### 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 Trident Seafoods Corporation

Plant Address 1705 Tongass Avenue, Ketchikan, Alaska

NPDES Permit # AK-G52-0132

Date of Visit Thursday, August 12, 2010 People Contacted Edwin Acevedo Quality Control Manager

eacevedo@tridentseafoods.com

907-225-6664 Jenifer White General Manager of VA, CW, CI jwhite@tridentseafoods.com

206-297-5623 Company Website www.tridentseafoods.com

Seafood processed All species, predominantly salmon but also black cod (sablefish)

halibut

rockfish geoduck

sea cucumbers Products Frozen whole fish (headed and gutted) Fresh whole and filleted fish (h&g)

Smoked salmon Frozen roe skeins (sujiko) Range of annual production volume 3.2 to 6.5 million pounds Months of operation Year round Discharge type Grind and discharge

Trident’s plant at 1705 Tongass Avenue, Ketchika n was formerly owned by NorQuest Seafood, Inc. Trident’s plant on the south side of Ke tchikan operates a large salmon cannery line. In contrast, this plant produces fresh and frozen whole fish and fillets from a variety of fish. Most of the salmon processed is the lower value species (i.e ., chum and pink). It also produces a small

amount of smoked canned salmon. At the time of th e visit, this plant was processing about 50,000 pounds of salmon per day.

Waste Management. During the 2010 season, Trident/NorQuest stored salmon heads on ice until they were trucked to the Trident Cannery also located in Ketchikan, AK. At the cannery, the salmon heads were pumped to the Alaska Protein Re covery barge where they were processed into salmon oil and protein hydrolysate.

In 2010, the remaining waste passed through two grinders, Muffin Monste rs, and two Vaughn’s and was then discharged directly to Tongass Narrows, about 280 feet off shore.

### 2 If they were required to haul their waste out to sea, rather than discharge it through their outfall, Mr. Acevedo and Ms. White suggested that Trid ent would hire a tender to haul the waste. However, Ms. White noted that state wide Alask a was experiencing a tender shortage. Fishermen who formerly operated tenders move d elsewhere after the crab rationalization. In this program, the government bought back Individual Fishing Quotas (IFQ) in order to reduce the number of crab fisherman. Ms. White explained, “This did no t allow crabbers to participate in any fisheries programs for the duration of their existence. In conjunction the crab rationalization made it economically unfeasible for many vessels to operate and thus have chosen to remain tied up so they are not operating in the negative, moneta rily speaking. Tenders cannot operate on short seasons and must have multiple month contracts to make it cost effective to operate; multiple month contracts are very scarce (due to the nature of the different fisheries in Alaska). Although prices paid to tenders have gone up; due to the s hortage, they still cannot make a living with short term contracts. One good example is in Bristol Bay area where average tender prices have gone from $2,500 to $5,000 per day on a 60 day contract this equals $300,000 pre taxes. Although initially this seems like a fair amount of money after tenders pay the crew (wages, food ect), insurance, R&M (which is substantial for vessels typically), fuel, fish buying equipment repair, slip fees for off times, taxes ect tenders end up loosing money



### . For this reason many fishermen

have moved their tenders out of Alaska or have tied up, resulting in a shortage of available

tenders.”

Ms. White hypothesized that this tender shorta ge could result in increased cost for waste disposal.

Facility Tour. The fish is offloaded from fishing vessels into the plant via totes (see Figure 1 ). The weight and temperature are recorded and each tote receives an identification number.

Fish are transported into the plant on an automated conveyor ( Figure 2 ) but the seafood at this facility is entirely processed by hand. The fi sh are gutted and the guts drop onto a pocket conveyer belt where workers can separate out the roe sacs. The unwanted guts are collected into a tote or washed down a 5” hole on that table connected to a pipe that goes directly into the drain in the floor. The drains on the floor send any fish waste directly to the grinders. Any material not removed from the fish body cavity by hand is removed by a vacuum system.

Next the fish enter the grading area and are then further processed into frozen headed and gutted (H&G) fish, fish fillets, or fresh H&G fish. To produce frozen whole fish, fish are loaded into trays and frozen in four flash freezers. After freezing the flash frozen fish are knocked off the trays on the “break table” and glazed (to reduce dehydration during storage). Glaze is a mixture of water and Lycasin ® . H&G frozen fish are packed in tot es and loaded into freezer containers right outside the facility. When the containers ar e full, they are sealed, locked, and shipped off

site.

To produce fillets, fish must be warmed s lightly (above freezing) ensure the processing equipment works correctly. The fish are processed in a line that removes fins, tails, and collars. Next the fish are sawed into three part s: two fillets and the frame (bones) ( Figure 3a ). Although

considerable flesh is still attached to the frame, it is considered waste. Trident (and the industry) has and is still investigating markets, product form s and equipment to use frame meat in a cost effective manner. The fillets are trimmed by hand ( Figure 3 ) then pass through an automated pin bone puller, followed by hand pulling of any remaini ng pin bones. The fillets are aged to ease the removal of the pin bones and allow the flesh to relax and go through ri gor. The relaxation process can last up to 1 to 2 days until the fish is processed.

### 3 Finally the fillets are rinsed and the grader removes any fish that have bruises or other imperfections. The fillets that pass this last in spection are sent to coolers and vacuum packed ( Figure 4 ). The packaged fillets are then sent thr ough a “drag” freezer, which consists of containers of trays that are conveyed or dragged through a freezer. Lastly, the frozen fillets are

boxed.

Grade 2 fillets are sorted ( Figure 5 ), frozen, then glazed and packed in various product configurations such as single frozen portions for bags for retailers or food service.

Smoker. The smoker operated by Trident/NorQuest Ke tchikan uses small scale, hand production, to produce a high value product. King salmon is fille ted, the fillets are injected with brine, and they staged for the smoker. Smoke is produced by burning a blend of hardwood shavings. The only flavoring is natural smoke. The smoker adds flavor but doesn’t fully cook the fish. After smoking, the fish is canned and then cooked in a mini-retort ( Figure 6 )



### Figure 1. Totes on Dock

Figure 2. Automated Conveyor

### 4 Figure 3a. Sawing salmon into fillets.

Figure 3. Hand Trimming

### 5 Figure 4. Vacuum Packs

Figure 5. Freezing prep

### 6 Figure 6. Canning smoked salmon