# Ketchikan Seafood Processors

Waste Pile and Water Column Studies

2001

Report by Kenwyn George, P.E., Environmental Engineer State of Alaska Department of Environmental Conservation

December 20, 2001Table of Contents

Executive summary ............................................................................................................. 1

Introduction .................................................................................................................. ....... 1 Purpose of study .............................................................................................................. .... 3 Study Methodology ............................................................................................................. 3 Original Proposal ............................................................................................................. ... 3

Results of the dive studies................................................................................................... 4

Water body dive surveys, June 22 and 23, 2001 ............................................................. 4

Wards Cove/E.C. Phillips and Norquest. ..................................................................... 4

Trident and Alaska General Seafoods .......................................................................... 5 Water body dive surveys, July 30 and 31, 2001 .............................................................. 5 Sampling surveys .............................................................................................................. .. 6 Summary of sampling results.............................................................................................. 7

Conclusions ................................................................................................................... .... 10

Recommendations ............................................................................................................. 1 1 Photographs: .................................................................................................................. ... 12Ketchikan seafood waste pile studies report.doc Page 1 Executive summary

Dive and sampling studies were conduc ted prior to and during the 2001 seafoodprocessing season in Ketchikan. The purpos e was to see whether seafood wastes resuspended above waste piles from pile draggi ng operations resulted in a violation of the Alaska Water Quality Standards. Video cove rage of suspended wastes was not possible during dragging operations for safety reasons, but diver swimming action did demonstrate the magnitude of seafood waste re-suspension. Video footage of wastes discharged during normal outfall operation showed suspended wastes orders of magnitude greater than that from dragging ope rations. Sampling results did not show any concerns related to dragging operations, but did show that during normal operation the plume extended beyond the 100-foot mixing zone boundary.

Introduction

Seafood processing has been a major industry in Ketchikan for many decades. There are five processors, one in Wards Cove six miles to the northwest of th e city, and four near

downtown Ketchikan. Those downtown are lo cated in pairs to the northeast and southwest of the center of town, the tw o processors, Wards Cove/E.C. Phillips and Norquest to the northeast are a mile or so from downtown and comprise the two lowervolume processors. Those to the southwes t, Trident Seafoods and Alaska General Seafoods, are closer to downtown; they ar e the larger-volume processors. The two processors in each pair are in close proximity to each other, and the pairs of processors are approximately a mile apart.

Historically, processing wastes have been discharged directly to the sea floor of Tongass Narrows. The piles to the northwest are at a depth of approximately 40 to 60 feet, and those to the southwest are at a depth of 50 to 100+ feet. Each smaller processor pile

receives between 2 and 4 milli on lb of seafood waste annually; each larger processor pile receives between 5 and 11 million lb waste per year. The piles that the wastes discharge to are called Zones of Deposit, or ZODs. The exact amount discharges each year is dependent on the abundance of fish to be processed.

In both 1998 and 1999 the volume of fish proces sed was high. In 1999, at low, low tides, gasses formed within the pile from the d ecomposition of seafood wastes rose to the surface, as did decomposing seafood waste. Th is occurred at low, low tides because the head of water and associated water pressure were least at that time. The gas, hydrogen sulfide, and the decomposing wastes br ought unacceptable foul, obnoxious and nauseous odors to the downtown community, where there are cruise ships doc k, tourists, tourist shops, commerce and residences.

In order to prevent the reo ccurrence of off-gassing, the companies discussed ideas with the regulatory agencies and determined that dragging the piles with chains suspended from a heavy frame might help the situa tion. Dragging chains through piles had been shown to effectively reduce the size of a pile at the Alyeska facility in Dutch Harbor inKetchikan seafood waste pile studies report.doc Page 2 1997 and 1999. It is surmised that aerobic bact eria were introduced to the pile, and that these are far more efficient at breaking down wastes than anaerobic bacteria.

In order to conduct the pile dragging, Trident and Al aska General Seafoods both manufactured devices with heavy steel cros sbeams and heavy chains. The Trident unit had two chains that hung down in two loops, whereas Alaska Genera l had five straight lengths of chain with heavy weights at the ends (see photographs). During periods of high processing activity, the piles were dragged daily.

Currently, all the operators in Ketchika n operate under the EPA General Permit for Seafood Processors. During the years 1999 through 2001 permit conditions were formulated for the renewal of this permit, and DEC certified the permit for compliance

with Alaska water quality standards.

During this period, 1999 through 2001, complaints were received from members of the public, not only about the foul gasses a nd decomposing wastes, but also about decomposing entrails and other fish parts collecting on the shorel ine where houses were located, and on boat haul lines.

In order to try to reduce or eliminate these problems, Tr ident brought a meal plant to Ketchikan for August 2001, the busiest month. Alaska General Seafoods barged their wastes to a point 15 miles southeast of Ketchi kan, just south of Bold Island, in deep water

and 1-mile off shore.

Both processors wanted to drag chains through the piles during the 2001 season in order to ensure no off-gassing would occur. It wa s also hoped that the si ze of the piles would be reduced by the dragging operations, because they exceeded the 1-acre limit specified

in the General Permit.

EPA was concerned that the dragging ope ration would re-suspend solids and cause a violation of State Water Quality standards. In order to determine whether this in fact occurred, a dive study was proposed that would show whether these solids were likely to be re-suspended; this was termed the drag dive study.

In order to determine the magnitude of re -suspension by dragging operations and whether

or not there was a violation of water quality standards, it wa s decided that dives would be conducted immediately before and after the dragging. This was to occur both prior to the operating season and just after it. It should be noted that the General Permit does allow a 100-foot radius mixing zone. Water quality st andards can be exceeded in this area for the whole depth of the water body, but water quality standards are to be met outside of this zone. If pollutants are discharged such that they could cause a wa ter quality violation outside the mixing zone, then limits can be placed in the permit to prevent this from occurring. In order to determine impacts beyond the mixing zone boundary, water quality samples were taken.Ketchikan seafood waste pile studies report.doc Page 3 Because seafood wastes are detrimental in some ways, e.g., they totally eliminate benthic communities within the ZOD, yet are also a be neficial source of food, a study was needed

to consider the overall burden or benefit to the water body. In order to do this, a dive study was planned to take place while operati ons were under way, during the busy part of the season, in August. This was cal led the “Water Body” dive study.

Purpose of study

The main purpose of the study was to see whether seafood particle s were re-suspended during dragging operations, and carri ed outside of the mixing z one. It was also to show the effects of dragging chains over the piles. The survey was also to note changes in aquatic life near and over the piles, then compare this data with locations remote from the piles, but within the same water body.

Study Methodology

Both sampling and dive events were planne d. Three sampling events were scheduled. One during each of the drag operations be fore and after processing, and one during processing and discharge, but not while drag ging. The parameters checked were TSS, SS, BOD, COD, DO, temperature and salinity. A Secchi disk wa s to be used to determine light transmissivity.

Original Proposal

The original proposal, conducted to indicate water quality im pacts, stated the following:

Pile dragging studies:

There are two pairs of piles, Trident Seafoods and Alaska General Seafoods, and Norquest and EC Phillips. One proposal would be to dive on one pile in each pair on one day, then dive on the other pile in each pair another day (possibly the ne xt day). An alternate proposal is to drag both piles in one pair one day, and the othe r piles in the other pair another day.

The dives shall be conducted both before and after the dragging operations. Proposal for sequencing dragging, sa mpling and diving:

Pre-drag survey both piles in one pair. Drag the down-current pile, place drogues and st art sampling 5 minutes after start of drag. Drag the pile for the normal time piles are dragged. Conduct the post-drag dive on this pile. Drag the up-current pile after diver returns from first post-drag survey. Sample as before. Conduct the post-drag dive on this pile.

Note: Dive survey information:

The size of the pile need not be determined.Ketchikan seafood waste pile studies report.doc Page 4 The purpose of this dive is to see the effects of dragging on the pile and the area surrounding the pile. Video and take still photos of the pile and the area around the pile affected by dragging operations (i.e. to where material spreads out). The still photos must be able to show detail clearly, e.g. worm holes, clams, etc. Take at least 6 photos around the perimeter and 6 of the pile that show typical effects from the dragging operation. Determine the thickness of the material spread out by the dragging opera tion, and the extent to which it was dragged out. Determine this in (say) six locations.

Water body dive studies:

One water body dive study shall be conducted for each pair of piles, once only during the processing season. The dive studies are to be done during typical processing, e.g. one mont h after processing has commenced, or around early August.

The water column dives shall be vertical di ves through the water colu mn to the sea floor, provided the sea floor is at 100 feet or less.

There will be 5 dive stations to each side of each pair of piles. From the up-current and downcurrent edges of each pair, the stations shall be, from the pile, at 50’, 100’, 200’, 400’ and 600’. The diver shall descend to 10 feet, th en take a 360-degree video shot.

He shall then descend to 60 feet and take anothe r 360-degree video shot, or take this at the sea

floor if the sea floor is at less than 60 feet. He shall then descend to the bottom, if the bottom is less than 100 feet deep. Here still photographs will be take to show life on the sea floor. The still photos must be able to show detail clearly, e.g. worm holes, clams, etc. A video will be taken if it shows anything additional to the 60-foot depth level.

Should the diver consider it worthwhile to take still photographs at the 10’ and 60’ depths, then

these shall be taken. GPS readings shall be taken of each dive location in order to repeat a dive in approximately the same location at some future date, sh ould that be necessary or desired.

Results of the dive studies

Water body dive surveys, June 22 and 23, 2001

Wards Cove/E.C. Phillips and Norquest.

These two plants were not in a “Pre-season” mode. They were processing wastes prior to the drag study, but ceased operations for a fe w hours while the dive study was conducted. The pre-drag dive occurred on J une 22. It could be seen that the wastes were easily resuspended by the diver and his flippers. When the diver looked back to where he had just swum, large clouds of debris rose into the water column, several of the pieces could be seen to be a few inches long. Fish were observed swimming over the pile, indicating that

there was not a dissolv ed oxygen problem.Ketchikan seafood waste pile studies report.doc Page 5 For the Wards Cove/E.C. Phillips pile, the ba r and chains were dragged through the pile for about 20 minutes, or eight times. The dr agging commenced at 3:00 p.m. on June 23, 2001. Low tide that day was at 3:25 p.m. Three transects were swum. After the dragging operation using the straight ch ains with heavy balls on the end, grooves approximately 6 inches deep by 5-inches wide could be seen. The greatest depth of the pile was around 6 feet. The edge of the pile at the boundary could be clearly seen, with the depth at the boundary approxima tely 1.5” to 2”. It did no t look like there was debris beyond the pile; possibly tidal currents sweep cl ean the waste material outside the ZOD.

Because the dive occurred at slack water, there was very little current. Also, it is said that there is an eddy at this loca tion and that the currents are far lower here than at the Trident/Alaska General piles.

The Norquest pile was similarly dragged 7- 8 times on June 23, between 4:15 and 4:45 p.m. Again, there was little current at the pile, seafood wastes were re-suspended by the diver, and as clouds of waste ro se around him, visibility dropp ed to about one foot. After the dragging, a few grooves could be seen about 12” or so deep. This pile was also dragged with the straight chains with heavy balls at the ends. No material was observed dragged beyond the pile boundary, nor drifte d there by the operat ion. One of the transects was along the periphery of the pile.

Trident and Alaska General Seafoods

These two processors had not commenced processing, so the study was a “preprocessing” survey. The first attempt at a pr e-drag dive was the morning of June 22, but because there was a 17’-6” tide (this means th ere was a large tidal range, and movement of water in Tongass Narrows), the current was too strong, running at approximately 3 knots. The depth of water over the pile was 90 to 108 feet. The di ve was next conducted the following morning at 7 am on the Trident p ile. The depth to the pile was 70 feet. It was determined that the discharge pipe had been caught and turned by a ship’s anchor such that it formed a big loop. The pile ha d been spread because of that. The pile appeared to be flat, the depth at the pile varied from 93 to 111 feet. Because of the depth, the diver was able to swim only one transect approximately 110’ long, for a total of 9 minutes. The pile had a gray appearance. A cl oud of fine material, with a few 1” or so sized pieces rose up around the diver from his movements.

Water body dive surveys, July 30 and 31, 2001

These dives were conducted while processing and seafood waste discharges were under way. The first dive commenced approximately 1⁄4 mile down-current to the northwest of the Wards Cove/EC Phillips plant, and the di ver swam towards the outfall then to the Norquest outfall, and eventually to a seaplane float to the south of the Norquest plant. The depth at the start of the dive was 68 feet and visibility was about eight feet. As the diver approached the pile, the visibility decreased. At the point of discharge a cloud of seafood wastes was suspended in the water co lumn. The second dive commenced at the Alaska General Seafoods buoy at the end of th e outfall pipe. The de pth was 63 feet. TheKetchikan seafood waste pile studies report.doc Page 6 seafood wastes created a thick cloud rising so me 30 feet in the wa ter column. Solids could be found to 3” in length and a complete, intact tail was found. Near the pile in the plume, visibility was 1 foot. There were num erous dog sharks in excess of 3-feet long at

the site.

Another dive was conducted to the southeast of the pile to look at seafloor impacts. The location was at the shoreline, in line with the Alaska Ge neral Seafoods offices. The water column contained white specks from the discharge, approximately 1/16” to 1⁄4” in size. At a depth of 40 feet were found small sculpins. Kelp was present, and on it was a white growth. Also observed were sea anem ones, baby Ling cod, and on the silty bottom clam shells, a bullhead fish, and shrimp. Visi bility was from 15 to 20 feet. A shoal of herring swam by.

During the dives around the piles turbot, ro ckfish, sea cucumbers and ratfish were observed. A dead juvenile halibut was seen. The dive operator, Greg Updike of Alaska Commercial Divers, said that he had seen dead fish at other times, sometimes with food hanging out of their mouths. He thinks the fish die from gorging too much, too rapidly.

For comparative purposes, two remote si tes were dove upon, both just off the shore across Tongass Narrows, almost opposite the pr ocessors, and at a similar depth to the waste piles. One site in Whisky Cove opposite Alaska General Seafoods, off Pennock Island at a depth of 50 feet had a sandy bottom with seashells, sea anemones, sea cucumbers, geoducks, free swimming scallops and rock scallops.

The other site was similar, having a greater abundance of relatively immobile sea floor life. Visibility at both site s was 25 to 30 feet. The photographs included with this report

show differences between the starfish and s ea bottom adjacent to the piles and at the remote sites. For example, there appears to be a gray film partially covering the starfish near the outfalls. The impact of this film was not analyzed.

The dive vessel allowed access to the shorel ine near Whisky Cove. No seafood wastes apart from two tails (one up on a rock, possi bly brought there by a bi rd) could be found in a stretch of a few hundred yards. Th ere were no odors of seafood wastes.

Sampling surveys

The first set of samples was taken in June of 2001 prior to processing commencing at either Trident or AGS. Norquest and Wards Cove/EC Phillips plants had been processing, but were not discharging at the time of dragging and sampling. The samples were taken during the dragging events from the edge of the zone of deposit (ZOD) and down-current of the ZOD. Drogues were used to determine the down-current location. However, the drogues were surface drogues a ffected by winds and surface currents, so the samples may not have been taken where the deeper currents took waste particles. Possibly because of this, the results of th e testing showed that during the dragging operation there were no advers e effects observed on the water column, nor any addition in suspended solids.Ketchikan seafood waste pile studies report.doc Page 7 Because the results of the first water column dive survey showed that seafood wastes were likely being carried some distance from the piles, the focus of the sampling changed slightly, as did the parameters tested. Instead of recording parameters up to 1⁄4-mile from the pile, it was decided to see what the effect s were up to 1-mile from the pile. The test for COD was dropped because it was thought th ere were too many interferences from salt in the seawater, and no information was being gained from running this test. However,

additional tests were r un for turbidity, pH, H 2 S, and TOC.

Results of the second set of samples were taken when the plants were actually discharging. One set of samples was taken for each pair of processors /discharges. At the time of sampling, AGS was barging their solids to the south of town, and Trident was operating a meal plant. Accordingly, th e discharges from both of these outfalls comprised screened effluent. Norquest and Wards Cove/EC Phillips were in an operational mode, however it is unknown exactly what was being discharged at the time of sampling, or even if they were discharging at that time. Results from the tests indicated that a discharge was occurring. These discharg es would have contained solids. To better follow any plume that may exist at depth, a si ngle drogue was used to track the current at a depth of 8 meters.

The results of this second set of samples show that for both sets of discharges, the Secchi disk results are similar. This is probably because the plume traps below 8 meters and the depth to which the Secchi disk was observed (although there may have been a local rise of the plume 100 feet from the AGS or Trident outfalls.) Hydrogen sulfide (H 2 S ) was only meant to be recorded over the pile, howev er it was recorded at all stations because

of a miscommunication. No H 2 S was seen in the samples. Conductivity showed the influence of fresh water at depth with the No rquest/EC Phillips discharge at 100 feet and 1⁄4-mile from the outfall. The only noticeable increase in turbidity occurred at 100 feet

from this same outfall. No settleable solids were seen with the sc reened discharge, but there was one sample at the Norquest/EC Phillips site that showed 0.5 ml/l. Total Suspended Solids results were similar for both s ites, with a couple of higher values noted per site. Total Organic Carbon values did not vary greatly from background levels. Elevated BOD was seen in the samples at 100 feet from the AGS/Trident outfalls, and in virtually all samples from Norquest/EC Phillips. There is no increase over the outfall, possibly because the sample was taken when a current carried the plume away from where the sample was taken. Also, it is not known at what depth the sample was taken

over the outfall.

Summary of sampling results

Note, these results are available in hard copy form but are not included in this report. Samples taken at the outfalls may not in clude any of the effluent, depending upon whether the sample was taken in the plume or slightly up-current of the plume.

June 2001 Sampling – Alaska General Seafoods, pre-discharge. These samples were taken approximately 100 feet from the outfall. Depths from 4 to 15 feet from the bottom.Ketchikan seafood waste pile studies report.doc Page 8 Parameter Samples 100’ to 300’ from outfall Samples at outfall Seawater blank

TSS: 9.75 to 29.75 mg/l, Ave 17.5 mg/l 22.25 mg/l 11 mg/l

Settleable solids: All less th an 0.1 ml/l <0.01 ml/l 0.0 ml/l COD: 63 to 738 mg/l 288 mg/l 1962 mg/l BOD: 2.23 to 2.72 mg/l. 2.37 mg/l Non-detect DO: 7.93 to 9.21 mg/l 8.11 mg/l 8.46 mg/l pH: 8.11 to 8.36 8.12 8.14 Turbidity: 0.0 to 1.0 NTU 0.2 NTU 0.0 NTU

Secchi disc: 5m to 6m 5.5 m 6.5 m

June 2001 Sampling – Trident Seafoods, pre-discharg e. These samples were taken between 50 and 200 feet from the outfall. Depths from 4 to 15 feet from the bottom.

Samples 100’ to 300’ from outfall Samples at outfall Seawater blank

TSS: 9 to 15.5 mg/l, Ave 12 mg/l 11 mg/l 8 mg/l

Settleable solids: All less th an 0.1 ml/l <0.01 ml/l 0.0 ml/l COD: 270 to 1773 mg/l 477 mg/l 288 mg/l BOD: 1.43 to 2.39 mg/l. Non-detect Non-detect DO: 7.7 to 9.0 mg/l 9.0 mg/l 8.46 mg/l pH: 8.02 to 8.17 8.1 8.14 Turbidity: 0.0 to 6.2 NTU 0.0 NTU 0.0 NTU

Secchi disc: 5m to 7m 5.0 m 6.5 m

June 2001 Sampling – Wards Cove / EC Phillips, disc harge prior to dragging. These samples were taken approximately 50 to 100 feet from the outfall. Depths from 4 to 15

feet from the bottom.

Parameter Samples 100’ to 300’ from outfall Samples at outfall Seawater blank

TSS: 6.25 to 12.5 mg/l, av. 8.83 mg/l 15 mg/l 12.5 mg/l

Settleable solids: All less th an 0.1 ml/l <0.01 ml/l <0.01 ml/l COD: 27 to 1332 mg/l 315 mg/l 936 mg/l BOD: 0.45 to 3.24 mg/l. Non-detect Non-detect DO: 8.37 to 8.99 mg/l 8.37 mg/l 8.49 mg/l pH: 8.2 to 8.32 8.2 8.16 Turbidity: 0.0 to 8.9 NTU 8.9 NTU 0.0 NTU Secchi disc: Range 5m to 5.5m 5.5 m 6.1 mKetchikan seafood waste pile studies report.doc Page 9 June 2001 Sampling – Norquest, discharge prior to dr agging. These samples were taken approximately 50 to 100 feet from the outfall. Depths from 4 to 15 feet from the bottom.

Samples 100’ to 300’ from outfall Samples at outfall Seawater blank

TSS: 7.5 to 21.75 mg/l, av. 13.94 mg/l 31.75 mg/l 8 mg/l

Settleable solids: All less than 0.1 ml/l 0.0 <0.01 ml/l COD: 270 to 1575 mg/l 5.04 mg/l 45 mg/l BOD: ND to 4.17 mg/l. Non-detect Non-detect DO: 8.64 to 9.43 mg/l 9.31 mg/l 9.55 mg/l pH: 8.15 to 8.28 8.21 8.17 Turbidity: 0.4 to 5.9 NTU 1.5 NTU 1.2 NTU

Secchi disc: 6m to 6.5m 6.0 m 7 m

August 2001 Sampling

– Notes from sampling team: When sampling the EC Phillips/Norquest area the current wa s much stronger than when sampling the AGS/Trident area. More plume was visi ble for greater distances in the EC Phillips/Norquest area, possibly due to the greater current. In the AGS/Trident area the plume appeared to be concentrat ed within 100 feet of the outfall.

These were also effluents with different characteristics – screened versus ground discharge and deeper ve rsus shallower water.

AGS/Trident, during discharge of screened e ffluent. Distances ranged from 100 ft to 1- mile from the outfall. Depths from 10 to 30 feet from the bottom.

Parameter Samples 100’ to 1 mile from outfall Samples at outfall Seawater blank

TSS: 2.2 to 20.4 mg/l, average 14.7 mg/l

Settleable solids: All 0.0 ml/l 0.0 ml/l 0.0 ml/l COD: Not sampled BOD: ND to 5.23 mg/l. 3.2 mg/l Non-detect TOC: 1160 to 6730 mg/l, av. 3534 mg/l 2930 mg/l 5880 mg/l TOC % dry matter: 82.8% to 90.5% 90.42% 84% DO: 3.75 to 11.77 mg/l 16.65 mg/l 17.69 mg/l pH: 7.03 to 7.85 7.03 7.46 Turbidity: 0 to 12.0 NTU 7.8 NTU 7.6 NTU

Secchi disc: 5.25m to 6.5m 6.5 m 6.5 m Hydrogen Sulfide: All 0.0

August 2001 Sampling – Wards Cove/EC Phillips & Norquest, during discharge of 1⁄2” ground effluent. Distances ranged from 100 ft to 1-mile from the outfall. Depths from

10 to 30 feet from the bottom.Ketchikan seafood waste pile studies report.doc Page 10 Parameter Samples 100’ to 1 mile from outfall Samples at outfall Seawater blank

TSS: 12.1 to 19 mg/l, Ave 14.7 mg/l

Settleable solids: 0.0 to 0.5 ml/l 0.0 ml/l 0.0 ml/l COD: Not sampled BOD: 2.17 to 4.35 mg/l. Non-detect Non-detect TOC: 2370 to 11490 mg/l, Ave 5135 mg/l 1760 mg/l 5880 mg/l TOC % dry matter: 67.3% to 90.2% 93.5% 84% DO: 9.57 to 15.28 mg/l 8.33 mg/l 17.69 mg/l pH: 7.29 to 7.82 7.43 7.6 Turbidity: 0 to 119 NTU 36.4 NTU 7.6 NTU Secchi disc: Range 6m to 8m 6.5 m 6 m Hydrogen Sulfide: All 0.0

Conclusions

The pile dragging studies indicated that, b ecause of the nature of the seafood, it is doubtless being re-suspended during the drag ging operations. However, because dragging occurred at a slow rate of speed, th e solids that did ri se up would no doubt soon drop back down again, most probably within th e Zone of Deposit. If the dragging is done during periods of high currents, then some of the particles may leave the pile area, but would not necessarily result in a detrimental effect to the water column or sea floor. They are most probably carried some distan ce from the pile at those times. From the

relative volumes of s eafood wastes during pile disturba nce and seafood waste discharge, one may conclude that the magnitude of su spended material introduced into the water column by dragging operations can be consid ered minimal compared with the solids suspended in the water column during the discharge of processed wastes.

Sample results did not show a ny significant impacts within th e water column. As would be expected, elevated solids and BOD occurred n ear the discharge. However, little effect was noticeable away from the piles. It is possible that the sample s were not taken from within the plume for the more distant sampli ng events, despite sampling near an 8-meter deep drogue that may have drifted with, or close to the plume.

The video taken during the dive study when the processors were discharging clearly

shows that a considerable volume of solids is suspended in the water column and that the solids drift away from the pile. The dive was conducted near slack water, so one can

conclude that when currents ar e fast, at say 3-4 knots, then the solids would be carried a long way from the outfall. Some pieces of th e light, thin viscera or skin were three inches or more long. These pieces also appeared to have near-neutral buoyancy. Because these long pieces of waste are the cause of complaints from residents living alongside Tongass Narrows, this issue needs to be addressed. One of the problems to be

resolved is that of the solid s accumulating on shorelines, resu lting in foul odors. Another complaint has been that the long pieces collect on boat haul li nes, where they decompose.Ketchikan seafood waste pile studies report.doc Page 11 This has resulted in nauseating conditions wh en the boats are hauled in, e.g. in the morning as people leave for work.

Recommendations

1. Processors should be allowed to continue to drag the piles to eliminate the buildup of gasses, and possibly reduce the size of the piles. This should be allowed year-round, provided no water quality viola tions are noted from the operations, and the processors should be allowed to set their own sc hedule and method of dragging in order to mitigate problems.

2. A study needs to be conducted to see wh ether the 1⁄2” grind size currently in seafood processor permits is the optimum size for waste consumption and decomposition, or whether a larger grind size would result in equal or better results. This study would need the approva l of EPA, and would also need to be well planned and documented in order to provide acceptable findings to all interested parties. Issues related to particle size incl ude waste pile location, rate of consumption, rate of decomposition, n eed for dragging to release gasses or reduce pile size and suspended offal that ends up on the shoreline or boat haul

lines.

3. The processors need to provide agencies with interim solutions for reducing the amount of suspended wastes in the water column of Tongass Narrows.

Possibilities to consider w ould be the separating of wa ste types within the waste stream for different types of treatment or disposal, e.g. discharging heads and tails whole versus creating meal or a hydrolysate product with the visc era. Meal plants or barging the waste to a remote site should remain acceptable methods of disposal unless reasons become apparent that either option is not acceptable.

4. Processors should provide agencies an a nnual update on the latest technologies for treating wastes within the fishing industry, and provide specific information on which technologies are feasible within Al aska. The agencies need to be better informed about the practicality, costs and environmental effects of waste disposal methods in order to specify appropriate permit requirements.

5. Because seafood wastes and waste waters are clearly visible beyond the 100-foot mixing zone boundary, a more appropriat e size for an acceptable mixing zone needs to be determined by DEC. Accord ingly information regarding impacts to

the water column need to be determined at varying distances, up to say 1-mile from the point of discharge.Ketchikan seafood waste pile studies report.doc Page 12 Photographs:

List of photographs:

Typical outfall line discharge.

Seafood waste “cloud” rising approximat ely 30 feet in the water column.

Dog sharks feeding on fish wastes.

Dog sharks feeding on fish wastes.

Dead halibut on waste pile.

Typical seafloor approximately 1⁄4 mile from the discharge.

Clams near to the waste pile.

Sea urchins near to the waste pile.

Starfish near the waste pile.

Starfish near the waste pile.

Anemones near outfall

Anemones near outfall

Sea cucumber at remote site.

Starfish at remote site.

Straight chain drag

Semi-circular chain drag

Drag boat and sampling skiff

Shark exiting top of waste pile “cloud”

Fish swimming above waste pile

Fish debris.

Note: Additional photographs available from Kenwyn George. There is also a series of

videos taken during the dive s that are available for review. The video camera was

located on top of the divers helmet.Ketchikan seafood waste pile studies report.doc Page 13 Typical outfall line discharge.

Seafood waste “cloud” rising approximately 30 feet in the

water column.Ketchikan seafood waste pile studies report.doc Page 14 Dog sharks feeding on

fish wastes.

Dog sharks feeding on

fish wastes.Ketchikan seafood waste pile studies report.doc Page 15 Dead halibut on waste pile.

Typical seafloor approximately 1⁄4 mile from the discharge.Ketchikan seafood waste pile studies report.doc Page 16 Clams near to the waste pile.

Sea urchins near to the waste pile.Ketchikan seafood waste pile studies report.doc Page 17 Starfish near the waste pile.

Starfish near the waste pile.Ketchikan seafood waste pile studies report.doc Page 18 Anemones near outfall

Anemones near outfallKetchikan seafood waste pile studies report.doc Page 19 Sea cucumber at remote

site.

Starfish at remote site.Ketchikan seafood waste pile studies report.doc Page 20 Straight chain drag

Semi-circular chain dragKetchikan seafood waste pile studies report.doc Page 21 Drag boat and sampling

skiff

Shark exiting top of waste pile “cloud”Ketchikan seafood waste pile studies report.doc Page 22 Fish swimming

above waste

Fish debris