1

Kodiak Seafood Processors General Permit Proposed NPDES Permit AK-G52-8000

FACT SHEET

United States Environmental Protection Agency, Region 10

1200 Sixth Avenue, OW--134

Seattle, Washington 98101

(206) 553-1214

Proposed reissuance of a general National Pollutant Discharge Elimination System

(NPDES) permit to discharge pollutants pursuant to the provisions of the Clean Water

Act, 33 U.S.C. § 1251 et seq. for

SEAFOOD PROCESSORS OPERATING SHOREBASED FACILITIES IN

 KODIAK, ALASKA.

This fact sheet includes (a) the tentative determination of the Environmental Protection

Agency (EPA) to issue a general NPDES permit, (b) information on public comment,

public hearings and appeal, (c) the description of the potential permittees and their

discharges, and (d) other conditions and requirements.

Persons wishing to comment on the tentative requirements contained in the proposed

general permit may do so before the expiration date of the public notice. All written

comments should be submitted to EPA as described in the public comments section of

the attached public notice. Comments directed at specific permit requirements and

supported by a basis are appreciated.

After the expiration date of the public notice, the Director, Office of Water, EPA

Region 10, will make a final determination with respect to reissuance of the general

permit. The tentative requirements contained in the draft general permit will become final

conditions if no substantive comments are received during the public comment period.

The permit is targeted to become effective in March 1998.

Within 120 days following the Federal Register issuance notice of EPA's final permit

decision under 40 CFR § 124.15, any interested person may appeal the permit in the

Federal Court of Appeal in accordance with Section 509(b)(1) of the Clean Water Act.

Persons affected by a general permit may not challenge the conditions of the permit as

a right of furtherEPA proceedings. Instead, they may either challenge the permit in court

or apply for an individual NPDES permit and then request a formal hearing on the

issuance and denial of an individual permit.
2

Kodiak Seafood Processors General Permit Proposed NPDES Permit AK-G52-8000

The draft general NPDES permit and Fact Sheet, and other referenced documents may

be inspected at the address on page 1 any time between 8:30 a.m. and 4:00 P.M.,

Monday through Friday. Copies and other information may be requested by writing to

EPA at the same address to the attention of Jeanette Carriveau or by calling (206)

553-1214.

The draft general NPDES permit and Fact Sheet is also available for inspection at the

following places in Alaska:

USEPA Alaska Operations Office USEPA Alaska Operations Office

Federal Building, Room 537 410 Willoughby Avenue, Suite 100

222 West 7th Avenue Juneau, Alaska 99801

Anchorage, Alaska 99513-7588 Telephone: (907) 586-7619

Telephone: (907) 271-5083

Alaska Dept. Of Environmental Conservation ADEC Environmental Health 

Wastewater Program 316 Mission Road

555 Cordova Street Griffin Building

Anchorage, Alaska 99501 Kodiak, Alaska 99615

Telephone: (907) 269-7500 Telephone: (907) 486-3350
Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page i

TABLE OF CONTENTS

page

1.0 THE BASIS FOR ISSUANCE OF A GENERAL NPDES PERMIT ......... 1

2.0 A GENERAL PERMIT FOR THE SEAFOOD PROCESSORS OPERATING 

SHOREBASED FACILITIES IN KODIAK, ALASKA ..................... 1

 2.1 Applying for Coverage under this Permit ............................. 2

 2.2 Requirements of an Individual Permit ............................... 2

2.2.1 How an individual permit will differ from the general permit .......... 2

2.2.2 When a general permittee would be required to apply for an individual

 permit .................................................... 2

2.2.3 How to apply for authorization to discharge under an individual permit . 3

3.0 FACILITIES COVERED BY THE KODIAK GENERAL PERMIT ........... 3

 3.1 Existing Facilities ............................................... 3

 3.2 Facilities Not Covered by the Permit ................................ 4

4.0 PROPOSED DISCHARGES ....................................... 4

 4.1 Composition ................................................... 4

4.1.1 Seafood processing wastes .................................. 4

4.1.2 Processing disinfectants ..................................... 4

 4.2 Treatment and Discharge ......................................... 4

 4.3 Other Wastewaters .............................................. 5

 4.4 Storm Water ................................................... 5

 4.5 Discharges Not Authorized by the Permit ............................ 5

5.0 RECEIVING WATERS ............................................ 5

 5.1 Near Island Channel and St. Paul Harbor ............................ 5

 5.2 Water Quality .................................................. 6

6.0 EFFLUENT LIMITATIONS ........................................ 6

 6.1 General Approach ............................................... 6

 6.2 Technology-based Evaluation ..................................... 7

6.2.1 Statutory basis for technology-based limitations .................. 7

6.2.2 Technology-based effluent limitations .......................... 7

6.2.3 Surimi processing limitations ................................. 8

6.2.4 Fish powder processing limitations ............................ 8

6.2.5 Mechanical v conventional processing ......................... 8

 6.3 Water Quality-based Evaluation .................................... 9

6.3.1 Statutory basis for water quality-based limitations ................ 9
Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page ii

6.3.2 Applicable water quality standards ............................ 9

 6.4 Summary of Effluent Limitations ................................... 10

 6.5 Seafood Processing Solid Waste Limitations ........................ 10

7.0 MONITORING REQUIREMENTS ................................... 11

 7.1 Discharge Monitoring ........................................... 11

 7.2 Seafloor Monitoring ............................................. 11

 7.3 Sea Surface and Shoreline Visual Monitoring ....................... 12

8.0 SPECIAL CONDITIONS REQUIRED BY THE PERMIT .................. 12

 8.1 Basis for Quality Assurance Requirements .......................... 12

 8.2 Basis for Best Management Practices Plan .......................... 13

9.0 OTHER LEGAL REQUIREMENTS .................................. 13

 9.1 Coastal Zone Management Act ................................... 13

 9.2 Pollution Prevention Act ......................................... 14

 9.3 Endangered Species Act ........................................ 14

9.3.1 National Marine Fisheries Service ........................... 14

9.3.2 U.S. Fish & Wildlife Service ................................ 14

9.3.3 EPA determination ........................................ 15

 9.4 Marine Protection, Research and Sanctuaries Act .................... 16

 9.5 Oil Spill Requirements .......................................... 16

 9.6 State Water Quality Standards and Certification ...................... 16

 9.7 Presidential Oversight of Federal Regulations ........................ 17

 9.8 Paperwork Reduction Act ........................................ 17

10.0 REFERENCES ................................................. 17

11.0 ATTACHMENTS ................................................ 18

 11.1 Calculating Multi-processing Limits for TSS .......................... 19

 11.2 Calculating Multi-processing Limits for O&G ......................... 20

 11.3 Maps showing Locations of Kodiak Facilities ........................ 21
Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 1

1.0 THE BASIS FOR ISSUANCE OF A GENERAL NPDES PERMIT

Section 301(a) of the Clean Water Act (CWA, or the Act) provides that the

discharge of pollutants to surface waters of the United States is unlawful except in

accordance with a National Pollutant Discharge Elimination System (NPDES) permit. 

EPA's regulations authorize the issuance of general NPDES permits to categories of

discharges when a number of point sources discharges:

! involve the same or substantially similar types of operations;

! discharge the same types of wastes;

! are located within a geographic area;

! require the same effluent limitations;

! require the same operating conditions;

! require the same or similar monitoring requirements; and 

! in the opinion of EPA, are more appropriately controlled under a general

permit than under individual permits [40 CFR § 122.28].

2.0 A GENERAL PERMIT FOR THE SEAFOOD PROCESSORS OPERATING 

SHOREBASED FACILITIES IN KODIAK, ALASKA 

Since 1986 all the seafood processing facilities in Kodiak have been required to

treat seafood processing wastes by screening the effluent, to recover the waste solids,

and to send the waste solids to a by-product reduction facility. EPA has determined

that issuing a general NPDES permit for seafood processors in Kodiak meets the

requirements and intent of 40 CFR § 122.28. Under the permit, the owners and

operators of the shorebased seafood processing facilities engaged in the processing

seafood in Kodiak, Alaska, are authorized to discharge seafood processing wastewaters

to St. Paul Harbor and Near Island Channel, in accordance with effluent limitations,

monitoring requirements and other conditions set forth in the permit.

As provided in 40 CFR §§ 124.8 and 124.56, this fact sheet briefly describes the

facilities, discharges, and receiving waters covered by the permit. It also sets forth the

principal facts and the significant factual, legal, methodological, and policy questions

considered in preparing the permit and its requirements.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000
Fact Sheet Page 2

Coverage under this permit will expire five years from the date of issuance. An

expired general permit continues in force and effect until a new general permit is

reissued [40 CFR § 122.28(b)]. Any discharger wishing authorization to discharge under

an expired general NPDES permit, however, must receive authorization to discharge

prior to the date of expiration.

As with individual NPDES permits, a violation of a condition contained in a

general NPDES permit constitutes a violation of the Act and subjects the permittee to

the penalties specified in CWA § 309.

Issuing a general permit for several qualified facilities efficiently utilizes scarce

agency resources and ensures that permit limitations and conditions continue to protect

state water quality standards.

.

2.1 Applying for Coverage under this Permit

In order to be authorized to discharge any of the pollutants allowed under this

general permit, any seafood processing facility discharging to St. Paul Harbor and Near

Island Channel must apply for coverage under this permit. As a Notice of Intent to be

Covered under this general permit, any new applicants (other than those identified at

3.1) wishing authorization to discharge under this Permit shall submit EPA Form 3510-1

General Information; EPA Form 3510.2C NPDES; and a copy of the completed State of

Alaska Coastal Project Questionnaire and Certification Statement.

2.2 Requirements of an Individual Permit

2.2.1 How an individual permit will differ from the general permit

An individual permit would require technology-based permit limitations with

treatment accomplished through the use of fine mesh screening (1 mm) or equivalent

technology and disposal of all solid processing wastes to a by-product recovery facility. 

These are the same requirements determined by EPA to be appropriate for the general

NPDES permit for shorebased seafood processing facilities in Kodiak.

2.2.2 When a general permittee would be required to apply for an individual permit

[40 CFR § 122.28(b)(3)]

EPA may require any discharger covered by a general permit to apply for and

obtain an individual permit. In addition, any interested person may petition EPA to take

this action. EPA may consider the issuance of individual permits when:

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000
Fact Sheet Page 3

! the single discharge or the cumulative number of discharges is/are a

significant contributor of pollution;

! the discharger is not in compliance with the terms and conditions of the

general permit;

! a change has occurred in the availability of demonstrated technology or

practices for the control or abatement of pollutants applicable to the point

source; or

! a Water Quality Management Plan containing requirements applicable to such

point sources is approved.

2.2.3 How to apply for authorization to discharge under an individual permit

[40 CFR § 122.28(b)(3)(iii)]

Owners or operators covered by a general permit may be excepted from such

coverage by applying to EPA for an individual permit. This request may be made by

submitting an individual NPDES permit application (Forms 1 and 2C) to EPA. This

request shall be submitted no later than 90 days after publication by EPA of the final

general permit in the Federal Register, or 180 days prior to the commencement of

operation of a new source or new discharger.

3.0 FACILITIES COVERED BY THE GENERAL PERMIT

3.1 Existing Facilities 

The following facilities currently operating in Kodiak under individual permits are

allowed to discharge under this general permit, having submitted the Notice of Intent to

be Covered described at 2.1:

 Individual Permit # General Permit #

Alaska Fresh Seafoods AK-000110-4 AK-G52-8110

Alaska Pacific Seafoods AK-000043-4 AK-G52-8434

Cook Inlet Processing -- Gibson Cove AK-004864-0 AK-G52-8486

East Point Seafoods AK-000042-6 AK-G52-8426

International Seafoods -- #1 Shelikof St. AK-000035-3 AK-G52-8353

International Seafoods -- #2 Marine Dr. AK-002666-2 AK-G52-8266

Ocean Beauty (King Crab) AK-000049-3 AK-G52-8493
Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 4

Tyson Enterprise Seafoods (Alcod) AK-000036-1 AK-G52-8361

Tyson Enterprise Seafoods-Star/Kodiak AK-000083-3 AK-G52-8833

Western Alaska Seafoods AK-000082-5 AK-G52-8825

3.2 Facilities Not Covered by the Permit

Facilities which have not submitted applications as required in 2.1 above and

have not received EPA approval in writing are not authorized to discharge under this

permit. 

4.0 PROPOSED DISCHARGES

4.1 Composition 

4.1.1 Seafood processing wastes

The Kodiak shorebased facilities discharge a pollutant wasteload consisting of

biochemical oxygen demand 5-day (BOD5 ), total suspended solids (TSS; including

floating, suspended, and settleable residues), seafood oils and grease (O&G), pH,

temperature, and residual disinfectants. One facility also has a small domestic and

sanitary discharge.

The seafood wastewater discharge consists of butchering waste streams, surimi

processing waste streams, and a fish powder waste stream which must all be screened

before discharge. 

A review of completed discharge monitoring reports revealed that in 1996, four

facilities operated between 192 and 287 days.

4.1.2 Processing disinfectants

Process water, obtained from the City of Kodiak, is chlorinated prior to use as

needed. As a result of periodic use, free chlorine may be present in residual amounts.

However, total residual chlorine was monitored during the first year of the previous

permit and there was no detection of total chlorine residual in the discharge.

4.2 Treatment and Discharge

The facilities currently collect and route seafood processing wastes and

wastewaters to a treatment system consisting of 1 mm screens (or equivalent

technology) with the discharge of wastewater to St. Paul Harbor or Near Island Channel;

the solid seafood wastes are conveyed to a waste holding area, collected and

transported by truck
Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 5

to the by-product recovery facility (Kodiak Fish Meal Company in Gibson Cove), or in the

case of International Seafoods, processed in their fish powder facility.

All but one of the facilities listed in 3.1 above discharge domestic and sanitary

wastewater to the City of Kodiak’s sewage treatment facility where it receives secondary

treatment prior to discharge. Cook Inlet Processing treats its domestic and sanitary

wastes in a secondary treatment package plant and discharges the treated wastewater

through the main outfall with the seafood processing wastewaters.

4.3 Other Wastewaters

Other wastewaters, including noncontact cooling water, boiler water, freshwater

pressure relief water, refrigeration condensate, water used to transfer seafood to the

facility, and live tank water, are authorized for discharge under the permit. The

wastewaters listed in this paragraph with the exception of transfer water, do not occur in

significant amounts and are unlikely to impact water quality. The transfer water may

create foam and scum on the surface of the receiving water. If the foam and scum are

persistent, there is potential to cause some impact on water quality. Permittees are

required to conduct daily sea surface and shoreline visual monitoring on days of

operation and report the occurrence of persistent foam and scum.

4.4 Storm Water

According to information received from EPA Headquarters, seafood processing

activities do not fall within the definition of industrial activity that requires a storm water

permit, provided that the processing activities are not exposed to storm water. Storm

water will be addressed in the Best Management Practices Plan.

4.5 Discharges Not Authorized by the Permit

The permit does not authorize any pollutants which are not expressly authorized

in the Permit. This includes, but is not limited to, petroleum hydrocarbons and toxic

pollutants listed in 40 CFR § 401.15.

5.0 Receiving Waters

5.1 Near Island Channel and St. Paul Harbor

Nine of ten existing facilities are along the harbor front on the Near Island

Channel and St. Paul Harbor. The other facility extends its outfall through the mouth of

Gibson Cove into St. Paul Harbor.
Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 6

Both receiving waters are classified by the Alaska State Water Quality Standards

as Classes (2)(A)(I)(ii)(iii), (B)(I)(ii), (C), and (D) for use in aquaculture, seafood

processing and industrial water supply, contact and secondary water recreation, growth

and propagation of fish, shellfish, other aquatic life and wildlife, and harvesting for the

consumption of raw mollusks or other raw aquatic life.

5.2. Water Quality

The state water quality parameters which could be affected by the discharge are

dissolved oxygen, pH, turbidity, oil and grease, residual chlorine, total suspended solids,

and settleable solids.

Settleable solid residues on the seafloor have been eliminated by the screening

requirement and disposal of waste solids to the by-product recovery facility. While there

may be some temporary turbidity during heavy processing periods, the tidal currents

carry the pollutants out of the immediate receiving water areas. Dive surveys over the

past five years show that there are no accumulations of seafood wastes at the end of

any of the 

outfalls. Visual observation of the surface of the receiving water and shorelines during

processing days is a continuing requirement and the number of observations is reported

on the monthly discharge monitoring report.

6.0 EFFLUENT LIMITATIONS

6.1 General Approach

The Clean Water Act declares that “the discharge of any pollutant by any person

shall be unlawful” except as in compliance with the Act [CWA Section 301].

Sections 101, 301, 302, 304, 308, 401, and 402 of the Act provide the basis for

the effluent limitations and other conditions in an NPDES permit. EPA evaluates

discharges with respect to these sections of the Act and relevant NPDES regulations

[40 CFR

§§ 121-125] in determine which limitations apply to the discharges. The permit

limitations will reflect whichever limitations (technology-based or water quality-based)

are more stringent.

EPA must also include monitoring requirements in the permit to monitor

compliance with effluent limitations [CWA Section 402(a)(2)]. In the event that any

condition of a permit for discharges to surface waters of the United States has been

violated, EPA or citizens may undertake an enforcement action against the facility [CWA

Section 402(h)]. 
The evaluation of technology-based and water quality-based limitations is

described in more detail below.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 7

6.2 Technology-based Evaluation

6.2.1 Statutory basis for technology-based limitations

The Act requires that all NPDES permitted discharges achieve technology-based

effluent limitations established under Section 301, 306, or 402(a)(1), and comply with

the state water quality standards established under Section 303 of the CWA. The

NPDES regulations, 40 CFR 122.44(d), specifically require an NPDES permit to include

effluent limitations for those pollutants that have a reasonable potential to cause or

contribute to an in-stream excursion above the allowable ambient concentration of a

state water quality standard. 

Particular categories of industrial dischargers are required to meet effluent

limitations established by EPA. Technology-based limitations are based on effluent

guidelines developed by EPA for specific industries.

6.2.2 Technology-based effluent limitations

Technology-based requirements for Canned and Preserved Seafood Processing 

have been promulgated in 40 CFR § 408 and supported by a number of technical

development documents [USEPA 1975, Jordan 1979]. These limitations are applicable

to conventional/hand-butchering or mechanical processing of seafood.

Existing point sources located in processing centers including Kodiak (nonremote) shall meet the technology-based effluent limitations representing the degree of

effluent reduction attainable by the application of the best conventional pollutant control

technology (BCT). The use of fine mesh screening (1 mm), or equivalent technology,

continues to be the application of the best practicable control technology currently

available to achieve the effluent limitations as referenced in the following: Alaskan Hand

Butchered Salmon Processing [40 CFR § 408.167], Non-Alaskan Mechanized Bottom

Fish Processing [40 CFR § 408.227], Alaskan Bottom Fish Processing [40 CFR §

408.207], Non-Remote Alaskan Whole Crab and Crab Sections Processing [40 CFR §

408.67], and Non-Remote Alaskan Shrimp Processing [40 CFR § 408.97].

The applicable limitations for BCT are the same as those specified for

conventional pollutants found in the following: Alaskan Hand-Butchered Salmon

Processing [40 CFR § 408.162], Non-Alaskan Mechanized Bottom Fish Processing [40

CFR § 408.222], Alaskan Bottom Fish Processing [40 CFR § 408.202], Non-Remote

Alaskan Whole Crab and Crab Sections Processing [40 CFR § 408.62], Alaskan Shrimp

Processing [40 CFR § 408.92].
Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 8

The limitations in 40 CFR § 408.207 for Alaskan Bottom Fish was based on

halibut being the dominant bottom fish species. With the introduction of a multitude of

other bottom fish being processed, such as cod, pollock, flounder (arrowtooth),

rockfish/red snapper, black cod/sable fish, flatfish/sole, and other whitefish species, the

limitations based on halibut did not adequately reflect the current processing. The

bottom fish species are usually brought to the plant whole, where processing the fish

involves more extensive butchering and mechanization; therefore, it has been

determined that Non-Alaskan Mechanized Bottom Fish Processing Effluent Guidelines

[40 CFR § 408.222] more accurately reflect current processing operations for bottom

fish.

6.2.3 Surimi processing limitations

There are no effluent guidelines for surimi processing. Based on technology

used to recover solids, a size limit on solids of 1 mm is included based on Best

Professional Judgement. Monitoring of flow, BOD5

 , TSS, and O&G will required by the

permit.

6.2.4 Fish powder limitations

The operation of a fish powder processing plant is being done by one facility and

is significantly different than the fish meal production done in other facilities where the

effluent guidelines [40 CFR § 408.155] have been applied. EPA does not have the data

to support a determination of appropriate technology-based limits for fish powder

processing at this time. This facility will monitor BOD5, TSS, O&G, pH, temperature,

flow, and settleable solids during the period of the permit to establish a basis for

limitations in any subsequent permit.

6.2.5 Mechanical v conventional processing

In the previous individual permits, when more then one species was processed

on a sampling day, the effluent limitation for that day was based on the proportion of

each species processed. This proposed permit is emphasizing the way seafood is

processed rather than what is processed; i.e., mechanized or conventional.

Mechanical processing may be characterized as skinning, scaling, gutting,

removing heads and fins, mincing, filleting, and deboning by an automated or machine

method. Conventional processing may be characterized as heading, gutting, removing 

fins, deboning, skinning, and filleting by hand. 
As a benchmark in selecting which limitations to apply to the processing waste

stream, the permittees will determine how much of the weight of the solid wastes

generated is from the use of more than one automated and/or mechanized method.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 9

If more than 50% of the weight of the solid wastes is from automated and/or

mechanized methods, then the mechanized limitations can be applied (e.g., just heading

halibut is not considered mechanized even if done by a chopping machine).

Once the designation of mechanized or conventional processing is determined,

the loading values for TSS and O&G are expressed in terms of pounds of pollutant per

1000 pounds of raw product processed and reported for a designated parameter on the

monthly 

Discharge Monitoring Report (DMR). If both mechanized and conventional processing

occurs during the month, than calculations to determine the variable limitations will need

to be done and reported for the designated parameter for multi-processing. Sample

calculations are included in 11.1 and 11.2 of this Fact Sheet.

6.3 Water Quality-based Evaluation

6.3.1 Statutory basis for water quality-based limitations

Sections 302 and 307 of the Act require the establishment of limitations in permits

necessary to meet water quality standards. The NPDES regulations at 40 CFR

§ 122.44(d)(1) require that permits include limits on all pollutants or parameters which

“are or may be discharged at a level which will cause, have the reasonable potential to

cause, or contribute to an excursion above any state water quality standard, including

state narrative criteria for water quality” [54 Fed.Reg. 23868-23899, June 2, 1989].

All discharges to state waters must comply with state and local coastal

management plans as well as with state water quality standards, including the state’s

antidegradation policy. Discharges to state waters must also comply with conditions

imposed by the State as part of its coastal management program consistency

determination and of its certification of NPDES permits under Section 401 of the Act. 

The stipulated requirements of the State’s Section 401 certification of the 

permit must be necessary to assure compliance with both the Act and appropriate

requirements of state law and must be more stringent than the conditions of the permit

[40 CFR § 124.53(e)].

6.3.2 Applicable water quality standards
One of the water quality concerns is seafood processing residue. The Alaska

Water Quality Standards state that residues, including floating solids, debris, sludge,

deposits, foam scum, or other residues, “may not, alone or in combination with other

substances or wastes, make the water unfit or unsafe for the use, or cause chronic

problem levels . . . (or) . . . cause a film, sheen, or discoloration on the surface of the

water or adjoining shorelines; cause leaching of toxic or deleterious substances; or

cause a sludge, solid, or emulsion to be deposited beneath or upon the surface of the

water, 

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 10

within the water column, on the bottom, or upon adjoining shorelines” [Alaska

Administrative Code (ACC) § 18.70.020].

Additional water quality concerns include seafood oil and grease, pH, and total

chlorine residual. The State water quality standards for oil and grease is that the effluent

discharge “may not cause a film, sheen, or discoloration on the surface or floor of the 

water body or adjoining shorelines . . . surface waters must be virtually free from floating

oils.” The permit requires no discharge of floating solids, visible foam, or oily wastes

which produce a sheen on the surface of the receiving water, no accumulation of

seafood processing wastes on the shoreline, and no accumulation of wastes on the

seafloor of the receiving water. In addition the sea surface and shoreline monitoring and

reporting requires daily observation for occurrences of sheens, floating solids, foam, oily

wastes, and scum on the water surface and shoreline. Also a survey of the sea floor is

required. 

 The standard for pH is that the effluent discharge may not be less than 6.5 or

greater than 8.5 standard units.

 The standard for total residual chlorine is that the effluent discharge “may not

exceed 2.0 μg/L for salmonoid fish, or 10.0 μg/L for other organisms” [ACC §

18.70.020].

In the previous permit, the sampling for chlorine residuals revealed that there was no

detectable amounts found in the discharges; for that reason there are no total residual

chlorine limitations in the permit.

6.4 Summary of Effluent Limitations

EPA has determined that the applicable technology-based effluent limits as set

forth in 40 CFR § 408 and the use of fine mesh screening ( 1 mm) or equivalent

technology as the application of best conventional pollutant control technology is

protective of water quality.
EPA has determined that the water quality limits for pH and residues, in

conjunction with the screening of all seafood processing wastes, is protective of the

receiving water and marine environment and meet Alaska Water Quality Standards.

6.5 Seafood Processing Solid Waste Limitations

All solid seafood processing wastes will be disposed of at a by-product reduction

facility. Seafood wastes shall not be pulverized, ground, chopped, or otherwise altered

prior to screening. No grinding of seafood wastes prior to screening is a best

management practice which carries out the intent of the Clean Water Act to reduce the

amount of pollutants entering the receiving waters.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 11

7.0 MONITORING REQUIREMENTS

7.1 Discharge Monitoring

Monitoring is required pursuant to 40 CFR § 122.44(I) and is necessary for

determining compliance with permit effluent limitations and to evaluate potential water

quality impacts resulting from the discharge. Monitoring frequencies are based on the 

Agency's determination of the minimum sampling required to adequately monitor the

performance of the facility. Weekly sampling and monitoring is required in this proposed

permit. Monitoring results are to be summarized and reported on monthly Discharge

Monitoring Reports which are to be postmarked by the 10th of the month.

Sampling is to be representative of the waste stream flow. When processing is

for short periods or intermittent periods, samples are to be taken midway during the

processing period, provided the processing is more than 6 hours

Depending on the processing of individual facilities, the surimi and fish powder

waste streams are sampled prior to screening and commingling with the final effluent

discharge waste stream. The concentrations of TSS and O&G in the surimi and fish

powder waste streams can be subtracted from the final effluent waste stream

concentrations of TSS and O&G. The purpose of this allowance is to appropriately

apply the mechanized or conventional limitations to the final effluent waste stream minus

the surimi or fish powder waste streams. 

As provided in the previous permit, this proposed permit will allow for oil and

grease analysis to be done by the Collins-Tenny test procedure. The oil and grease

methods using trichlorotrifluoroethene (Freon-113) are to be replaced by Method 1664

which is a chlorofluorocarbon-free alternative to determine oil and grease by extraction

and gravimetry. 
7.2 Seafloor Monitoring

Dive surveys are considered the only accurate means of assessing the efficacy

of the screening technology and the impacts of the discharge on marine biota and

sediments. Annual dive surveys over the past five years have shown that there has

been no accumulations of seafood wastes and that there is a level of marine biota along

the outfalls and at the terminuses.

The proposed permit requires one dive survey, documented on video to be

conducted by September 30, 2000, and submitted to EPA by December 31, 2000.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 12

7.3 Sea Surface and Shoreline Visual Monitoring

Based on concerns about possible impacts of the effluents on aesthetic

conditions of the sea surface and shoreline, daily surveys during operating periods are

required to ensure that the permittee is aware of any problems which could develop from

the discharge in a timely fashion.

Instances of floating solids, visible foam, or oily wastes only need to be reported 

when it is a persistent occurrence. When floating solids, visible foam, or oily wastes are

seen on the sea surface, monitoring should be done frequently (every hour or two) to

document the occurrence and determine the length of time the occurrence persists. If

the floating solids, visible foam, or oily wastes persist longer than one tidal cycle, then

the occurrence needs to be reported in accordance with the 24-hour noncompliance

condition of the Permit. Logs of the daily visual monitoring shall be kept to aid in

documenting the number of days of visual monitoring during the month on the DMR.

Accumulations on the shoreline should be removed if possible and also reported

in accordance with the 24-hour noncompliance condition of the Permit.

8.0 SPECIAL CONDITIONS REQUIRED BY THE PERMIT

8.1 Basis for Quality Assurance Requirements

The permittee is required to properly operate and maintain all facilities which are

used by the permittee to achieve compliance with the conditions of the permit [40 CFR

§ 122.41(e)]. The permittee is also required to ensure adequate laboratory controls and

appropriate quality assurance procedures whether in their own on-site laboratory or with

the use of a commercial laboratory.

The proposed permit requires the permittee to ensure that the collection and

analysis of effluent and water quality data is in accordance with EPA-approved quality 
assurance and quality control (QA/QC) procedures. Noncompliance with the quality

assurance requirements of the permit constitutes noncompliance with the Permit.

The proposed permit requires that the QA/QC Plan be developed and

implemented within 6 months from the date of issuance of this Permit. Certification that

the QA/QC plan has been developed and implemented is due to EPA and ADEC not

later than 6 months from the date of issuance of the permit.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 13

7.2 Basis for Best Management Practices Plan

Best Management Practices (BMPs) in addition to numerical effluent limitations

are required to control or abate the discharge of pollutants in accordance with 40 CFR

§ 122.44(k). The permit requires the development and implementation of a Best

Management Practices Plan which prevents or minimizes the generation of pollutants, 

their release, and potential release from the facility to the waters of the United States 

through normal operations and ancillary activities, including material storage areas,

storm water, loading or unloading operations, or spillage or leaks. The BMP Plan should 

incorporate elements of pollution prevention as set forth in the Pollution Prevention Act

of 1990 [42 U.S.C. § 13101].

The BMP Plan must be amended whenever there is a change in the facility or in

the operation of the facility which materially increases the potential for an increased

discharge of pollutants. The BMP Plan will become an enforceable condition of the

permit; a violation of the BMP Plan will constitute a violation of the permit. Guidance

documents are available to support the development of BMP Plans (USEPA 1993,

PPRC 1993, Ismond 1994a and 1994b, Nicklason and Hill 1995).

The proposed permit requires that the BMP Plan be developed and implemented

within six months from the date of issuance of the Permit. Certification that the BMP

plan has been developed and implemented is due to EPA and ADEC not later than 6

months from the date of issuance of the permit.

9.0 OTHER LEGAL REQUIREMENTS

9.1 Coastal Zone Management Act

The Coastal Zone Management Act and its implementing regulations [15 CFR

§ 930] prohibit EPA from issuing a permit for an activity affecting land or water use in the
coastal zone until the applicant certifies that the proposed activity complies with the

State Coastal Zone Management program, and the State or its designated agency

concurs with the certification [40 CFR § 122.49(d)]. The applicants identified in Section

2.1 have 

certified in the Coastal Project Questionnaire and Certification Statement that the

activities authorized by this draft permit are consistent with local and State Coastal

Management Plans. The draft permit and request for consistency determination will be

submitted to the State of Alaska for State interagency review at the time of public notice. 

The requirements for State Coastal Management Review and approval must be

satisfied before the permit may be issued. However, EPA has determined and hereby

certifies that the General NPDES Permit for Seafood Processors Operating Shorebased

Facilities in Kodiak, Alaska, does comply with the State Coastal Zone Management

Program.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 14

9.2 Pollution Prevention Act

It is the national policy that, whenever feasible, pollution should be prevented or

reduced at the source, that pollution which cannot be prevented should be recycled in an

environmentally safe manner, and that disposal or release into the environment should

be 

employed only as a last resort and should be conducted in an environmentally safe

manner.

9.3 Endangered Species Act

The Endangered Species Act (ESA) and its implementing regulations [50 CFR

Part 402] require EPA to ensure, in consultation with the Secretary of the Interior or 

Commerce, that any action authorized by EPA is not likely to jeopardize the continued

existence of any endangered or threatened species or adversely affect critical habitats

[40 CFR § 122.49(c)].

The consulting services will also be able to provide comments on the draft permit

and EPA will consider their comments in the final permit decision. EPA will initiate

consultation should new information reveal effects not previously considered, should the 

activities be modified in a manner beyond the scope of the original opinion, or should the

activities affect a newly listed species.

A list of endangered and threatened species and species of concern was

requested by EPA from the National Marine Fisheries Service and U.S. Fish & Wildlife

Service for the Kodiak area.

9.3.1 National Marine Fisheries Service (NMFS)
According to NMFS, several species of endangered whales occur seasonally in

waters off the Kodiak Island group but are uncommon in St. Paul Harbor. The Steller

sea lion, recently listed as endangered, are commonly found in St. Paul Harbor near the

processing facilities. However, there are no designated haulouts or rookeries in the

vicinity of the receiving waters.

9.3.2 U.S. Fish & Wildlife Service (USFW)

According to USFW, four species are listed, delisted and proposed in the Kodiak

Island area. The American peregrine falcon is endangered; the Arctic peregrine falcon

has been delisted; the Short-tailed albatross is endangered; and the Steller’s eider

(Alaska breeding population) is threatened.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 15

The American peregrine falcons nest throughout the forested interior of Alaska,

mainly on cliffs along rivers and near lakes. Those that nest in Alaska winter from the

southern U.S. south to Argentina. During spring and fall migrations, they may be present

anywhere in Alaska. There is no designated critical habitat for this species in Alaska.

The Arctic peregrine falcon was removed from the list of endangered and

threatened species in October 1994. Arctic peregrine falcons nest in the treeless tundra 

areas of northern and western Alaska and migrate south through Canada and the U.S. 

During spring and fall migrations, they may be present anywhere in Alaska.

The Alaskan breeding population of Steller’s eiders were listed as a threatened

species on July 11, 1997. Steller’s eiders nest in the coastal tundra area of the Alaskan

arctic coastal plain and arctic Russia. Within Alaska, the only known remaining breeding

concentration of Steller’s eiders in the vicinity of Barrow. Most of the world’s population

winters in protected marine waters of the Alaska Peninsula, the coastal areas of south

central Alaska including Kodiak Island and surrounding islands, and the eastern Aleutian

Islands. There is no critical habitat proposed for Steller’s eiders.

The Short-tailed albatross is listed as a “foreign” endangered species and is

considered listed anywhere outside the 3-mile territorial limit of the U.S. Whereas

waters beyond three miles are regulated for U.S. fisheries and off-shore mining to the

200-mile limit, the requirements for ESA consultation apply to activities that occur

between 3 and 200 miles from U.S. shores. The albatross spend the non-breeding

season (summer and fall) feeding on small fish and squid in the Gulf of Alaska, along the

Aleutian chain, and north into the Bering Sea.

9.3.3 EPA Determination
Based on the information received from NMFS, the proposed permit for seafood

processors operating shorebased facilities in Kodiak, Alaska, will not affect the listed

species for the following reasons:

! The identified species of endangered whales are uncommon in St. Paul

Harbor.

! While the Steller sea lions may be attracted to seafood processing wastes,

the wastewater discharge would not provide any feeding opportunities since

no solid processing wastes are discharged into the receiving waters.

Based on the information received from USFW, the proposed permit for seafood

processors operating shorebased facilities in Kodiak, Alaska, will not affect the listed

species for the following reasons:

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 16

! American Peregrine falcon - while the falcons may be present anywhere in

Alaska during migrations, it is unlikely they would be attracted to the seafood

processing wastewater discharge to St. Paul Harbor or Near Island Channel

in Kodiak.

! Arctic Peregrine falcon - this specie has been delisted and while they may be

present anywhere in Alaska during migrations, it is unlikely they would be

attracted to the seafood processing wastewater discharge to St. Paul Harbor

and Near Island Channel in Kodiak.

! Steller’s eiders - while they winter in protected marine waters and migrate in

the spring and fall along coastlines, it is unlikely that they would be attracted

to discharges from the Kodiak shorebased facilities to St. Paul Harbor and

Near Island Channel in Kodiak..

! Short-tailed albatross - the listing for protection is beyond the 3 mile territorial

limit and the discharge from the seafood processors occur within St. Paul

Harbor and Near Island Channel which is between the Kodiak mainland and

Near Island, well within the 3-mile limit.

9.4. Marine Protection, Research and Sanctuaries Act

No marine sanctuaries as designated by this Act exist in the vicinity of the 

discharge area.

9.5 Oil Spill Requirements
Section 311 of the Clean Water Act prohibits the discharge of oil and hazardous

materials in harmful quantities. Discharges specifically controlled by the draft permit are 

excluded from the provisions of Section 311. However, this permit does not preclude

the institution of legal action or relieve the permittee from any responsibilities, liabilities,

or 

penalties for other, unauthorized discharges of toxic pollutants which are covered by

Section 311 of the Act.

9.6 State Water Quality Standards and Certification

Since State waters are involved in the draft permit, the provisions of Section 401

of the Act apply. Furthermore, in accordance with 40 CFR § 124.10(c)(1), public notice

of the draft permit has been provided to the State of Alaska and Alaska State agencies

having jurisdiction over fish, shellfish and wildlife resources, and over coastal zone

management plans.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 17

9.7 Presidential Oversight of Federal Regulations [Executive Order 12866]

The Office of Management and Budget has exempted this action from the review

requirements of Executive Order 12866 providing for presidential oversight of the

regulatory process pursuant to Section 6 of that order.

9.8 Paperwork Reduction Act

EPA has reviewed the requirements imposed on regulated facilities in the permit

under the Paperwork Reduction Act. Most of the information collection requirements

have 

already been approved by the Office of Management and Budget (OMB) in submissions

made for the NPDES permit program (OMB No. 2040-0004 for DMRs and OMB No.

2040-0086 for applications).

10.0 REFERENCES

Crapo, Chuck, Brian Paust, and Jerry Babbitt. 1993. Recoveries and yields from Pacific

fish and shellfish. Alaska Sea Grant College Program, Fairbanks, AK. 

Ismond, Alan. 1994a. Best management Practices and Low-tech Solutions for Increasing

the Efficiency of Seafood Processing Plants. Province of British Columbia, Ministry of

Agriculture, Fisheries, and Food, Victoria. (Available from Warehousing and Asset

Investment Recovery, B.C. Ministry of Finance and Corporate Relations, Brian McNeil

(250) 952-4560)
Ismond, Alan. 1994b. How to Do a Seafood Processing Plant Water, Waste, and

Wastewater Audit. Province of British Columbia, Ministry of Agriculture, Fisheries, and

Food, Victoria. (Available from Warehousing and Asset Investment Recovery, B.C.

Ministry of Finance and Corporate Relations, Brian McNeil (250) 952-4560)

Jordan, Edward C. Co., Inc. 1979, Reassessment of effluent limitations guidelines and

new source performance standards for the canned and preserved seafood processing 

point source category. Prepared by Edward C. Jordan Company for the U.S.

Environmental Protection Agency, Effluent Guidelines Division. December 1979.

Nicklason, Peter M., and H. Burney Hill. 1995. Seafood Processing Handbook for

Materials Accounting and Best Management Practices Plans. October 13, 1995. Seattle,

Washington. (Available Region 10 Office of Water, (206) 553-1760)

PPRC. 1993. Pollution prevention opportunities in the fish processing industry. Pacific

Northwest Pollution Prevention Research Center, Seattle, Washington.

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 18

SWAMC. 1992. Ways to Reduce, Reuse, and Recycle Solid Waste Generated by

Southwest Alaska’s Fish Processing Industry. September 1992. Southwest Alaska

Municipal Conference. (Copies available from Region 10 Office of Water, (206) 553-

1760)

USEPA. 1975. Development document for effluent limitations guidelines and new source

performance standards for the fish meal, salmon, bottom fish, clam, oyster, sardine,

scallop, herring, and abalone segment of the canned and preserved fish and seafood 

processing industry point source category. U.S. Environmental Protection Agency,

Washington, D.C. EPA 440/1-75/041a. September 1975. (Reference copy available in

the Region 10 Library)

USEPA. 1988. You and Quality Assurance in Region 10. U.S. Environmental

Protection Agency, Region 10 Quality Assurance Management Office, Seattle,

Washington. EPA 910/R-88-100. March 1988. (Copies available from Region 10

Office of Water, (206) 553-1760 or on the Internet at

http://www/epa/gov/r10earth/offices/oea/qaindex.htm)

USEPA. 1994. EPA Requirements for Quality Assurance Project Plans for

Environmental Data Operations. [Draft Interim Final} U.S. Environmental Protection

Agency, Quality Assurance Division, Washington, D.C. EPA QA/R-5. August 1994.

(Copies available from Region 10 Office of Water, (206) 553-1760 or on the Internet at

http://www/epa/gov/r10earth/offices/oea/qaindex.htm)
USEPA. 1996. The Volunteer Monitors Guide to Quality Assurance Project Plans. U.S.

Environmental Protection Agency, Office of Wetlands, Oceans, and Watersheds,

Washington, D.C. EPA 841-B-96-003. September 1996. (Copies available from Region

10 Office of Water, (206) 553-1760 or on the Internet at

http://www/epa/gov/r10earth/offices/oea/qaindex.htm)

USEPA. 1996. EPA Guidance for Quality Assurance Project Plans. [External Working

Draft} U.S. Environmental Protection Agency, Quality Assurance Division, Washington,

D.C. EPA QA/G-5. November 1996. (Copies available from Region 10 Office of Water,

(206) 553-1760 or on the Internet at

http://www/epa/gov/r10earth/offices/oea/qaindex.htm).

11.0 Attachments (See next three pages)

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 19

11.1 CALCULATING MULTI-PROCESSING LIMITS FOR TSS and WHAT TO REPORT

(Parameter Code: 00141 “R”)

Raw Incoming Product

BF Mech BF Conv Salmon Conv Salmon Mech

9-3 -- 157,989 (14%) 703,231 (63%) 253,491 (23%) 1,114,711

9-10 91,386 (8%) 137,221 (12%) 692,862 (62%) 205,392 (18%) 1,126,861

9-18 123,931 (21%) 101,583 (17%) 142,744 (24%) 215,119 (38%) 582,377

9-26 103,159 (26%) 96,442 (25%) -- 193,556 (49%) 393,157

 318,476 (10%) 493,235 (15%) 1,538,837 (48%) 867,558 (27%) 3,218,106

Limits

DM MA DM MA

Bottom Fish Mech 22 12 Bottom Fish Conv 3.1 1.9

Salmon Mech 44 26 Salmon Conv 2.6 1.6

TSS Daily Max Results

lbs/day ÷ Prod = DM Results DM Limit

9-3 3088 1115 2.77 12.19

9.10 3381 1127 3.00 11.66
9-18 5793 583 9.93 22.49

9-26 4985 393 12.68 report as TSS DM for “R” 28.06

 17247 3218

TSS Daily Max Limit for Multi-Processing DM limit x percentage + etc.

9-3 3.1 x .14 [0.43] + 2.6 x .63 [1.64] + 44 x .23 [10.12] = 12.19 

9-10 22 x .08 [1.76] + 3.1 x .12 [0.37] + 2.6 x .62 [1.61] + 44 x .18 [7.92] = 11.66

9-18 22 x .21 [4.62] + 3.1 x .17 [0.53] + 2.6 x .24 [0.62] + 44 x .38 [16.72] = 22.49

9-26 22 x .26 [5.72] + 3.1 x .25 [0.78] + + 44 x .49 [21.56] = 28.06 

TSS Monthly Average Results for Non-Multi-Processing Total lbs pollutant ÷ lbs/thousand lbs

17247 ÷ 3218 = 5.36 report as MA for “R”

TSS Monthly Average Limit for Multi-Processing MA limit x percentage + etc.

1.6 x .48 [0.77) + 1.9 x .15 [0.29] + 26 x .27 [7.02] + 12 x .10 [1.20] = 9.28 MA Limit 

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 20

11.2 CALCULATING MULTI-PROCESSING LIMITS FOR O&G and WHAT TO REPORT

(Parameter code: 00152 “R”)

Raw Incoming Product

BF Mech BF Conv Salmon Conv Salmon Mech

9-3 -- 157,989 (14%) 703,231 (63%) 253,491 (23%) 1,114,711

9-10 91,386 (8%) 137,221 (12%) 692,862 (62%) 205,392 (18%) 1,126,861

9-18 123,931 (21%) 101,583 (17%) 142,744 (24%) 215,119 (38%) 582,377

9-26 103,159 (26%) 96,442 (25%) -- 193,556 (49%) 393,157

 318,476 (10%) 493,235 (15%) 1,538,837 (48%) 867,558 (27%) 3,218,106

Limits

DM MA DM MA

Bottom Fish Mech 9.9 3.9 Bottom Fish Conv 4.3 0.56

Salmon Mech 29 11 Salmon Conv 0.31 0.19

O&G Daily Max Results

lbs/day ÷ Prod = DM Results DM Limit

9-3 4300 1115 3.86 7.47

9.10 5730 1127 5.08 6.73
9-18 4545 583 7.80. 13.90

9-26 7140 393 16.17 report as TSS DM for “R” 21.48

 21715 3218

O&G Daily Max Limit for Multi-Processing DM limit x percentage + etc.

9-3 4.3 x .14 [0.60] + .31 x .63 [0.20] + 29 x .23 [6.67] = 7.47 

9-10 9.9 x .08 [0.79] + 4.3 x .12 [0.52] + .31 x .62 [0.19] + 29 x .18 [5.22] = 6.73

9-18 9.9 x .21 [2.08] + 4.3 x .17 [0.73] + .31 x .24 [0.07] + 29 x .38 [11.02] = 13.90

9-26 9.9 x .26 [6.19] + 4.3 x .25 [1.08] + + 29 x .49 [14.21] = 21.48 

O&G Monthly Average Results for Non-Multi-Processing Total lbs pollutant ÷ lbs/thousand lbs

23715 ÷ 3218 = 6.75 report as TSS MA for “R”

O&G Monthly Average Limit for Multi-Processing MA limit x percentage + etc.

0.19 x .48 [0.09) + 0.56 x .15 [3.73] + 11 x .27 [2.97] + 3.9 x .10 [0.39] = 7.18 MA Limit 

Kodiak Seafood Processors General Permit Proposed NPDES Permit No. AK-G52-8000

Fact Sheet Page 21