for 

Alyeska Seafoods, Inc, (NPDES ID Number: AK-OOOO27-2) 

Dear Mr. Wilt: 

The Environmental Protection Agency (EPA) has received and reviewed the above 

referenced NPDES application dated September II, 2007 . EPA has determined that the 

application is incomplete pertaining to 40 C.F.R. Section 122.21, with the following 

comments below. 

1. NPDES Application Form 2C, for Outfall No. 001. Page V-I. Part A. 

Please provide the missing data for the listed pollutants (b) to (i). 

"2. NPDES Application Form 2C, for Outfall No. 002, Page V-I. Part A. 

Please provide the missing data for the listed pollutants (a) to (i). 

3, NPDES Application Form 2C, for Outfall No. 003, Page V-I. Part A. 

Please provide the missing data for the listed pollutants (a) to (i). 

4. NPDES Application Form 2C. for Outfall No. 004, Page V-I. Part A. 

Please provide the missing data for the listed pollutants (a) to (i). 

5. NPDES Application Form 2C, for Outfall No. 004. Page V-2, Part B(h) 

Please provide the missing data for "Oil and Grease". 
2 

Note that after receipt of a complete application, EPA may request additional information 

during the development of the draft permit to clarify, modify, or supplement previously 

submitted material. If you have questions, please contact Mr. Kai Shum of my staff at 

(206) 553-0060. 

Sincerely, 

·:~e.e NPDES Permits Unit 

2