1 Site Visit Report Alaska Seafood Processing Industry Petition Response

Lindsay Guzzo Environmental Engineer U.S. Environmental Protection Agency Region 10 Permits Division guzzo.lindsay@epa.gov

206-553-0268 Betsy Bicknell Senior Environmental Engineer Eastern Research Group, Inc. (ERG) betsy.bicknell@erg.com

703-633-1612

Plant Name Trident Seafoods, Cordova South

Plant Address Cordova, Alaska

NPDES Permit # AKG520491

Date of Visit Thursday, August 19, 2010 People Contacted William S. (Bill) Gilbert, Plant Manager Jeremy Mallett, QA Manager

Seafood processed Salmon (all five species)

Halibut Cod (black, grey, and Pacific)

Rockfish Products Fresh and frozen (fillets and H&G) Salmon roe (ikura an sujiko) Range of annual production volume 7 to 14 million pounds per year (lower production in odd years, due to pink salmon life cycle) Months of operation March - October Discharge type Grind and discharge Company Website www.tridentseafoods.com

The Trident Seafoods Cordova South plant ha s had several owners. It began as the Copper River Cooperative. It was then owne d by Silver Lining Seafoods who merged with Lafayette. In 1994 NorQuest Fisheries bought the plant. Th ey sold it to Trident in 2004. Mr. Gilbert began working at the plant in 1993, as Cordova was recovering from the Exxon Valdez oil spill 1 . Mr. Gilbert noted that when he started, the plant processed about 4 million pounds per year of salmon and herring. The herring fisheries were wiped out by the Exxon Valdez oil spill and have not recovered. The last herring season was in

1996.

Operations. In 2010, Trident South processed all fi ve species of salmon, halibut, cod (black, grey, and Pacific), and rockfish. Sa lmon typically represents about 3⁄4 of their production. In 2009, they processed 7.5 million pounds of salmon out of total production of 14 million pounds. In 2010 they processed about 10 million pounds of salmon.

Most (70%) of their pr oduction is shipped to the conti guous U.S. They produce fresh and frozen products, mostly whole fish (H&G), some fillets, and some block frozen products. The percentage of their production that is fi llets has increased every year since they

1 The Exxon Valdez oil spill occurred in Prince William Sound, Alaska, on March 24, 1989. The spill did not reach Cordova but did affect the fishing grounds fished by Cordova fisherman.2 started producing frozen fillets five years ago. With the change to producing fillets, the

amount of waste has increased. This chal lenges Trident and other producers to find alternative products to get to total utilization of the harvested fish.

The species processed change. Every year it is a slightly different mix. In 2009 they processed 1 million pounds of grey cod. They al so began selling cleaned and frozen black cod collars to Japan.

Mr. Gilbert explained that Trident Cordova South does more “money” (high value) fish, while Trident Cordova North processes larg e volumes of pink and chum salmon. But Trident Cordova South began processing pink salmon in 2008 and 2009. This is because pink salmon production in Prince William Sound has increased. He noted that pink salmon harvests are lower in odd years than even years, due to the salmon life cycle. This

is documented in historical records from the 1930s on. Hatcheries were built in the 70s

and 80s to even out the salmon returns by increasing production in the years of nonabundance.

Increasing Yield. Trident South is continuously l ooking for ways to sell a higher percentage of each fish processed. The sell Pacific cod heads, halibut cheeks, and sockeye salmon frames and bellies. They plan to add a mincer in 2011 to recover fish from frames and may inject mince into the fill ets. When the mincer is in place, they may make other products like salmon bur gers and block-frozen products.

Waste Management. In 2010, Trident South trucked al l of its salmon heads to the Trident North by-product recovery plant. In 2011 they plan to truck the frames as well. They may also truck black cod heads. Trident Cordova South processes 400,000 to 500,000 pounds of black cod per year, resulting in 40,000 pounds per year of heads. The heads are more than 3% oil, so it may be po ssible to recover the c od head oil profitably. In 2010, Trident froze a batch of cod head s and will process them at the by-product recovery plant at the end of the season to determine the effect of freezing on oil quality.

Mr. Gilbert said that collecting the salmon head s to iced totes and trucking them to the recovery plant requires minor additional cost s. He estimates that the labor demand was not more than two additional jobs, including dr iving the truck to th e by-products plant. The incremental cost per pound of fish is minimal.

Mr. Gilbert recalled that fo r years, Cordova wanted to build a cooperative (public) oil/meal plant but they could not find fi nancing. Trident, a huge company, bought the Bear and Wolf cannery and was able to fina nce their own by-products recovery plant.

Plant Tour. Jeremy Mallett provided Ms. Guzzo a nd Ms. Bicknell with a tour of the Trident Cordova South plant.

Groundfish (i.e., fish other than salmon) ar e off-loaded from the fishing boats and repacked into totes of slush ice. Figure 1 shows a tote containing fish waiting to be processed. Salmon is pumped onto the sorting tabl e, where it is separated by species, then3 packed into iced totes. Fish are weighed, l ogged in, and each tote is tagged with a code that provides complete traceability to the boat th at delivered it. Mr. Mallett explained that storing fish in totes provides be tter temperature control. If the temperature gets below 34° F the roe will begin to freeze and be damage d. The totes are unloade d in a deicing bin and the contact ice is routed to the plant sump and discharged through the outfall. They do not use refrigerated sea water tanks.

Fork lifts transfer the tote s into the plant and they are moved around inside the plant using a pallet jack. Fish are de-headed using a foot-operated header. Heads drop into an

iced bin. Figure 2 shows a iced tote filled with fish h eads. Before the heads were used in the by-products plant, they were flumed in to a grinder and pumped to the outfall.

Waste is hosed into floor drains ( Figure 3 ). All drains in the but chering area flow to a common sump equipped with four Vaughan chopper pumps ( Figure 4 ). From the sump, the wastewater passes through a Muffin Mons terTM before it is discharged through the

outfall.

Roe is recovered from headed hand butchere d fish. Trident Cordova South makes several roe products:

 Frozen green (unbrined) roe;

 Sujiko (brined sockeye roe skeins); and

 Ikura (brined separated chum roe).

After rinsing the fish are graded by size and quality. They are eith er frozen whole or further processed in one of four fillet lines, one for Pacific cod and three for salmon. Each line is equipped with a three-pi ece splitter (splits the whole fish into two fillet halves and the frame). Some sockeye frames and bellies are frozen, but what is not sold is ground and discharged through the outfall. Figure 5 shows the processing line.

The fillets are de-boned in a pin bone m achine followed by manual removal of the remaining pin bones. This step is followed by grading (and some trimming), and secondary grading (by color). For frozen produc ts, the fillets are lo aded into freezer racks. The racks are tagged with boat load number. This number will be included in the lot number that appears on the product label. The fillets are flash-frozen in one of three

blast freezers. Trident Cordova South can freeze up to 150,000 pounds of fish per day (depending on the size of the fish: larger fish require a longer freezing time and that will reduce through-put). From the freezer, fish are glazed and boxed or vacuum packed. Glazed, vacuum packed fillets have a 2-year shelf life. Legally, the glaze can account for 5 to 7 % by weight of H&G product.

Some products are packed into boxes and bl ock frozen. These products include roe, frames and bellies, Pacific cod trim, and cod roe and milt (that are produced in March and April). An overview of the processing area is shown in Figure 6.4 Boxed frozen fish are loaded into refriger ated vans. Trident Cordova South has six van stalls but typically use only th ree to four at a time to preven t bottle necks. They typically ship three vans/day of frozen product, including roe and pink salmon. The vans are loaded into barges or ships and routed to Europe and other destinations.

Fresh product is shipped by air (Alaska Airl ines cargo planes) to Seattle and other

destinations.

Figure 1. Fish tote5 Figure 2. Iced fish heads

Figure 3. Floor drain6 Figure 4. Waste chopper pumps

Figure 5. Processing line7 Figure 6. Trident Cordova South Plant Overview