Revised Draft

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

1200 Pennsylvania 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, 2010

EPA comments received: November 5, 2010

EPA Comments addressed: November 12, 2010

Work stops if QAPP not approved: November 30, 2010

Addendum added August 2013

EPA Contract No. 68-C-02-095

Work Assignment 8-30
i

Addendum – August 2013

In early December 2010, project staff, EAD managers and the QAO, and CONTRACTOR 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 revision 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 Cost 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 (Facilities 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 Alternate Work Assignment Manager (ERG Support Contract) 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

ii
iii

TABLE OF CONTENTS

Page

1.0 INTRODUCTION .................................................................................................................1-1

2.0 PROJECT MANAGEMENT ELEMENTS .................................................................................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 Collected 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 DATA GENERATION, ACQUISITION, AND USE ...................................................................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 DEVELOPMENT AND USE OF ECONOMIC ANALYSIS MODELS............................................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 Application...............................................................................................4-4

4.4.2 Restrictions ..............................................................................................4-4
TABLE OF CONTENTS (Continued)

Page

iv

5.0 ASSESSMENT AND OVERSIGHT ELEMENTS........................................................................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 DATA VALIDATION AND USABILITY ELEMENTS ...............................................................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 Requirements (Element D.3) ......................................6-3

7.0 REFERENCES .....................................................................................................................7-1

Appendix A: QUESTIONNAIRE FOR CANNED AND PRESERVED SEAFOOD 

PROCESSING FACILITIES IN “NON-REMOTE” LOCATIONS OF ALASKA

Appendix B: CHECK LISTS

Appendix C: NON-REMOTE ALASKAN SEAFOOD PROCESSORS PETITION 

RESPONSE PROJECT FILE MANAGEMENT PLAN
v

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

LIST 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...................................................................................... 3-3
vi

History of QAPP for Support for EPA Response to Industry Petition on ELGs for NonRemote 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 Response to Industry 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 scope 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 economics 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 profile 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 

costing

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 Response to Industry 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 the 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 quality.

Appendix C Added Non-Remote Alaskan Seafood Processors Petition Response Project 

File Management Plan
viii

Distribution

(Element A.3)

This Quality Assurance Project Plan (QAPP) will be distributed to staff of the U.S. 

Environmental Protection Agency 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 project, 

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

Office 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 Anderson

Work Assignment Manager

(202) 566-1021

Anderson.Donaldf@epamail.

epa.gov

Todd Doley

Economics Task Manager

(202) 566-1160

Doley.Todd@epamail.epa.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.Bartram@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)

Debra.Falatko@erg.com

Kathleen Wu

Chemist

(703) 633-1625 (phone)

Kathleen.Wu@erg.com

Anne Jones

Economics Task 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.com
Section No. 1.0

Revision No. 1

Date: November 12, 2010

Page 1 of 2

1.0 INTRODUCTION

The U.S. Environmental Protection Agency (EPA) received a petition from 

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 Register 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 for 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, 

EPA never completed a final response to this 1980 petition. ERG is supporting 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 engineering 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 (non-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, Development of the Survey Questionnaire, in the spring of 2010 under 

Work Assignment 7-30. Under Work Assignment 8-30, ERG will support EPA in completing 

Steps 3, 7, 9, 13a, and 13c. 

As directed by Work Assignment 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 specified 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. 
Section No. 1.0

Revision No. 1

Date: November 12, 2010

Page 2 of 2

ERG has organized this document 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 PROJECT MANAGEMENT ELEMENTS

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 

approach 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: Project 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.

Elements 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 communicate 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 Coordinator 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/Background (Element A.5)

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

this project. Primary data collection includes an industry questionnaire that EPA/OW and EPA 

Region 10 developed and sent 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-alone 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 literature 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 

facilities 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 the 

authority of CWA §308. 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. 

The questionnaire requested information about each facility that the company operates in Alaska. 

Among other things, this questionnaire requested information about the facility’s operation, 

processing capacity, seafood processing waste generation, and current waste recycle/recovery 

and disposal practices. The questionnaire also asked 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. 

On 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 sheet 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;

• Analyzing 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 transportation, 

— Reduction of fish into fish meal, fish oil, and fish protein 

hydrolysate, including costs, and

— Financial summary data for firms and facilities.

EPA, rather than ERG, is responsible for certain questionnaire-related activities; 

therefore, they are not described in this ERG QAPP. These activities include: 

• Development of the questionnaire and mailing list;

• Mail out of the questionnaire;

• Answering 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 collecting and analyzing information from stand-alone seafood by-products 

plants via telephone, e-mail, 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. During 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 for 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

— Reduction of recovered solids to fish meal, fish oil, and fish 

protein hydrolysate; and 

• Collecting information 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 conjunction with primary data collected via 

§308 data collection efforts to estimate 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 (supplemented 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 wider 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

economic analysis of the financial health of, at a minimum, the facilities and firms in the petition 

areas, both in the baseline and after consideration of ELGs compliance costs. In this economic 

analysis ERG will use secondary sources of information to provide methods 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 objectives of this QAPP are to ensure that:

1. Data 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. The results of the analyses of these data are documented and of the type, quality, 

transparency, and reproducibility 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 Collected Under CWA §308 Authority

The quality objectives for data collected by activities conducted 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 Seafood Processing Facility Questionnaires

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 criteria ERG will use for this evaluation are 

presented in Table 2-1, along with acceptable values for each criterion. ERG will identify 

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

data.” The identification of responses that do not meet quality criteria will be recorded in the 
Section 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 data 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.

• Responses 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 response includes answers 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-remote 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 Questionnaire 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 be 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 Seafood By-product Plant Information Requests

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 images, 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 40 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 to 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 discharges 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 engineering 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 criterion. 

ERG will only use sources 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) Does the information reflect 

current conditions?

Year of publication (or presentation, if a paper presented 

at a conference).

For byproduct recovery - Priority : 2005 or after; 

consider: 2000 or after.

For screening and ocean disposal – use professional 

judgment.
Section No. 2.0

Revision No. 1

Date: November 12, 2010

Page 8 of 17

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 

reflect 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 

province)

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 costs for Alaskan seafood processors to 

install and operate wastewater pollution control technologies, including byproduct recovery 

processes and barging and ocean disposal. In addition to information reported in the §308 

Questionnaire, ERG will obtain current (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 sources that meet these criteria will to develop or evaluate 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 “non-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

Revision No. 1

Date: November 12, 2010

Page 9 of 17

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 requests.

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 EPA’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 analysis

• Include one-time costs for equipment purchase and installation.

• Include on-going operating, and maintenance costs (annual costs).

Appropriate for actual 

processing plant locations

• Equipment costs include transportation to each processing center. Installation 

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 costs escalated to 2010, using Means Construction Index 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 Profile and Economic Analyses

ERG will develop an 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

Revision No. 1

Date: November 12, 2010

Page 10 of 17

• 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 

analyses. 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 community 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 economic information are

summarized in Table 2-5 along with acceptable values for each criterion. ERG will only use 

sources that meet these criteria for the economic profile.

Table 2-5. Economic Profile and Analysis Data Acceptance Criteria

Acceptance Criterion: 

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 operate 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 information 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 community. 

Dun and Bradstreet and RMA data will be 

considered “reasonably reliable.” Other sources will 

be reviewed and used with caveats discussed, as 

necessary.
Section No. 2.0

Revision No. 1

Date: November 12, 2010

Page 11 of 17

Table 2-5. Economic Profile and Analysis Data Acceptance Criteria

Acceptance Criterion: 

Literature Review Description/Definition Specification

Comparability Are data, such as numbers of firms 

and facilities in certain areas, etc.

comparable to those across various 

sources where more than one 

source provides information?

ERG will rank sources by reliability and, among 

those of similar reliability, ERG will compare the 

sources in the profile and economic analysis.

2.5 Special Training/Certification (Element A.8)

Information 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 outlined in ERG’s CBI 

security plans. ERG will permit only 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 ERG’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 Information 

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 document the circulation 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 members 

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. 3.0

Revision No. 1

Date: November 12, 2010

Page 1 of 6

3.0 DATA GENERATION, ACQUISITION, AND USE

In its Requirements of Quality Assurance Project Plans (EPA, 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 Analytical 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 responsible for 

those parts of the project scope. For this reason, those elements are not discussed in this QAPP. 

To fulfill the work assignment direction, this section describes: 

1. The activities and procedures ERG will use to collect secondary data, how ERG 

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 review and economic profile, 

how ERG will determine 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 information 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 determination will be documented. 

3.1 Non-direct Measurements (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 

used 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

• Economic Profile and Analysis Data.
Section No. 3.0

Revision No. 1

Date: November 12, 2010

Page 2 of 6

3.1.1 Activities and Procedures for Collection and Use of Secondary Data

Collection of Secondary Data. ERG will obtain secondary data from 

sources such as government publications and databases, scientific literature, financial literature, 

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 secondary 

data:

• ERG researchers will collect full bibliographic information on all 

collected publications, including “date accessed” for information collected 

from the Internet.

• ERG researchers will save Web pages as PDF files, so that the data source 

can be added to the electronic project file.

• ERG researchers will submit the publications and meta data to the 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 keeper 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 all telephone contacts using the 

Telephone Contact Report depicted in Figure 3-1. 

• ERG researchers will save all email contacts as pdf files, so that they can 

be added to the electronic project file.

• ERG researchers will ensure that telephone contact reports and email 

records are added to the Alaska Seafood Processing Project File.
Section No. 3.0

Revision No. 1

Date: November 12, 2010

Page 3 of 6

Project No.: DISTRIBUTION

Page 1 of 1 

Project Name: 

TELEPHONE CALL 

RECORD

 Outgoing Call

Date: Time: 

Company Name: Contact Name: 

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 

supporting 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 analysis 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 acceptance criteria specified in Sections 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. Copies will be retained in the project file to 

document that ERG evaluated the quality of the collected secondary data.
Section No. 3.0

Revision No. 1

Date: November 12, 2010

Page 4 of 6

• 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 industry 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 

deliverable 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 project 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 provides

detailed instructions for developing 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). The ERG WAM has assigned a project team member (the “index 

keeper”) the responsibility 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 

docket 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 Work Assignment 7-30, ERG developed a Microsoft Access® database to record and 

analyze responses to the §308 Questionnaire. 

ERG data entry staff are entering responses directly into the database for simple 

questions and use Access Forms for data table questions. This combination approach minimizes

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 related 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 they 
Section No. 3.0

Revision No. 1

Date: November 12, 2010

Page 5 of 6

complete each form. To further ensure that the database is accurate, a second CBI-cleared ERG 

staff member will independently review 50 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 

additional review (i.e., greater than 50 percent) that ERG should perform on data entry. When 

errors in database entry are discovered during review, ERG will correct the erroneous data fields. 

ERG staff not involved in the data entry corrections will perform a 100 percent check to ensure 

that resolved errors are corrected 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. 

ERG will store the completed database on ERG’s CBI server computer network. 

If the EPA WAM and ERG determine that 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 these 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 that 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 ERG 

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 ELGs requirements for non-remote Alaskan seafood processing 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 spreadsheet, ERG will:

• Assign a unique name and number to the revised version of the 

spreadsheet; 
Section No. 3.0

Revision No. 1

Date: November 12, 2010

Page 6 of 6

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

• In a separate QA worksheet (spreadsheet) in the workbook (notebook) 

itself, log the changes made to the different 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 adequately 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 equations 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 estimates 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

Revision No. 1

Date: November 12, 2010

Page 1 of 4

4.0 DEVELOPMENT AND USE OF ECONOMIC ANALYSIS MODELS

This section describes the procedures ERG will use to ensure the quality of the 

Alaska Seafood Processing Industry Financial Model. These procedures address the appropriate 

elements of NRMRL QAPP Requirements for Research Model Development and Application 

Projects (EPA 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 ELGs for Non-Remote 

Alaska Seafood Processors. ERG will use the following: 

• Excel spreadsheet software;

• §308 questionnaire data;

• Additional financial data submitted by the respondents 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 which 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: 

• Used before in EPA economic analysis of effluent guidelines; 

• Generally accepted by financial analysts who investigate investment risks;

• Best suited for use among the group of affected entities given their 

geographic location and the small size of the affected group; and/or 

• Best reflect how firm owners or investors would judge the financial 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 binary 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 Processing Industry, might require 

different benchmarks due to unique considerations or available data. 
Section No. 4.0

Revision No. 1

Date: November 12, 2010

Page 2 of 4

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 Development

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 database 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 financial 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 considered 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 used 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 are 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 the 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 benchmarks 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 entire operation from input data to result for those entities to 

ensure that outputs match those calculations.
Section No. 4.0

Revision No. 1

Date: November 12, 2010

Page 3 of 4

Finally, the QA reviewer will review the final model at completion, spot checking 

data extraction, reviewing all equations and logic again, and hand 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 provide 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 since 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 Validation

Calibration is the process of adjusting model parameters within physically 

defensible 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

Revision No. 1

Date: November 12, 2010

Page 4 of 4

Validation consists of comparing the prediction of a calibrated model with 

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

Calibration and validation 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 are 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 available for many years hence. 

Because the model is similar (or in some regards identical) to economic 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 reasonably 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 of secondary data. The ERG 

economics task leader and the EPA WAM and Alternate WAM will meet to discuss assumptions 

and calculation logic to assess reasonableness. ERG will perform additional internal review to 

ensure all data used have met the acceptability 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 receipt of the model and its data. Its use is limited to judging 

financial impacts on the Alaska Seafood Processing Industry from the final ELGs for NonRemote Alaska Seafood Processors, other alternatives to the ELGs, 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

Revision No. 1

Date: November 12, 2010

Page 1 of 2

5.0 ASSESSMENT AND OVERSIGHT ELEMENTS

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 all work conducted on this project to technical review. 

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

“state of the art.” ERG’s WAM will conduct this review. In addition, reports and memoranda to 

the record will be reviewed by a senior-level engineer (for engineering activities) 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 off 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 project-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 Reports to Management (Element C.2)

ERG will describe 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 by 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 (or 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 

specifications.

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) review.

Cost estimate spreadsheet (loaded) review.

Cost estimate quality review (comparison to Table 2-4 prior to delivery to economists).

In addition, any quality deficiencies detected by technical reviewers or the Project 

QA Coordinator will be communicated, 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 DATA VALIDATION AND USABILITY ELEMENTS

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 

analyses 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 how ERG will 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

• Database 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 requirements
Section 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 Model 

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 Profile and Economic Analysis

Review and documentation of the quality of economic profile information 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 in previous EPA ELGs analyses, and government sources such 

as:

a. Census data;

b. Other U.S. Department of Commerce data;

c. Bureau of Labor Statistics data;

d. Securities and Exchange Commission data;

e. Financial analysis textbooks reviewed by oversight committees

f. Altman, E.I., and E. Hotchkiss, Corporate Financial Distress and 

Bankruptcy, 2006.

g. Small Business Administration data

h. Other EPA economic analyses.

2. Proprietary data such as:

a. Dun & Bradstreet data;

b. RMA data; and 

c. Other journal and university publication data.

3. News 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 lower 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 sources that do not meet the criteria specified in Table 2-5 (e.g., news items, nonuniversity 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 Reconciliation 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 this 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 identifications 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 REFERENCES

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. Environmental 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 Protection Agency. NRMRL QAPP Requirements for Research 

Model Development and Application Projects, Revision 0. Office of Research and Development. 

October 2008. 

ERG, 2008. Eastern Research Group, Inc. Security Plan for Handling Confidential Business 

Information Under the Clean Water Act. September 25, 2008. 

ERG, 2005. Eastern Research Group, Inc. Security Plan for Handling CWA Confidential 

Business Information, Lexington, MA Office, October 25, 2005.
Appendix A

QUESTIONNAIRE FOR CANNED AND PRESERVED SEAFOOD PROCESSING 

FACILITIES IN “NON-REMOTE” LOCATIONS OF ALASKA
United States 

Environmental Protection 

Agency 

Questionnaire for 

Canned and Preserved Seafood 

Processing Facilities in 

Certain Locations of Alaska 

EPA is distributing this questionnaire under the authority of Section 308 of the 

Clean Water Act. You must return the completed questionnaire(s) to EPA 

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 2010 
i 

INTRODUCTION 

The U.S. Environmental Protection Agency (EPA) is conducting 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 operations 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 facilities in these locations (the “study area”) to respond to an 

industry petition that was submitted to EPA in 1980. This petition requested EPA to revise effluent 

limitations and standards and prohibitions for direct 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, 1981 Federal Register Notice, EPA also proposed 

to redefine the term “non-remote” for the Alaskan segment of the industry to eliminate 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 Cove 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 allow 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 questionnaire 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 water (MLLW) and near-shore seafood 

processing facilities operating and discharging from one (1) to one-half (0.5) nautical mile from 

shore at MLLW. 

EPA will use the technical data collected from each facility 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 the possible economic impacts associated with 

alternative waste disposal practices. 

EPA is distributing this questionnaire under the authority of Section 308 of the Clean Water Act. You 

must return the completed questionnaire(s) to EPA 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. 
ii 

INSTRUCTIONS FOR COMPLETING THE QUESTIONNAIRE 

QUESTIONNAIRE OVERVIEW

This questionnaire is divided into two primary sections. 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, including those onboard vessels, you operate in Alaska.

You should complete Part B for the following facility 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 questionnaire and complete a copy for each additional processing 

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 used 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 information 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 validate 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 EPA 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 questionnaire, 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.gov 
iii 

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 facility 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 Express, 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 completed questionnaire for each facility, including 

attachments, in the event that we need to contact you 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 industry’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. You may assert a business confidentiality claim covering 

part or all of the information you submit, other than 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 claim. A business which is submitting 

information to EPA may assert a business confidentiality 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 notice complying language such as ‘trade 

secret,’ ‘proprietary,’ or ‘company confidential.’ Allegedly 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 occurrence of a certain event, the notice should so 

state.” 

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. Therefore, it is strongly recommended that 

only those pieces of information that are the most sensitive (e.g., certain financial information and data) 

as described in 40 CFR Part 2, should be claimed as CBI. 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 confidential treatment, pursuant to Section 308(b) of the Clean 

Water Act, and thus will be treated as nonconfidential even if the CBI box is checked. In addition, 

information that is publicly available should not be claimed confidential. 

Information covered by a claim of confidentiality will 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 disclosed to other employees, officers, or authorized 

representatives of the United States concerned with implementing the Clean Water Act. 

Information covered by a claim of confidentiality will be made available to EPA contractors to enable the

contractors to perform the work required by their contracts with EPA. All EPA contracts provide that 

contractor employees use the information only for the purpose 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 statement then sign and complete the remainder of this 

page. 

Certification Statement #1

I certify under penalty of law that the attached questionnaire was prepared under my direction or supervision 

and that qualified personnel properly gathered and evaluated the information submitted. The information 

submitted is, to the best of my knowledge and belief, accurate 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 believe to be company confidential business information

as defined under 40 CFR Part 2, Subpart B. We understand that we may be required at a later time to justify 

our claim in detail with respect to each item claimed confidential. I am aware that there are significant 

penalties for submitting false information, including the 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 corporation 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 submitting 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 Number 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 Code 
Part A. Corporate Information Alaskan Canned and Preserved 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 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 entry 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 apply 

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 questions 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 addition, if additional pages are required to clarify a 

response, please write the associated question number, 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 how 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 confidential. 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 claims are not recommended and individual claims 

must be carefully considered. Read carefully the CONFIDENTIAL BUSINESS INFORMATION 

section on page iv and understand the implications before 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 expected 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 Preserved Seafood Processing 

Copy of 

A-2 

A-1. Please provide contact information for the corporate 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 firm. 

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 partially 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 business organization. 

 Sole proprietorship 

 Partnership 

 Corporation (standard, “C” corporation) 

 Subchapter S Corporation 

 Limited Liability Corporation 

 Other: 

A-5. Please provide your parent company’s financial reports for 2005 through 2009. These financial 

reports can be accounting reports or tax forms and must include income statement information 

(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 if 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. 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part A. Corporate Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

A-3 

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

 State______________________________ 

A-7. Please indicate whether your parent firm is owned 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 incorporation? 

 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 HIGHEST 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 seafood canning at this highest corporate level 

would be classified in NAICS 311711; those whose revenues 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 highest corporate level at year end 2009. 

Total 2009 year end employment 

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

Total 2009 revenues $ 

Instructions: From this point on to the end of Part 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 company. 

A-12. If your company owns any commercial vessels, please 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?

 Yes
Part A. Corporate Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

A-4 

A-13. Please indicate your company’s type of business organization. 

 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 legal entity (if foreign, please indicate NA)? 

State: 

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

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 through 2009. These financial reports can be accounting 

reports or tax forms and must include income statement information (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 if 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 your 

company? 

 Yes. You have completed Part A. Please proceed to Question 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 outside of Alaska in 2009. 

Please provide the number of facilities and their number 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?

 Yes
Part A. Corporate Information Alaskan Canned and Preserved 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 financial data are not yet available, or if other years’ data 

are not applicable, please enter NA. 

Company Revenues 

2005 2006 2007 2008 2009 

a. Revenues from Sale of 

Processed Seafood 

$ $ $ $ $ 

b. Revenues from Sale of 

Secondary Byproducts

$ $ $ $ $ 

c. Other Revenues (please 

describe): 

$ $ $ $ $ 

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

A-21. For fiscal years 2005 through 2009, please provide 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 of Part B. 

CBI?

 Yes

CBI?

 Yes
Part A Comments Alaskan Canned and Preserved Seafood Processing 

Copy of 

A-6 

PART A COMMENTS 

The questionnaire requests information for 2005 through 2009. While year-to-year operations are expected to 

vary, please add a note in the Comments Table if the 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 page. 

Question 

Number CBI? Comment 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 
Part A Definitions Alaskan Canned and Preserved Seafood Processing 

Copy of 

A-7 

PART A DEFINITIONS 

The terms identified below are identified in the text 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 sheet items (assets, liabilities, and equity). 

Alaska Pollock – Walleye pollock, Theragra chalcogramma. 

Amortization -- The deduction of capital expenses over a specific period 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 transporting freight that is towed or pushed by other craft. 

Bottom Fish – Alaska pollock, halibut, flounders, rock fishes, ocean perch, hake, red 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 industrial wastewater and transports it to 

a centralized wastewater treatment facility and/or discharge point. 

Clean Water Act (CWA) – A Federal statute enacted by Congress “to restore and maintain the chemical, 

physical, and biological integrity of the Nation’s waters.” (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 described in 40 

CFR Part 2 Subpart B. 

Depreciation -- The deduction of capital expenses over a specific period of time (usually over the life of the 

asset). Tangible assets are depreciated. (Source: Investopedia.com) 

Direct Discharge – (1) Any addition of any pollutant or combination of pollutants to waters of the United 

States from any point source; or (2) any addition of any pollutant or combination of pollutants to the waters 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 fish or parts thereof, generally produced by 

cooking raw fish or shellfish with steam and pressing the material to obtain the solids which are then dried. 

Fish Oil – Oil processed from the body or liver of fish. Typically 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 uniform size (e.g., 0.5 inch or less). Includes grinding 

pumps, macerator pumps, and devices with rotating cutting teeth or gears (comminutors). 
Part A Definitions Alaskan Canned and Preserved Seafood 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 pollock, 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 the Alaska seafood processing 

industry, that requested EPA to modify the BPT regulations for the Alaskan seafood processing industry by 

deleting Anchorage, Cordova, Juneau, Ketchican, and Petersburg 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 source 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 centers including but not limited to 

Anchorage, Cordova, Juneau, Ketchikan, Kodiak, and Petersburg. 

NPDES Permit – A permit issued under the National Pollutant Discharge Elimination System (NPDES) 

program, which is the national program for issuing, modifying, revoking and reissuing, terminating, monitoring 

and enforcing permits, and imposing and enforcing pretreatment requirements under sections 307, 318, 402, 

and 405 of the Clean Water Act. 

Offshore disposal – Disposal at-sea of waste(s) produced at a shore-based seafood processing facility. 

Other Alaska – Areas of Alaska outside of Anchorage, Cordova, Juneau, Ketchikan, Petersburg, Dutch 

Harbor, and the Kenai Peninsula 

Outfall – A wastewater discharge. See point source. 

Point Source – A discernible, confined, and discrete conveyance, including but not limited to, any pipe, ditch, 

channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, 

landfill leachate collection system, vessel or other floating craft from which pollutants are or may be 

discharged. This term does not include return flows from irrigated agriculture or agricultural storm water 

runoff. (See 40) CFR §122.2). 

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

Questionnaire Package – Certification Statement; Part A - Corporate Information; 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 transporting bulk freight, garbage, or other waste. 

Screen – A mechanical device for separating solids and liquids. Screens used to separate seafood

processing solids from wastewater include revolving drums, vibrating screens, pressure screens, and many 

others. 
Part A Definitions Alaskan Canned and Preserved Seafood Processing 

Copy of 

A-9 

Seafood – The raw material, including freshwater and saltwater 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/or processing fish and 

seafood. Fresh fish are eviscerated and/or processed by removal 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-product. 

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 become primary product. 

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

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 which cannot be directly linked to the sale of a specific unit, 

but which are proportionally allocated to all units sold during a certain period, such as telephone, interest 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, Dutch Harbor, and the Kenai Peninsula 

Tugboat – A boat designed and built to maneuver other vessels by pushing or towing them. 
Part B. Facility Information Alaskan Canned and Preserved 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 accurate. 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 blanks. 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 entry 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 questions applicable to your facility, please provide 

your best estimates. 

• Include any clarifying attachments. If additional pages are required to clarify a response, 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 attachment page. 

• Some pages of the questionnaire may need to be photocopied before you respond, indicate how 

many copies of the page(s) you are submitting by completing the entry “Copy ___ of ___” in the top 

right corner, unless instructed otherwise. 

• Indicate information that should be treated as confidential. 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 claims are not recommended and individual claims 

must be carefully considered. Read carefully the CONFIDENTIAL BUSINESS INFORMATION 

section on page v and understand the implications before 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 expected 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 Preserved Seafood Processing 

Copy of 

B-2 

QUESTIONNAIRE ASSISTANCE

If you have any questions as you complete Part B of this 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.gov 
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-3 

B-4. Please provide the primary contact for Part B of this questionnaire, if different than the contact for 

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 than one (1) nautical mile from shore at 

MLLW) 

 STOP. You have completed Part B for this facility. 

 Shore-based (operating and discharging less than one-half (0.5) nautical mile from shore at 

MLLW).

 Near-shore vessel (operating and discharging from one (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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-4 

B-9. Please provide information about expansions and capacity increases. 

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

 

 

B-10. Indicate all the types of fish or marine life processed 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, red 

snapper, cod, and other Alaska groundfish species. 

CBI?

 Yes

CBI?

 Yes
Part B. Facility Information Alaskan Canned and 

B-5 

B-11. For each type of seafood indicated in Question B-10, please provide total weight (pounds) of raw fish and shellfish 

2009. In lieu completing the table below, you can attach an existing data report as long as the data provided includrequested below. 

Table 1. Total Pounds (lbs) Raw Fish and Shellfish Processed 

Seafood Type 2005 2006 2007 200

Example: Canned Salmon 56,000 68,000 43,000 50,0Fresh/Frozen Salmon Canned Salmon Tanner Crab Section Tanner Crab Meat Dungeness Crab Section King Crab Meat King Crab Section Bottom Fish a Shrimp Herring Other (please specify): Other (please specify): Other (please specify): 

a Bottom fish includes: Alaska pollock, halibut, flounders, rock fishes, ocean perch, hake, red snapper, cod, and other Ala

CBI?

 Yes
Part B. Facility Information Alaskan Canned and 

B-6 

B-12. For the seafood types in the following table, please indicate the average pounds/day processed in each month to 

distribution through one peak production year selected between 2005 and 2009. (Refer to Table 1. For each sea

with the largest production. Complete Table 2 for that year. The year does not need to be the same for each seafo

Table 2. Seasonal Average lbs/Day Processed 

Seafood Type Year Jan Feb Mar April May Jun Jul Aug Sep 

Example: Salmon, Canned 2006 0 0 0 200 1,000 14,000 25,000 16,000 8,000 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, red snapper, cod, and other A

CBI?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-7 

B-13. For the seafood types in the following table, please indicate the peak production week and day for 

the peak year between 2005 through 2009 as well as the rate of production during these time frames. 

The peak year should be the same as the peak years indicated 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, red snapper, cod, 

and other Alaska groundfish species. 

CBI?

 Yes
Part B. Facility Information Alaskan Canned and Preserved 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 units 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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-9 

B-19. Please indicate the total pounds of raw material 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 Materials 

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 or provide a copy (copies) of contracts, letter 

agreements, etc., that provide such details. 

B-21. What is the distance (road miles, or nautical miles 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 explain: 

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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-10 

Questions about Waste Generation and Disposal 

B-23. In the blank space below, please provide a schematic diagram of the facility’s production process 

showing all waste streams leaving the process. An example 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 adequate 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 Schematic 
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

B-11 

B-24. Using data for a typical year between 2005 through 2009 please provide a percentage estimate of the following: A

facility that becomes product, B) seafood that becomes secondary seafood by-product at an on-site facility C) ssecondary seafood by-product at an off-site facility D) seafood waste that is discharged to an outfall or city sewe

that is taken away from the plant through means other than an outfall or city sewer. The total of the 5 estimates shocalculation for each stream refers to the labeled example schematic diagram in Question B-23. 

Table 6. Estimated Breakdown of Product, Secondary By-product, and Waste (for a typical y

(A) Percent of Weight 

Processed that 

Becomes Seafood

Product 

(B) Percent of Weight 

Processed that 

becomes Secondary 

By-product Onsite

(C) Percent of Weight 

Processed that 

becomes Secondary 

By-product Offsite

(D) Percent of We

Processed that 

Discharged to a

Outfall or City Se

Seafood Types Processed A=100*(a/r) B=100*(b/r) C=100*(c/r) D=100*(d/r) 

Example: Canned Salmon 35% 0% 0% 65% Fresh/Frozen Salmon Canned Salmon Tanner Crab Section Tanner Crab Meat Dungeness Crab Section King Crab Meat King Crab Section Bottom Fish Shrimp Herring Other (please specify): Other (please specify): 

Weight processed means raw fish and/or shellfish. Bottom fish means Alaska pollock, halibut, flounders, rock fishes, ocean perch, other Alaska groundfish species. 

CBI?

 Yes
Part B. Facility Information Alaskan Canned and Preserved 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 facility? Indicate if 

there is any treatment of the wastewater before leaving 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, identify the year between 2005 and 2009 with the greatest 

production. For this year, report in Table 7, the average volume (gallons per day) of seafood

processing wastewater directly discharged through your plant 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 estimate wastewater volume. You also have the 

option of enclosing these data in an available format as attachments in lieu of completing the table 

below. Please identify the units of measure (e.g., gallons per day). 

Table 7. Average Volume of Seafood Processing Wastewater Discharge by Month 

Year of Greatest If discharge volume is not available, report 

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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-13 

Questions about Disposal of Screenings and Other Solid Wastes 

B-27. Are solid wastes separated from wastewater and 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., pounds, 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 describe 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 site is from the dock. 

 Map Attached 

 Approx. GPS location(s) 

Distance from dock: nautical miles 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-14 

B-32. During the period of 2005 through 2009, indicate any times you were not able to haul the waste to an 

off-shore location and explain why (e.g., weather, etc) 

Date Explanation why waste could not be hauled off shore 

 

 

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 separate 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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved 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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-16 

Questions about Available Dock Space 

B-36. During peak fishing season, is there sufficient 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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-17 

Questions About Offsite Secondary By-product Facilities 

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 question B-38, has your seafood processing facility/company

attempted to enter into long term agreements or arrangements to have your seafood processing 

waste transported to any of these reduction facilities? 

 Yes 

If “Yes,” describe in detail the business agreement or 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 production) system. 

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

 The offsite facility(ies) does not have the capacity to 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 such 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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved 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 distance 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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-19 

Questions about Facility Financial Information 

B-42. Please provide the contact information of the individual who completed the facility’s financial section 

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 provide revenues 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, please insert NA and provide 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 from 

Secondary Byproducts Sold 

$ $ $ $ $ 

c. Other Revenues 

(please describe): 

$ $ $ $ $ 

d. Total Revenues 

(a+b+c) $ $ $ $ $ 

CBI?

 Yes

CBI?

 Yes
Part B. Facility Information Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-20 

B-44. For fiscal years 2005 through 2009, please provide 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, please insert NA and provide an explanation in the 

Comments Section on Page B-22. 

Operating and Other Costs for Seafood Processing Facility 

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?

 Yes
Part B. Facility Information Alaskan Canned and Preserved 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?

 Yes
Part B Comments Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-22 

PART B COMMENTS 

The questionnaire requests information for 2005 through 2009. While year-to-year operations are expected to 

vary, please add a note in the Comments Table if the 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 page. 

Question 

Number CBI? Comment 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 

 Yes 
Part B Definitions Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-23 

PART B DEFINITIONS 

The terms identified below are identified in the text 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 sheet items (assets, liabilities, and equity). 

Alaska Pollock – Walleye pollock, Theragra chalcogramma. 

Amortization -- The deduction of capital expenses over a specific period 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 transporting freight that is towed or pushed by other craft. 

Bottom Fish – Alaska pollock, halibut, flounders, rock fishes, ocean perch, hake, red 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 industrial wastewater and transports it to 

a centralized wastewater treatment facility and/or discharge point. 

Clean Water Act (CWA) – A Federal statute enacted by Congress “to restore and maintain the chemical, 

physical, and biological integrity of the Nation’s waters.” (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 described in 40 

CFR Part 2 Subpart B. 

Depreciation -- The deduction of capital expenses over a specific period of time (usually over the life of the 

asset). Tangible assets are depreciated. (Source: Investopedia.com) 

Direct Discharge – (1) Any addition of any pollutant or combination of pollutants to waters of the United 

States from any point source; or (2) any addition of any pollutant or combination of pollutants to the waters 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 fish or parts thereof, generally produced by 

cooking raw fish or shellfish with steam and pressing the material to obtain the solids which are then dried. 

Fish Oil – Oil processed from the body or liver of fish. Typically 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 uniform size (e.g., 0.5 inch or less). Includes grinding 

pumps, macerator pumps, and devices with rotating cutting teeth or gears (comminutors). 
Part B Definitions Alaskan Canned and Preserved Seafood 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 pollock, 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 the Alaska seafood processing 

industry, that requested EPA to modify the BPT regulations for the Alaskan seafood processing industry by 

deleting Anchorage, Cordova, Juneau, Ketchican, and Petersburg 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 source 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 centers including but not limited to 

Anchorage, Cordova, Juneau, Ketchikan, Kodiak, and Petersburg. 

NPDES Permit – A permit issued under the National Pollutant Discharge Elimination System (NPDES) 

program, which is the national program for issuing, modifying, revoking and reissuing, terminating, monitoring 

and enforcing permits, and imposing and enforcing pretreatment requirements under sections 307, 318, 402, 

and 405 of the Clean Water Act. 

Offshore disposal – Disposal at-sea of waste(s) produced at a shore-based seafood processing facility. 

Other Alaska – Areas of Alaska outside of Anchorage, Cordova, Juneau, Ketchikan, Petersburg, Dutch 

Harbor, and the Kenai Peninsula 

Outfall – A wastewater discharge. See point source. 

Point Source – A discernible, confined, and discrete conveyance, including but not limited to, any pipe, ditch, 

channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, 

landfill leachate collection system, vessel or other floating craft from which pollutants are or may be 

discharged. This term does not include return flows from irrigated agriculture or agricultural storm water 

runoff. (See 40) CFR §122.2). 

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

Questionnaire Package – Certification Statement; Part A - Corporate Information; 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 transporting bulk freight, garbage, or other waste. 

Screen – A mechanical device for separating solids and liquids. Screens used to separate seafood

processing solids from wastewater include revolving drums, vibrating screens, pressure screens, and many 

others. 
Part B Definitions Alaskan Canned and Preserved Seafood Processing 

Copy of 

B-25 

Seafood – The raw material, including freshwater and saltwater 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/or processing fish and 

seafood. Fresh fish are eviscerated and/or processed by removal 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-product. 

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 become primary product. 

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

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 which cannot be directly linked to the sale of a specific unit, 

but which are proportionally allocated to all units sold during a certain period, such as telephone, interest 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, Dutch Harbor, and the Kenai Peninsula 

Tugboat – A boat designed and built to maneuver other vessels by pushing or towing them. 
Appendix B

CHECK LISTS
B-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 commercial 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., Canada, state, or province)

For academic researcher:

• Publication in peer-reviewed journal

• Presentation at professional technical conference

For vendor researcher:

• Publication in peer-reviewed journal
B-2

Pollution Control Technology Cost Data Quality Check List

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 List

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.” Peerreviewed 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.

Comparability

For sources of similar reliability, similar values are reported 

for the same variable (factor).
Appendix C

NON-REMOTE ALASKAN SEAFOOD PROCESSORS PETITION RESPONSE 

PROJECT FILE MANAGEMENT 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 Avenue, 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 07-30
C-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. INTRODUCTION AND DEFINITIONS........................................................................................ 3

1.1 Background............................................................................................................. 3

1.2 Alaskan Seafood Petition Response Project File .................................................... 3

1.3 Docket..................................................................................................................... 4

1.4 Federal Docket Management 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. GENERAL PROCEDURES ....................................................................................................... 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 Response Archive............................................ 16

3. QUALITY CONTROL PROCEDURES...................................................................................... 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 from the Alaskan Seafood Petition Response 

Project File ................................................................................................ 19

3.2.4 Project File Plan Revision......................................................................... 20

4. DOCKET ASSEMBLY........................................................................................................... 21

Attachment 1: ALASKAN SEAFOOD PETITION RESPONSE PROJECT FILE OUTLINE

Attachment 2: EXAMPLE ELECTRONIC PROJECT FILE LOG-IN FORM

Attachment 3: FDMS GUIDELINES FOR FREE TEXT FIELDS
C-3

1.0 INTRODUCTION AND DEFINITIONS

This document is 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” locations 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, as 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 regulatory 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 members 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 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 Register 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 for 

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, EPA never completed a final response 

to this 1980 petition. 

EPA’s Response to the Industry Petition on ELGs for Non-Remote 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 “Notice 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 Petition 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 EPA, 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 written 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 appropriate 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;

• Internal 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 performance 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 documents 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-makers, 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 draft guidance, policy statements, information collection requests 

under the Paperwork Reduction Act, and other non-rule activities. Each time an Agency action is 
C-5

announced in the Federal Register, a docket is established and assigned a tracking number to 

accumulate 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 prepared 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 federal agencies and entities. FDMS is built 

on a document management 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 materials. 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 the 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 Response 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 and 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 Files
C-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 space requirements under control. Working drafts of CBI and CBI 

computer files are managed according to ERG’s CBI security plan entitled 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 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 file. 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 index 

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 page 

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 

accompanies 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 treatment (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 containing 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 information 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, etc.) 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 the 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 the 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, project 

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 file 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 inclusion 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 identified 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 

“sanitized” 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 and 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 used to submit materials to the project file, 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 the 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 will 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 electronic 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. Include 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, spreadsheets, 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 will 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 submission 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 may 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 assemble 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 prior 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 will 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. For 

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 files 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-mail 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 few exceptions 

described later. For hard-copy documents, it is critical that indexing and filing occur 

simultaneously. No changes will be made to section assignments in the index unless the item is 

physically re-filed. 

Project Deliverables. As materials are sent as deliverables to clients via e-mail 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 complete 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 Materials. 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 included 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 related series of calculation sheets.

CBI Items. 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 Compact Disk (CD), Digital Video Disk (DVD), or Diskette. 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 EPA 
C-11

docket on DVD, 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 Website 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 

information 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 Alaskan 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 will 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 are 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 saving 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 DCNs 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 extensions, 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 added 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 will 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 file 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 network. 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 first 15

fields are included on the project file log-in form and will 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 completed 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 text 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 

capitalization. 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 count 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 type. 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 additional 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 study 

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 information 

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 specific 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 accompanies an ICR.

 4 Docket staff also use the abstract to explain aspects of the document that might otherwise be confusing to the user 

(for example, 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, study, 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: agenda, 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 which 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 document 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 Transcript, 

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 afforded 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/state/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 Federal 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 strength, 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 is 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 the 
C-15

metadata for copyright protected 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 

standard 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/rfull/joc10108.html 

(accessed January 7, 2002).

• Internet Materials: <www.epa.gov/water/residuals/wtrdoc.html>. (Accessed 

May 17, 1998). 

*Author Name. Name 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, edition, 

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 provide 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 exists 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 project 

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 project 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 

Response 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 field 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 stored 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 the 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 Response 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 information 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 distinguish appendices or copies. 

These extensions are recorded in the DCN extension database field. The index 

keeper will use the following convention for assigning DCNs:

— DCN XXXXX;

— Attachments to the DCN will be DCN XXXXXA001, DCN 

XXXXXA002, etc.

• Input Date: This 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 two 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 project 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 responses 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 project 

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 Signoff 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 available 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 spelling, 

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 materials.

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 parts and assign each part to 

an Alaskan Seafood Petition Response technical team member for 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 control checks on the project file index, hardcopy 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 listed 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 monthly 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 technical 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 

document 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 Petition 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 documents 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 

and 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 was 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 protected 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 the 
C-20

words “For Internal Use Only” or “Confidential – 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 

uploaded 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 files 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 to 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 contacts 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 http://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 permission, 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 identifying 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) without 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 moving 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 edit 

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 Register notice and other supporting documentation. ERG will periodically 

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 metadata 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 provide 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 provide 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 consultation 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, ERG 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 necessary.” 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 Entry 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 information 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 that will not be uploaded to FDMS:

— CBI documents,

— Copyright protected publications,

— Databases and large spreadsheets, and 

— Other materials as directed by docket staff.

• Assign 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.

• Assign 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 keeper, who will obtain the correct PDF from the ERG WAM or project 

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 upload” 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 into 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 document record (metadata) for hard-copy material, as described above. 

The document record includes 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 PETITION RESPONSE DRAFT PROJECT FILE OUTLINE

September, 2013

1.0 NON-REMOTE ALASKAN SEAFOOD PROCESSORS PETITION AND 

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 Nonremote 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 list

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 and 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 NPDES 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 estimates
Attachment 1-2

5.0 ECONOMIC DATA, INTERPRETATION, AND ANALYSIS 

6.0 ENVIRONMENTAL IMPACTS

7.0 NOTICE OF DATA AVAILABILITY MATERIALS (Includes Federal Register Notice)

8.0 PUBLIC COMMENTS ON NODA

9.0 FINAL PETITION RESPONSE PACKAGE (Includes Response to Comments document, 

Federal Register Notice, Regulation text)
Attachment 2

Attachment 2

EXAMPLE ELECTRONIC PROJECT FILE LOG-IN FORM
Attachment 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 recorded 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 generated 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 parenthetical 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 are 

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 used 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 sentences. 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 parameters 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 and depends most often on the organization’s 

policy. Company names are especially arbitrary as many businesses desire a unique look and feel 
Attachment 3-2

to distinguish their name and letterhead from other firms. For example, Gulf + Western 

Industries, Inc. is the actual 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 many 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 data 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).....

Followed 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, USEPA/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 abbreviation 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 description 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 contains.... 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 

occurring 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 US
Attachment 3-3

Guidelines for Abbreviations

Laws and bylaws when first 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

Scientific 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 are 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 unless 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, radar, 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 recognizable 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 

designate 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 

capitalized.

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 capitalized.

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 expressed 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. Ordinal numbers should not be used. 

January 1, 2003

 not

the 1st 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 

unless 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 marks 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 make 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 quoted 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 following 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 normally 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 known 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: OAR2002-0012, 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 Phrases 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, 2003

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-publish

non-road
Attachment 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-Iraq 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]

glycerine [glycerin]