# Revised D raft Quality Assurance Project Plan : Support for EPA Response to

Industry Petition on ELGs for

Non

- Remote Alaskan Seafood Processors

Prepared for:



## U.S. Environmental Protection Agency

Engineering and Analysis Division
Office of Water

1 200 P ennsylvania Avenue, NW Washington, D.C. 20460

Prepared by:



## Eastern Research Group, Inc.

14555 Avion Parkway

Suite 200 Chantilly, VA 20151

- 1102

Original prepared March 29, 2010 Revision 1 prepared October 21 , 20 10

EPA comments received : November 5 , 2010

EPA Comments addressed: November 1 2 , 2010 Work stops if QAPP not approved: November 30, 2010 Addendum added August 2013

EPA Contract No. 68

- C

- 02

- 095 Work Assignment 8

- 30i Addendum

– August 2013

In early December 2010, project staff, EAD managers and the QAO, and CONTRACT OR staff, upon reviewing and discussing that draft QAPP agreed on next steps. It was agreed that supporting documents and reports to the record would be revised in response to QAO comments to supplement the Revised Draft QAPP and in place of a major revisi on of the Revised Draft QAPP. As agreed at that time and for purposes of the Work Assignment, responsibility for the

final revisions to the Revised Draft QAPP, as necessary and in response to comments on the NODA, rests with the EPA WAM. This agreement to supplement the Revised Draft QAPP, and in place of a major revision of the Revised Draft QAPP, was to incorporate Quality Assurance requirements in three technical documents, as follows:

1) Report of Quality Activities Supporting Alaska Seafood Processing Co st Estimates, February 2012,

2) Report of Quality Activities Supporting Alaska Seafood Processing Questionnaire Database Development and Analysis, February 2012, and

3) Report to the Record Costs and Economic Impact Analysis for Alaska Seafood Processors (Facili ties and Firms), March 16, 2012.TITLE AND APPROVAL SHEET

Quality Assurance Project Plan for Support for EPA Response to Industry Petition on ELGs for Non- Remote Alaskan Seafood Processors

/s/ 11/12/2010
Betsy Bicknell - ERG Work Assignment Manager Date

/s/ 11/12/2010

Anne Jones - ERG Economics Task Lead Date

/s/ 11/12/2010

Debbie Falatko

- ERG Project Quality Assurance Coordinator Date

/s/ 11/29/2010
Damon Highsmith - EPA Technical Project Officer (ERG Support Contract) Date

/s/ 11/29/2010
Don Anderson- EPA Work Assignment Manager (ERG Support Contract) Date

/s/ 11/29/2010
Todd Doley- EPA Altern ate Work Assignment Manager (ERG Support Contrac t) Date

/s/ 11/29/2010

Jan Matuszko - EPA Branch Chief (Acting) , Engineering and Analytical Support Branch Date

/s/ 11/29/2010
Marion Kelly - EPA/EAD Quality Assurance Coordinator Date

iiiii TABLE OF CONTENTS

Page

1.0 I NTRODUCTION

................................ ................................ ................................ ................. 1

- 1

2.0 P ROJECT M ANAGEMENT E LEMEN TS

................................ ................................ ................. 2

- 1

2.1 Project Organization (Element A.4)

................................ ................................ .... 2

- 1

2.2 Problem Definition/Background (Element A.5)

................................ .................. 2

- 2

2.3 Project/Task Description (Element A.6)

................................ .............................. 2

- 3

2.3.1 §308 Data Collection Effort

................................ ................................ ..... 2

- 3

2.3.2 Secondary Data Collection and Use

................................ ........................ 2

- 4

2.3.3 Pollution Control Technology Costing

................................ .................... 2

- 5

2.3.4 Secondary Data Activities Supporting Industry Profile and Economic Analyses

................................ ................................ .................. 2

- 5

2.4 Quality Objectives and Acceptance Criteria (Element A.7)

................................ 2

- 5

2.4.1 Data Collecte d Under CWA §308 Authority

................................ ........... 2

- 5

2.4.2 Secondary Data Supporting Engineering Analyses

................................ . 2

- 7

2.4.3 Pollution Control Technology Cost Estimates

................................ ......... 2

- 9

2.4.4 Secondary Data Supporting the Economic Profile and Economic Analyses

................................ ................................ ................................ ... 2

- 9

2.5 Special Training/Certification (Element A.8)

................................ .................... 2

- 11

2.6 Documents and Records (Element A.9)

................................ ............................. 2

- 11

3.0 D ATA G ENERATION

, A CQUISITION

, AND U SE

................................ ................................ ... 3

- 1

3.1 Non

- direct Measurements (Secondary Data) (Element B.9)

............................... 3

- 1

3.1.1 Activities and Procedures for Collection and Use of Secondary

Data

................................ ................................ ................................ .......... 3

- 2

3.1.2 QC Activities Related to Collection and Use of Secondary Data

............ 3

- 3

3.2 Data Management (Element B.10)

................................ ................................ ...... 3

- 4

3.2.1 Project File Management and QC Activities

................................ ........... 3

- 4

3.2.2 Questionnaire Response Management, Data Entry, and QC

Activities

................................ ................................ ................................ .. 3

- 4

3.3 Pollution Control Technology Costing

................................ ................................ 3

- 5

3.3.1 Development of Cost Estimates

................................ ............................... 3

- 5

3.3 .2 QC Activities Related to Development of Cost Estimates

...................... 3

- 6

4.0 D EVELOPMENT AND U SE OF E CONOMIC A NALYSIS M ODELS

................................ ............ 4

- 1

4.1 Model Description

................................ ................................ ............................... 4

- 1

4.2 Model Development

................................ ................................ ............................. 4

- 2

4.2.1 Spreadsheet Development

................................ ................................ ........ 4

- 2

4.2.2 Code Verification

................................ ................................ ..................... 4

- 2

4.2.3 Computer Requirements

................................ ................................ .......... 4

- 3

4.2.4 Model Documentation

................................ ................................ ............. 4

- 3

4.3 Model Calibration and Validation

................................ ................................ ....... 4

- 3

4.4 Model Evaluation and Application

................................ ................................ ...... 4

- 4

4.4.1 Ap plication

................................ ................................ ............................... 4

- 4

4.4.2 Restrictions

................................ ................................ .............................. 4

- 4TABLE OF CONTENTS (Continue d)

Page

iv 5.0 A SSESSMENT AND O VERSIGHT E LEMENTS

................................ ................................ ........ 5

- 1

5.1 Assessments and Response Actions (Element C.1)

................................ ............. 5

- 1

5.2 Reports to Management (Element C.2)

................................ ............................... 5

- 1

6.0 D ATA V ALID ATION AND U SABILITY E LEMENTS

................................ ............................... 6

- 1

6.1 Data Review, Verification, and Validation; and Validation Methods (Elements D.1 and D.2)

................................ ................................ ....................... 6

- 1

6.1.1 Technical Data Collection and Use

................................ .......................... 6

- 1

6.1.2 Economic Profile and Economic Analysis

................................ .............. 6

- 2

6.2 Reconciliation with User Requ irements (Element D.3)

................................ ...... 6

- 3

7.0 R EFERENCES

................................ ................................ ................................ ..................... 7

- 1

Appendix A: QUESTIONNAIRE FOR CA NNED AND PRESERVED S EAFOOD

PROCESSING FACILITIE S IN “NON

- REMOTE” LOCATIONS OF ALA SKA

Appendix B: CHECK LISTS

Appendix C: NON

- REMOTE ALASKAN SEAFO OD PROCESSORS PETITI ON

RESPONSE PROJECT FIL E MANAGEMENT PLANv LIST OF TABLES

Page

2

- 1 §308 Questionnaire Data Acceptance Criteria

................................ ................................ . 2

- 6

2

- 2 Literature Review Data Acceptance Criteria

................................ ................................ ... 2

- 7

2

- 3 Pollution Control Technology Cost Data Acceptance Criteria

................................ ........ 2

- 8

2

- 4 Cost Estimate Quality Specifications

................................ ................................ ............... 2

- 9

2

- 5 Economic Profile and Analysis Data Acceptance Criteria

................................ ............ 2

- 10

5

- 1 Reporting QA/QC Activities

................................ ................................ ............................ 5

- 2

6

- 1 Summary of Data and Results Quality Verification

................................ ........................ 6

- 1

LI ST OF FIGURES

Page

2

- 1 Project Level QA Organization for ERG’s Support for WA 7

- 30

................................ ... 2

- 2

3

- 1 Telephone Contact Report Form

................................ ................................ ...................... 3

- 3vi History of QAPP for Support for EPA R esponse to Industry Petition on ELGs for Non

Remote Alaskan Seafood Processors

Revision 0 Revision 1

Delivery Date March 29, 2010 October 21, 2010

Work Assignment 7

- 30 8

- 30

Scope Questionnaire data management, literature review, industry profile Adds site visits and economic analyses

Comments Received None November 5, 2010

Comments Addressed No comments received November 12, 2010

Approval Not approved Required by November 30, 2010 or ERG must stop work

Major Changes to QAPP for Support for EPA Re sponse to Indu s try Petition on ELGs for

Non

- Remote Alaskan Seafood Processors , Revision 1

Section Revision 1 Delivered October 21, 2010 EPA Comments Addressed November 12, 2010

Overall Past tense for completed activities. Updated to reflect additional s cope of WA 8

- 30. Updated to reflect additional QA requirements of WA 8

- 30.

Introduction Added references to the flow chart for EPA’s Effluent Guidelines. Development Process that was attached to WA 8

- 30

2.1 project organization Expanded discussion of e conomics task leader to reflect expanded scope of

WA 8

- 30.

Figure 2

- 1 Added ERG economics task leader, economics staff, and EPA Alt WAM to the organization chart.

2.3 project description Added descriptions of:

• Site visits;

• Collection of data from stand

- alone seafood by

- products plants;

• Pollution control technology costing; and

• Economic profile and analyses.

2.4 quality objectives and acceptance criteria Added criteria for:

• Site visit reports;

• Cost estimates; and

• Secondary data supporting industry profil e and economic analyses.

2.5 Special training Added CBI plan for the ERG Lexington office.

3.1 Secondary data Expanded discussion of how ERG researchers will document that they check the quality of secondary data and report the results to EPA.

3.2 Data management Expanded discussion of project file to refer to the Project File Management

Plan. Revised discussion of questionnaire response data entry to reflect current activities and expand discussion of qc checks.

3.3 Pollution control technology

costin g Added a new section.

4.0 Development and Use of Economic Analysis Models Added a new section following NRMRL QAPP Requirements for Research Model Development and Application Projects (EPA 2008).vii Major Changes to QAPP for Support for EPA Re sponse to Indu s try Petition on ELGs for

Non

- Remote Alaskan Seafood Processors , Revision 1

Section Revision 1 Delivered October 21, 2010 EPA Comments Addressed November 12, 2010

5.2 Reports to Management Added a new table summarizing t he QA/QC activities that will be included in monthly QA/QC reports.

6.1 Data Review, Verification, and Validation; and Validation Methods Added a new table summarizing data and results quality verification procedures.

7.0 References Added reference, EPA 2008 (NRMRL QAPP Requirements for Models)

Appendix A Replaced draft questionnaire with final questionnaire.

Appendix B Added checklists for:

• Literature review data quality;

• Pollution control technology cost data; and

• Economic profile and analysis data qu ality.

Appendix C Added Non

- Remote Alaskan Seafood Processors Petition Response Project File Management Planviii Distribution (Element A.3)

This Quality Assurance Project Plan (QAPP) w ill be distributed to staff of the U.S. Environmental Protection Agenc y and Eastern Research Group, Inc. (Table 1). A copy of the

document will be provided to all Eastern Research Group , Inc. staff involved in the pro ject, including those who join the project after publication of the QAPP.

Table 1. QAPP Distribution

Name

Title Contact Information Mailing Address

U.S. Environmental Protection Agency

Damon Highsmith Technical Project Officer (202) 566

- 2504 (phone) highsmith.damon@epa.gov

U.S. Environmental Protection Agency

O ffice of Science and Technology 1200 Pennsylvania Avenue, NW (4303T) Washington, DC 20460 (202) 566

- 1053 (fax) Marion Kelly Quality Assurance Coordinator (202) 566

- 1045 (phone) kelly.marion@epa.gov

Don Ander son Work Assignment Manager (202) 566

- 1021 Anderson.Donaldf@epamail.

epa.gov
Todd Doley Economics Task Manager (202) 566

- 1160 Doley.Todd@epamail.ep a.gov
Jan Matuszko, Engineering and Analytical Support Branch Chief (Acting) (202) 566

- 1035 matuszko.jan@epa.gov

Eastern Research Group, Inc

Deborah Bartram ERG Program Manager (703) 633

- 1669

Deborah.Bar tram@erg.com

Eastern Research Group, Inc. 14555 Avion Parkway

Suite 200 Chantilly, VA 20151

- 1102 (703) 263

- 7280 (fax) Mary Willett ERG Quality Assurance Officer (703) 633

- 1615 Mary.Willett@erg.com

Betsy Bicknell Work Assignment Manager (703) 633

- 1612 Betsy.Bicknell@erg.com

Debbie Falatko Project Quality Assurance Officer (703) 633

- 1607 (phone)

Deb ra .Falatko@erg.com

Kathleen Wu

Chemist (703) 633

- 1625 (phone) Kathleen.Wu@erg.com

Anne Jones

Economics Tas k Manager (781) 674

- 7328 (phone) Anne.Jones@erg.com Eastern Research Group, Inc

110 Hartwell Avenue Lexington, MA 02421

- 3136 (781) 674

- 2851 (fax) Melanie Sands

Economist (781) 674

- 7321

Melanie.Sands @erg.comSectio n No. 1.0

Revision No. 1

Date: November 12, 2010 Page 1 of 2

1.0 I NTRODUCTION

The U.S. Environmental Protection Agency ( EPA ) received a petition fr om Alaskan seafood processors in 1980. This petition requested that EPA suspend regulations applicable to seafood processors in “non

- remote” locations in Alaska. It also requested that EPA change the regulations using a rulemaking process. In a Federal Reg ister notice dated January 20,

1981

, EPA published a proposed response which denied the petition and maintained the status of four of five locations (Anchorage, Cordova, Ketchikan, Petersburg) as “non

- remote” processing centers, and granted the petition fo r Juneau, thus changing the status of that location to “remote.” In the proposed response, EPA also indicated that the earlier suspension of the regulations for good cause would remain in effect until a final response to the petition was issued. However,

E PA never completed a final response to this 1980 petition. ERG is support ing EPA’s efforts to complete a final response to the petition. This response will involve a coordinated effort with EPA Region 10, led by the EPA Work Assignment Manager (WAM) for en gineering tasks and the Alternate EPA WAM for economic analysis tasks.

Development of EPA’s response includes a subset of the steps common to EPA’s development of Effluent Limitations Guidelines ( ELGs )

. 1 These steps include:

• 3. Secondary Data Collection (n on

- EPA data sources) ;

• 4. Survey Questionnaire ;

— Engineering ; and

— Economic ;

• 7. Engineering, Economic Analysis of Questionnaire Responses ;

• 9. Site Reports on Technology ;

• 13a. Technology Costing ; and

• 13c. Economic Analysis

.

EPA completed Step 4, Developm ent of the Survey Questionnaire, in the spring of 2010 under Work Assignment 7

- 30

. U nder Work Assignment 8

- 30, ERG will support EPA in completing

S teps 3, 7, 9, 13a, and 13c.

As directed by W ork A ssignment 7

- 30 , ERG prepared a detailed Quality

Assurance Project Plan (QAPP) addressing the support it will provide for EPA’s response to the Alaskan seafood industry petition

. Work Assignment 8

- 30 directed ERG to prepare this revision

of the original QAPP. This QAPP is responsive to all applicable elements spec ified in EPA Requirements for Quality Assurance Project Plans QA/R

- 5 (EPA, 2001b)

. It is a project

- specific plan that describes the procedures that staff supporting EPA will use to plan, implement, and assess project quality.

1 A flow chart for EPA’s Effluent Guidelines Development Process was attached to WA 8

- 30. ERG uses the numbering used in that flow chart in the following discussion.Sectio n No. 1.0

Revision No. 1

Date: November 12, 2010 Page 2 of 2

ERG has organized this docume nt according to the elements outlined in the

above

- mentioned EPA guidance document. Group A elements are addressed from the title page through Section 2.6 of the document, while applicable Group B elements are addressed in

Section 3.0

, Group C elements are addressed in Section 5 .0, and applicable Group D elements

are addressed in Section 6 .0. Section 4 presents the Group B and D elements that are specific to economic modeling. References are provided in Section 7 .0.Section No. 2.0

Revision No. 1

Date: November 12, 2010 Page 1 of 17

2.0 P ROJECT M ANAGEMENT E LEMENTS

This section addresses project management, including project history and objectives, roles and responsibilities, and project goals

. In addition, this section presents the mechanisms EPA and ERG will use to ensure that all participants understand the goals and the

appr oach to be used for this project

. In its Requirements of Quality Assurance Project Plans (EPA, 2001b), EPA identifies the following nine project management elements:

• A.1: Title and Approval Sheet;

• A.2: Table of Contents;

• A.3: Distribution List;

• A.4: Proje ct Organization;

• A.5: Problem Definition/Background;

• A.6: Project/Task Description;

• A.7: Quality Objectives;

• A.8: Special Training/Certification; and

• A.9: Project Documents and Records.

Element s A.1 through A.3 have been provided earlier in this document

. The remaining elements are presented below.

2.1 Project Organization (Element A.4)

Project Organization is depicted in Figure 2

- 1 , listing the staff with program management and technical responsibilities and those with QA/QC roles. It shows the relationship and lines of communication among all project participants, including those from EPA.

ERG’s Work Assignment Manager (WAM) will be responsible for ensuring that the quality of work, schedule, and budget meet project . She will provide technical direction to ERG staff and will be responsible for the daily activities on the project. The ERG WAM will be the principal contact for the EPA WAM on project issues, deliverables, and schedule. The ERG WAM will be assisted by the ERG Economics Task Leader who will commu nicate with the EPA Alternate WAM on matters related to the economic analyses. The ERG WAM and ERG

Economics Task Leader will also keep the Project QA Coordinator and the ERG Program Manager advised of any quality problems that arise. The ERG Project QA Co ordinator is responsible for the development and execution of QA activities throughout the course of the project , including all data collection activities.Section No. 2.0

Revision No. 1

Date: November 12, 2010 Page 2 of 17

ERG National Strategy Contract QA

Coordinator

ERG Project QA

Coordinator

ERG Technical

Reviewers ERG Work Assignment

Manager ERG Program Manager

EPA Work Assignment

Manager EAD QA

Coordinator

EPA Alternate

WAM ERG Project

Staff ERG

Economics

Task Leader

ERG

Economics

Staff Lines of communication

Reporting authority

Figure 2

- 1

. Project Level QA Organization for ERG’s Support for WA 7

- 30

2.2 Problem Definition/Back ground (Element A.5)

ERG will support EPA’s primary data and secondary data collection efforts for this project

. P rimary data collection includes an industry questionnaire that EPA/OW and EPA Region 10 develop ed and sen t to nine Alaska seafood processing companies

. ERG will compile and analyze data submitted in response to this questionnaire. EPA may also collect primary data

from stand

- alon e seafood byproducts plants, under the authority of Clean Water Act (CWA) §308 ; EPA will likely use facility

- specific information requests (letters and/or email), not a questionnaire, to collect this information.

Secondary data that ERG will use on this work assignment include NPDES permit documents (notices of intent and discharge monitoring reports), technical literatu re pertaining to seafood processing waste management

, information obtained from vendor about the costs of seafood processing waste management , and publicly available economic information , such as Census, NOAA, and Small Business Administration information.Section No. 2.0

Revision No. 1

Date: November 12, 2010 Page 3 of 17

Information acquired during data collection activities will be used to answer the following key questions:

• What technologies for control of wastewater pollutant discharges from Alaskan seafood processors are technically and logistically feasible for

faci lities in non

- remote locations?

• What would implementation of these technologies cost?

• What are the likely economic impacts of implementation of these technologies , at the facility, firm, and community levels ?

2.3 Project/Task Description (Element A.6)

This subsection provides a management level overview of the work ERG will perform in support of this project

. ERG will perform this work at the direction of EPA.

2.3.1 §308 Data Collection Effort

ERG will support the data collection effort EPA is undertaking under t he authority of CWA §308

. EPA/OW and EPA Region 10 develop ed a questionnaire and sent it to nine Alaska seafood processing companies from which they expected responses for 68 facilities

. The questionnaire request ed information about each facility that the company operates in Alaska. Among other things, this questionnaire request ed information about the facility’s operation, processing capacity, seafood processing waste generation, and current waste recycle/recovery and disposal practices. The questionnaire also ask ed for financial information to characterize the

economic status of each facility and its owner firm and to estimate the possible economic impacts associated with alternative waste disposal practices. The questionnaire is included in Appendix A.

O n Work Assignment 7

- 30, ERG developed a Microsoft Access ® database to store and analyze questionnaire responses

. ERG will compile and analyze facility information submitted in response to the questionnaire. This effort will include:

• Developing a tracking s heet to record the status of the questionnaire

responses ;

• Entering questionnaire responses into the database (key entry);

• Developing and executing database queries to check the range and logic of responses and notifying EPA of problematic responses;

• An aly zing the questionnaire database to provide descriptions of:

— Raw materials, processes, and products;

— Production schedules;

— Waste and wastewater management practices;

— Cost and efficiency of seafood processing solids screening;Section No. 2.0

Revision No. 1

Date: November 12, 2010 Page 4 of 17

— Screened solids transportat ion,

— R eduction of fish into fish meal

, fish oil , and fish protein hydrolysate, including costs , and

— F inancial summary data for firms and facilities.

EPA, rather than ERG, is responsible for certain questionnaire

- related activities ; therefore, they are n ot described in this ERG QAPP. These activities include:

• Development of the questionnaire and mailing list;

• Mail out of the questionnaire;

• Answer ing respondent questions about the questionnaire (helpline support); and

• Follow

- up with respondents to compel response, clarify responses

, or obtain missing responses

.

In addition to the questionnaire sent to seafood processing companies, ERG will

support EPA in collect ing and analyzing information from stand

- alone seafood by

- products plants via telephone, e

- mai l, and or letter requests

. This information will include the costs to install and operate by

- products recovery equipment.

Finally, ERG will support EPA during site visits at Alaskan seafood processing plants and stand

- alone seafood processing plants . Duri ng these site visits, ERG will collect more information about waste management activities. ERG will prepare individual reports, including digital images, of each visit

.

2.3.2 Secondary Data Collection and Use

ERG is supporting EPA in the following activities fo r collection and use of secondary data:

• Identifying current, relevant technical publications that describe options for control of wastewater pollutant discharges from Alaskan seafood

processors ;

• Collecting information about the costs for Alaskan seafood processors to install and operate waste management technologies, including:

— Solids screening;

— Transporting recovered solids for off

- shore disposal; and

— R eduction of recovered solids to fish meal, fish oil, and fish protein hydrolysate; and

• Collecting in formation about the production and waste generation at affected seafood processors.Section No. 2.0

Revision No. 1

Date: November 12, 2010 Page 5 of 17

2.3.3 Pollution Control Technology Costing

ERG will use the secondary data in conjuncti on with primary data collected via §308 data collection efforts to e stimat e the costs for 1) screening and ocean disposal, and 2) screening, byproduct recovery, and ocean disposal of residual waste for the affected seafood processing facilities.

2.3.4 Secondary Data Activities Supporting Industry Profile and Economic Analyses

ERG will collect and use of secondary data ( supplement ed with § 308 questionnaire data ) to develop a profile of the petition areas (Anchorage Cordova, Juneau, Ketchikan, and Petersburg), other areas of EPA interest (Dutch Harbor, Kenai

— without Seward, Seward, and Sitka)

, and the w ider population of seafood processors in Alaska and the U.S. The profile will discuss numbers of firms, facilities, employment and petition

- area community economics and demographics. Additionally, ERG will collect and use secondary data for an

ec onomic ana lysis of the financial health of, at a minimum, the facilities and firms in the petition

areas , both in the baseline and after consideration of ELG s compliance costs. In this economic analysis ERG will use secondary sources of information to provide method s for financial analysis and financial health criteria (e.g., “benchmarks” used by financial analysts for determining investment risks)

.

2.4 Quality Objectives and Acceptance Criteria (Element A.7)

The primary objective s of this QAPP are to ensure that :

1. D ata generated and collected are of the quality necessary for EPA to respond to the industry petition on ELGs for non

- remote Alaskan seafood processors ; and

2. T he results of the analys e s of these data are documented and of the type, quality, transparency, and re producibility needed

.

Measures and descriptions of data quality that ERG will use to identify data that

are fit for this use are described in this section

.

2.4.1 Data Collect ed Under CWA §308 Authority

The quality objectives for data collected by activities c onducted under CWA §308 authority (seafood processing facility questionnaires, stand

- alone seafood by

- product plant

information requests , and Alaskan seafood facility site visits) are presented in this section.

2.4.1.1 Quality Objectives for S eafood P rocessing F ac ility Q ues tionnaires

EPA sent a data collection questionnaire to nine companies that operate seafood processing facilities in Alaska. ERG will enter data from these questionnaires into a database and evaluate the data quality using database queries

. The c riteria ERG will use for this evaluation are presented in Table 2

- 1

, along with acceptable values for each criterion. ERG will identify

r esponses to individual questions that do not meet these criteria as “qualified: best available

data

. ” The identificatio n of responses that do not meet quality criteria will be recorded in theSection No. 2.0

Revision No. 1

Date: November 12, 2010 Page 6 of 17

questionnaire database either as qualifier fields for each response or as listing of poor quality data in another database table that is linked to the question. ERG will use these dat a structures to provide the EPA WAM a report of facility technical information that includes a discussion of data quality. The EPA WAM will determine if qualified data will be used for this project.

Table 2

- 1 . §308 Questionnaire Data Acceptance Criteria

Acceptance Criterion:

Questionnaire Data Description/Definition Specification

Unambiguous For an individual response, can the response to the question be interpreted without confusion? • Units of measure are identified.

• Responses to open

- ended questions are clear

.

• The question was interpreted consistently by multiple respondents.

Internal consistency For an individual response, are the answers to one question consistent with answers to other questions? • Responses follow questionnaire skip patterns

.

• Response s to multiple questions asking for

similar or related information are comparable

and consistent

. Completeness For a facility’s response, were all questions answered? For each question, was it answered by all respondents? • A facility’s r esponse include s ans wers all applicable questions.

• Each question is answered by all respondents to which it applies.

Reasonableness For an individual response, are reported values consistent with operating seafood processing plants? • Reported facility production and flows are within the range of seafood processing facility flows available from Region 10

, ADEC , and other government data sources

. Representativeness Do the facilities that responded to the questionnaire reflect the population of seafood processing plants in non

- r emote Alaska

locations that are the subject of the industry petition ? Will be determined based on professional judgment. a

Comparability For a facility’s response, Is the information provided in response to the §308 Q uestionnaire consistent with facility descriptions in NPDES permit documents , including the annual report? • Questionnaire

- reported discharge flows

, production, and/or pounds of waste discharged

are not more than 50% different from the

values reported in NOI and not more than 15%

different from values included in the facility annual report

.

a

– The extent that the facilities that responded to the questionnaire reflect the population of seafood processing plants in non

- remote Alaska locations that are the subject of the industry petition cannot b e absolutely determined because the questionnaires were not sent to a statistical sample of the plants. However, out of 14 facilities, only 3 were not surveyed. With such a large percentage surveyed (nearly 80 percent), and with judgments made to obtain a good mix of size and type of processor in each petitioning center, the non

- surveyed facilities are each expected to

be reasonably similar to at least one of the surveyed facilities in their processing center.

2.4.1.2 Stand

- alone S eafood B y

- product P lant I nformati on R equests

Information requests for stand

- alone seafood by

- product plants have not yet been developed. Quality specifications will be developed along with the requests.Section No. 2.0

Revision No. 1

Date: November 12, 2010 Page 7 of 17

2.4.1.3 Seafood Plant Site Visit Reports

Site visits, documented in reports and digital image s, were conducted to understand the operation of seafood processing facilities in non

- remote processing centers.

• Site selection criteria:

— Site is located in non

- remote processing center; and

— Site conducts operations that fall under the applicability of 4 0 CFR

Part 408.

• Site visit report criteria:

— The location and operator of the facility are accurately identified;

— Facility waste management practices are described;

— Information that the facility operators claim as Confidential Business Information ( CBI ) is clearly identified; and

— The facility operator confirms accuracy of information provided in the report.

2.4.2 Secondary Data Supporting Engineering Analyses

ERG is supporting EPA in several secondary data collection activities

. The

criteria that ERG will use t o evaluate the quality of secondary data collected in these activities is

described in this section.

2.4.2.1 Literature and Other Information Search and Review

ERG will collect information about the applicability and costs of the control of wastewater pollutant d ischarges from Alaskan seafood processors

. This information will include reports of research, processes, and commercial products recovered from fish and shellfish

. ERG

will also contact equipment vendors to obtain information that can be used in engineerin g design of control options suitable for developing planning level cost estimates.

The criteria ERG will use to evaluate the quality of information collected during

literature reviews are summarized in Table 2

- 2 along with acceptable values for each criter ion

. ERG will only use s ources that meet these criteria to develop or evaluate control options

.

Table 2

- 2

. Literature Review Data Acceptance Criteria

Acceptance Criterion:

Literature Review Description/Definition Specification

Currency (up to date) Doe s the information reflect

current conditions? Year of publication (or presentation, if a paper presented at a conference)

. For byproduct recovery

- Priority : 2005 or after ;

c onsider: 2000 or after. For screening and ocean disposal

– use professional judg ment

.Section No. 2.0

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Table 2

- 2

. Literature Review Data Acceptance Criteria

Acceptance Criterion:

Literature Review Description/Definition Specification

Demonstration Status Does the information reported reflect processes used at a

commercial scale? Priority: full

- scale processes in commercial use. Consider: processes demonstrated in pilot scale

.

Geographic Scope Does the information reported

refl ect an area relevant to the study? Priority: processes used in Alaska

. Consider: processes used in British Columbia and the

U.S. Pacific northwest.

Accuracy/Reliability Is the information reported

true? Government publication (U.S., Canada, state, or

pro vince)

For academic researcher:

• Publication in peer

- reviewed journal

• Presentation at professional technical conference

For vendor researcher:

• Publication in peer

- reviewed journal

2.4.2.2 Pollution Control Technology Costs

ERG will collect information about the c osts for Alaskan seafood processors to install and operate wastewater pollution control technologies, including byproduct recovery processes and barging an d ocean disposal. In addition to information reported in the §308 Questionnaire, ERG will obtain curr ent (e.g., 2009

- 2010) cost information from ocean waste disposal services and process and equipment vendors that serve the Alaska areas included in this study

. EPA requested information about waste management costs in the §308 questionnaire. In addition, ERG will attempt to obtain project costs for similar projects completed by stand

- alone

Alaska seafood by

- products plants via telephone, e

- mail, and or letter requests . ERG will

compare costs provided by seafood processors and by

- products plants to vendor prices.

The criteria ERG will use to evaluate the quality of pollution control technology

cost information are summarized in Table 2

- 3 along with acceptable values for each criterion

. ERG will only use s ources that meet these criteria will to develop or e valuate control options.

Table 2

- 3

. Pollution Control Technology Cost Data Acceptance Criteria

Acceptance Criterion:

Literature Review Description/Definition Specification

Currency (up to date) Does the information reflect

current conditions? Costs are current (e.g., 2009

– 2010 )

.

Geographic Scope Does the information reported

reflect an area relevant to the study? Costs are appropriate for the “n on

- remote ” areas of Alaska included in this study.

Accuracy/Reliability Is the information reported

true? Obtained from a vendor who does business in the Alaska areas included in this study.Section No. 2.0

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Table 2

- 3

. Pollution Control Technology Cost Data Acceptance Criteria

Acceptance Criterion:

Literature Review Description/Definition Specification

Comparability Are the costs comparable to costs provided by sources that meet these acceptance

criteria. Comparable to costs obtained in §308 information collection reque sts.

2.4.3 Pollution Control Technology Cost Estimates

ERG will estimate costs for the affected seafood processors to manage and dispose of their wastes. The criteria that ERG will use to determine if the estimated costs are of the quality needed to support EP A’s response to the industry petition are summarized in Table 2

- 4, along with acceptable values for each criterion.

Table 2

- 4

. Cost Estimate Quality Specifications

Acceptance Criterion:

Cost Estimates Specification

Meet requirements for economic analy sis • Include one

- time costs for equipment purchase and installation

.

• Include o n

- going operating, and maintenance costs (annual costs)

. Appropriate for actual processing plant locations • Equipment costs include transportation to each processing center. Insta llation costs reflect the costs for supplies and labor in each processing center.

• Operating costs (electricity, diesel fuel, labor, chemicals, etc., reflect the costs in each processing center)

. Unit costs are on specified, standard year basis • Input cost s escalated to 2010, using Means Construction I ndex or other standard cost index, adjusted for Alaska as necessary

. Complete • Include costs for all elements necessary to implement the waste management option

. Accurate (spreadsheet input) • Cost spreadsheet inputs reflect design assumptions agreed on with project team

.

• Cost spreadsheet inputs reflect baseline conditions at each facility

. Accurate (spreadsheet calculations) • Spreadsheet calculations are correct.

• Unit conversions are correct.

Reasonable • Order

- of

- magnitude of costs is comparable to costs for similar installations at similar plants

.

• Cost trends follow the design basis trends (i.e., costs for large plants are greater than the costs for small plants)

.

2.4.4 Secondary Data Supporting the Economic Profil e and Economic Analyses

ERG will develop a n economic profile of the firms that will be affected by the seafood processing ELGs for Alaskan subcategories in the five petitioner processing centers.

ERG will base portions of the profile on publicly available information. Potential sources of publicly available information are:Section No. 2.0

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• U.S. Economic Census;

• U.S. Small Business Administration (SBA) data;

• NPDES permits;

• SEC filings, if any;

• Bureau of Labor Statistics data;

• Risk Management Association (RMA) data;

• NOAA coastal community data;

• Alaska Department of Environmental Conservation data;

• U.S. Department of Commerce Seafood Inspection Program; and

• Dun & Bradstreet , if directed to use

.

ERG will also use secondary sources to assist with developing the economic

an alyses . These economic analyses will compare current financial health of firms and facilities in the five processing centers with their predicted financial health after the estimated compliance costs are considered and will also consider employment and com munity impacts, if measurable.

The sources will include items such as:

• Some or all of the above sources;

• Financial analysis textbooks and handbooks;

• Previously published economic analyses of ELGs;

The criteria ERG will use to evaluate the quality of econo mic information are summarized in Table 2

- 5 along with acceptable values for each criterion

. ERG will only use

s ources that meet these criteria for the economic profile

.

Table 2

- 5

. Economic Profile and Analysis Data Acceptance Criteria

Acceptance Criteri on:

Literature Review Description/Definition Specification

Currency (up to date) Does the information reflect

current conditions? Most recent available

.

Geographic Scope Does the information reported

reflect an area relevant to the study? Firms that oper ate facilities in the non

- remote areas of Alaska included in this study. Wider scope data (e.g., all Alaska) also investigated for applicability and for use in characterizing the petition area within broader economic groups

. Accuracy/Reliability Is the in formation reported true? Government data will be considered “best

available.” Peer

- reviewed items such as college textbooks will be considered “reliable,” as will be widely accepted handbooks for financial analysis used throughout the financial analysis co mmunity

. D un and B radstreet and RMA data will be

considered “ reasonably reliable .” O ther sources will be reviewed and used with caveats discussed, as

necessary.Section No. 2.0

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Table 2

- 5

. Economic Profile and Analysis Data Acceptance Criteria

Acceptance Criteri on:

Literature Review Description/Definition Specification

Comparability Are data, such as numbers of firms and facilities in certain areas, e tc.

compar able to those across various

sources where more than one source provides information ? ERG will r ank sources by reliability and

, among those of similar reliability, ERG will compare the

sources in the profile and economic analysis

.

2.5 S pecial Training/Certif ication (Element A.8)

I nformation and data collected during by the §308 Questionnaire may be classified as Confidential Business Information (CBI) by the seafood processing companies

. Therefore, ERG will train project staff in CBI

- handling procedures as ou tlined in ERG’s CBI security plan s

. ERG will permit o nly staff demonstrating their understanding of CBI handling procedures by passing a written test to access CBI on this project.

ERG will strictly adhere to all EPA procedures when handling industry CBI. ERG will manage all reports, documents, and other materials and all draft documents developed under this work assignment in accordance with the procedures set forth in E RG’s CBI security plans or their successor approved plans:

• Security Plan for Handling Confidential Business Information Under the

Clean Water Act , dated September 25, 2008 and approved by Ahmar Siddiqui, EPA’s Document Control Officer for this contract, on March 12, 2009; and

• Security Plan for Handling CWA Confidential Business Informatio n Lexington, MA Office dated Oct. 25, 2005.

2.6 Documents and Records (Element A.9)

ERG has developed and instituted document control mechanisms for the review, revision, and distribution of QAPPs

. Each QAPP has a signed approval form, title page, table of contents, and EPA

- approved document control format (see header at the top of each page in this QAPP)

. During the course of the project, the ERG WAM will circulate any revision to the approved QAPP to all ERG and EPA project staff . ERG will docume nt the cir culation of the revised QAPP to project staff with a signature page for the revision.

ERG’s WAM is responsible for designating an individual to maintain all project

files , known as the index keeper . She is also responsible for ensuring that project team me mbers document all data sources used. ERG will handle and store all information collected, generated, and analyzed during this project in a centralized record. This centralized record contains all data

collected or accessed from other sources and documents analyses of data collected (e.g., literature reviews and database analyses). The contents of the record are indexed using a

Microsoft Office AccessTM database.Section No

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3.0 D ATA G ENERATION , A CQUISITION , AND U SE

In its Requirements of Quality Assurance Project Plans (E PA, 2001a), EPA identifies 10 elements to ensure that appropriate methods for data collection and generation are employed and documented. The 10 elements are:

• B.1 Sampling process design;

• B.2 Sampling methods;

• B.3 Sample handling and custody;

• B.4 Analytic al methods;

• B.5 Quality control;

• B.6 Instrument/equipment testing, inspection and maintenance;

• B.7 Instrument/equipment calibration and frequency;

• B.8 Inspection/acceptance of supplies and consumables;

• B.9 Non

- direct measurements; and

• B.10 Data management.

Only elements B.9 and B.10 are applicable to ERG’s activities for this project.

These elements are discussed below. Although Elements B.1 (sampling process design) and B.2 (sampling methods) are relevant to the §308 data collection effort , ERG was not re sponsible for

th ose part s of the project scope

. For this reason, those elements are not discussed in this QAPP

.

To fulfill the work assignment direction, t his section describes :

1. T he activities and procedures ERG will use to collect secondary data , h ow ER G

will determine if the collected data meet the data acceptance criteria specified in

Section 2. 4.2 and 2.4.4

, and how this determination will be documented ; 2. How ERG will use secondary data for a literature r eview and economic profile,

h ow ERG will determi ne that the literature review and economic profile meet project objectives

, and how this determination will be documented ; 3. How ERG will manage project documents and data provided in response to EPA’s §308 data collection effort;

4. How ERG will use informati on collected with EPA’s §308 data collection effort and collected secondary data to estimate pollution control technology costs, how ERG will determine if the estimated costs meet the quality requirements specified

in Section 2. 4.3 , and how this determinat ion will be documented.

3.1 Non

- direct M easurements (Secondary Data) (Element B.9)

Non

- direct measurements means data or information obtained from existing data sources, not directly measured or generated on this project. The term “secondary data” is also

us ed for such existing data that were collected for another purpose. This project includes collecting and using the following types of secondary data:

• Literature Review Data (Supporting Engineering Analyses) ;

• Pollution Control Technology Cost Data ; and

• Econ omic Profile and Analysis Data

.Section No

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3.1.1 A ctivities and P rocedures for C ollection and U se of S econdary D ata

Colle ction of Secondary Data. ERG will obtain secondary data from sources such as government publications and databases , scientific literature, financial l iterature, and vendor quotes. In addition to published information, ERG will collect pollution control technology cost information by contacting vendors by telephone and/or email

.

ERG staff will use the following procedures when collecting published secon dary

data:

• ERG researchers will collect full bibliographic information on all collected publications, including “date accessed” for information collected

from the I nternet.

• ERG researche r s will save Web pages as PDF files, so that the data source can be ad ded to the electronic project file.

• ERG researche r s will submit the publications and meta data to t he project file index keeper . The index keeper will add meta data describing the publications to the Alaska Seafood Processing Project File Index

. Following the procedures detailed in the project file management plan, the

index k eeper will add the publication file to the Alaska Seafood Processing Electronic Project File.

ERG staff will use the following procedures when collecting secondary data via telephone and email contact.

• ERG researchers will document a ll telephone contacts using the Telephone Contact Report depicted in Figure 3

- 1

.

• ERG researchers will save a ll email contacts as pdf files , so that they can be added to the electronic project file

.

• ERG re searchers will ensure that telephone contact reports and email

records are added to the Alaska Seafood Processing Project File.Section No

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Project No.: DISTRIBUTION

Page 1 of 1

Project Name:

TELEPHONE CALL

RECORD

Outgoing Call Date: Time:

Company Name: Contact Nam e:

Phone No.:

Name:

GENERAL SUBJECT :

TOPICS DISCUSSED AND ACTION TAKEN

Figure 3

- 1. Telephone Contact Report Form

Use of Secondary Data. ERG will prepare reports of the literature review supportin g engineering analyses in formats directed by the EPA WAM. Formats could include annotated spreadsheets or technical memoranda, including tables of findings and bibliographic citations. ERG will prepare an industry profile using economic profile and analys is data. Cost data will be used to develop cost estimates, as discussed in Section 3.3 below.

3.1.2 QC Activities Related to Collection and Use of Secondary Data

Collection of Secondary Data. ERG will determine if collected secondary data meet the data acceptan ce criteria specified in Section s 2.4.2 and 2.4. by using the check lists found in Appendix B:

• Literature Review Data Quality Check List;

• Pollution Control Technology Cost Data Quality Check List; and

• Economic Profile and Analysis Data Quality Check List.

ERG researchers may use hard copies of these check lists or include all information in an Excel Spreadsheet. Copies of the check list (or spreadsheet) will be provided to EPA with any deliverables prepared from the data. Copie s will be retained in the pro ject file to document that ERG evaluated the quality of the collected secondary data.Section No

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• Use of Secondary Data. ERG will use secondary data to prepare an economic industry profile and may prepare a literature review. ERG will plan and document review of the i ndustry profile, literature review, and any other documents developed using secondary data. The ERG WAM (or

other reviewer ) will verify that the data sources used meet quality specifications by reviewing the associated data quality check lists. The

deliver able review will be documented in a sign off sheet. An electronic copy of the sign off sheet will be retained in the project network area to

document that the review occurred.

3.2 Data Management (Element B.10)

This section describes how ERG will manage pro ject data.

3.2.1 Project File Management and QC Activities

ERG is using a project file management plan for this project adapted from similar plans prepared for other work assignments on Contract No. 68

- C02

- 095 . The plan provide s detailed instructions for develop ing a project index and a system to manage information collected on this project. This system is compatible with the needs of the Federal Docket Management System (FDMS). T he ERG WAM has assigned a project team member (the “index keeper”) the responsibilit y of maintaining the file index and filing documents in the electronic project file

.

The Non

- Remote Alaskan Seafood Processors Petition Response Project File Management Plan includes detailed procedures for ensuring the quality of the project file and

doc ket and for quality checks that will be performed during the assembly of the public and CBI

dockets. ERG will report the following activities to EPA in our monthly QA activity report:

• Periodic project file review; and

• Project file reviews conducted during docket assembly.

3.2.2 Questionnaire Response Management, Data Entry , and QC Activities

EPA/OW and EPA Region 10 developed a questionnaire and sent it to nine Alaska seafood processing companies from which they expected responses for 68 facilities.

Under Wor k Assignment 7

- 30

, ERG develop ed a Microsoft Access ® database to record and analyze responses to the §308 Questionnaire.

ERG data entry staff are entering r esponses directly into the database for simple questions and use Access Forms for data table quest ions. This combination approach minimize s both data entry errors and database programming. In addition to question responses, the database

will identify responses industry respondents claimed as CBI.

A CBI

- cleared ERG employee with prior experience relate d to questionnaire data

entry will enter information from the hard

- copy questionnaires into the database directly and by using the Access Forms. The data entry staff member will check their entries for errors as theySection No

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complete each form. To further ensure t hat the database is accurate, a second CBI

- cleared ERG

staff member will independently review 5 0 percent of the questionnaires (approximately 34 facility responses ) for data entry accuracy. If data entry errors are identified, ERG will

coordinate with the EPA WAM to determine, based on the resources available, the extent of

additio nal review (i.e., greater than 5 0 percent) that ERG should perform on data entry. When errors in database entry are discovered during review, ERG will correct the erroneous data f ields. ERG staff not involved in the data entry corrections will perform a 100 percent check to ensure

that resolved errors are correct ed in the Microsoft Access database.

The questionnaire database will be managed as CBI. After the database is developed, ERG will work with the EPA WAM to determine if the non

- CBI responses can be

moved to a non

- CBI database without permitting CBI to be deduced.

E RG will store t he completed database on ERG’s CBI server computer network

. If the EPA WAM and ERG determine tha t a non

- CBI database can be developed, it will be stored on the project network area.

After all responses are added to the database, ERG will execute a series of queries to determine whether any responses are missing, do not add to a reported total, are outliers, or are otherwise problematic for a given question for any questionnaire respondent. ERG will review the logic and programming for database queries and document this review in a database table

. ERG will prepare a report documenting the extent of t hese problems. EPA is responsible for

follow

- up with respondents

. ERG will add any clarified or supplemental responses obtained by EPA during this follow up to the questionnaire database and update the questionnaire database quality report. ERG assumes tha t EPA will provide one set of supplemental responses and that ERG will provide one updated database quality report.

ERG will deliver a copy of the CBI database on DVD to ERG’s Lexington Office (Economics) who will maintain the CBI database on disk in its CBI room, as specified in the CBI plan for that office.

3.3 Pollution Control Technology Costing

ERG will estimate costs for the affected seafood processors to manage and dispose of screened seafood processing solids. The estimated costs will be provided to E RG economics staff who will analyze the economic impact of the estimated costs.

3.3.1 Development of Cost Estimates

ERG will develop several spreadsheets to estimate costs for seafood processing plants to meet ELG s requirements for non

- remote Alaskan seafood pr ocessing plants. ERG will check spreadsheet data entry and calculations and document these checks in a separate table in the spreadsheet workbook . Cost information will meet the quality requirements specified in

Table 2

- 3. When changers are made to a sprea dsheet, ERG will:

• A ssign a unique name and number to the revised version of the spreadsheet ;Section No

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• M aintain a historical file of the spreadsheet(s); and

• I n a separate QA worksheet (spreadsheet) in the workbook (notebook) itself, log the changes made to the di fferent versions and explain what was revised, the date the revision was made, and by whom.

ERG will document its planned costing approach in a draft summary memo. ERG will discuss the memo, draft cost spreadsheets, and other costing documentation to the EPA WAM, economists, and Region 10 staff. ERG will revise the spreadsheets to reflect changes agreed on by this team, complete cost estimates for the affected seafood processing centers and provide estimated capital and operating and maintenance costs to ERG economists.

ERG anticipates that facilities will claim their financial and cost information to be CBI. Calculations, including estimated costs, dependent on CBI will be managed as CBI until EPA determines that facility

- specific information has been ad equately masked.

3.3.2 QC Activities Related to Development of Cost Estimates

Evaluating and Documenting Cost Estimate Quality

. An ERG technical reviewer will verify the appropriateness of the technical approach and verify that original data are correctly input into the spreadsheet. ERG will use standard engineering references to document that calculations are appropriate. ERG will review any constants used for appropriateness, will check that units are converted properly, and will document and check the equation s used in the costing spreadsheets. The spreadsheet reviewer will provide the spreadsheet developer with a written summary of the data checked, any errors or problems found, and any recommendations

for revisions.

Before ERG engineers deliver the cost esti mates to the economists, ERG will compare the estimated costs to the quality specifications listed in Table 2

- 4. ERG will document the results of this comparison in a memorandum to the EPA WAM.Section No. 4.0

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4.0 D EVELOPMENT AND U SE OF E CONOMIC A NALYSIS M ODELS

This sectio n describes the procedures ERG will use to ensure the quality of the Alaska Seafood Processing Industry Financial Model. These procedures addre ss the appropriate

elements of NRMRL QAPP Requirements for Research Model Development and Application Projects (E PA 2008). As such, this section presents the QA/QC activities that ERG will perform to ensure that the results obtained from this model are documented and of the type, quality, transparency, and reproducibility needed to meet the objectives of the project

.

4.1 Model Description

To estimate firm and establishment impacts from the final ELG s for Non

- Remote Alaska Seafood Processors. ERG will use the following:

• Excel spreadsheet software;

• § 308 questionnaire data;

• Additional financial data submitted by the respo ndents to this questionnaire

,

• Cost data developed by ERG;

• Calculations necessary to integrate compliance costs into the financial line items submitted by the respondents and to create financial ratios; and

• Logic statements that identify the point at whic h an existing firm or facility would be considered to be in poor financial health and thereby considered a baseline or post

- compliance firm failure or facility closure.

The basic inputs are firm

- and establishment

- level financial data EPA collected using its §308 questionnaire, the compliance costs developed by ERG, and “benchmarks” of financial health. ERG will use financial health benchmarks that meet the following criteria:

• U sed before in EPA economic analysis of effluent guidelines;

• G enerally accepte d by financial analysts who investigate investment risks;

• B est suited for use among the group of affected entities given their geographic location and the small size of the affected group ; and/or

• B est reflect how firm owners or investors would judge the f inancial health

of the firms and facilities

.

The logic of the Alaska Seafood Processing Industry Financial Model will reflect a mix of financial calculations (such as cash flows), financial ratios, and other assessments that will define, ultimately, a bi nary conclusion: financially healthy/financially distressed (firm failure or facility closure)

. To assess firm and facility financial health ERG will rely on logic and benchmarks that are similar to or identical (if appropriate, given industry differences) to those used in economic analyses of previously promulgated ELGs. In this way, ERG adheres to logic that has generally been reviewed under notice and comment rulemakings to the extent possible given that each industry, including the Alaska Seafood Proces sing Industry, might require different benchmarks due to unique considerations or available data.Section No. 4.0

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4.2 Model Development

ERG will build the Alaska Seafood Processing Industry Financial Model using the procedures described in this section.

4.2.1 Spreadsheet Developme nt

ERG will create an Excel file (“workbook”) containing multiple spreadsheets that link through VLookup functions and other linkages. The input database from the § 308 questionnaire will be extracted from the Access version of the § 308 questionnaire databa se to create an input sheet for firms and one for facilities. Other sheets will include:

• Estimated costs (discussed in Section 3.3);

• Calculations for present value of cost and annualized costs, both pre

- tax and post

- tax;

• Calculations designed to put fina ncial data on the basis of identified benchmarks; and

• Logic equations that will compare the outputs of financial calculations to the benchmarks, with further outputs indicating which firms and which facilities fall below benchmarks and are thereby conside red to be financially distressed.

4.2.2 Code Verification

ERG will use several steps to verify model inputs, calculations, and results.

First, the § 308 data must be extracted from the Questionnaire database, because

not all data from the questionnaire will be u sed in the model. Once extracted by the model builder, the ERG economics task leader or her designate (other than the model builder) will review the extraction to ensure that all necessary fields from all firms and facilities to be analyzed in the model ar e present and will spot check data points to ensure that the extraction matches the original § 308 database data.

The model builder will also copy in each new version of compliance costs as they are delivered. The task leader or her designate will review th e costs included in the model to ensure they are the most recent

.

The model builder will incorporate the equations, logic, and benchmarks spelled out in the final approved methodology. The task leader will check to see that all equations, logic

, and bench marks have been properly entered

.

The model builder will create output tables that summarize the baseline status and impacts by firm, by facility, and in the aggregate

. The task leader will select a sample of facilities

and firms and hand calculate the en tire operation from input data to result for those entities to ensure that outputs match those calculations.Section No. 4.0

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Finally, the QA reviewer will review the final model at completion, spot checking data extraction, reviewing all equations and logic again, and han d calculating another sample of facilities and firms. In response to QA reviewer comments, the model builder will make any necessary changes, which will be reviewed by the task leader and QA reviewer.

At each stage of model review, the reviewer will provid e a written summary of the data and calculations checked, any errors or problems found, and any recommendations for

revisions.

ERG will create a read me page in the file. This page will present purpose of the file, last updated date, and changes made sinc e last update. The spreadsheets will also contain documentation and comments, where necessary to clarify the various steps through the model. Each significant change (for example, when we insert a new round of costs) to the model will also be tracked using naming conventions that apply a new date to the file name whenever a significant change is completed.

4.2.3 Computer Requirements

The model will be based in Microsoft Excel 2003. No additional programming or software will be required. Given the number of firms and facilities expected to be analyzed, virtually any computer running Microsoft XP, Vista, or Windows 7 would be able to handle the computing requirements.

4.2.4 Model Documentation

ERG will include the following elements in the documentation:

The documentation of the modeling will include:

• Description of the model;

• Flow charts (if necessary);

• Database (see Section 3.0);

• Data sources (see Section 3.0);

• Documentation of benchmarks and sources;

• The equations on which the model is based;

• The underlying assumptions ;

• Any bounding assumptions that can be toggled for sensitivity analyses;

• The method used to solve the equations; and

• Any limiting conditions.

4.3 Model Calibration and V alidation

Calibration is the process of adjusting model parameters within physically defen sible ranges until the resulting predictions give the best possible or desired degree of fit to the observed data. Calibration should be applied each time the model is modified.Section No. 4.0

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Validation consists of comparing the prediction of a calibrated model with

ava ilable data that were not used in the model development and calibration.

Calibration and v alidation are not possible for this model because there are no observed data against which estimates produced by the model can be compared. The outputs of

the model a re designed to reflect the financial conditions of firms and facilities over the next ten years. Data to calibrate and validate these models would not be a vailable for many years hence. Because the model is similar (or in some regards identical) to economi c and financial models used to evaluate impacts from other ELGs and these similar models have gone through notice and comment, ERG believes that the Alaska Seafood Processing Industry Financial Model will reflect an approach that the affected entities and others would consider to reasonabl y forecast facility and firm financial conditions.

4.4 Model Evaluation and Application

The quality of the model will depend on the quality of the § 308 Questionnaire data responses, assumptions made in the model, and quality o f secondary data. The ERG economics task leader and the EPA WAM and Alternate WAM will meet to discuss assumptions

and calculation l ogic to assess reasonableness. ERG will perform additional internal review to ensure all data used have met the acceptabilit y criteria outlined in Section 2.4 and that all QA procedures and documentation outlined in the QAPP have been completed and updated at each significant modification.

4.4.1 Application

This model is for use by EPA, ERG, or any other person with the appropriate CBI clearance who EPA designates for rece ipt of the model and its data. Its use is limited to judging financial impacts on the Alaska Seafood Processing Industry from the final ELG s for Non

Remote Alaska Seafood Processors, other alternatives to the ELG s , and other related regulations or changes to regulations going forward.

4.4.2 Restrictions

Much of the data contained within the model will be CBI. As such, the model’s full use with all data is restricted only to those discussed above under application.Section No. 5.0

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5.0 A SSES SMENT AND O VERSIGHT E LEMENTS

This section describes the methods ERG will use to assess that this QAPP is implemented as prescribed

.

5.1 Assessments and Response Actions (Element C.1)

ERG will subject a ll work conducted on this project to technical review.

Tec hnical review is a documented critical review of work that has been performed within the

“state of the art.” ERG’s WAM will conduct t his review. In addition, reports and memoranda to the record will be reviewed by a senior

- level engineer (for engineering a ctivities) or economist (for economics activities) not directly involved with the project. All deliverables will subsequently be reviewed by the EPA WAM. ERG will document all reviews of project

deliverables and maintain copies of deliverable review sign o ff sheets in the project QA files

.

ERG’s Project QA Coordinator for this project or her designee will assess the implementation of QA/QC procedures on this project as follows:

• Review the QAPP (this document) for completeness and applicability; and

• Audit project files to ensure and verify the following:

— That project staff have developed QC procedures and that these procedures are used; and

— That project staff are documenting these QC activities by completing checklists, review spreadsheet, and other proje ct

- specific forms

.

Documentation of any Project QA Coordinator audits will be included in the project QA files.

At any time or at the end of the project or work assignment, the Corporate QA Manager or her designee may inspect the project QA files.

5.2 Repo rts to Management (Element C.2)

ERG will d escribe QA activities conducted for major deliverables, such as summary memos, when such documents are delivered to EPA. These descriptions may be included in the document or in the transmittal email, as directed b y EPA.

Additionally, ERG will provide the EPA WAM with monthly reports on the status of quality assurance (QA) activities. These reports will be incorporated into our monthly technical progress reports which will be supplemented to include the following:

• Quality assurance activities performed during the reporting period as part of the implementation of the work assignment;

• Identification of any problems encountered;

• Identification of any deviations from the QAPP; and

• Identification of problem resolution and/or corrective actions taken during the reporting period, if any.Section No. 5.0

Revision No. 1

Date: November 12, 2010 Page 2 of 2

Table 5

- 1 provides a list of the QA/QC activities performed during the reporting period as part of the implementation of the work assignment that ERG will report to the EPA WAM.

Table 5

- 1. Reporting QA/QC Activities

Data Generation, Acquisition, and Use QA/QC Activities that ERG will report to EPA in the monthly QA activity report

Non

- direct

Measurements (Secondary data) The number of secondary data collection check lists completed (o r the number of sources

reviewed )

. A list of the deliverable review sign off sheets completed.

Questionnaire

Response Management, Data

Entry, and QC Questionnaire data entry check by second person, including the number of questions for which any errors found were corrected.

Development, execution, and results of database QC queries.

Documentation of the occurrence and results of questionnaire response review.

Documentation of EPA decisions about using responses that don’t meet quality specificatio ns.
Evaluation of a complete questionnaire database to determine if the combined responses meet the quality specifications in Table 2

- 1 and documentation that this evaluation

occurred.

Development of Cost

Estimates Cost estimate spreadsheet (template) r eview

. Cost estimate spreadsheet (loaded) review

. Cost estimate quality review (comparison to Table 2

- 4 prior to delivery to economists).

In addition, a ny quality deficiencies detected by technical reviewers or the Project QA Coordinator will be comm unicated, in writing, to the ERG WAM. The ERG WAM is responsible for ensuring that appropriate corrective action is taken and reported to the Project QA Coordinator. ERG will include any reports of corrective actions in the project QA files.Section No. 6.0

Revision No. 1

Date: November 12, 2010 Page 1 of 3

6.0 D ATA V ALIDATI ON AND U SABILITY E LEMENTS

ERG will compare the quality of collected data to quality objectives described in

Section 2. 4 and report our findings to the EPA WAM to enable him to determine whether the collected and analyzed data are of sufficient quality for use in responding to the Alaska seafood industry petition

. This subsection discusses how ERG will review data quality and report the

results.

6.1 Data Review, Verification, and Validation; and Validation Methods (Elements D.1 and D.2)

Data verification means confirmation that data quality specifications have been met. Verification of a result (for example, estimated costs) means confirmation that the results are of the type, quality, transparency, and reproducibility needed. ERG will assume that data and analy ses that meet the quality specifications set out in this QAPP are acceptable for use in this project, unless otherwise instructed by the EPA WAM. This section summarizes how ERG will

determine that data and results meet quality specifications and h ow ERG w ill document data quality review occurred.

6.1.1 Technical Data Collection and Use

Table 6

- 1 provides a summary of the procedures ERG will use to determine that data used and results generated on this project meet quality specifications.

Table 6

- 1. Summary of Data and Results Quality Verification

Data Source and

Use Specification How ERG Will Determine That Data Meet Quality Specifications How ERG Will Document Data Quality Review

Questionnaire Data Table 2

- 1 • Database development review

• Data entry checks

• Da tabase query review

• Range and logic checks

• Compare database to Table 2

- 1 specifications • Database and database queries

will be documented on internal tracking table.

• Range and logic check results and comparison to Table 2

- 1 will be

documented in database report.

Site Visit Reports Section 2.4.1.3 • Deliverable review • Deliverable review checklist

Literature review (engineering) Table 2

- 2 • Compare data source to Table 2

- 2 requirements • Literature Review Data Quality

Check List

Cost Data Table 2

- 3 • Compare data source to Table 2

- 3 requirements • Pollution Control Technology Cost Data Quality Check List

Cost Estimates Table 2

- 4 • Spreadsheet reviews; Compare to

Table 2

- 4 requirements • Summary memo delivered to

EPA

Economic profile and analysis data Table 2

- 5 • Compare data source to Table 2

- 5 requirements • Economic Profile and Analysis Data Quality Check List

Project File Project File

Plan • Comparison to FDMS docket requirements • Preparation of project file and project file index that meet FDMS requirementsSection No. 6.0

Revision No. 1

Date: November 12, 2010 Page 2 of 3

Table 6

- 1. Summary of Data and Results Quality Verification

Data Source and

Use Specification How ERG Will Determine That Data Meet Quality Specifications How ERG Will Document Data Quality Review

Economic Mod el Output Section 4

- 4 • Discussions with EPA WAM and Alternate WAM; industry comments received during public comment period • Summary memo delivered to

EPA

6.1.2 Economic P rofile and Economic Analysis

Review and documentation of the quality of economic profile in formation not supplied by the § 308 Questionnaire database will take place during the profile development and economic analysis

. (Note that the use of the § 308 Questionnaire data within the economic analysis models and the output of aggregated questionnaire data for use in the profile ( also provided within the model spreadsheets ) are covered in Section 4.0.) ERG will rank the reliability of data sources as follows:

1. Peer

- reviewed journal data and textbooks, widely accepted financial analysis

handbooks used i n previous EPA ELG s analyses, and g overnment sources such

as :

a. Census data ; b. O ther U.S. Department of Commerce data ;

c. Bureau of Labor Statistics data;

d. S ecurities and E xchange C ommission data ;

e. Financial analysis textbooks reviewed by oversight committees

f. A ltman, E.I., and E. Hotchkiss, Corporate Financial Distress and Bankruptcy, 2006.

g. Small Business Administration d ata
h. Other EPA economic analyses

.

2. P roprietary data such as :

a. D un & B radstreet data ; b. RMA data; and

c. O ther journal and university publication dat a

.

3. N ews reports and various other online sources.

Data from highest ranking sources are used first, with subsequently lower levels of sources relied on only for information that can be found nowhere else

. ERG will include appropriate caveats if any lowe r level sources are included in the Economic Profile or Economic Analysis . Where data sources of similar reliability provide similar data, ERG will compare the

results and describe the comparison in the profile or economic analysis memoranda

. ERG will

not use s ources that do not meet the criteria specified in Table 2

- 5 (e.g., news items, non

university websites, anecdotal information, and other information unsubstantiated by more reliable sources) directly in the economic profile or economic analysis

.Section No. 6.0

Revision No. 1

Date: November 12, 2010 Page 3 of 3

6.2 Reco nciliation with User Requirements (Element D.3)

ERG will work with EPA to determine to what extent data that do not meet the specified data acceptance criteria may be used to support EPA’s response to the petition from Alaskan seafood processors and how t his determination will be documented.

ERG will include an evaluation of data quality in all project deliverables. ERG will also identify the sources of data, assumptions made, and calculations used in their development in all project deliverables. These i dentifications will be sufficiently detailed and transparent to ensure the reproducibility of the work by qualified third parties. All project deliverables will meet EPA’s standards of transparency, objectivity, integrity, and utility as specified in EPA’s Information Quality Guidelines (EPA, 2002).Section No. 7.0

Revision No. 1

Date: November 12, 2010 Page 1 of 1

7.0 R EFERENCES

EPA, 2001

. U.S. Environmental Protection Agency

. EPA Requirements for Quality Assurance Project Plans QA/R

- 5

. EPA/240/B

- 01/003

. Office of Environmental Information

. March 2001.

EPA, 2002

. U.S. En vironmental Protection Agency

. Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection Agency

. EPA/260R

- 02

- 008

. October 2002.

EPA, 2008. U.S. Environmental Protec tion Agency. NRMRL QAPP Requirements for Research Model Development and Application Projects , Revision 0. Office of Research and Development.

October 2008.

ERG, 200 8

. Eastern Research Group, Inc. Security Plan for Handling Confidential Business Informati on Under the Clean Water Act

. September 25, 2008

.

ERG, 2005. Eastern Research Group, Inc. Security Plan f or Handling CWA Confidential Business Information , Lexington, MA Office, October 25, 2005

.Appendix A

QUESTIONNAIRE FOR CA NNED AND PRESERVED S EAFOO D PROCESSING

FACILITIES IN “NON

- REMOTE” LOCATIONS OF ALASKAUnited States

Environmental Protection Agency



# Questionnaire for
Canned and Preserved Seafood

Processing Facilities in
Certain Locations of Alaska

EPA is distributing this questionnaire under the author ity of Section 308 of the
Clean Water Act. You must return the completed questionnaire(s) to E PA within 45 days of receiving it. If you fail to respond, file late , or fail to comply with the instructions, you may be subject to criminal fines, civil penalties, and other sanctions, as provided by law.



### April 2010i INTRODUCTION

The U.S. Environmental Protection Agency (EPA) is condu cting an information gathering effort of nine or fewer corporations or entities within the Canned and Preserved Seafood Processing Category ( Seafood Processing Facilities ). This effort is focused on entities with operatio ns in certain locations in

Alaska. These locations include:

• Anchorage;

• Cordova;

• Juneau;

• Ketchikan;

• Petersburg;

• Dutch Harbor; and

• The Kenai Peninsula.

EPA will use the information it collects from facilit ies in these locations (the “ study area ”) to respond to an industry petition

that was submitted to EPA in 1980. This petition re quested EPA to revise effluent limitations and standards and prohibitions for dire ct discharges from seafood processing facilities in

“ non-remote ” locations in Alaska (see 40 CFR Part 408), including Anchorage, Cordova, Juneau, Ketchikan, and Petersburg. As noted in the January 9, 1 981 Federal Register Notice, EPA also proposed
to redefine the term “ non-remote ” for the Alaskan segment of the industry to eliminat e the words “population center,” and to add Dutch Harbor and the Kenai Peninsula to the list of non-remote processing centers. EPA also considered including Ward C ove as a non-remote area because of its proximity to the Ketchikan processing center. Ward Cove, however, has since been included in a finalized total maximum daily load evaluation, which does not al low discharges from seafood processing facilities, and so is not included in the scope of EPA’s current information gathering effort.

EPA identified nine corporations that operate seafood processing facilities in the study area . EPA is requiring these corporations to complete a quest ionnaire for each of the seafood processing
facilities they operate in Alaska; that is, facilities in the study area AND in any other part of Alaska, including shore-based seafood processing facilities operating and discharging less than one-half (0.5) nautical mile from shore at mean lower low wa ter (MLLW) and near-shore seafood processing facilities operating and discharging fro m one (1) to one-half (0.5) nautical mile from
shore at MLLW.

EPA will use the technical data collected from each fac ility to characterize the facility’s operation, processing capacity, seafood processing waste generation in terms of fluctuation in volume, and current waste recycle / recovery and disposal practices. EPA will use the collected financial data to characterize the economic status of the industry and to estimate t he possible economic impacts associated with alternative waste disposal practices.

EPA is distributing this questionnaire under the au thority of Section 308 of the Clean Water Act

. You must return the completed questionnaire(s) to EPA w ithin 45 days of receiving it. If you fail to respond, file late, or fail to comply with the instr uctions, you may be subject to criminal fines, civil penalties, and other sanctions, as provided by law.ii INSTRUCTIONS FOR COMPLETING THE QUESTIONNAIRE

QUESTIONNAIRE OVERVIEW

This questionnaire is divided into two primary sectio ns. Part A – Corporate Information requests corporate financial information while Part B – Facility Information requests information about the operations and finances of each of the facilities, in cluding those onboard vessels, you operate in Alaska. You should complete Part B for the following facilit y or facilities:

1. Plant A
2. Plant B 3. Any other seafood processing facility you operate in Alaska.

EPA has provided one copy of Part B for each seafood processing facility listed above that your company operates in Alaska. The name of each facility is listed at the beginning of each section. EPA has also provided a blank Copy of Part B. If you operate seafood processing facilities in Alaska that are not listed above, please copy the blank questionnai re and complete a copy for each additional processi ng facility not listed.

Please include any additional comments in the comments table at the end of each Part and identify the question(s) for which the comment(s) apply (e.g., A-7, B-3). EPA has provided definitions for key terms at
the end of each section

. These terms are shown in bold italics as they are use d throughout the questionnaire.

Please complete one copy of Part A for your seafood processing company for 2005 through 2009. Please complete one copy of Part B for each seafood processing facility you operate in Alaska for 2005 through 2009. Each question will specify if info rmation is requested for calendar years or fiscal

years.

CERTIFICATION

After you complete this questionnaire, a responsible corporate official must sign one of the Certification Statements on page v to either (1) verify and valida te the information provided, or (2) certify that the

company no longer engages in seafood processing in the EPA study area

.

TIMEFRAME FOR COMPLETING QUESTIONNAIRE

You must return the completed questionnaire(s) to E PA within 45 days of receiving it. Please consider this timeline when completing Section B for individual facilities.

QUESTIONNAIRE ASSISTANCE

If you have any questions as you complete this question naire, please contact EPA using the telephone numbers and email addresses provided below.

Contacts for Assistance

Part A (Corporate Information) Part B Questions B-41 to B-47 (Facility Financial Information)

Mr. Todd Doley (202) 566-1160 doley.todd@epa.gov Part B Questions B-1 to B-41 (Facility Technical Information)

Mr. Donald F. Anderson (202) 566-1021 anderson.donaldf@epa.goviii

SUBMITTING THE QUESTIONNAIRE PACKAGE TO EPA

When the questionnaire package is complete, sign the Certification Statement (page v). Assemble the final completed questionnaire package. Please include :

• Certification Statement;

• Part A - Corporate Information;

• Part B - Facility Information (one copy for each facil ity you operate in Alaska);

• Accounting Reports , and

• Other Attachments.

Return the completed questionnaire using the enclosed return label to the following address:

U.S. Mail or Overnight Delivery (e.g., Federal Expr ess, UPS, etc)

U.S. Environmental Protection Agency
Questionnaire for the Canned and Preserved Seafood Processing Facilities in Certain
Locations of Alaska c/o Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151-1102 (703) 633-1600

EPA recommends that you keep a copy of the complete d questionnaire for each facility, including attachments, in the event that we need to contact y ou to clarify your responses . EPA will review the information submitted and may ask additional, follow -up questions to complete our analyses.

EPA sincerely appreciates the time and effort you will put into responding to this questionnaire. Your information is vital to EPA’s response to your indus try’s petition.iv CONFIDENTIAL BUSINESS INFORMATION

EPA provides you the opportunity to claim information as confidential. If no business confidentiality claim accompanies the information when it is received by EPA, EPA may make the information available to the public without further notice.

Regulations governing the confidentiality of business information are contained in the Code of Federal Regulations (CFR) at Title 40 Part 2, Subpart B. Yo u may assert a business confidentiality claim covering part or all of the information you submit, other tha n effluent data and information or data that is otherwise publicly available , as described in 40 CFR 2.203(b):

“(b) Method and time of asserting business confidentiality clai m. A business which is submitting information to EPA may assert a business confidentia lity claim covering the information by placing on (or attaching to) the information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, or other suitable form of n otice complying language such as ‘trade secret,’ ‘proprietary,’ or ‘company confidential.’ Alleg edly confidential portions of otherwise nonconfidential documents should be clearly identified by the business, and may be submitted separately to facilitate identification and handling by EPA. If the business desires confidential treatment only until a certain date or until the occurr ence of a certain event, the notice should so

state.”

You may claim as confidential all information include d in the response to a question by checking the Confidential Business Information (CBI) box next to the question number. Note that you may be required to justify any claim of confidentiality at a la ter time. Therefore, it is strongly recommended that only those pieces of information that are the most se nsitive (e.g., certain financial information and dat a) as described in 40 CFR Part 2, should be claimed as C BI. Other types of information and data not protected from public disclosure, as also noted in 40 CFR Part 2, should not be claimed as CBI. Note also that facility effluent data are not eligible for con fidential treatment, pursuant to Section 308(b) of t he Clean
Water Act , and thus will be treated as nonconfidential even i f the CBI box is checked. In addition, information that is publicly available should not be claimed confidential.

Information covered by a claim of confidentiality wil l be disclosed by EPA only to the extent of, and by means of, the procedures set forth in 40 CFR Part 2, Subpart B. In general, submitted information protected by a business confidentiality claim may be discl osed to other employees, officers, or authorized representatives of the United States concerned with i mplementing the Clean Water Act

.

Information covered by a claim of confidentiality wil l be made available to EPA contractors to enable the contractors to perform the work required by their contr acts with EPA. All EPA contracts provide that contractor employees use the information only for the p urpose of performing the work required by their contracts and will not disclose any CBI to anyone other than EPA without prior written approval from each affected business or from EPA's legal office.Copy of

v CERTIFICATION STATEMENT

Please check only one applicable certification stat ement then sign and complete the remainder of this

page.

Certification Statement #1

I certify under penalty of law that the attached questio nnaire was prepared under my direction or supervision and that qualified personnel properly gathered and eva luated the information submitted. The information submitted is, to the best of my knowledge and belief, accu rate and complete. In those cases where we did not possess the requested information for questions applicable to our company, we provided best estimates. We have to the best of our ability indicated what we beli eve to be company confidential business information as defined under 40 CFR Part 2, Subpart B. We unders tand that we may be required at a later time to justi fy our claim in detail with respect to each item claimed con fidential. I am aware that there are significant penalties for submitting false information, including t he possibility of fines and imprisonment as explained in
Section 308 of the Clean Water Act

.

Certification Statement #2

I certify under penalty of law that this entity or corpor ation does not or will no longer operate any Seafood Processing Facility that processes seafood in any of the following Alaskan locations:

• Anchorage

• Cordova

• Juneau

• Ketchikan

• Petersburg

• Dutch Harbor

• The Kenai Peninsula

I am aware that there are significant penalties for sub mitting false information, including the possibility of fines and imprisonment as explained in Section 308 of the Clean Water Act

.

Signature of Certifying Official Date

( ) Printed Name of Certifying Official Telephone Numbe r of Certifying Official

Title of Certifying Official

( ) Email of Certifying Official Facsimile Number of Certifying Official

Company Name (if different from parent company)

Street Address

City State Zip CodePart A. Corporate Information Alaskan Canned and Pre served Seafood Processing

Copy of

A-1 PART A. CORPORATE INFORMATION

INSTRUCTIONS FOR FILLING OUT PART A

Please use the following guidelines for filling out the questionnaire:

• Use black ink

or type in the spaces provided.

• Mark responses for each question and do not leave blanks. Fill in t he appropriate response(s) to each question unless instructed to skip the question. Check the boxes that apply to your answers. Answer the questions in sequence. Do not leave any ent ry blank. If the answer is zero, enter “0" or

“zero”.

• Enter “N/A” if a question is not applicable to your Company. EPA prepared the questionnaire to be applicable to a variety of Companies; therefore, it is possible that not all of the questions will ap ply to every Company. Please complete each relevant item in the questionnaire and enter “N/A” if a question is not applicable to your Company.

If you do not have the requested information for qu estions applicable to your company, please provide your best estimates.

• Include any required attachments. Please attach your accounting reports as requested in Question A-5 (if applicable) and Question A-17. In a ddition, if additional pages are required to clarif y a response, please write the associated question numbe r, as well as the name of your Company in the top right corner of each attachment page.

• If you need to photocopy pages of the questionnaire before you respond, indicate ho w many copies of the page(s) you are submitting by completing the entry “Copy ___ of ___” in the top right

corner.

• Indicate information that should be treated as conf idential. You may claim as confidential all information included in the response to a question by checking the Confidential Business Information (CBI) box next to the question number. Note that you may be required to justify any claim of confidentiality at a later time. Blanket clai ms are not recommended and individual claims must be carefully considered. Read carefully the CONFI DENTIAL BUSINESS INFORMATION section on page iv and understand the implications be fore you make such a claim.

• Indicate atypical data in the Comments Table. The questionnaire requests information for 2005 through 2009. While year-to-year operations are expec ted to vary, please add a note in the Comments Table if the information for these years is not representative of normal operations and why.Part A. Corporate Information Alaskan Canned and Pre served Seafood Processing

Copy of

A-2 A-1. Please provide contact information for the corpo rate section of the questionnaire:

( ) Printed Name of Part A Contact Telephone Number

( )
Title of Part A Contact Facsimile Number

Convenient time to call between:

Email Address am / pm and

am / pm EDT

Street Address

City State Zip

A-2. Is your company owned by another firm?

Yes. Provide contact information for the parent fir m.

Firm’s Full Legal Name

Address

( )
Phone/Facsimile Number Website

No. ( Skip to Question A-12 .)

A-3. Please indicate whether your company is fully or p artially owned internationally by this parent firm by checking one of the two choices provided.

>50% U.S. Owned >50% Internationally Owned

A-4. Please indicate your parent company’s type of busin ess organization.

Sole proprietorship Partnership Corporation (standard, “C” corporation) Subchapter S Corporation Limited Liability Corporation
Other:

A-5. Please provide your parent company’s financial rep orts for 2005 through 2009. These financial reports can be accounting reports or tax forms and must include income statement infor mation (revenues, costs, earnings, interest and taxes) and balance sheet items (assets, liabilities, and equity). Please check the box below to acknowledge that accounting reports have been attached to this questionnaire submittal. If 2009 financial rep orts are not yet available or if other years’ data ar e not applicable, please note this in the Comments Sec tion on Page A-6 and provide an explanation.

Accounting reports

are attached. CBI?

Yes

CBI?
Yes

CBI?
Yes

CBI?

Yes

CBI?
YesPart A. Corporate Information Alaskan Canned and Pre served Seafood Processing

Copy of

A-3 A-6. In what state is this parent corporation organi zed as a legal entity (if foreign, please indicate NA )?

State______________________________

A-7. Please indicate whether your parent firm is owne d by another, ultimate parent company (your highest corporate level).

Yes. (Continue with Question A-8.)
No. (Skip to Question A-9.)

A-8. What is your ultimate parent company’s country of i ncorporation?

United States. (Continue with Question A-9.) Other (non-U.S.). (Skip to Question A-12.)

A-9. What is the major line of business at your HIGHE ST corporate level (parent or ultimate parent, as relevant)? (Provide EITHER a brief description OR primary six-digit NAICS code, if known.) Most firms whose revenues are primarily associated with se afood canning at this highest corporate level would be classified in NAICS 311711; those whose rev enues are primarily associated with fresh and frozen seafood processing would be classified in NAICS 311712. At the highest level of the corporate hierarchy, however, other NAICS might apply.

Description of major line of business:

OR Primary 6-Digit NAICS Code

___ ___ ___ ___ ___ ___

A-10. Please provide the total employment at your hi ghest corporate level at year end 2009.

Total 2009 year end employment

A-11. Please provide the total revenues at your high est corporate level at year end 2009.

Total 2009 revenues $

Instructions: From this point on to the end of Par t B Section 1, the questions apply to your lowest
level of firm organization, that is, the company directly owning the facility or facilities included in this survey, not your parent firm or ultimate parent com pany.

A-12. If your company owns any commercial vessels, pleas e report the number of vessels owned. For barges and scows , please indicate the capacity of each.

Fishing Vessels

Barges (capacity: )

Scows (capacity: )

Tugboats

Processing Vessels

Other (please specify):

Other (please specify): CBI?

Yes

CBI?
Yes

CBI?

Yes

CBI?
Yes

CBI?
Yes

CBI?
Yes

CBI?
YesPart A. Corporate Information Alaskan Canned and Pre served Seafood Processing

Copy of

A-4 A-13. Please indicate your company’s type of business org anization.

Sole Proprietorship Partnership Corporation (standard, “C” corporation) Subchapter S Corporation Limited Liability Corporation Other (please specify):

A-14. In what state is your company organized as a lega l entity (if foreign, please indicate NA)?

State:

A-15. Please indicate the month that your fiscal year s tarts.

Month:

A-16. Please provide the average interest rate your company paid on outstanding debt in 2009.

Interest rate in 2009: %

A-17. Please provide financial reports for 2005 thro ugh 2009. These financial reports can be accounting reports or tax forms and must include income statement info rmation (revenues, costs, earnings, interest and taxes) and balance sheet items (assets, liabilities, and equity). Please check the box below to acknowledge that accounting reports have been attached to this questionnaire submittal. If 2009 financial reports are not yet available or i f other years’ data are not applicable, please note this in the Comments Section on Page A-6 and provide an explanation.

Accounting reports

are attached.

A-18. Are you a single-facility company AND your facility financials are the same as those for yo ur company?

Yes. You have completed Part A. Please proceed to Questi on B-1 to answer questions about your facility.
No. (Continue with Question A-19.)

A-19. Please fill out the table below to the extent relevant. This table requests information on seafood processing facilities

that you owned and their employment in locations out side of Alaska in 2009. Please provide the number of facilities and their nu mber of employees in full-time equivalents (1 FTE = 2,080 hours) in the regions shown below.

Facilities and Employment Outside of Alaska

Region Number of Seafood

Processing Facilities (2009) Employment in Full-Time

Equivalents (2009)

Other U.S.

Non-U.S. CBI?
Yes

CBI?
Yes

CBI?
Yes

CBI?

Yes

CBI?

Yes

CBI?
Yes

CBI?
YesPart A. Corporate Information Alaskan Canned and Pre served Seafood Processing

Copy of

A-5 A-20. For fiscal years 2005-2009, please provide the consolidated revenues for your company in the categories listed in the table below. If 2009 financ ial data are not yet available, or if other years’ da ta are not applicable, please enter NA.

Company Revenues

2005 2006 2007 2008 2009

a. Revenues from Sale of
Processed Seafood $ $ $ $ $

b. Revenues from Sale ofSecondary Byproducts $ $ $ $ $

c. Other Revenues (please describe):

$ $ $ $ $

d. Total Revenues (a+b+c) $ $ $ $ $

A-21. For fiscal years 2005 through 2009, please prov ide the consolidated operating costs for your
company in the categories listed in the table below

. If 2009 financial data are not yet available, or if other years’ data are not applicable, please enter NA

.

Company Consolidated Operating Costs

2005 2006 2007 2008 2009

a. Operating Costs for
Processed Seafood

Sold $ $ $ $ $

b. Operating Costs for Secondary By-product
Produced $ $ $ $ $

c. Waste Disposal Costs $ $ $ $ $

d. Other Operating Costs (please describe):

$ $ $ $ $

e. Total Operating Costs (a+b+c+d) $ $ $ $ $

You have completed Part A. Please complete Part B – Facility Information for the facilities noted at the top of page ii and at the top of each copy o f Part B. CBI?

Yes

CBI?
YesPart A Comments Alaskan Canned and Preserved Seafood P rocessing

Copy of

A-6 PART A COMMENTS

The questionnaire requests information for 2005 thr ough 2009. While year-to-year operations are expected to vary, please add a note in the Comments Table if th e information for these years is not representative of normal operations and why. Cross reference your comments by question number and indicate the confidential status of your comment by checking (  ) the box in the column titled "CBI" ( Confidential Business
Information ). If you need additional rows, make copies of this pa ge.

Question
Number CBI? Comment

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

YesPart A Definitions Alaskan Canned and Preserved Seafoo d Processing

Copy of

A-7 PART A DEFINITIONS

The terms identified below are identified in the te xt of this data request in bold and italic font.

Accounting Reports

– Financial reports or tax forms that include income statement information (revenues, costs, earnings, interest, and taxes) and balance she et items (assets, liabilities, and equity).

Alaska Pollock

– Walleye pollock, Theragra chalcogramma.

Amortization

-- The deduction of capital expenses over a specific perio d of time (usually over the life of the asset). Intangible assets, such as patents, copyrights, goodwill, brand names, are amortized. (source: Investopedia.com)

Barge – An unpowered, water-tight vessel used for transport ing freight that is towed or pushed by other craft.

Bottom Fish – Alaska pollock , halibut, flounders, rock fishes, ocean perch, hake, r ed snapper, and other
Alaska groundfish

species.

Canned and Preserved Seafood Processing Category – An industrial category for which effluent limitations guidelines and standards are codified at 40 CFR Part 408.

Chitin – Biopolymer found in the external skeleton of crabs and other arthropods.

Chitosan

– A linear polysaccharide produced from chitin

.

City Sewer – Water conveyance system that collects domestic and indu strial wastewater and transports it to a centralized wastewater treatment facility and/or dis charge point.

Clean Water Act (CWA) – A Federal statute enacted by Congress “to restore an d maintain the chemical, physical, and biological integrity of the Nation’s wat ers.” (Federal Water Pollution Control Act of 1972, as amended, 33 U.S.C. 1251 et seq.).

Confidential Business Information (CBI) – Information determined to be confidential as describe d in 40 CFR Part 2 Subpart B.

Depreciation

-- The deduction of capital expenses over a specific p eriod of time (usually over the life of the asset). Tangible assets are depreciated. (Source: Inve stopedia.com)

Direct Discharge

– (1) Any addition of any pollutant or combination o f pollutants to waters of the United States from any point source; or (2) any addition of any pollutant or combination of pollutants to the w aters of the “contiguous zone” or the ocean from any point source other than a vessel or other floating craft that is being used as a means of transportation. See 40 CFR 122.2

Fish Meal – A ground, dried product made from fish or shell fi sh or parts thereof, generally produced by cooking raw fish or shellfish with steam and pressing the material to obtain the solids which are then dr ied.

Fish Oil – Oil processed from the body or liver of fish. Typical ly produced with fish meal

.

Fishing Vessel – Boat used to catch finfish and shellfish, including but not limited to seiners, longliners, trollers, trawlers, gillnetters, and crabbing boats and their auxiliary vessels (e.g., power skiffs).

Full-time equivalent (FTE) – Employment calculated on the basis of total hours worked by all employees, regardless of whether they are full time, part time, or seasonal; 1 FTE = 2,080 hours.

GPS – Global Positioning System

Grinder – Device to cut up solids into a smaller more unifor m size (e.g., 0.5 inch or less). Includes grinding

pumps, macerator

pumps, and devices with rotating cutting teeth or g ears (comminutors).Part A Definitions Alaskan Canned and Preserved Seafoo d Processing

Copy of

A-8 Groundfish – Species classified as groundfish by the Alaska Department of Fish and Game, including but not limited to, cods, sabelfish, rockfishes, walleye p ollock, and miscellaneous groundfish

.

Gurry Scow – A non-water-tight container made from logs and net or mesh, or from planks, towed by a
motorized vessel. Gurry scows capture the largest solids and allow smaller solids such as viscera to flow through the openings.

Industry Petition – The petition submitted May 7,1980 by a portion of t he Alaska seafood processing industry, that requested EPA to modify the BPT regul ations for the Alaskan seafood processing industry by deleting Anchorage, Cordova, Juneau, Ketchican, and Pet ersburg from the " non-remote " Alaska subcategories.

Macerator

– Grinding pump. See grinder

.

NAICS Code – North American Industry Classification System code for classifying business establishments. Firms are classified on the basis of their primary so urce of revenues. If the primary source of revenues a t a firm is from Seafood Canning, the NAICS is 311711; if it is from Fresh and Frozen Seafood Processing, it is

311712.

Non-Remote – As used in effluent guidelines for the Canned and Preserved Seafood Processing Category

, " non-remote " means areas in Alaska population or processing cent ers including but not limited to Anchorage, Cordova, Juneau, Ketchikan, Kodiak, and Pete rsburg.

NPDES Permit – A permit issued under the National Pollutant Disch arge Elimination System (NPDES) program, which is the national program for issuing, modifying, revoking and reissuing, terminating, moni toring and enforcing permits, and imposing and enforcing p retreatment requirements under sections 307, 318, 40 2,
and 405 of the Clean Water Act

.

Offshore disposal

– Disposal at-sea of waste(s) produced at a shore-b ased seafood processing facility.

Other Alaska – Areas of Alaska outside of Anchorage, Cordova, Junea u, Ketchikan, Petersburg, Dutch Harbor, and the Kenai Peninsula

Outfall – A wastewater discharge. See point source

.

Point Source – A discernible, confined, and discrete conveyance, incl uding but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, conta iner, rolling stock, concentrated animal feeding operat ion, landfill leachate collection system, vessel or other fl oating craft from which pollutants are or may be discharged. This term does not include return flows from irrigated agriculture or agricultural storm wate r runoff. (See 40) CFR §122.2).

Primary Products – Fresh, frozen, canned, or preserved fish and other seafood

.

Questionnaire Package – Certification Statement; Part A - Corporate Inform ation; Part B - Facility Information (one copy for each facility); Accounting Reports ; and Other Attachments.

Reduction Facility – See secondary by-product recovery facility.

Remote – As used in effluent guidelines for the Canned and Preserved Seafood Processing Category

,

" remote " means areas in Alaska other than Anchorage, Cordova , Juneau, Ketchikan, Kodiak, and Petersburg.

Scow – A self-propelled (powered) vessel used for transp orting bulk freight, garbage, or other waste.

Screen – A mechanical device for separating solids and liquid s. Screens used to separate seafood processing solids from wastewater include revolving dr ums, vibrating screens, pressure screens, and many
others.Part A Definitions Alaskan Canned and Preserved Seafoo d Processing

Copy of

A-9 Seafood – The raw material, including freshwater and saltwat er fish and shellfish to be processed, in the form that it is received at the processing facility.

Seafood Processing Company – A legal entity that owns one or more seafood processing facilities

.

Seafood Processing Facility – Establishment primarily engaged in preparing and/o r processing fish and
seafood . Fresh fish are eviscerated and/or processed by remov al of heads, fins or scales. Processing includes freezing, canning, cooking, smoking, salting, drying, curing, and fermenting as well as shucking and packing of clams and oysters.

Seafood Processing Waste – Discarded solid and liquid material, produced by seafood processing
facilities . Waste is material that is not a product or by-produ ct.

Secondary By-product – Seafood meal, fish oil

, chitin

, chitosan , fertilizer, and other by-products of
seafood processing.

Secondary By-product Produced – Includes by-product that is sold, used but not sold, and given away.

Secondary By-product Recovery – Process by which secondary by-products are produced from the portion of the fish or shellfish that does not becom e primary product.

Secondary By-product Recovery Facility – Establishment primarily engaged in producing seafoodbyproducts.

Selling, General & Administrative Costs (SG&A) –Reported on the income statement, it is the sum of all direct and indirect selling expenses and all general and administrative expenses. Direct selling expenses are expenses that can be directly linked to the sale of a specific unit such as credit, warranty and advertising expenses. Indirect selling expenses are expenses whi ch cannot be directly linked to the sale of a specific un it, but which are proportionally allocated to all units so ld during a certain period, such as telephone, intere st and postal charges. General and administrative expenses include salaries of non-sales personnel, rent, heat and lights (source: Investopedia.com)

Study Area – Anchorage, Cordova, Juneau, Ketchicakn, Petersburg, D utch Harbor, and the Kenai Peninsula

Tugboat – A boat designed and built to maneuver other vesse ls by pushing or towing them.Part B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-1 PART B. FACILITY INFORMATION

B-1. Name of the Facility: Plant A

B-2. Latitude: Longitude:

B-3. NPDES number of this facility: AKG520303

INSTRUCTIONS FOR FILLING OUT PART B

Please use the following guidelines for filling out the questionnaire:

• EPA has provided definitions for key terms at the end of each section

. These terms are shown in bold italics as they are used throughout the questionnaire

.

• Please confirm that the above information is accura te. Please note any changes in the Comments Table at the end of this questionnaire.

• Use black ink

or type in the spaces provided.

• Mark responses for each question and do not leave b lanks. Fill in the appropriate response(s) to each question unless instructed to skip the question. Check the boxes that apply to your answers. Answer the questions in sequence. Do not leave any ent ry blank. If the answer is zero, enter “0" or

“zero”.

• Enter “N/A” if a question is not applicable to your Seafood Processing Facility . EPA prepared the questionnaire to be applicable to a variety of Seafood Processing Facilities ; therefore, it is possible that not all of the questions will apply to every Seafood Processing Facility. Please complete each relevant item in the questionnaire and enter “N/A” if a question is not applicable to

your Seafood Processing Facility.

If you do not have the requested information for qu estions applicable to your facility, please provide your best estimates.

• Include any clarifying attachments. If additional pages are required to clarify a resp onse, please place the associated question number, as well as the name of each of your Seafood Processing
Facilities (if applicable) in the top right corner of each attachm ent page.

• Some pages of the questionnaire may need to be phot ocopied before you respond, indicate how many copies of the page(s) you are submitting by comple ting the entry “Copy ___ of ___” in the top right corner, unless instructed otherwise.

• Indicate information that should be treated as conf idential. You may claim as confidential all information included in the response to a question by checking the Confidential Business Information (CBI) box next to the question number. Note that you may be required to justify any claim of confidentiality at a later time. Blanket clai ms are not recommended and individual claims must be carefully considered. Read carefully the CONFI DENTIAL BUSINESS INFORMATION section on page v and understand the implications bef ore you make such a claim.

• Indicate atypical data in the Comments Table. The questionnaire requests information for 2005 through 2009. While year-to-year operations are expec ted to vary, please add a note in the Comments Table if the information for these years is not representative of normal operations and why.Part B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-2 QUESTIONNAIRE ASSISTANCE

If you have any questions as you complete Part B of thi s questionnaire, please contact EPA using the telephone numbers and email addresses provided below

.

Contacts for Assistance

Facility Technical Information
Questions B-1 to B-40

Mr. Donald F. Anderson (202) 566-1021 anderson.donaldf@epa.gov Facility Financial Information
Questions B-41o B-46

Mr. Todd Doley (202) 566-1160 doley.todd@epa.govPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-3 B-4. Please provide the primary contact for Part B o f this questionnaire, if different than the contact f or Part A.

Contact for Part B is the same as for Part A.
Use the contact below for Part B.

( ) Printed Name of Part B Contact Telephone Number

( )
Part B Contact Title Facsimile Number

Convenient time to call between:

Email Address am / pm and

am / pm EDT

Street Address

City State Zip Code

B-5. Please indicate the type of products your facility produces (choose one). Do not include fish waste
sent to an offsite reduction facility

.

Only produces secondary by-products : seafood meal, fish oil

, chitin or chitosan

, fertilizer, etc. (i.e., the facility is a stand-alone a reduction plant).

STOP. You have completed Part B for this facility.

Only produces seafood products from whole fish or shellfish: fresh, frozen , canned, smoked, salted or pickled seafoods

.
Produces BOTH primary products and secondary by-products

.

B-6. Please indicate the facility type.

Off-shore vessel (operating and discharging more th an one (1) nautical mile from shore at

MLLW)

STOP. You have completed Part B for this facility.

Shore-based (operating and discharging less than on e-half (0.5) nautical mile from shore at MLLW).

Near-shore vessel (operating and discharging from o ne (1) to one-half (0.5) nautical mile from shore at MLLW).

B-7. When did this facility begin its seafood processing operations? (Year)

B-8. What is the current capacity of this facility?

pounds/day raw fish and/or shellfish CBI?
Yes

CBI?
Yes

CBI?
Yes

CBI?
Yes

CBI?
YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-4 B-9. Please provide information about expansions an d capacity increases.

Year Capacity Added (pounds/day raw fish and/or shell fish)

B-10. Indicate all the types of fish or marine life p rocessed at your facility in a given year.

Salmon

Tanner Crab

Dungeness Crab

King Crab

Bottom Fish

( Alaska pollock

, halibut, and other groundfish )

Clam

Oyster

Sardine

Scallop

Herring

Abalone

Shrimp

Other (please specify):

Other (please specify):

Other (please specify):

Bottom fish

includes: Alaska pollock , halibut, flounders, rock fishes, ocean perch, hake, re d snapper, cod, and other Alaska groundfish species. CBI?
Yes

CBI?
YesPart B. Facility InformationAlaskan Canned and Preserved Seafood ProcessingCopyofB-5B-11. For each type ofseafoodindicated in Question B-10, please provide total weight (pounds) of raw fish and shellfish processed in2005 through2009. In lieu completing the table below, you can attach an existing data report as long as the data provided include all the informationrequested below.Table 1. Total Pounds (lbs) Raw Fish and ShellfishProcessedSeafoodType20052006200720082009Example: Canned Salmon56,00068,00043,00050,00055,000Fresh/Frozen SalmonCanned SalmonTanner Crab SectionTanner Crab MeatDungeness Crab SectionKing Crab MeatKing Crab SectionBottom FishaShrimpHerringOther (please specify):Other (please specify):Other (please specify):aBottom fishincludes:Alaska pollock, halibut, flounders, rock fishes, ocean perch, hake, red snapper, cod, and other Alaskagroundfishspecies.CBI?YesPart B. Facility InformationAlaskan Canned and Preserved Seafood ProcessingCopyofB-6B-12. For theseafoodtypes in the following table, please indicate the average pounds/day processed in each month to show the seasonaldistribution throughone peak production yearselected between 2005 and 2009.(Refer to Table 1. For eachseafoodtype, identify the yearwith the largest production. Complete Table 2 for that year. The year does not need to be the same for eachseafoodtype.)Table 2. Seasonal Average lbs/Day ProcessedSeafoodTypeYearJanFebMarAprilMayJunJulAugSepOctNovDecExample: Salmon,Canned20060002001,00014,00025,00016,0008,000000Salmon, Fresh/FrozenSalmon, CannedCrab (total of alltypes)Bottom FishaHerringOther (pleasespecify):aBottom fishincludes:Alaska pollock, halibut, flounders, rock fishes, ocean perch, hake, red snapper, cod, andother Alaskagroundfishspecies.CBI?YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-7 B-13. For the seafood types in the following table, please indicate the pe ak production week and day for the peak year between 2005 through 2009 as well as th e rate of production during these time frames. The peak year should be the same as the peak years indi cated in Table 2.

Table 3. Peak Production

Seafood Type Year Week of Peak
Production (MM/DD – MM/DD) Peak
Production Rate (lbs/Week) Day of Peak

Production (MM/DD) Peak Production

Rate (lbs/day)

Example: Salmon, Canned 2006 07/04 to 07/11 8,000 07/05 1,583

Salmon, Fresh/
Frozen

Salmon, Canned

Crab (Total of all types)

Bottom Fish a

Herring

Other (please specify):

a Bottom fish

includes: Alaska pollock , halibut, flounders, rock fishes, ocean perch, hake, re d snapper, cod,
and other Alaska groundfish species. CBI?

YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-8 Questions about Onsite Secondary By-products

B-14. Does your facility produce secondary by-products ? Do NOT include fish waste sent to an offsite reduction facility

.

No. (Skip to Question B-23.)

Yes. Both primary products and secondary by-products are produced at this facility. (Continue with Question B-15.)

B-15. When did secondary by-product recovery operations begin at this facility?

(Year)

B-16. What is the current capacity of this facility for secondary by-product production ?

(pounds/day or other unit, please specify: )

B-17. Please explain why your facility produces secondary by-products

.

B-18. Please indicate the total annual production for the peak year between 2005 and 2009. Please indicate the year for which you are providing production, the un its you use to measure the production of each product, and the numbers of days the facility operated during that peak year.

Table 4. By-product Production

By-product Year Annual
Production for
Peak Year Units Days Operated in
Peak Year

Example: Fish Oil 2009 110,000 Gallons 215

Fish Meal

(salmon)

Fish Meal

(whitefish)

Fish Meal

(shellfish)

Fish Oil

Chitin and or Chitosan

Fertilizer

Other (please specify):

Other (please specify):

Other (please specify): CB?

Yes

CB?
Yes

CB?
Yes

CBI?

Yes

CBI?
YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-9 B-19. Please indicate the total pounds of raw materi al for secondary by-product production generated onsite and the total pounds of seafood processing waste received from offsite facility(ies) each year

between 2005 and 2009.

Table 5. Secondary By-Product Production Raw Materi als

Year Pounds

of raw material for secondary by-product production generated onsite Pounds
of seafood processing waste received from offsite facility(ies)

2005

2006

2007

2008

2009

B-20. Does your facility accept seafood processing waste from one or more other seafood processing
facilities to be made into secondary by-product ?

Yes
No. (Skip to Question B-23.)

If “Yes,” describe in detail the business agreement o r provide a copy (copies) of contracts, letter agreements, etc., that provide such details.

B-21. What is the distance (road miles, or nautical m iles by water transport) from these other seafood processing facilities

to your facility?

1. By Truck (miles) By Barge (nautical miles)

2. By Truck (miles) By Barge (nautical miles)

3. By Truck (miles) By Barge (nautical miles)

If the waste is transported by other means please ex plain:

B-22. What is the cost of transporting the waste to this facility?

$/wet ton Total annual cost CBI?

Yes

CBI?

Yes

CBI?
Yes

CBI?

YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-10 Questions about Waste Generation and Disposal

B-23. In the blank space below, please provide a schem atic diagram of the facility’s production process showing all waste streams leaving the process. An ex ample schematic is provided to give you an idea of the level of detail you should include. Attaching an existing process schematic and description of the waste streams would be the most useful and an adeq uate alternative response.

Example Schematic CBI?

Yes

Seafood Processing

Screen or Grinder

(If present) Fresh or Marine Water

Final Seafood Product (a)

Seafood
Wastewater to Outfall or City Sewer (d)

Disposal (e) Onsite Reduction Facility (b) Unprocessed

Fish and /or Shellfish (r)

Offsite Reduction Facility (c) Solids

Solids Waste Water-Sluiced Waste

Solids Waste

Solids to By

- product Recovery

Plant A Process SchematicPart B. Facility Information Alaskan Canned and Preserved Seafood ProcessingCopyofB-11B-24. Using data for a typical year between 2005 through 2009 please provide a percentageestimateof the following: A)seafoodprocessed at thefacility that becomes product, B)seafoodthat becomessecondary seafood by-productat an on-site facility C)seafoodthat becomessecondary seafood by-productat an off-site facility D)seafoodwaste that is discharged to an outfall or city sewer, and E)seafoodwastethat is taken away from the plant through means otherthan an outfall or city sewer. The total of the 5estimates should equal 100%. Thecalculation for each stream refers to the labeled example schematic diagram in Question B-23.Table 6. Estimated Breakdown of Product, SecondaryBy-product, and Waste (for a typical year, 2005 to2009)(A) Percent of WeightProcessed thatBecomesSeafoodProduct(B) Percent of WeightProcessed thatbecomesSecondaryBy-productOnsite(C) Percent of WeightProcessed thatbecomesSecondaryBy-productOffsite(D) Percent of WeightProcessed that isDischarged to anOutfallorCity Sewer(E) Percent of WeightProcessed that istaken away fordisposal (e.g.,dumpedoffshoreor ina landfill)SeafoodTypes ProcessedA=100*(a/r)B=100*(b/r)C=100*(c/r)D=100*(d/r)E=100*(e/r)Example: Canned Salmon35%0%0%65%0%Fresh/Frozen SalmonCanned SalmonTanner Crab SectionTanner Crab MeatDungeness Crab SectionKing Crab MeatKing Crab SectionBottom FishShrimpHerringOther (please specify):Other (please specify):Weight processed means raw fish and/or shellfish.Bottom fishmeansAlaska pollock, halibut, flounders, rock fishes, ocean perch, hake, redsnapper, cod, andother Alaskagroundfishspecies.CBI?YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-12 Questions about Wastewater Disposal and Volumes

B-25. How is wastewater (stream ( d) on the example schematic) disposed of from your facil ity? Indicate if there is any treatment of the wastewater before leav ing your seafood processing facility.

Discharged through an outfall No treatment prior to discharge through plant outfall Solids are processed in a grinder / macerator
Screen is used to capture solids Other (please specify):

Discharged to city sewer Please provide the name of the municipality:

No treatment prior to discharge to city sewer Solids are processed in a grinder / macerator
Screen is used to capture solids Other (please specify):

B-26. Referring to Table 1 in Question B-11, identi fy the year between 2005 and 2009 with the greatest production. For this year, report in Table 7, the av erage volume (gallons per day) of seafood processing wastewater directly discharged through your pl ant outfall or discharged to a city sewer in each month. If you do not measure discharge volume of wastewater, record the volume of fresh and / or marine water used in the processing plant to esti mate wastewater volume. You also have the option of enclosing these data in an available forma t as attachments in lieu of completing the table below. Please identify the units of measure (e.g., g allons per day).

Table 7. Average Volume of Seafood Processing Wast ewater Discharge by Month

If discharge volume is not available, report Year of Greatest
Production: Average Volume of
Wastewater Discharged Units Volume of Freshwater Used (gpd) Volume of Marine

Water Used (gpd)

Example: January 10,000 Gallons per day NA NA

January

February

March

April

May

June

July

August

September

October

November

December CBI?

Yes

CBI?

YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-13 Questions about Disposal of Screenings and Other So lid Wastes

B-27. Are solid wastes separated from wastewater an d managed separately (e.g., trimmings are kept out of the drain and hauled to a landfill).

Yes
No. (Skip to Question B-35.)

B-28. What is the capacity of your facility to store seafood processing screenings and other solid waste? Please indicate units of holding capacity (e.g., poun ds, gallons, cu ft, cu yds).

B-29. If solids are screened or otherwise separated from wastewater, please indicate how they are managed.

Solids stored and disposed of off shore. Please de scribe any additional treatment (e.g., further dewatering or grinding)

Sent to an offsite secondary by-product recovery facility

No treatment prior to arrival at a secondary by-product recovery facility

Sent to a landfill

Other (please specify):

Other (please specify):

Other (please specify):

Other (please specify):

B-30. If you reported that screenings and other solid waste are disposed of off-shore in question B-29, please describe the type of vessel used to transport the waste.

Fishing vessel

Gurry scow

(log/net dimensions tow vessel engine HP )

Barge (holding capacity tow vessel engine HP )

Other (please specify):

Other (please specify):

B-31. If you reported that screenings and other solid waste are disposed of off-shore in question B-29, please report the location of your disposal site(s). You may attach a map with the site(s) marked or provide GPS

coordinates. Please report how far the disposal sit e is from the dock.

Map Attached Approx. GPS

location(s)

Distance from dock: nautical miles CBI?

Yes

CBI?
Yes

CBI?
Yes

CBI?
Yes

CBI?
YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-14 B-32. During the period of 2005 through 2009, indica te any times you were not able to haul the waste to an off-shore location and explain why (e.g., weather, et c)

Date Explanation why waste could not be hauled off s hore

B-33. Does your facility accept seafood processing waste from other processors for disposal offshore ?

Yes. Please provide the following information for the other seafood processing facility :

Name:

Location:

Contact:

Distance (please specify units):

No

B-34. Does your facility use the services of a separat e company to dispose of the seafood processing

waste offshore ?

Yes. Please provide the following information for the company:

Name:

Location:

Contact:

Distance (please specify units):

No CBI?

Yes

CBI?

Yes

CBI?

YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-15 B-35. Does your facility cooperatively use the services of another processor(s) to collectively transport and dispose of the seafood processing waste to an offshore

facility?

Yes. Please provide the following information for the seafood processing facility :

Name:

Location:

Contact:

Distance (please specify units):

Please describe in detail the business agreement or provide a copy (copies) of contracts, letter agreements, etc., that provide such details.

No CBI?

YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-16 Questions about Available Dock Space

B-36. During peak fishing season, is there sufficien t space on the docks to load seafood processing

waste onto a barge or vessel ?

Yes
No

B-37. Please estimate the percent of the shore line length and dock area used during peak fishing season? For what purposes are they used?

% of shore length used % of dock area used

Purpose or purposes CBI?
Yes

CBI?
YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-17 Questions About Offsite Secondary By-product Facili ties

B-38. Please provide the names of and distance from your facility to the closest offsite secondary byproduct recovery facility

.

1. is miles or nautical sea miles away.

2. is miles or nautical sea miles away.

3. is miles or nautical sea miles away.

B-39. For the facilities listed in response to quest ion B-38, has your seafood processing facility / company attempted to enter into long term agreements or arr angements to have your seafood processing

waste transported to any of these reduction facilities?

Yes

If “Yes,” describe in detail the business agreement o r provide a copy (copies) of contracts, letter agreements, etc., that provide such details.

No

If no, please indicate why not.

Our facility has an onsite reduction (by-product pro duction) system.

Our facility has never looked into the use of by-pr oduct production whether onsite or offsite.

The offsite facility(ies) does not have the capacity t o accept additional seafood processing

waste

. Other (please explain):

B-40. In some cases, secondary by-product recovery facilities were previously available but are not operating at the present time. Please indicate if su ch a dormant facility exists, in what location, and the distance from your seafood processing facility

.

Name:

Location:

Contact:

Distance (please specify units): CBI?

Yes

CBI?
Yes

CBI?
YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-18 B-41. Do you know of any proposed secondary by-product recovery facility that may be constructed in the near future? If so, what is the location and dis tance from your seafood processing facility ? Please provide any information regarding contacts and / or any available specifics for the proposed secondary by-product recovery facility

.

Yes. Please provide the following information for the proposed facility:

Name:

Location:

Contact:

Distance (please specify units):

No CBI?

YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-19 Questions about Facility Financial Information

B-42. Please provide the contact information of the i ndividual who completed the facility’s financial secti on of this questionnaire.

( ) Printed Name of Primary Contact Telephone Number

( ) Primary Contact Title Facsimile Number

Email Address

Street Address

City State Zip Code

B-43. For fiscal years 2005 through 2009, please prov ide revenues for this Seafood Processing Facility in the categories shown in the table below. If 2009 fin ancial data are not yet available or other years’ data are not applicable, please insert NA and provid e an explanation in the Comments Section on Page B-22.

Revenues for Seafood Processing Facility

2005 2006 2007 2008 2009

a. Revenues from
Processed Seafood
Sold $ $ $ $ $

b. Revenues fromSecondary Byproducts

Sold $ $ $ $ $

c. Other Revenues (please describe):

$ $ $ $ $

d. Total Revenues (a+b+c) $ $ $ $ $ CBI?

Yes

CBI?
YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-20 B-44. For fiscal years 2005 through 2009, please prov ide the operating and other costs for this Seafood Processing Facility

in the categories shown in the table below. If 2009 financial data are not yet available or other years’ data are not applicable, pl ease insert NA and provide an explanation in the Comments Section on Page B-22.

Operating and Other Costs for Seafood Processing Fa cility

2005 2006 2007 2008 2009

a. Operating Costs for
Processed Seafood

Sold $ $ $ $ $

b. Operating Costs for Secondary By-product

Produced $ $ $ $ $

c. Waste Disposal Costs $ $ $ $ $

d. Other Operating Costs (please describe):

$ $ $ $ $

e. Total Costs (a+b+c+d) $ $ $ $ $

f. Other Costs ( Selling,
General &
Administrative [ SG&A ] exclude any interest) $ $ $ $ $

g. Depreciation and
Amortization

(If not

accounted for at the facility, use N/A) $ $ $ $ $

h. Total facility costs (e+f+g) $ $ $ $ $

B-45. How many employees worked at this Seafood Processing Facility in 2009? Please provide the following information in the table.

Seafood Processing Facility Employees (2009)

Part-time Employees (full-year) Seasonal Workers Subcontractors

2009 Employment Full-time

Employees Persons Total
Hours Persons Total
Hours Persons Total
Hours

Local Labor (Reside in Alaska Year-Round)

Imported Labor (Permanent Residency Outside Alaska) CBI?
Yes

CBI?

YesPart B. Facility Information Alaskan Canned and Prese rved Seafood Processing

Copy of

B-21 B-46. During peak fishing season what was the maximum number of employees (full time and part time, in persons, not full time equivalents) working at this Seafood Processing Facility in 2009?

B-47. During peak fishing season what was the maximum number of total labor hours clocked in one day in
2009 at this Seafood Processing Facility ?

labor hours in one day

You have completed the questionnaire.

THANK YOU FOR YOUR TIME AND PARTICIPATION CBI?

Yes

CBI?

YesPart B Comments Alaskan Canned and Preserved Seafood P rocessing

Copy of

B-22 PART B COMMENTS

The questionnaire requests information for 2005 thr ough 2009. While year-to-year operations are expected to vary, please add a note in the Comments Table if th e information for these years is not representative of normal operations and why. Cross reference your comments by question number and indicate the confidential status of your comment by checking (  ) the box in the column titled "CBI" ( Confidential Business
Information ). If you need additional rows, make copies of this pa ge.

Question
Number CBI? Comment

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

YesPart B Definitions Alaskan Canned and Preserved Seafoo d Processing

Copy of

B-23 PART B DEFINITIONS

The terms identified below are identified in the te xt of this data request in bold and italic font.

Accounting Reports

– Financial reports or tax forms that include income statement information (revenues, costs, earnings, interest, and taxes) and balance she et items (assets, liabilities, and equity).

Alaska Pollock

– Walleye pollock, Theragra chalcogramma.

Amortization

-- The deduction of capital expenses over a specific perio d of time (usually over the life of the asset). Intangible assets, such as patents, copyrights, goodwill, brand names, are amortized. (source: Investopedia.com)

Barge – An unpowered, water-tight vessel used for transport ing freight that is towed or pushed by other craft.

Bottom Fish – Alaska pollock , halibut, flounders, rock fishes, ocean perch, hake, r ed snapper, and other
Alaska groundfish

species.

Canned and Preserved Seafood Processing Category – An industrial category for which effluent limitations guidelines and standards are codified at 40 CFR Part 408.

Chitin – Biopolymer found in the external skeleton of crabs and other arthropods.

Chitosan

– A linear polysaccharide produced from chitin

.

City Sewer – Water conveyance system that collects domestic and indu strial wastewater and transports it to a centralized wastewater treatment facility and/or dis charge point.

Clean Water Act (CWA) – A Federal statute enacted by Congress “to restore an d maintain the chemical, physical, and biological integrity of the Nation’s wat ers.” (Federal Water Pollution Control Act of 1972, as amended, 33 U.S.C. 1251 et seq.).

Confidential Business Information (CBI) – Information determined to be confidential as describe d in 40 CFR Part 2 Subpart B.

Depreciation

-- The deduction of capital expenses over a specific p eriod of time (usually over the life of the asset). Tangible assets are depreciated. (Source: Inve stopedia.com)

Direct Discharge

– (1) Any addition of any pollutant or combination o f pollutants to waters of the United States from any point source; or (2) any addition of any pollutant or combination of pollutants to the w aters of the “contiguous zone” or the ocean from any point source other than a vessel or other floating craft that is being used as a means of transportation. See 40 CFR 122.2

Fish Meal – A ground, dried product made from fish or shell fi sh or parts thereof, generally produced by cooking raw fish or shellfish with steam and pressing the material to obtain the solids which are then dr ied.

Fish Oil – Oil processed from the body or liver of fish. Typical ly produced with fish meal

.

Fishing Vessel – Boat used to catch finfish and shellfish, including but not limited to seiners, longliners, trollers, trawlers, gillnetters, and crabbing boats and their auxiliary vessels (e.g., power skiffs).

Full-time equivalent (FTE) – Employment calculated on the basis of total hours worked by all employees, regardless of whether they are full time, part time, or seasonal; 1 FTE = 2,080 hours.

GPS – Global Positioning System

Grinder – Device to cut up solids into a smaller more unifor m size (e.g., 0.5 inch or less). Includes grinding

pumps, macerator

pumps, and devices with rotating cutting teeth or g ears (comminutors).Part B Definitions Alaskan Canned and Preserved Seafoo d Processing

Copy of

B-24 Groundfish – Species classified as groundfish by the Alaska Department of Fish and Game, including but not limited to, cods, sabelfish, rockfishes, walleye p ollock, and miscellaneous groundfish

.

Gurry Scow – A non-water-tight container made from logs and net or mesh, or from planks, towed by a
motorized vessel. Gurry scows capture the largest solids and allow smaller solids such as viscera to flow through the openings.

Industry Petition – The petition submitted May 7,1980 by a portion of t he Alaska seafood processing industry, that requested EPA to modify the BPT regul ations for the Alaskan seafood processing industry by deleting Anchorage, Cordova, Juneau, Ketchican, and Pet ersburg from the " non-remote " Alaska subcategories.

Macerator

– Grinding pump. See grinder

.

NAICS Code – North American Industry Classification System code for classifying business establishments. Firms are classified on the basis of their primary so urce of revenues. If the primary source of revenues at a firm is from Seafood Canning, the NAICS is 311711; if it is from Fresh and Frozen Seafood Processing, it is

311712.

Non-Remote – As used in effluent guidelines for the Canned and Preserved Seafood Processing Category

, " non-remote " means areas in Alaska population or processing cent ers including but not limited to Anchorage, Cordova, Juneau, Ketchikan, Kodiak, and Pete rsburg.

NPDES Permit – A permit issued under the National Pollutant Disch arge Elimination System (NPDES) program, which is the national program for issuing, modifying, revoking and reissuing, terminating, moni toring and enforcing permits, and imposing and enforcing p retreatment requirements under sections 307, 318, 40 2,
and 405 of the Clean Water Act

.

Offshore disposal

– Disposal at-sea of waste(s) produced at a shore-b ased seafood processing facility.

Other Alaska – Areas of Alaska outside of Anchorage, Cordova, Junea u, Ketchikan, Petersburg, Dutch Harbor, and the Kenai Peninsula

Outfall – A wastewater discharge. See point source

.

Point Source – A discernible, confined, and discrete conveyance, incl uding but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, conta iner, rolling stock, concentrated animal feeding operat ion, landfill leachate collection system, vessel or other fl oating craft from which pollutants are or may be discharged. This term does not include return flows from irrigated agriculture or agricultural storm wate r runoff. (See 40) CFR §122.2).

Primary Products – Fresh, frozen, canned, or preserved fish and other seafood

.

Questionnaire Package – Certification Statement; Part A - Corporate Inform ation; Part B - Facility Information (one copy for each facility); Accounting Reports ; and Other Attachments.

Reduction Facility – See secondary by-product recovery facility.

Remote – As used in effluent guidelines for the Canned and Preserved Seafood Processing Category

,

" remote " means areas in Alaska other than Anchorage, Cordova , Juneau, Ketchikan, Kodiak, and Petersburg.

Scow – A self-propelled (powered) vessel used for transp orting bulk freight, garbage, or other waste.

Screen – A mechanical device for separating solids and liquid s. Screens used to separate seafood processing solids from wastewater include revolving dr ums, vibrating screens, pressure screens, and many
others.Part B Definitions Alaskan Canned and Preserved Seafoo d Processing

Copy of

B-25 Seafood – The raw material, including freshwater and saltwat er fish and shellfish to be processed, in the form that it is received at the processing facility.

Seafood Processing Company – A legal entity that owns one or more seafood processing facilities

.

Seafood Processing Facility – Establishment primarily engaged in preparing and/o r processing fish and
seafood . Fresh fish are eviscerated and/or processed by remov al of heads, fins or scales. Processing includes freezing, canning, cooking, smoking, salting, drying, curing, and fermenting as well as shucking and packing of clams and oysters.

Seafood Processing Waste – Discarded solid and liquid material, produced by seafood processing
facilities . Waste is material that is not a product or by-produ ct.

Secondary By-product – Seafood meal, fish oil

, chitin

, chitosan , fertilizer, and other by-products of
seafood processing.

Secondary By-product Produced – Includes by-product that is sold, used but not sold, and given away.

Secondary By-product Recovery – Process by which secondary by-products are produced from the portion of the fish or shellfish that does not becom e primary product.

Secondary By-product Recovery Facility – Establishment primarily engaged in producing seafoodbyproducts.

Selling, General & Administrative Costs (SG&A) –Reported on the income statement, it is the sum of all direct and indirect selling expenses and all general and administrative expenses. Direct selling expenses are expenses that can be directly linked to the sale of a specific unit such as credit, warranty and advertising expenses. Indirect selling expenses are expenses whi ch cannot be directly linked to the sale of a specific un it, but which are proportionally allocated to all units so ld during a certain period, such as telephone, intere st and postal charges. General and administrative expenses include salaries of non-sales personnel, rent, heat and lights (source: Investopedia.com)

Study Area – Anchorage, Cordova, Juneau, Ketchicakn, Petersburg, D utch Harbor, and the Kenai Peninsula

Tugboat – A boat designed and built to maneuver other vesse ls by pushing or towing them.A ppendix B

CHECK LISTSB

- 1 Literature Review Data Quality Check List

Reference Citation:

DCN

Reviewer Name:

Date Reviewed: Source Usability Determination: ____meets quality specifications

___ _does not meet quality specifications

Specification Value Comments

Year of publication (or presentation, if a paper presented at a conference) Priority : 2005 or after.

Consider: 2000 or after.

Demonstration Status Priority: full

- scale processes in c ommercial use. Consider: processes demonstrated in pilot scale.

Geographic Scope Priority: processes used in Alaska. Consider: processes used in British Columbia and the U.S.

Pacific northwest.

Type of Publication Government publication (U.S., Cana da, state, or province)

For academic researcher:

• Publication in peer

- reviewed journal

• Presentation at professional technical conference

For vendor researcher:

• Publication in peer

- reviewed journalB

- 2 Pollution Control Technology Cost Data Quality Check Li st

Cost Information Source:

DCN

Reviewer Name:

Date Reviewed: Source Usability Determination: ____meets quality specifications ____does not meet quality specifications

Specification Value Comments

Costs are current (e.g., 2009

– 2010).

Costs are appropriate for the “non

- remote” areas of Alaska included in this study.

Obtained from a vendor who does business in the Alaska areas included in this study.

Within +/

- 33% of other sources.B

- 3 Economic Profile and Analysis Data Quality Check Lis t

Information Source:

DCN

Reviewer Name:

Date Reviewed: Source Usability Determination: ____meets quality specifications ____does not meet quality specifications

Specification Value Comments

Year of Publication

Most recent available.

Geographic Scope Petitioner identified processing centers EPA identified processing centers

All Alaska

Type of publication

Government data will be considered “best available.” Peer

reviewed items such as college textbooks will be considered “reliable,” as will be widely accepted handbooks for financial analysis used throughout the financial analysis community. Dun and Bradstreet and RMA data will be considered “reasonably reliable.” Other sources will be reviewed and used with caveats discussed, as necessary.

Co mparability For sources of similar reliability, similar values are reported for the same variable (factor).A ppendix C

NON

- REMOTE ALASKAN SEAFO OD PROCESSORS PETITI ON RESPONSE

PROJECT FILE MANAGEM ENT PLAN

# Non

- Remote Alaskan Seafood Processors Petition Response Project File Management Plan

Prepared for:



## U.S. Environmental Protection Agency

Engineering and Analysis Division
Office of Water 1200 Pennsylvania A venue, NW Washington, D.C. 20460

Prepared by:



## Eastern Research Group, Inc.

14555 Avion Parkway

Suite 200 Chantilly, VA 20151

- 1102

July 2010 Updated September 2013

EPA Contract No. 68

- C

- 02

- 095 Work Assignment 07

- 30C

- 1 USE AND DISCLOSURE OF DATA

The data contained herein must be treated as privileged and confidential. As such, the contents of this document shall not be duplicated, used, or disclosed in whole or in part without the permission of Eastern Research Group, Inc. for any purpose other than to evaluate this project file management plan. The entire contents of this plan are subject to this restriction.C

- 2 CONTENTS

Page

1. I NTRODUCTION AND D EFINITIONS

................................ ................................ ........................ 3

1.1 Background

................................ ................................ ................................ ............. 3

1.2 Alaskan Seafood Petition Response Project File

................................ .................... 3

1.3 Docket

................................ ................................ ................................ ..................... 4

1.4 Federal Docket Mana gement System (FDMS)

................................ ....................... 5

1.5 Electronic Project File

................................ ................................ ............................. 5

1.6 Contract File

................................ ................................ ................................ ............ 5

1.7 Personal Files

................................ ................................ ................................ .......... 5

1.8 Project File Index

................................ ................................ ................................ .... 6

1.9 FDMS Metadata

................................ ................................ ................................ ...... 6

1.10 Confidential Business Information (CBI)

................................ ............................... 6

1.11 CBI

- Deducible Information

................................ ................................ ................... 6

2. G ENERAL P ROCEDURE S

................................ ................................ ................................ ....... 8

2.1 Submitting Material to the Project File

................................ ................................ ... 8

2.1.1 Step

- By

- Step Process for Submitting Record Materials

............................. 8

2.1.2 Detailed Discussion of Document Submission Process

.............................. 9

2.2 Document Control Numbers (DCNs)

................................ ................................ ... 11

2.2.1 Appendices and Attachments

................................ ................................ .... 11

2.2.2 Copies

................................ ................................ ................................ ....... 12

2.2.3 CBI Documents

................................ ................................ ......................... 12

2.3 Project File Index

................................ ................................ ................................ .. 12

2.3.1 Index Structure

................................ ................................ .......................... 12

2.3.2 Alaskan Seafood Petition Resp onse Archive

................................ ............ 16

3. Q UALITY C ONTROL P ROCEDURES

................................ ................................ ...................... 18

3.1 Responsibilities

................................ ................................ ................................ ..... 18

3.2 Project File Quality Review Procedures

................................ ............................... 18

3.2.2 Project File and Filing Review

................................ ................................ . 18

3.2.3 Developing a Docket fr om the Alaskan Seafood Petition Response Project File

................................ ................................ ................................ 19

3.2.4 Project File Plan Revision

................................ ................................ ......... 20

4. D OCKET A SSEMBLY

................................ ................................ ................................ ........... 21

Attachment 1 : ALASKAN SEAFOOD PETI TION RESPONSE PROJECT FILE OUTLINE

Attachment 2 : EXAMPLE ELECTRONIC P ROJECT FILE LOG

- IN FORM

Attachment 3 : FDMS GUIDELINES FOR FREE TEXT FIELDSC

- 3 1.0 INTRODUCTION AND DEFINITIONS

This document i s a plan for the preparation of the project file supporting EPA’s response to an industry petition requesting EPA to revise effluent limitations and standards and prohibitions for direct discharges from seafood processing facilities in “non

- remote” locatio ns in Alaska (see 40 CFR Part 408) . ERG is supporting this work through a series of work assignments on the National Strategy contract (EPA Contract No. 68

- C02

- 095). This project file management plan is a living document and will be revised and reissued, a s necessary. This plan includes definitions and procedures so that the team supporting EPA’s petition response will understand our file system. The definitions and procedures are project

- specific and may differ

from terms used for other studies or regulato ry development work.

All project file materials will be managed according to ERG’s EPA

- approved Confidential Business Information (CBI) security plan that describes the procedures we will use

to handle CBI on this contract. All ERG Alaska Seafood team me mbers will be trained and tested in CBI procedures before they are permitted to access CBI.

1 .1 Background

EPA received a petition from Alaskan Seafood p rocessors in 1980

. This petition requested that EPA suspend regulations applicable to seafood proces sors in “non

- remote” locations in Alaska. It also requested that EPA change the regulations using a rulemaking process. In a Federal Register notice dated January 20, 1981 EPA published a proposed response which denied the petition and maintained the statu s of four of five locations (Anchorage, Cordova, Ketchikan, Petersburg) as “non

- remote” processing centers, and granted the petition for Juneau, thus changing the status of that location to “remote.” In the proposed response, EPA also

indicated that the ea rlier suspension of the regulations for good cause would remain in effect until a final response to the petition was issued. However, EPA never completed a final response to this 1980 petition.

EPA’s Response to the Industry Petition on ELGs for Non

- Rem ote Alaskan Seafood

Processors (i.e. “Alaskan Seafood Petition Response”) has or is planned to include the following

activities:

• A §308 data collection effort ;

• Estimates of control option costs;

• Analysis of the economic impacts of control options;

• A “No tice of Data Availability” (NODA) that describes control options, their costs, and potential economic impacts;

• Review and responding to public comments on the NODA; and

• Federal Register Notice of EPA’s final action on the petition.

1.2 Alaskan Seafood Pet ition Response Project File

The Alaskan Seafood Petition Response project file will contain items that are collected or developed during the support of EPA’s petition response . These items may include:C

- 4 • Records of communications with parties outside of E PA, including telephone calls, memoranda, and letters;

• Industry responses to EPA’s §308 data collection effort ;

• Copyright

- protected literature, presenting data of interest to the Alaskan Seafood Petition Response;

• Facility

- provided comments , including wri tten opinions, data, and other information; and

• Permit materials, such as applications and National Pollution Discharge Elimination System permits, and other regulatory information

.

The project file may also contain certain material that would not be app ropriate for inclusion in public dockets, such as:

• Internal briefing packages;

• “Deliberative” items, including memoranda from ERG to EPA that present potential study objectives ;

• Project plans;

• Drafts of Site Visit Reports and Sampling Episode Reports with affected facility review comments (where only the final version is placed in the public docket);

• EPA Work Group briefing materials and reports;

• EPA management briefing materials;

• I nternal EPA communications; and

• Memoranda from ERG to EPA that set out the pros and cons of various technical approaches if they are deliberative in nature.

The project file should not contain contractual materials:

• ERG’s contracts with EPA or our subcontractors;

• Work assignments, work plans, monthly reports, etc.;

• Contract pe rformance evaluations; and

• Any other material relating to the contract between ERG and EPA.

All items in the Alaskan Seafood Petition Response project file will be assigned an ERG document control number (DCN) for document management purposes

. Documents that become part of an EPA docket will be assigned an additional document number through the Federal Docket Management System (FDMS). See Section 2.2 for more information.

1.3 Docket

An official docket serves as the repository for the collection of docu ments or information related to a particular agency action or activity

. The official docket generally consists of the documents specifically referenced in the Federal Register notices, any public comments received, and other information used by decision

- ma kers, or otherwise related to the Agency action or activity

. Agencies most commonly use dockets for regulatory actions, but dockets may

also be used for various other non

- rulemaking activities, such as Federal Register notices seeking public comments on dr aft guidance, policy statements, information collection requests under the Paperwork Reduction Act, and other non

- rule activities

. Each time an Agency action isC

- 5 announced in the Federal Register , a docket is established and assigned a tracking number to

ac cumulate materials throughout the development process.

EPA has not yet created a docket for the Alaskan Seafood Petition Response; however, EPA will do so at a later date. For this reason, the Alaskan Seafood Petition Response Project File will be prepa red so project file documents and metadata can be easily added to a docket following FDMS requirements.

1.4 Federal Docket Management System (FDMS)

FDMS is designed for use by over a hundred feder al agencies and entities. FDMS is built

on a document ma nagement system platform and has internet access for both public users and agency personnel

. FDMS is used to establish the public docket, index the docket contents, and to the extent feasible, provide the electronic version of publicly available docket mat erials

. On November 28, 2005 FDMS replaced EDocket as EPA ’ s docketing system. The public interface with FDMS can be accessed at http://www.regulations.gov.

1.5 Electronic Project File

The electronic project file is the network area in which ERG stores t he electronic version

of items in the Alaskan Seafood Petition Response project file

. These files are named by DCN

. Electronic versions of any CBI items in the Alaskan Seafood Petition Response project file will

be stored in the Alaskan Seafood Petition Re sponse area on the CBI server

.

1.6 Contract File

A contract file contains materials specific to ERG ’ s management of the contract with

EPA

. These materials would not be passed on to a succeeding contractor and would be retained by ERG at the conclusion of the contract . A contract file contains the following:

• The contract;

• Work assignments;

• Work plans and cost estimates;

• Contract and task instructions;

• Weekly and monthly reports;

• Invoices;

• Contract performance evaluations;

• Project wrap

- up meeting notes a nd reports;

• ERG document review sign

- off sheets (completed for all project deliverables);

and

• Correspondence with the EPA Contracting Officer.

Items in the ERG contract file are filed separately from the Alaskan Seafood Petition Response project file and are not assigned DCNs.

1.7 Personal FilesC

- 6 Personal files include project team member notes that are not necessarily interpretable by others, as well as copies of non

- CBI materials that are referred to frequently

. Copies will be minimized to keep file s pace requirements under control

. Working drafts of CBI and CBI computer files are managed according to E RG’s CBI security plan entitled Security Plan for Handling Confidential Business Information Under the Clean Water Act , dated September 25, 2008 and app roved by Ahmar Siddiqui, EPA’s Document Control Officer for this contract, on March 12, 2009 or its successor approved plans.

1.8 Project File Index

The project file index is a listing of all documents in the Alaskan Seafood Petition Response project fi le

. The index is a computerized database that allows for sorting and searching the project file by section, date, DCN, docket number, etc

. The project file index lists all documents, CBI and non

- CBI

. Index entries should not contain CBI information. The in dex includes a field that designates the CBI status of each item

. See Section 2.3 for more details on the project file index.

1.9 FDMS Metadata

Metadata are descriptive information about the elements of a set of data

. For FDMS the

elements are documents and the set of data is the docket

. Thus, FDMS metadata are descriptions

of each document in a docket

. FDMS metadata are similar to the information contained in the project file index, and include among other information, the title, abstract, author, and p age

count.

1.10 Confidential Business Information (CBI)

At the time a business, site, or trade association supplies information to EPA, they may assert a business confidentiality claim covering all or part of the information

. If no such claim accompanie s the information, EPA may make it available to the public without further notice to

the business

. If EPA receives a request from an outside party for information claimed confidential, it will determine if the information is entitled to confidential treatm ent (see 40 CFR Part 2)

. Please refer to ERG’s Security Plan for Handling Confidential Business Information

Under the Clean Water Act , dated September 25, 2008 , for further information on handling CBI.

As specified in ERG ’ s CBI Plan, documents containin g CBI will be stored in a designated locked archive or file cabinet

. Electronic files containing CBI will be stored on

ERG ’ s separate, limited

- access CBI server.

Documents containing CBI will be sanitized prior to their placement in a public docket

. The original non

- sanitized version of the document will be maintained as a CBI document.

1.11 CBI

- Deducible Information

CBI

- deducible information is information that is not CBI, but when used in conjunction with other publicly

- available materials, this inf ormation can be used to deduce CBI

. Examples of documents containing CBI

- deducible information include pre

- test questionnaires and non

- CBI screener questionnaires which contain both facility identifier information (e.g., facility name,C

- 7 address, contacts, e tc.) and facility codes

. To prevent the deduction of CBI, documents containing CBI

- deducible information will be sanitized prior to their placement in the public

docket

. The sanitization step will be designed to remove the information that allows CBI to be

deduced

. The original non

- sanitized version of the document will be maintained as a CBI

document.C

- 8 2.0 GENERAL PROCEDURES

All Alaskan Seafood Petition Response project file items (i.e., excluding ERG contract file items) will be recorded in the project file index and assigned a unique DCN (discussed in section 2.2)

. Project file items are those items and materials which are defined in Section 1.2 of this project file plan . Team members will submit items that are ready to be entered into the project file , using the steps detailed further in this section to t he ERG staff member with primary responsibility for the project file index (the index keeper) . The index keeper will issue DCNs as individual documents are generated and submitted.

The outline for t he project file, which specifies project file sections, is included as

Attachment 1 to this plan. The project file outline will be modified as needed during the performance of this work. Except for CBI documents and files existing only in hard copy , projec t
file materials will be stored in the Alaskan Seafood Petition Response electronic project file on

ERG’s network , filed by DCN

. Files existing only in hard copy will be physically placed in the Alaskan Seafood Petition Response archive, filed by project f ile section and DCN.

When EPA directs ERG to assemble a docket supporting an Agency action (such as a NODA or other Federal Register Notice) , a subset of the items included in the Alaskan Seafood Petition Response project file will be identified for incl usion in that docket. The appropriate docket number will be added to the project file index database to identify these items. Electronic files of these documents will be moved from the project file folder to the appropriate docket

folder.

If any items id entified for inclusion in the docket contain CBI or CBI

- deducible information, a sanitized version of the item will be prepared. If CBI is removed from a document to create a “sanitized” version of the document, that document will receive a new DCN. The

“s anitized” version of the document will be designated with a non

- CBI cover sheet and noted “sanitized version.” In some cases it may be impossible to produce a sanitized version of the document. In these cases, the document will be described in the index an d the CBI document will

continue to be stored on the CBI server.

2.1 Submitting Material to the Project File

This section presents the processes to be u sed to submit materials to the project f ile, first

as step

- by

- step procedures (Section 2.1.1) then in a more detailed discussion of the submission process (Section 2.1.2)

.

2.1.1 Step

- By

- Step Process for Submitting Record Materials

Documents will be submitted to the project file following the steps below :

1. Complete an electronic project file log

- in form (see Attachment 2). The fields included on the log

- in form are described in Section 2.3.1. For electronic files, make sure to include the full path for the electronic file location ; if you think the electronic file location may change, also e

- mail a copy of the electronic file to the index keeper You can log in many items within a single login sheet, as is

convenient.C

- 9 2. If you have an electronic file, email the file (if the document is not CBI and if you think the electronic file location will change) and t he log

- in form to the index keeper

.

3. The index keeper will add the data from the log

- in form to the project file index and assign the item a DCN. If you are logging in many items, the metadata will occupy several rows on the log

- in form. The index keeper w ill upload the login sheet as a table into the Access database record index. The index keeper will then run a standard query to update the index table and append the new index fields. 2

4. If the item is hard copy only, complete the first row of the electroni c log

- in form, print out the printable log

- in form

, and attach it to the hard copy . Place the item and log

- in form in the Alaskan Seafood Petition Response project file inbox in the index keeper’s office . E

- mail the electronic log

- in form to the index . Inc lude a message explaining that the hard copy is in the Alaskan Seafood Petition Response project file inbox.

5. If the electronic item is not CBI, the index keeper will save it as a portable document format ( PDF ) file named dcn.pdf. Large documents, spreadsh eets, and

databases will not be saved as PDF

.

6. Materials that are submitted in hard copy will be labeled and filed by project file section and DCN in the Alaskan Seafood Petition Response archive

.

7. If the item is CBI, a single copy labeled with the DCN w ill be retained in the project file CBI storage area (for hard

- copy materials) or the CBI network area (for electronic files).

Additional explanation of the submi ssion process is provided below.

2.1.2 Detailed Discussion of Document Submission Process

You should submit material to the project file in electronic format as much as possible. Electronic files are easy to retrieve from the project file, which allows project team members to access project documents quickly and efficiently. In addition, EPA m ay create a docket for the Alaskan Seafood Petition Response at a later date. Because official dockets generally consist, with a few exceptions, of electronic files, submitting documents in electronic format now will

save time when we are tasked to assembl e the docket.

In addition to final reports supporting the EPA action, project file materials include ERG deliverables and background materials such as telephone contact reports, journal articles, NPDES permits, etc. These materials should be submitted to the project file as they are finalized.

2 The index keeper will always save a copy of the index table prio r to running an append or update query. When the query is complete, she or he will confirm that the proper updates have been made by comparing the two tables.C

- 10 As of November 28, 2005 EPA is using the Federal Docket Management System (FDMS) to store and manage its dockets. FDMS is a web

- based database that holds document records (metadata) that describe each document in a docket and electronic copies of the

documents. Because the FDMS

- preferred format for documents is portable data format ( PDF ), ERG will store project file documents as PDF files in the electronic project file network area. The electronic project file wil l have read

- only access to preserve the integrity of the project file items. In addition to standard network backups, the index keeper will back up additions to electronic project file on CD or DVD on a regular basis. The DCN will serve as the filename. Fo r example, 00066.pdf will be the electronic version of document 00066. If a DCN is comprised of multiple documents, either a folder will be created using the DCN as the folder name, and each

document will be available within the folder (in this case, the f iles will not be renamed), or the additional documents after the first will be listed with extensions such as 00066A1.pdf and so on

.

The first step in submitting materials to the project file is to complete an electronic project file log

- in form and e

- m ail it to the index keeper with the item to be added to the project file. The index keeper will add the data from the log

- in form to the project file index and assign the item a DCN. The project file index is used to complete the FDMS metadata description for the document, so it is essential that the log

- in form is completed properly. The index keeper will store project file documents in the electronic project file (electronic form), with a f ew exceptions

described later. For hard

- copy documents, i t is crit ical that indexing an d filing occur simultaneously. N o changes will be made to section assignments in the index unless the item is physically re

- filed.

Project D eliverables. As materials are sent as deliverables to clients via e

- ma il and in electronic format, they will also need to be submitted to the index

- keeper or a designee for addition to the Alaskan Seafood Petition Response project file. Once the deliverable is sent, the sender must submit the item to the record keeper and co mplete an electronic project file log

- in sheet for each item. Attachment 2 contains an example log

- in sheet. Instructions for the completion of the log

- in sheet are presented in Section 2.3.1. If the transmittal e

- mail or letter of

the deliverable contains pertinent information, it should be included in the submittals to the

record keeper.

Related M aterials

. Related materials that do not need to be indexed separately can be logged in as one item and given one DCN. Examples of materials that may be include d under

one DCN are:

• Materials presented by several participants in one meeting;

• A series of telecons between two people about one subject;

• Correspondence between two people on one subject; and

• A relat ed series of calculation sheets.

CBI I tems. CBI items will not be maintained electronically on the Alaskan Seafood Petition Response network. CBI materials must be used and stored as described in ERG’s CBI

Plan and any electronic CBI materials must be maintained on the CBI server.

Electronic Files on C ompact D isk (CD), D igital V ideo D isk (DVD), or D iskette. As noted above, PDF is the FDMS preferred file format. Some docket items, such as databases and large spreadsheets cannot be saved as PDF files. These items will be submitted to the EPAC

- 11 docket on DV D, CD, or diskette. Copies will be stored in the Alaskan Seafood Petition Response archive, similar to hard

- copy printouts of documents. Similarly, computer files received on diskettes, CDs, or DVDs will be identified in the project file index in the title field as being on diskette, CD or DVD. Diskettes, CDs, or DVDs will be clearly marked with the item name and

DCN and filed in the Alaskan Seafood Petition Response archive in pouches/envelopes attached to the project file item file folder.

Internet Webs ite Material. Because web addresses and web site content may change over time and become unavailable electronically, Internet website materials should be saved or printed as a PDF file (or html file if the team member cannot print to PDF995) Log

- in

informa tion should include the URL and date accessed

. The index keeper will convert any html

files to PDF and add the electronic version to the electronic project file.

E

- mail Correspondence. E

- mail correspondence to be added to the project file should be

saved as a PDF file and managed like other project file documents. DO NOT simply forward the message on to the index keeper. If the file transmitted by email is larger than 3.0 MB (i.e., transmitted via FTP), the file will be burned to a CD, stored in the Alask an Seafood Petition Response archive, and noted in the project file index to conserve network space.

Copyright Protected Material. Copyright protected material is often part of an official docket. However, these materials cannot be stored in FDMS. FDMS w ill include the metadata for the copyright protected material, but will not include an electronic copy of the document. Hard copies of copyright protected materials will be available in the docket office for public

review.

Hard

- Copy Items

. Items that ar e only available in hard

- copy format will be stored in the Alaskan Seafood Petition Response archive. The team member will provide the hard copy and completed log

- in form to the index keeper, who will convert them to an electronic file (by scanning and sav ing the material in pdf format) , then file the hard

- copy document.

2.2 Document Control Numbers (DCNs)

All Alaskan Seafood Petition Response project file items will be assigned a unique document control number (DCN)

. The ERG index keeper will issue DCN s as individual documents are generated and submitted

. The index

- keeper may also issue batches of DCNs to the EAD Document Control Officer to assign to CBI materials received or generated at EAD

. Each DCN will consist of five digits (i.e., 00001) plus exte nsions, if applicable

.

2.2.1 Appendices and Attachments

Major appendices and attachments to documents, such as the analytical data reports

attached to a 308 Questionnaire response , will be given the same DCN as the parent document

with an extension adde d to designate the appendix

. For example, 09289A1 will designate Appendix 1 to document 09289.C

- 12 2.2.2 Copies

In accordance with ERG ’ s CBI plan, each individual copy of a CBI document will be tracked in a separate electronic copy log (the CBI copy log)

. The copy log tracks the copy numbers, date generated, destination, and ultimate disposition (e.g., returned to ERG, destroyed)

. The copy number of a CBI document will be incorporated into the DCN as an extension

. For example, 09287C1 will designate copy 1 of document 09287

. Multiple copies of non

- CBI materials will not be tracked or designated.

2.2.3 CBI Documents

CBI documents will be designated in the project file index as a “ yes ” in the CBI column

of the index. A sanitized version of the document wi ll have an “ S ” added to the end of the DCN (i.e., 00026S)

. CBI documents will be stored in a designated, locked storage space

. CBI

electronic files will be stored on the CBI server.

2.3 Project File Index

The project file index will list all project f ile items. The index will be maintained using

Access® 2003 database software. Entries to the index will be made by the index keeper, or their designee . Alaskan Seafood Petition Response project team members will have read

- only access

to the index via the n etwork

. The file will be located under P: \ Alaska Seafood \ Record \ Project

File

.

2.3.1 Index Structure

The index key fields are listed below with a brief description of their content. The f irst 15 fields are included on the project file log

- in form and wil l be completed by the document submitter. These entries are used to complete the FDMS metadata description of the document, so it is essential that the log

- in form entries are consistent with FDMS metadata requirements. Additional index fields are complete d by the index keeper as described below. An asterisk (*) preceding the index field name indicates that it is included in the FDMS system. 3

Four of the index fields that will be included in FDMS (Title, Abstract, Source Citation, Author Name) are free te xt format. However, information should be recorded in a consistent format to ensure easy retrieval. Because the Document Title is a searchable field, it is especially important that it be free of typos and use consistent abbreviations, punctuation, and

cap italization. FDMS guidelines for free text fields are presented in Attachment 3

.

FDMS free text fields are size limited, in terms of number of characters (including blank spaces). The character count of an index entry can be checked using tools/word cou nt in MS

Word.

* Title

. This should be the full title of the article, study, or report, limited to 400

characters . For memoranda, letters, and e

- mail correspondence, use the format:

3 Only two fields are required to upload a document into FDMS: the document title and document ty pe. However, ERG will include information from all fields listed in this document as part of its record

- keeping support to EPA.C

- 13 • Memorandum to Angela Beard, Vice President, Medical Research Department

, Flonasd Corporation, Subject ;

• Letter to Susan Clark, Citizen, Subject ; or

• Email to John Wright, Contractor, Viztronix, Subject

.

For records of telephone conversations, use the format:

• Notes from telephone conversation between John Smith, ERG and Jane Doe, XYZ Corporation, August 6, 2001.

When entering the document title into the FDMS metadata field, the ERG index keeper or her designee will add our DCN to the end of the title.

* Abstract

. This field is used to provide addition al description of the individual document. It may be the continuation of a lengthy title. 4 Be descriptive; do not simply repeat

information that is contained in the title. Abstracts are limited to 500 characters.

* Document Sub

- type

. This is an FDMS field with a drop

- down menu of allowable document subtypes. To expedite the index keeper’s entry of FDMS metadata, choose from the following types.

Sub

- Type Description

Analysis A review and summation of data or facts which might be used in a report and/or s tudy or which might serve as the basis of an audit, assessment, or evaluation.

Comment Response Agency responses to public comments.

Data Facts and figures used to support a position or for the modeling or forecasting of outcomes. Typically these records are provided electronically as data dumps on alternative media or as listings or spreadsheets.

Economic Analysis A review and summation of economic data or facts.

Fact/Data Sheet This subtype includes Material Safety Data Sheets (MSDS). Formalized infor mation regarding a particular event, chemical, product, or other used as a tool to disseminate knowledge in a standardized factual manner. Broad announcements of events or information might otherwise be classified as "Press Releases, Public Announcements, Public Notices."

Federal Register Document A draft or formal document published or to be published in the Federal Register which is used as a supporting document as opposed to authorizing a comment period

or other action.

Form Any government form not spe cific elsewhere or not part of a larger subtype category such as audit forms which should be classified under "Audit, Assessment,

Evaluation."

Guidance, Interpretation, Policy, Procedure Documents which provide direction to Agency employees, contractors, or the public including Standard Operating Procedures, methodologies, and guidelines. Documents which alert others to events used primarily to distribute broad knowledge

in a standardized manner.

ICR Supporting Statement The supporting statement which acc ompanies an ICR.

4 Docket staff also use the abstract to explain aspects of the document that might otherwise be confusing to the user (for examp le, if a document file is not included because it is CBI or a duplicate of another document).C

- 14 Sub

- Type Description

Index A listing of materials or cross

- reference of sources or citations in a publication, report or study.

Interagency Review Draft materials reviewed by outside entities which show signs of being edited including redline/strikeouts. Do not include specific OMB reviews of documents in this category. See "Office of Management and Budget" below.

Letter, Memorandum,

Email Correspondence both internal and external to the Agency.

Map A stand

- alone map not included in the body of a report, st udy, presentation, etc.

Meeting or Teleconference

Materials Telephone contact reports, meeting minutes, and materials used to schedule, inform, conduct or summarize a meeting, teleconference, or less formal telephone call including but not limited to: age nda, presentations/handouts/slides, and attendee lists/sign

- in sheets.

Office of Management and Budget (OMB) Correspondence to and from and drafts reviewed by specifically by OMB.

Other Non

- copyright protected web pages.

Permit, Registration A form whic h registers or permits the holder to perform a certain action or to use a specific chemical (e.g., NPDES discharge permit).

Physical Item Any item which is considered a record under the NARA definition but which cannot

be otherwise classified as a documen t or be imported as an image into the system such as a brick, paper plate, or bag.

Press Release, Public

Announcement/Notice Documents which alert others to events used primarily to distribute broad knowledge

in a standardized manner.

Public Hearing Tran script, Deposition, Testimony Documents that reflect the words spoken during a legal or administrative law proceeding or interview, typically created by a court reporter.

Publication; Copyrighted

Material Any non

- governmental work which appears to be affo rded US copyright protection including journal or magazine articles, abstracts, books or any portion thereof, newspaper articles, online/trade articles, online news wires or services including

MSN.com or CNN.com

Publication; Other

Governmental Federal/sta te/local government publication other than EPA publications.

Publication; USEPA USEPA publication; include an EPA Publication Number in the title.

Questionnaire Industry response to 308 Questionnaire and all associated attachments.

Report A statement of fact and findings usually formalized. This subtype includes status reports on projects or contracts as well as outcomes and findings from the analysis, audit, review or study of processes or procedures whether scientific or business in

function.

Signed F ederal Register

Document Document authorizing the submission to and release of a Federal Register by NARA

Speech Presentation or transcript of a speech

Study A study is a compilation of analysis, data, multiple assessment or audits to ascertain

the str ength, accuracy or outcome of a position or methodology. Studies differ from reports in that a study offers more detailed scientific data, facts or figures from a variety of sources.

Test Data

*Source Citation. For copyright protected material, this i s a mandatory field. It consists of a bibliographic citation the public can use to identify the document and to locate a copy through alternative means such as a reference library. Source citation is an important part of theC

- 15 metadata for copyright protecte d documents because it allows FDMS to link back to the paper

record.

The source citation does NOT need to include the title or the author name because those metadata are captured elsewhere in the system. The citation should, however, include such

standar d information as the publisher’s name and city, date of publication, editor or compilers’ names, and volume or serial numbers. Source citations are limited to 150 characters.

See the ERG Style Guide, Appendix C (available under tools on the ERG Intranet ) for bibliographic formats. Three commonly used citations are shown below:

• Journal article: Nature 393(2002):639

- 40.

• Article in electronic journal: Journal of the American Medical Association . 287, no. 5 (2001), http:/jama.ama

- assn.org/issues/v287n5/rfu ll/joc10108.html (accessed January 7, 2002).

• Internet Materials: <www.epa.gov/water/residu als/wtrdoc.html>. (Accessed May 17, 1998).

* Author Name

. N ame of the individual who authored, edited, compiled or wrote the memorandum, report, study, article, or book. For documents with multiple authors, list the primary author (e.g., Bartram, Deborah, et. al.). Use full names whenever possible. Author Name

is limited to 25 characters.

* Author Date

. Enter as MM/DD/YYYY. Provide the date of publication, issue, e dition, or version. Letters and memoranda usually bear a date in their respective headings. Reports, reviews, and studies usually have a date located within their respective forwards. Publications bear copyright dates. For meeting and telephone notes provi de the date of the actual event. If only the month and year are known, enter the first day of the month. For example: use

05/01/2002 rather than 05/2002.

Page Count

. Enter the total number of pages of the PDF. If the document is copyrighted or only exist s in hard copy , include the page count of the paper document. This is the total page count so be sure to include all blank pages. Page Count is limited to 5 characters.

* Copyright Protected (Y or N)

. All project file items will be identified in the proje ct file index as Y (the item is copyright protected) or N (the item is not copyright protected). The

document sub

- type of copyright protected material is typically “Publication; Copyrighted

Material.”

Confidential Business Information (Y or N)

. All proje ct file items will be identified in the project file index as Y (all or part of the item contains CBI or is CBI

- deducible) or N (the

entire item is non

- confidential).

Hard Copy Only ? (Y or N)

. This entry is specific to the Alaskan Seafood Petition Respon se project file index and will not be included in the FDMS metadata. All project file items will be identified in the project file index as Y (only a hard copy of this file exists and will be located in the Alaskan Seafood Petition Response archive) or N ( the file exists electronically and will be located in the electronic project file).C

- 16 Electronic Copy File Location

. This entry is specific to the Alaskan Seafood Petition Response project file index and will not be included in the FDMS metadata. This fiel d refers to
the source location of the document on ERG’s network area. Once the document is submitted to the index keeper for addition to the project file, it will be re

- saved with the DCN as the file name and stored in the electronic project file. Items s tored on the CBI server should be identified as such. They will be stored in the electronic project file on the CBI server.

Docket Item (Y or N)

. Project file items will be identified in the project file index as Y (the item is or will be delivered to t he EPA docket) or N (the item is project file, only, and will not be delivered to the EPA docket). The document submitter should complete this field, entering N if they are not certain that the document will be added to a docket. However, the list of items

for the docket will be reviewed and approved by EPA before any documents are uploaded to

FDMS.

Project File Section Number

. To help locate documents addressing related topics or subjects ERG created a subject outline of the Alaskan Seafood Petition Res ponse project file (see

Attachment 1 ). Each outline section is numbered. The individual submitting an item to the index keeper for inclusion in the project file will identify the outline section for the item.

The index keeper adds the following informat ion to the index as they manage the project

file.

• Document Control Number (DCN) : This entry is specific to the Alaskan Seafood Petition Response project file index

. As described in Section 2.2, some project file items will have a DCN extension to disting uish appendices or copies.

These extensions are recorded in the DCN extension database field. The index keeper will use the following convention for assignin g DCNs:

— DCN XXXX X ;

— Attachments to the DCN will be DCN XX X XXA001, DCN

X X XXXA002, etc.

• Input Date: T his field is the date the index keeper adds the item to the index, electronic project file , and/or Alaskan Seafood Petition Response file room

archive.

2.3.2 Alaskan Seafood Petition Response Archive

The Alaskan Seafood Petition Response archive is in t wo locations. Non

- CBI materials

ares located in the non

- CBI EAD archive on the first floor, interior

- side hallway of ERG’s Chantilly office. Most items filed in the archive are those which exist in hard copy only. Project file items will be filed by projec t file section and within each section, documents will be filed in ascending numerical DCN order. The outline for the project file is included as Attachment 1. The project file outline will be modified as needed during the performance of this work. CBI and

non

- CBI materials will be distinguished by a separate field in the project file index. In addition, records from EPA’s previous work on the Alaskan Seafood Petition will be stored in this area until they are returned to EPA.C

- 17 CBI materials, including re sponses to the §308 data collection efforts that respondents claim to be CBI, will be stored in the National Strategy Contract CBI archive on the first first floor, interior

- side hallway of ERG’s Chantilly office. Project file items will be filed by projec t file section and within each section, documents will be filed in ascending numerical DCN order.C

- 18 3.0 QUALITY CONTROL PROCEDURES

Only fully legible, complete documents should be added to the project file, unless specifically noted as a document excerpt . All documents prepared by ERG will be reviewed prior to submission to the project file. This review will be documented on a Deliverable Review Sign

off Sheet

. As indicated on the sign

- off sheet, review of all deliverables includes checking and reviewing for completeness of supporting documentation. Data and calculations will be checked according to the appropriate ERG Standard Operating Procedure. The documentation (such as backup calculations, spreadsheets, and telephone contact reports) will be added to the project file at the same time as the document. In most cases, a document will be added to the Alaskan Seafood Petition Response project file when its final version is delivered to EPA.

No item will be added to the project file index unless it is ava ilable in hard copy to be filed in the archive and/or electronic form for the electronic project file. Correct spelling, accepted abbreviations, and consistent format are required to ensure the index can function as a

database.

3.1 Responsibilities

The overall responsibility for the quality of the project file and index belongs to the ERG Work Assignment Manager (WAM) for Work Assignment 7

- 30 and its successor work assignments

. The index keeper is responsible for the quality of the index (i.e., correct s pelling, consistent format) and for correct filing of project file materials. Each team member is responsible for submitting materials to the project file in a timely fashion and is responsible for completing project file log

- in forms when submitting mater ials.

The Alaskan Seafood Petition Response technical team member providing the technical lead for a particular activity will be responsible for project file submittals on the activity, including index entries. They will also be responsible for ensuring that this plan is carried out and that materials are submitted to the project file in a timely manner.

Periodically, the ERG WAM will divide the project file into p arts and assign each part to an Alaskan Seafood Petition Response technical team member fo r review. In general, the team member providing the technical lead for the activity included in a project file section will be assigned that section for review.

3.2 Project File Quality Review Procedures

ERG will perform quality assurance/quality contro l checks on the project file index, hard

copy project file, and the electronic project file on a periodic basis to ensure completeness and accuracy. ERG will also periodically review this plan for possible revision.

3.2.1 Project File and Filing Review

Review of the project file content and filing will occur periodically (e.g., at project milestones) . The index keeper will conduct the following checks:

• Prepare a printout of the Alaskan Seafood Petition Response project file index;C

- 19 • Ensure all items lis ted in the index are filed in the archive in the section listed in the index;

• Ensure all filed materials in the archive and electronic project file are listed in the index with complete and accurate information;

• Ensure all deliverable items listed in the m onthly reports are indexed and filed in the archive and electronic project file; and

• Communicate all discrepancies to the ERG WAM for resolution.

The ERG WAM will divide the index into parts and assign each part to an Alaskan Seafood Petition Response te chnical team member. The technical team reviewers will conduct the following checks:

• Resolve discrepancies identified by the index keeper;

• Ensure all appropriate documents (e.g., deliverables, reference materials, etc.) have been entered into the project file;

• Ensure all back

- up materials (i.e., references, calculations, etc.) for each document are indexed and filed;

• Ensure index entries accurately represent the material; and

• Ensure the CBI and copyright status identification in the index and on the

docume nt is accurate and consistent.

When the project file reviews are complete, the team will meet to discuss and resolve discrepancies and to discuss any possible changes needed in the project file plan.

3.2.2 Developing a Docket from the Alaskan Seafood Pe tition Response Project File

EPA has not yet created a docket for the Alaskan Seafood Petition Response; however, EPA will do so at a later date. For this reason, the Alaskan Seafood Petition Response Project File will be prepared so project file documen ts and metadata can be easily added to a docket following FDMS requirements.

At the time that EPA directs ERG to add Alaskan Seafood Petition Response Project File documents to a docket, ERG will review the documents to ensure proper management of CBI

a nd copyright protected materials. This review will include:

• Identification of copyright protected material or other restricted use material that is not marked as such. For example, some site visit reports contain materials provided by the facility that w as visited. The map or other document provided may contain a copyright symbol or a statement that the document’s use is restricted. In these cases, ERG project team members or EPA staff should obtain permission to make the document public or exclude the pr otected information from the document being uploaded. As another example, web sites are often copyright protected, but the registry symbol appears only on the home page. This type of document should also be marked as copyright protected.

• Identification of non

- CBI material that contains the word “confidential” in the document. For example, facilities may provide a document to EPA that is not claimed as CBI; however, pages within the document have been marked with theC

- 20 words “For Internal Use Only” or “Confid ential

– Draft.” In these cases, ERG project team members or EPA staff should obtain permission to make the document public or exclude information marked “Confidential” from the document being uploaded. This check is important because if a document is uplo aded to FDMS containing any indication of confidential or internal material, the FDMS docket staff will automatically designate it as CBI.

Prior to submitting material to the docket, ERG will review the index entries (metadata) and electronic project file s against FDMS requirements. ERG will send a printout of the index to the EPA WAM for his approval. The ERG checks and EPA WAM approval will be documented for each entry by fields in the project file index database.

3.2.3 Project File Plan Revision

This plan will be reviewed each year after the index keeper and technical team have completed their annual reviews. As necessary, the ERG WAM will ensure the plan will be revised and submitted to EPA for review. All revisions to the plan will be communicated t o the ERG team, following approval from EPA.C

- 21 4.0 DOCKET ASSEMBLY

At some point, EPA will request that ERG prepare materials from the project file for inclusion in a docket. If EPA does not yet have a docket number, ERG will ensure that the EPA

WAM cont act s the Docket (202

- 566

- 2426) to obtain a Docket number (which will be included in the preamble).

EPA staff is responsible for opening the docket and working with the EPA Docket staff

to create the docket in FDMS. The FDMS web page can be accessed at ht tp://www.fdms.gov ; however, only approved users can upload files and access other FDMS tools. The ERG index keeper (and a few other ERG project team members) has an FDMS user ID and password. EPA/EAD staff (the “docket contact” in FDMS) must grant permissi on, by FDMS user ID, for ERG staff to access a specific docket. Once access is granted, ERG staff can create documents by entering metadata and uploading document files. EPA Docket staff conducts a series of QC steps on the created documents, eventually id entifying the document as “Pending Post.” The document will not be released to the publicly accessible side of FDMS until a date (“docket phase posting date”) specified by the EPA/EAD docket contact.

ERG can create document records (enter metadata) witho ut uploading the document files. Once a document file is uploaded, ERG cannot delete it. If the document has not been posted (released to the public), ERG can request the docket staff to delete the entire record (Document ID, metadata, and document) by mov ing it to an FDMS area called the “sandbox”. If the document has been posted, the docket cannot change or delete a posted entry, but will add the revised file and insert a comment to the original entry that a revised document has been uploaded

with the new assigned FDMS number

. Because of these limitations, it is essential that only final documents (no drafts!) be uploaded to FDMS. However, the document record can be created, and a Document ID assigned, without uploading the document file. Note, ERG can edi t document records before public posting.

ERG will identify items from the project file to be included in the docket and designate those items in the record index, as discussed in Section 2.3.1. These items will include references

cited in the Federal Re gister notice and other supporting documentation. ERG will p eriodically

submit a printout of the index of the suggested docket materials to EPA for review. Upon approval from EPA, ERG will add documents to the docket using FDMS by completing the

document m etadata and uploading the pdf files from ERG’s electronic project file. For electronic databases and large spreadsheets that can’t be rendered to pdf, ERG will complete the document

metadata and obtain an FDMS “Document ID” for the document

. ERG will provi de electronic copies of these materials on removable media (e.g., CD, DVD, or diskette) labeled with the

Document ID number.

All documents will be added to the docket as pdf files, with the following exceptions:

• Copyright protected material. ERG will p rovide electronic copies on removable

media of these materials.

• Physical objects (maps, aerial photos, colored charts, etc.).C

- 22 • Large documents that present an undue burden for ERG (as contractor to the EPA program office) to scan (determined after consul tation with EPA/EAD and docket staff).

• Databases and large spreadsheets that cannot be rendered to pdf. ERG will provide copies of these documents on DVD, CD, diskette, or other electronic medium acceptable to the docket.

• Any document containing CBI, ER G will complete the FDMS metadata for CBI documents and include the following in the abstract field: “This document

contains Confidential Business Information. Please contact the Document Control Officer listed in the Federal Register Notice if access is n ecessary.” ERG will not provide copies of CBI to the docket.

Below are abbreviated instructions for submitting material to the Docket. The index keeper and other staff will receive more detailed instructions prior to the use of FDMS.

• FDMS Metadata Entr y into internal Alaskan Seafood Petition Response project file index, including adding the ERG DCN at the end of the FDMS document

title.

• EPA approves index entries from project file index printout.

• Index keeper retypes (or block/copies) index informatio n as FDMS metadata into

the interface at http://www.fdms.gov

, and each document is assigned an FDMS Document ID. Use the FDMS “create document” wizard for this process.

• Add descriptions to the abstract of documents tha t will not be uploaded to FDMS:

— CBI documents,

— Copyright protected publications,

— Databases and large spreadsheets, and

— Other materials as directed by docket staff.

• A ssign a second staff person to open the metadata for a subset of the entries and

compare the document details to the project file index printout. Any discrepancies will be brought to the attention of the index keeper, who will correct the FDMS metadata, as appropriate. The ERG work assignment manager and index keeper

will determine the number of entries to review.

• A ssign a second staff person to open the pdf files for all entries and compare the pdf to the metadata . Any discrepancies will be brought to the attention of the

index kee per, who will obtain the correct PDF from the ERG WAM or proje ct
team member , as appropriate.

• Upload electronic files

.

— Document files can be added at the same time that the document record is created, or as a separate step.C

- 23 — Use the “create document” wizard to add files. In general, ERG will not use the “bulk uploa d” function.

— Upload pdf files from ERG’s electronic project file to FDMS.

— The ERG index keeper will notify docket staff in advance of docket

activities.

— As specified by the project, the index keeper or her designee will open the uploaded files to confirm they match the metadata.

• Prepare hard

- copy material for docket submittal. The index keeper will try to

convert hard

- copy material in to an electronic file, typically by scanning and saving the material in pdf format . If the material cannot be converted, the index keeper will prepare a hard copy for submittal. This is only expected for the following materials:

— Copyright protected publications (may be provided to the docket staff on CD, DVD, or diskette, but they will not be uploaded to FDMS) ;

— Databases and large spreadsheets on DVD, CD or diskette;

— Large Books;

— Physical Objects (maps, and aerial photos); and

— Other materials as directed by docket staff.

• Create a docu ment record (metadata) for hard

- copy material, as described above.

The document record inc ludes the FDMS document ID.

• Create a label for the hard

- copy material. The label must not obscure any

information. The label should include:

— Docket number;

— FDMS Document ID (in pencil);

— ERG Section number;

— ERG DCN.

• Prepare paper documents as two

- sided copies.

• Assemble all copies in FDMS Document ID order.

• Place copies in top tab accordion folders.

• Submit a hard

- copy list (index) of the documents at the time they are delivered.

• Deliver hard

- copy docket materials by Fed Ex, courier or ERG staff to the following address: EPA Water Docket, EPA

- West Room 3334, 1301 Constitution Avenue, Washington, D.C. 20460.Attachment 1

- 1 Attachment 1

ALASKAN SEAFOOD PETI TION RESPONSE DRAFT PROJECT FILE OUTLINE September, 2013

1.0 NON

- REMOTE ALASKAN SEAFOOD PROCESSORS PETITION AN D

BACKGROUND INFORMATION

1.1 Industry Petition

1.2 Previous Federal Register Notices

1.3 Public Comments on EPA’s EPA’s 1981 Proposed Response to the Non

remote Alaskan Seafood Processors Petition

1.4 Background Information Supporting EPA’s 1981 Proposed Response to the

Non

- remote Alaskan Seafood Processors Petition

1.5 Correspondence with Industry and other Commenters

2.0 TECHNICAL DATA

2.1 §308 Data Collection from Seafood Processing Facilities

2.1.1 Questionnaire and Mailing List Generic Questionnaires Part A and Part B mailing li st tracking information

2.1.2 Telecons and Correspondence with Industry about Questionnaire (due date extension, questions about applicability and how to respond)

2.1.3 Completed questionnaire responses

2.1.4 Seafood Processing Questionnaire Database (MS access database an d analysis)

2.2 §308 Data Collection from Stand

- alone Seafood Byproduct Facilities

2.2.1 Telecons and correspondence

2.2.2 Site Visit Reports and Meeting Reports

2.3 Industry Submitted Data (NPDES annual compliance reports)

2.4 Literature Searches, Articles, Internet Searchers

3.0 N PDES PERMITS AND TMDL DOCUMENTS

3.1 General Permits

3.1.1 General Permits

3.1.2 Facility Notices of Intent to be covered by the general permit

3.2 Individual Permits and Permit Applications

4.0 COST ESTIMATES

4.1 Cost Data

4.1.1 Screening, barging, and ocean disposal alternative

4.1.2 Seafood by

- product production alternative

4.2 Facility cost estimatesAttachment 1

- 2 5.0 ECONOMIC DATA, INTERPRETATION, AND ANALYSIS

6.0 ENVIRONMENTAL IMPACTS

7.0 NOTICE OF DATA A VAILABILITY MATERIALS (Includes Federal Register Notice)

8.0 PUBLIC COMMENTS ON NODA

9.0 FINAL PETITION RESPONSE PAC KAGE (Includes Response to Comments document, Federal Register Notice, Regulation text)Attachment 2 Attachment 2

EXAMPLE ELECTRONIC P ROJECT FILE LOG

- IN FORMAttachment 2

- 1 

## Alaskan Seafood PETITION RESPONSE

ELECTRONIC PROJECT FILE INDEX LOG

- IN SHEET

Submitted by:

DCN: Index Keeper will assign DCN

TITLE:

AUTHOR NAME:

AUTHOR DATE:

ABSTRACT:

DOCUMENT_SUB TYPE:

SOURCE_CITATION:

PAGE_COUNT:

COPYRIGHT PROTECTED (Yes or No):

CBI (Yes or No):

HARD COPY ONLY (Yes or No):

ELECTRONIC LOCATION:

PROJECT FILE SECTION:

DOCKET_ITEM (Yes or No)Attachment 3

- 1 Attachment 3

FDMS GUIDELINES FOR FREE TEXT FIELDS

Information for free text fields should be recor ded in a consistent format to ensure reliable

retrieval.

The guidelines described below cover the most common types of errors: grammar, abbreviations, capitalization, use of numerals, and punctuation. Two additional areas where errors are likely to be ge nerated include spelling and typographical formatting. Use of spell checking software and proofreading entered data can reduce spelling errors. Typographical or formatting errors can be caused by sloppy cut and paste functions, forgetting to close a parent hetical expression, or failing to use quotation marks correctly. These errors can be addressed by using grammar checking software and, again, carefully proofreading data entry.

Within the FDMS system, the Document ID, Document Title, and Document Type ar e searchable fields. The search fields are case sensitive. Document Title is a free text field, so special care for consistency in capitalization must be taken with this field. If the user searches on a term using a mix of upper and lower case letters, the database will only return results that match that specific mix of characters. Searches performed using letters of a single case will return results regardless of specific character combinations. Since users are most likely to use a mix of upper and lower case letters with proper names, you must be sure that the metadata are entered in the correct format for a proper name. Guidelines are included below on the use of abbreviations, capitalization, numerals, and punctuation. Additional resources that can be u sed in making formatting decisions include dictionaries and the MLA Handbook for Writers of Research Papers , Sixth Edition (2003).

I. Grammar Review

The same careful thought given to writing a memorandum or a letter should be used when composing metadata . Fields such as Abstract are designed to allow the data entry operator to present information using anywhere from a single sentence to a full paragraph. It is important, therefore, that this information be presented in proper syntax using complete sentenc es. Run

- on sentences should be avoided

. As with any free text field, it is important that the data be presented in a way that other readers will find clear and concise. Since space in the field is limited, you may need to redraft text to fit within the par ameters of the field. When doing so, it is important be sure that all unnecessary characters have been removed and that the new text conforms to the flow of the existing sentences.

II. Abbreviations

Abbreviation styling is, unfortunately, inconsistent a nd depends most often on the organization’s policy. Company names are especially arbitrary as many businesses desire a unique look and feelAttachment 3

- 2 to distinguish their name and letterhead from other firms. For example, Gulf + Western Industries, Inc. is the actua l company name. This firm selected to represent the word “and” not with the more traditional “&” but with a positive or plus sign “+”

. In such cases, you should default to the official name as presented by the organization.

Abbreviations are used for man y reasons in document development. The most common reasons include (1) to avoid repetition of long words and phrases that may distract the reader, (2) to save space and time, (3) to replace keystrokes and increase output, and (4) to reflect statistical dat a in limited space. When using an abbreviation that may be unfamiliar or confusing to the reader, one should give the full form first followed by the abbreviation in parentheses as

Summary of Orders from the Office of Management and Budget (OMB).....

F o llowed in subsequent references by just the abbreviation, as

At the June 14, 2003, OMB meeting, agents met to discuss......

When abbreviating an Agency employee’s various program affiliations, it is acceptable to use virgules

. For example: Dave Beck, US EPA/ESED/CPB/CM

If a position title had been provided, the proper format would have been: Dave Beck, Regulatory Analyst, USEPA/ESED/CPB/CM

Guidelines for Abbreviations

The only terms which do not require use of the full form before the use of the abbre viation are those business units within the U.S. Environmental Protection Agency or the agency name

itself.

If the full form and abbreviation are used in the docket or document title field, then the abbreviation may stand alone in the docket or document d escription field.

Guideline Sample

The Environmental Protection Agency should be abbreviated according to Agency Standard. USEPA

Beginning a sentence with an abbreviation

should be avoided unless the abbreviation represents a courtesy title. Page 22 con tains.... but not P. 22 contains ....

Dr. Smith is here. or Doctor Smith is here.

Company names are not abbreviated unless abbreviations comprise their official name. Ginn and Company Harwood Engineering Co., Inc.

Compass points are abbreviated when

oc curring after street names and they can be unpunctuated. 2122 Apple Street, NW

Geographical and topographical names should

utilize U.S. Postal Service abbreviations. AL AK MN DC

BLVD ST PL RR USAttachment 3

- 3 Guidelines for Abbreviations

Laws and bylaws when fi rst mentioned are typed in full; however, subsequent references may be abbreviated. first reference Article I, Section 1 subsequent reference Art. I, Sec. 1

Personal names should not be abbreviated. George S. Patterson not Geo. S. Patterson

Scie ntific terms in binomial nomenclature may have the genus abbreviated after the first

full form reference. first reference Escherichia coli subsequent reference E. coli

Titles that are invariably abbreviated include Mr., Mrs., Ms., Messrs., and Dr

. Honorable

and Reverend when used with The are typed

out. If used without The , these forms of address may be abbreviated. Colonel COL John P. Howe, USA General GEN John P. Howe, USA Private PVT John P. Howe, USA

Versus is abbreviated as the lowercase Roman

letter v. in legal contexts. In general context, it

is abbreviated as vs. Smith v. State of Vermont honesty vs. dishonesty

III. Capitalization

Upper case letters are used for two broad purposes in English: they mark the beginning of a sentence and they signal a proper noun or adjective. Keeping mind that the database’s search function are case sensitive, it becomes even more critical for you to apply the rules of capitalization accurately.

Guidelines for Capitalization

Abbreviations a re only capitalized if the words they represent are proper nouns or adjectives.

The first word of a sentence, of a sentence fragment, or of a complete sentence enclosed in parentheses is capitalized.

Guideline Sample

Most acronyms are capitalized unle ss they have been assimilated into the language as parts of speech.

Consult a dictionary for proper styling. Acronyms that are not part of the daily language: MIRV NOW account

Acronyms that are used as part of the daily language: scuba, quasar, laser, r adar, sonar,

snafu

Abbreviations of air force, army, coast guard, and navy ranks are all capitalized. Those of the marine corps are capitalized and lower

cased. BG John P. Howe, USA LCDR Mary I. Lee, USN Col. John P. Howe, USMC

Abbreviations of academic degrees and professional ratings may be all capitalized or capitalized and lower

- cased depending on the term. Consult a dictionary for proper styling. D.D.S

. M.B.A.

P.E

. C.P.A.

Ph.D

.Attachment 3

- 4 Guidelines for Capitalization

Branches and units of the armed forces are capitalized, as are easily r ecognizable short

forms. United States Army and Army Rangers

Popular names of localities are capitalized. Capitol Hill Foggy Bottom Georgetown the Sunshine State

the Corn Belt the Eastern Shore

Nouns used with numbers or letters to design ate major reference headings are capitalized; however, minor reference headings and subheads are typically

lowercased. Book II Volume V Part 1 Table 5 Figure A Appendix III

footnote 14 page 12 line 8

item 16 note 10 paragraph 7

Words in titles of printed matter are capitalized except for internal conjunctions, prepositions, and articles. Introduction to Word Processing

Before the Fall

Journal of Scientific Medicine

The first word following a colon in a title is

cap italized. CBS: Reflections in a Bloodshot Eye Women in Baseball: The Forgotten History

Trademarks, brand names, and service marks are capitalized. the Dell workstation Federal Express

Touch

- Tone

The names of ships, airplanes, and spacecraft are capit alized. space shuttle Columbia Spirit of St. Louis

M. V. West Star

IV

. Numerals

In modern business writing, most numerals

- and especially exact numbers above 10

- are expressed in figures. Since there is flexibility in expressing monetary units, dates, and other numerical combinations, the overriding consideration is to be consistent in the standard selected.

Provided below are the standards selected for use of numerals in the FDMS database.Attachment 3

- 5 Guidelines for Numerals

Guideline Sample

Ages are expresse d in figures. Her 11 year

- old son..

. A 65 year

- old veteran...

Space permitting, numbers that begin a

sentence are to be written out. Thirty

- two birds died.

Dates should be written as Month, Day, and Four Digit Year when expressed in narrative

format. Ord inal numbers should not be used. January 1, 2003

not
the 1 st of January, 2003

Dates may be represented in figures when not

in narrative format but must be in the format

of MM/DD/YYYY. 11/21/2003

Exact amounts are usually expressed in figures

unle ss they begin a sentence. Thirty

- two birds died. Due to the chemical spill, 32 birds died.

Percentages will use the % character. 10 % not 10 percent

Figures over 999 will use a comma except

when the number is a set combination such as

a contract number, policy number, check or invoice number, address or room number. 1,135 keystrokes not 1135 keystrokes

Check 34567 the year 2003 page 4526

Room 6000

- B Contract No. W

- 03

- 12456

V

. Punctuation

The English writing system uses punctuation mar ks to separate groups of words for meaning and emphasis; to convey an idea of the variations of pitch, volume, pauses, and intonation of speech; and to help avoid contextual ambiguity. Punctuation marks should be used sparingly as special

characters can ma ke searching for and retrieving data difficult.

Spacing is an important issue in the use of special characters. There should be no space between the following combinations: any word and the punctuation that closes a sentence, quotation marks and the quot ed matter, parentheses or brackets and the words or figures that they enclose, between initials comprising abbreviations, between hyphenated compounds, or on either side of a dash. There should be one space after a comma or semicolon, after a period follow ing an initial in a proper name (Mr. H. C. Milker), before and after mathematical signs, and between U. S.

Postal Service state abbreviations and the ZIP Code.Attachment 3

- 6 Guidelines for Punctuation

Virgules (/) are not used to separate items in a list or to divide phrases but can be used if it is part of a title or acronym. (E.g. OEI/OIAA)

Use of the ampersand (&) should be avoided whenever possible. Spell out the word “and” instead. Use of the ampersand is permissible when it is a part of a proper noun such as a company name or is part of a legal case title or publication title.

Hyphens/dashes (

- ) are not used to introduce a list of items.

Ellipses (...) are used when a title or quote is to long to fit within a field.

Guideline Sample

While apostrophes normall y mark the omission of numerals or letters, this use

should be avoided in the FDMS database

where the electronic record will be retained indefinitely. the class of 1967 not the class of ‘67

fiscal year 1987 not fiscal year ‘87

Apostrophes are used in possessive nouns. One Man’s Junk

The History of the Thirty Years’ War

Brackets set off extraneous data and function as parentheses within parentheses. The company deceived them [the suspects] and is now paying hefty penalties.

(Bowman Act [also kn own as the Freedom Act] Ch. 4, sec. 4, p. 50)

Colons introduce a clause or phrase that explains, illustrates, amplifies or restates what has gone on before. The Hazards of Benzene: An Inhalation Study

Colons introduce items in a series. Please reference the following dockets: OAR

2002

- 0012, OAR

- 1999

- 0014, and

OW

- 2001

- 0142.

Colons separate elements in set formulas such as ratios, time, volume and page references, biblical citations, and place and publisher. a ratio of 3:5 8:30 a.m.

Words and Phrase s 11:261 John 4:10 Springfield, MA: Merriam

- Webster Inc.

Commas divide items in a list and set off cities from states, dates from years, and lines in an

address. ...includes: OAR

- 2002

- 0012, OAR

- 1999

- 0014, and OW

- 2001

- 0142. Shreveport, LA December 7, 2 003

Hyphens are used only in numerical sets where dictated by style. OAR

- 2003

- 0012

Contract No. W

- 03

- 125

- 8954A

Hyphens are used between some prefix and

root combinations.

Consult a dictionary for proper styling. trans

- Atlantic flight

pre

- 2003

re

- publis h

non

- roadAttachment 3

- 7 Guidelines for Punctuation

Hyphens are used in compound words, especially those containing a preposition.

Consult a dictionary for proper styling. chairperson

- elect attorney

- at

- law

Hyphens are used between compound adjectives. light

- duty large

- scale eight

- cylinder

Hyphens are used in expressing written out numbers, between a numerator and denominator, dividing years and pages in a range, or showing a distance relationship. forty

- two flowers

a two

- thirds majority pages 40

- 67

the decade 1960

- 1970

US

- Ir aq relations

Ellipses (...) are used when a title or quote is too long to fit within the field. The organization replied that it “felt overwhelmed by the workload required

under...the Clean Air Act.”

Alternative spellings of English terms should

be retained in formal titles and affiliations. In FDMS, include the American spelling of the

term in brackets after the foreign language spelling.

Consult your dictionary for the proper American spelling. organisation [organization] colour [color] centre [center] gly cerine [glycerin]