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, 2001 
Table 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 ............................................................................................................. 11 

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

Executive summary 

Dive and sampling studies were conducted prior to and during the 2001 seafoodprocessing season in Ketchikan. The purpose was to see whether seafood wastes resuspended above waste piles from pile dragging operations resulted in a violation of the 

Alaska Water Quality Standards. Video coverage 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 operations. 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 the city, and four near 

downtown Ketchikan. Those downtown are located in pairs to the northeast and 

southwest of the center of town, the two 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 southwest, Trident Seafoods and Alaska General 

Seafoods, are closer to downtown; they are 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 million 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 processed was high. In 1999, at low, low tides, 

gasses formed within the pile from the decomposition of seafood wastes rose to the 

surface, as did decomposing seafood waste. This 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 brought unacceptable foul, obnoxious and nauseous 

odors to the downtown community, where there are cruise ships dock, tourists, tourist 

shops, commerce and residences. 

In order to prevent the reoccurrence 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 situation. Dragging chains through piles had been 

shown to effectively reduce the size of a pile at the Alyeska facility in Dutch Harbor in 
Ketchikan seafood waste pile studies report.doc Page 2 

1997 and 1999. It is surmised that aerobic bacteria 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 Alaska General Seafoods both 

manufactured devices with heavy steel crossbeams and heavy chains. The Trident unit 

had two chains that hung down in two loops, whereas Alaska General 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 Ketchikan 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 and decomposing wastes, but also about 

decomposing entrails and other fish parts collecting on the shoreline where houses were 

located, and on boat haul lines. 

In order to try to reduce or eliminate these problems, Trident 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 Ketchikan, 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 was also hoped that the size 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 operation 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 was 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 standards 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 water 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 beneficial 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 operations were under way, during the busy part of 

the season, in August. This was called the “Water Body” dive study. 

Purpose of study 

The main purpose of the study was to see whether seafood particles were re-suspended 

during dragging operations, and carried outside of the mixing zone. 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 planned. Three sampling events were scheduled. 

One during each of the drag operations before and after processing, and one during 

processing and discharge, but not while dragging. The parameters checked were TSS, SS, 

BOD, COD, DO, temperature and salinity. A Secchi disk was to be used to determine 

light transmissivity. 

Original Proposal 

The original proposal, conducted to indicate water quality impacts, 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 next day). An alternate proposal is to drag both 

piles in one pair one day, and the other piles in the other pair another day. 

The dives shall be conducted both before and after the dragging operations. Proposal for 

sequencing dragging, sampling and diving: 

Pre-drag survey both piles in one pair. 

Drag the down-current pile, place drogues and start 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 operation, 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 month after processing has 

commenced, or around early August. 

The water column dives shall be vertical dives through the water column 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, then take a 360-degree video shot. 

He shall then descend to 60 feet and take another 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, should 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 few hours while the dive study was conducted. 

The pre-drag dive occurred on June 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 dissolved oxygen problem. 
Ketchikan seafood waste pile studies report.doc Page 5 

For the Wards Cove/E.C. Phillips pile, the bar and chains were dragged through the pile 

for about 20 minutes, or eight times. The dragging 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 chains 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 approximately 1.5” to 2”. It did not look like there was debris 

beyond the pile; possibly tidal currents sweep clean 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 location 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 rose around him, visibility dropped 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 drifted there by the operation. 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 pre-drag dive was the morning of June 22, but 

because there was a 17’-6” tide (this means there 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 dive was next conducted 

the following morning at 7 am on the Trident pile. 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 had 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 cloud 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 diver 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 column. The second dive commenced at the 

Alaska General Seafoods buoy at the end of the outfall pipe. The depth was 63 feet. The 
Ketchikan seafood waste pile studies report.doc Page 6 

seafood wastes created a thick cloud rising some 30 feet in the water 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 numerous 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 General 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 anemones, baby Ling cod, and on the silty bottom 

clam shells, a bullhead fish, and shrimp. Visibility was from 15 to 20 feet. A shoal of 

herring swam by. 

During the dives around the piles turbot, rockfish, 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 sites were dove upon, both just off the shore 

across Tongass Narrows, almost opposite the processors, 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 sites was 25 to 30 feet. The photographs included with this report 

show differences between the starfish and sea 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 shoreline near Whisky Cove. No seafood wastes 

apart from two tails (one up on a rock, possibly brought there by a bird) could be found in 

a stretch of a few hundred yards. There 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 affected 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 the testing showed that during the dragging 

operation there were no adverse 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 effects were up to 1-mile from the pile. The test 

for COD was dropped because it was thought there were too many interferences from salt 

in the seawater, and no information was being gained from running this test. However, 

additional tests were run for turbidity, pH, H2S, 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, the 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 discharges would have contained solids. To better 

follow any plume that may exist at depth, a single 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 (H2S ) was 

only meant to be recorded over the pile, however it was recorded at all stations because 

of a miscommunication. No H2S was seen in the samples. Conductivity showed the 

influence of fresh water at depth with the Norquest/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 screened 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 sites, 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 include 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 than 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-discharge. 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 than 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, discharge 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 than 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 m 
Ketchikan seafood waste pile studies report.doc Page 9 

June 2001 Sampling – Norquest, discharge prior to dragging. 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 was much stronger than when sampling the 

AGS/Trident area. More plume was visible 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 concentrated within 100 feet of the outfall. 

These were also effluents with different characteristics – screened versus ground 

discharge and deeper versus shallower water. 

AGS/Trident, during discharge of screened effluent. 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, because of the nature of the seafood, it is 

doubtless being re-suspended during the dragging operations. However, because 

dragging occurred at a slow rate of speed, the solids that did rise up would no doubt soon 

drop back down again, most probably within the 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 distance from the pile at those times. From the 

relative volumes of seafood wastes during pile disturbance and seafood waste discharge, 

one may conclude that the magnitude of suspended material introduced into the water 

column by dragging operations can be considered minimal compared with the solids 

suspended in the water column during the discharge of processed wastes. 

Sample results did not show any significant impacts within the water column. As would 

be expected, elevated solids and BOD occurred near the discharge. However, little effect 

was noticeable away from the piles. It is possible that the samples were not taken from 

within the plume for the more distant sampling 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 are fast, at say 3-4 knots, then the solids would be carried a 

long way from the outfall. Some pieces of the 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 solids accumulating on shorelines, resulting in foul odors. Another 

complaint has been that the long pieces collect on boat haul lines, where they decompose. 
Ketchikan seafood waste pile studies report.doc Page 11 

This has resulted in nauseating conditions when 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 violations are noted from the operations, 

and the processors should be allowed to set their own schedule and method of 

dragging in order to mitigate problems. 

2. A study needs to be conducted to see whether 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 approval 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 include waste pile location, rate 

of consumption, rate of decomposition, need 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 would be the separating of waste 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 viscera. 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 annual update on the latest technologies 

for treating wastes within the fishing industry, and provide specific information 

on which technologies are feasible within Alaska. 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 appropriate size for an acceptable mixing zone 

needs to be determined by DEC. Accordingly 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 approximately 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 dives 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 outfall 
Ketchikan 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 drag 
Ketchikan 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