### 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 Name E.C. Phillips

Plant Address Ketchikan, Alaska

NPDES Permit # AKG520001

Date of Visit Friday, August 13, 2010 People Contacted Paul Cyr, General Manager

Seafood processed Chum, Coho, King , Sockeye, and Pink salmon Halibut, Rockfish, Shrimp, Cod Fish, Sablefish, Herring

Sea Cucumber and Geoduck

Products Fish is sold fresh and frozen, whole with head on, Headed & gutted, filleted, portioned, Salmon roe and

Ikura No canned products Range of annual production vol ume [Confidential Business Information (CBI), removed from this report] Months of operation Year round Discharge type Grind and discharge Company Website www.ecphillipsalaska.com

E.C. Phillips has operated in Ketchikan since 1926 (almost 90 years) 1 . The plant, built in 1950, operates year round. When salmon season ends in October, they begin processing dive fish (sea cucumbers and geoduck) and continue to process salmon that was frozen in the summer months into portions and fillets. Crabs are not processed at the plant.

The final products from this facility are pack aged into boxes and transported in shipping

containers all over the world. Fish are sold fresh and frozen, whole with head on, headed & gutted, filleted and portioned.

Waste Management. [CBI, removed from this report] fish heads were iced and sent to [CBI, removed from this report]. The remaining fish pr ocessing waste (guts and frames) is sent through the grinders and discharged shore side.

Paul Cyr has managed the E.C. Phillips plant for about a year. Mr. Cyr asked how environmental impact of at-sea disposal differed from disposal through their current outfall. Ms. Guzzo explained that the disposal area is much larger at sea. Mr. Cyr stated that the E.C. Phillips plant is now set up to grind their fish waste to a specific size before disposal and the small fragments are

1 For history of the plant and product descriptions see http://www.ecphillipsalaska.com/

### 2 washed away without generating a pile on the sea floor 2 . He asked why EPA is considering changing these guidelines if they currently are e nough to protect the environment. Ms. Guzzo explained the industry petition and EPA’s in formation collection to respond to it.

EPA §308 Request

Mr. Cyr stated that the financial portion of the questionnaire was quick and easy to complete but retrieving discharge reports for 2003 to 2005 h as taken longer. He asked why the questionnaire was not distributed during their slow season between October and March.

Mr. Cyr noted that they had not received a questi onnaire for the E. C. Phillips buying station in Craig. This facility receives fish in totes and ma y add ice. The facility is permitted to discharge but currently generates no sea food processing waste. They operate an ice machine 3

.

Facility Tour.

Production was low on the day of the tour. How the fisheries are managed im pacts when they get fish. At the time of the visit, the seine schedule was two days open, two days closed. This resulted in a similar production schedule. During the visit, workers were cleaning fish processing equipment, as shown in Figure 1 shows workers cleaning equipment.

The fish arrive packed in totes or are pumped out directly from the fish hold tanks of tenders. The fish are gutted and the roe sacs are sorted out. The guts are disposed of into slurry before entering two grinders and then pumped out shore side. Figure 2 shows fish waste on the floor as it is washed into the floor trains for sluicing to the grinders.

The heads are stored in green totes and i ced before they are sent to be processed.. Figure 3 shows totes at the E.C. Phillips street entrance, waiting for pick up. Figure 4 shows the truck arriving to pick up the totes.

Whole fish is processed in one line while a sep arate smaller line is entirely for pink salmon processing. The pink salmon line is about ha lf the size of the main processing line. Figure 5 shows workers glazing whole fish.

All of the ikura that leaves the plant is frozen pr oduct. Fillets are cut to standard size, resulting in trimmings (bits and pieces) of salable product. Th ese bits and pieces and tails are frozen and sold. Figure 6 shows workers preparing fillets for freezing.

Troll fish (fish caught by trolling) is generally cleaned at sea so on-shore processing generates very little waste. Processing sea cucumbers a nd geoduck generates no waste. Processing herring also generates no waste. Roe herring and bait herring are frozen and shipped whole.

2 See http://yosemite.epa.gov/opa/admpress.nsf/31f0470aec334c5c852572a000655938/167539a9dcb0280e85257 2040060b6f4!OpenDocument for a news release of E.C. Phillips 2006 settlement of NPDES permit violations: failed to treat seafood processing waste and instead discharged the untr eated waste directly into Tongass Narrows and onto the adjacent shoreline; failed to ensure that its effluent was one-half inch or less prior to discharge; and failed to develop and implement an adequate Best Management Practices Plan.

3 After the site visit, Paul Cyr and Don Anderson disc ussed the E.C. Phillips facility in Craig. Mr. Anderson told Cyr that EPA did not need a questionnaire for the Craig plant.

### 3 Figure 1 Equipment Cleaning

Figure 2 Waste sluicing

### 4 Figure 3 Totes waiting for pick up

Figure 4 Truck arriving for totes

### 5 Figure 5 Glazing whole fish

Figure 6 Preparing fillets for freezing