1 Site Visit Report Alaska Seafood Processing Industry Petition Response

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

206-553-0268 Betsy Bicknell Senior Environmental Engineer Eastern Research Group, Inc. (ERG)

betsy.bicknell@erg.com

703-633-1612

Plant N ame Kodiak Fishmeal Company

Plant Address Kodiak , Alaska

NPDES Permit # AKG528234

Date of Visit Wednesday , August 1 8 , 2010 People Contacted Gary Anthony, Plant Manager

Seafood processed Fin fish heads, viscera, trimmings, and other processing

waste. Some crab waste.

Products White fish meal, salmon fish meal, salmon oil, and bond

meal Range of annual production volume 900 MT maximum capacity; typically 100 to 350 MT/day. Months of operation Year round Discharge type Process wastewater

Website http://www.kodiakfishmealcompany.com

Information presented in this report was obtained from di scussions with Mr. Gary Anthony, Plant Manager and reflects his opinions. The Kodi ak Fishmeal Company website was also consulted for some production informatio n and photographs. Mr. Anthony provided a diagram of the process operations (atta ched to this report) after the

site visit.

Background. Kodiak Fishmeal Company (shown in Figures 1 and 2 ) is located on

Gibson Cover Road about 11⁄2 miles southwest of the 7-8 sea food processors for which it processes waste. Its location outside of the main harb or and town center has reduced complaints about odor from the plant compared to a prede cessor plant located closer to

town.

According to their website, “Kodiak Fishmeal Company open ed business with a new fish by-products processing facility in January of 1995. Its purpose is to produce top-grade fishmeals for use in the aquaculture and livestock feed mar kets as well as the agriculture business. The facility consists of 23,216 square feet and is capable of processing over 1,000 metric tons of fish per day.” (source : http://www.kodiakfishmealcompany.com/about.html )

Mr. Anthony noted that the maximum capacity is 900 MT/day. For 10 to 12 days during pollock season they run 800 to 900 MT/day. The 1,000 MT rating po sted on the website described the plant when it was new; it is not the curre nt operating maximum. They typically run 100 to 350 MT/day. Kodiak Fishmeal has 18 full t ime employees, including 3 office staff, 10 day shift operators, and 5 night shift opera tors.2

Kodiak Fishmeal operates all year round. They make fishm eal from January through October. They make some intermittent batches during in N ovember and December and use the down time for plant maintenance. Table 1 lists t he fish processed, by date.

Table 1: Kodiak Fishmeal Production

Dates Fish January 1 - January 20 cod January 20 - February 14 pollock February 15 - March 6 cod

March 15 - March 28 pollock

March 30 - June 1* Sole and flounder June 9 - July 4 * Salmon (sockeye) July 5 - July 31 Sole and flounder August 1 - August 20 Salmon (pink) August 20 - September 5 Pollock

October 1 - October 14 Pollock

November 1 - December 31* cod *Intermittent or limited production
Source: http://www.kodiakfishmealcompany.com/production.html

They process a mixed waste stream, taking whatever wastes the Kodiak seafood processors generate; however, because fish harvests diff er by season, the meal produced

can be sold as “White Fish Meal” or “Salmon Meal.” Wa ste processed includes a small amount of crab, including some Tanner Crab in the winter

.

The Kodiak Fishmeal Company is owned by five Kodiak seafood processing plants:

1. Trident Seafoods;

2. Alaska Fresh Seafoods;

3. Western Alaska Seafoods;

4. Ocean Beauty; and

5. North Pacific Seafoods.

[ Confidential Business Information (CBI) has been removed from this repor t. ]

In addition to the five co-owners, Kodiak Fishmeal take s waste from the two other seafood processors in Kodiak. [ CBI has been removed from this report. ]

Western Alaska Seafoods operates its own truck, which is totally enclosed. The other processors contract with a private trucking company to tra nsport wastes to the Kodiak Fishmeal, [ CBI has been removed from this report. ]

In January 2008, about 30 bald eagles became entangled in fi sh waste as it was being loaded into a truck destined for the fish meal plant. Sinc e that time, the processors have3

been extra diligent about covering the trucks and curtaining the truck loading stations at each plant. Eagles are more likely to go after the was te in the winter. In summer there are plenty of salmon in the streams and the eagles do not need to scavenge at the seafood processing plants.

The seafood processors typically manage their crab sh ell waste separately from the finfish waste. The fishmeal plant would prefer that the processors not segregate and grind

the crab shells. This is because the crab shells can “ bridge” in the storage silos, requiring extra labor to empty them.

The plant produces white fish meal, salmon meal, salmon oil, and some bone meal. [ CBI has been removed from this report. ] White fish oil is burned in the fishmeal plant boilers

.

There were at least two predecessors to the current me al plant: Biodry, which was privately owned, and Kodiak Reduction, a partnership. The B iodry plant was up on the

hill closer to Gibson Cove Road. It had to shut down when the wind blew toward town because the community objected to the odor. The new plan t is located below the road elevation, not visible from the road. It has generate d fewer odor complaints.

To control odor from the current plant, all exhaust is vented through a condenser and then Venturi scrubber that uses seawater as a scrubbing medium ( Figure 3). The scrubbed exhaust gasses are used as make-up air for the boiler. Th e seawater line into the scrubber is equipped with a strainer to remove kelp and other large ma terials. After use in the scrubber, the seawater is discharged via the permitted outf all. Mr. Anthony noted that processing salmon season waste generates the most smel l.

Plant operators collect product samples from each pallet and van load. The samples are analyzed for protein, ash, fat, and moisture content. Ba gs of excess sample are retained in the event that customers have questions.

Bone, which is high in ash (mainly calcium and phosphorus) and low in protein, is sifted out of the meal to obtain a product with relatively high er protein concentration. High ash (bone) fish meal is sold for use as fertilizer. [ CBI has been removed from this report. ]

If the fishmeal plant goes down because of mechanical f ailure or other upset, they are responsible for disposing of the waste from the Kodiak se afood processing plants. They

can store 360 MT of waste. Waste in excess of that amo unt must be disposed of off shore. Kodiak Fishmeal Company contracts with a bargeman who is “on call,” [ CBI has been removed from this report. ] Mr. Anthony reports they used the barge once in the las t four years. When the fishmeal plant can’t take the waste, the processing plants transfer it to

the dock at Western Alaska Seafoods where it is loaded i nto the barge.

Maintenance and Cleaning. To minimize possible downtime, the fishmeal plant maintains a large inventory of extra parts. It also has its own machine shop (lathes and milling machines) to repair and fabricate parts.4

The plant requires continual maintenance. Saltwater cor rodes mild steel so they are converting augers to stainless steel. The plant is 15 ye ars old and in that time the mild steel augers rusted through.

Most of the plant equipment was manufactured by Atlas S tord, but they have some Alfa Laval separators. The plant equipment is cleaned-in-plac e with caustic between runs. The oil centrifuge is the most difficult to clean piece of equipment. The Alfa Laval separator is easy to disassemble for cleaning.

Energy Use. The Kodiak Fishmeal Company plant burns a blend of 99% fish oil and 1% diesel oil. [ CBI has been removed from this report. ]The fish oil is produced from pollock. There is little oil in cod waste and salmon oil is sold. They have four 18,000 gallon tanks to store up to 70,000 gallons of fish oil and one diesel oil tank. The fish oil can gel-up in winter, so they must use diesel oil for 3-4 we eks in the winter when the temperatures are consistently below 20°. They also use d iesel oil during salmon season.

In July, Kodiak Fishmeal Company spent $24,600 for electricity and used 150,500 kWhr (16.3 cents per kWhr). Kodiak’s electricity is supplied by Ko diak Electricity Association, a rural electric cooperative. KEA generates electricity by a combination of hydroelectric, diesel, and wind turbines. The three 1.5 MW wind turbines ar e new and generated about 7% of Kodiak’s electricity in 2010.

Mr. Anthony estimated that per MT of raw product they use d 37kW of electricity and roughly 10 gallons of diesel or fish oil to fuel the steam boilers.

Recovery Processes. Trucks arriving at Kodiak Fishmeal dump their loads into a hoppe r at one end of the plant ( Figure 3 ). The driver logs the amount and species of fish waste

delivered. A bucket elevator lifts the fish waste to a sc rew conveyor which conveys it into two 180 MT insulated silos ( Figure 4 ). [ CBI has been removed from this report. ]

From the storage silos, the fish waste is transferred into the plant via conveyors. Figures

6 and 7 show the interior of the plant. The waste is cooked a t 95 to 100°C or above for 20 minutes. The cooking temperature is controlled by monitoring the liquid temperature

at the cooker exit. The cooked waste is dewatered with a st rainer followed by double screw presses. Steam is vented to the Venturi scrubber. The press cake is transferred to a

drier. Waste heat from the drier is used in the 4 th effect of the stickwater evaporators.

The liquids pressed from the cooked waste flow into a heat ed tank then to a decanter to remove additional solids. Next, the liquid is processed in three centrifuges to separate the oil and aqueous phases. A fourth centrifuge is used during salm on season for salmon oil polishing. Oil is pumped to a holding tank. Salmon oil is dispens ed into 55 gallon drums [ CBI has been removed from this report. ]. Mr. Anthony said he hopes to be able to change to SpaceKraft totes. Pollock oil is stored in four 18,000 gallon tanks outside of the building.5

[ CBI has been removed from this report. ]. The pollock oil was recently tested and found to have higher Btu (104%) than diesel oil.

The aqueous phase (stickwater) is about 6% solids but is evapo rated to a 30 to 35% solids concentration to mix with the press cake. Stickwater i s gummy, so they add enzymes to reduce evaporator gum-up. Hot stickwater from the centrifuges i s transferred to a holding tank, cooled to less than 60°C, and dosed with a protease enzyme . Although it is possible to run the plant continuously, they have to shut down for an hour every 3-4 days to degum the stickwater evaporators.

From the evaporator, the stickwater is transferred to a holding tank, cooled to 99°C, and then mixed with dry fish meal at a controlled rate 1 . If the stickwater is added too quickly the mixture will ball-up. From the mixing process the fish meal passes through a shaker hashing machine then to a drier. The drier operates at 160 to 165 psi. It is equipped with a steam jacket and steam is injected. Drying the meal requ ires about 2 hours through time.

From the drier, the meal is transferred to an Atlas me al cooler. If the meal is stored without cooling it can combust spontaneously. After the coo ler, the meal goes to a shaker equipped with screens to separate bone (ash). For salmon, the screens are 1⁄2” mesh. For other products, the screens have a smaller mesh to take o ut more ash. After final grinding in two hammermills (equipped with dust control) the meal is stored in six storage silos prior to packaging. Salmon meal is packed in 1400 lb totes. Whit e fish meal is packed in 25 kg bags. The meal is 9-13% moisture as it is removed from the drier and 6-8% moisture at the end of the process.

Kodiak Fishmeal recently switched to an automated bag fi lling process. In this process, filled bags are separated by a slip sheet of cardboard, st acked, and wrapped in plastic. This wrapped stack approach eliminates the use of wooden shipping pallets which cost $6 each. The wrapped stacks are transferred into a shipping van with a wide paddle fork lift. Production[ CBI has been removed from this report. ] is shipped by barge.

Process controls. The plant is controlled using PLC controls. With the ex ception of new memory boards for new equipment, the original control system from when the plant was

built in 1995 is still in use.

Changes since construction. Kodiak Fishmeal added additional storage, the hammermill, and an additional oil centrifuge. They are pl anning to replace the mild steel augers that have corroded with stainless steel augers.

1 [ CBI has been removed from this report. ] NPDES Permit AKG-52-8234 allows Kodiak Fishmeal to discharge stickwater as long as they minimize its gen eration and discharge. The permit requires Kodiak Fishmeal to monitor stickwater recycling and discharge, i ncluding the percentage of stickwater recycled per day on a monthly average, the total gallons of stickwat er recycled monthly, and the total gallons of stickwater discharged monthly. Kodiak Fishmeal samples the outfall once a week and monitors for BOD 5 , O&G, TSS, SS, and temperature. They monitor color and pH monthly. [ CBI has been removed from this report. ]6

Figure 1 Kodiak Fishmeal Company ( sourc:e http://www.kodiakfishmealcompany.com )

Figure 2 Kodiak Fishmeal Company ( sourc:e http://www.kodiakfishmealcompany.com )7

Figure 3. Kodiak Fish Meal Air Pollution Control Scrubber8

Figure 4. Kodiak Fish Meal Waste Receipt

Figure 5. Kodiak Fish Meal Fish Oil Storage Tanks9

Figure 6. Kodiak Fish Meal Interior (source: http://www.kodiakfishmealcompany.com/product.html)

Figure 7. Kodiak Fish Meal Interior (source: http://www.kodiakfishmealcompany.com/product.html)10