PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY



# Report to the Record Profile of the Alaska Seafood

Processing Industry U.S. Environmental Protection Agency

Office of Water (4303T) 1200 Pennsylvania Ave., NW Washington, DC 20460

August 2013PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY 

### TABLE OF CONTENTS **1.0 BACKGROUND**  **................................ ................................**  **................................ ............................**  **1** 1.1. History of the Regulation
................................ ................................ ................................ .... 1 1.2. Current Administration of the ELG in Alaska
................................ ................................ .... 3 1.3. Reconsideration of the Alaskan Seafood Processing Subcategories
................................ ... 3 1.4. Organization of the Industry Profile
................................ ................................ ................... 3 **2.0 OVERVIEW OF THE SEAF**  **OOD PROCESSING INDUS TRY**  **................................ ..............**  **4** 2.1. Description of the Industry
................................ ................................ ................................ . 4 2.2. Significance of the Alaska Fisheries and Seafood Processing Industry in the Global, U.S., and Regional Economies
................................ ................................ ........................... 4 2.2.1. Fisheries
................................ ................................ ................................ ................. 4 2.2.2. Seafood Processing
................................ ................................ ................................ 6 2.3. Overview of the Seafood Processing Industry in Alaska
................................ .................... 7 2.4. The Major Alaskan Fisheries and their impact on Seafood Processing Finances
............... 8 **3.0 ALASKA SEAFOOD PROCE**  **SSING FACILITIES AND FIRMS IN THE**  **PETITIONING NON -**  **REMOTE PROCESSING LO CATIONS AND ADDITION**  **AL R** **EMOTE PROCESSING LOC ATIONS OF INTEREST**  **................................ ......................**  **11** 3.1. Overview Of Facilities and Firms
................................ ................................ ..................... 12 3.1.1. Petitioning Non

- Remote Processing Location Facilities
................................ ..... 12 3.1.1.1. Cordova

................................ ................................ ............................ 13 3.1.1.2. Juneau

................................ ................................ .............................. 17 3.1.1.3. Ketchikan

................................ ................................ .......................... 17 3.1.1.4. Petersburg

................................ ................................ ........................ 18 3.1.2. Processing Locations of Interest Currently Classified as Remote
....................... 18 3.1.2.1. Dutch Harbor

................................ ................................ ................... 19 3.1.2.2. Kenai Peninsula

................................ ................................ ............... 19 3.1.2.3. Sitka

................................ ................................ ................................ .. 20 3.2. Firms Owning Facilities in the Petitioning Non

- Remote Processing Locations and Remote Locations of Interest
................................ ................................ ............................ 21 3.2.1. Firms Owning Petitioning Processing Location Facilities
................................ ... 24 3.2.2. Other Firms Owning Remote Facilities in Procressing Locations of Interest (Dutch Harbor, Kenai Peninsula, Sitka)
................................ .............................. 25 3.2.2.1. Dutch Harbor

................................ ................................ ................... 25 3.2.2.2. Kenai Peninsula

................................ ................................ ............... 26 3.2. 2.3. Sitka

................................ ................................ ................................ .. 27 **4.0 CURRENT INDUSTRY PRA**  **CTICES FOR MANAGING WASTE**  **................................ .....**  **27** 4.1. General Waste Management Practices
................................ ................................ .............. 27 4.2. Seafood By

-products
................................ ................................ ................................ ......... 28 4.2.1. Fishmeal
................................ ................................ ................................ ............... 28 4.2.2. Bone Meal
................................ ................................ ................................ ............ 28 4.2.3. Fish Oil
................................ ................................ ................................ ................ 29 4.2.4. Hydrolyzed Protein
................................ ................................ .............................. 29 4.2.5. Montlake Process
................................ ................................ ................................ . 29 4.2.6. Compost and Crop Nutrient
................................ ................................ ................. 30 4.2.7. Modified Silage
................................ ................................ ................................ .... 30 4.2.8. Chondroitin Sulfate (CS)
................................ ................................ ..................... 30 4.2.9. Dried Salmon Fish Heads
................................ ................................ .................... 30PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY
4.2.10. Chitin
................................ ................................ ................................ ................... 30 4.3. Markets f

or Seafood Processing By

-products
................................ ................................ ... 30 4.3.1. Fishmeal
................................ ................................ ................................ ............... 31 4.3.2. Fish Oil
................................ ................................ ................................ ................ 32 4.3.3. Hydrolysate
................................ ................................ ................................ .......... 33 **5.0 ALASKA** **N BY -**  **PR ODUCT MARKET CONSI**  **DERATIONS ................................**  **................ 33**  5.1. Number of By

-product Processing Facilities
................................ ................................ .... 34 5.2. Current By
-product Processing in The Petitioning Locations and Additional Locations of Interest
................................ ................................ ................................ .......................... 36 5.2. 1. Status of By

-product Recovery in the Petitioning Locations
............................... 36 5.2.1.1. Cordova

................................ ................................ ............................ 36 5.2.1.2. Juneau

................................ ................................ .............................. 36 5.2.1.3. Petersburg

................................ ................................ ........................ 37 5.2.1.4. Ketchikan

................................ ................................ .......................... 37 5.2.2. Status of By

-product Recovery in the Locations of Interest
................................ 38 5.2.2.1. Dutch Harbor

................................ ................................ ................... 38 5.2.2.2. Kenai Peninsula

................................ ................................ ............... 38 5.2.2.3. Sitka

................................ ................................ ................................ .. 38 5.3. Total Waste Available in Petition Processing Locations
................................ .................. 39 5.4. Waste utilization estimates
................................ ................................ ............................... 41 **6.0 COMPARING POTENTIAL**  **ALASKAN AND GLOBAL Q UANTITIES OF BY**  **** **PRODUCTS ................................**  **................................ ................................**  **................................ .**  **42 7.0**  **OTHER FACTORS AFFECT ING PROCESSORS IN NO**  **N -**  **REMOTE PROCESSING LOCATIONS**  **................................ ................................**  **................................ ...............................**  **43 8.0**  **REFERENCES ................................**  **................................ ................................**  **............................. 49** PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY
**LIST OF TABLES** Table 1. 2008 Fish Production and Processing Overview
................................ ................................ ............ 5 Table 2. Alaska Seafood Processing in the Context of Its Region and the U.S. Seafood Processing Industry
................................ ................................ ................................ ................................ ......................... 7 Table 3. Facility Overview by Petitioning Locations and Locations of Interest
................................ ........ 14 Table 4. Firms with Potentially Affected Petitioning Alaskan Processing Facilities and Those with Facilities in the Locations of Interest
................................ ................................ ................................ .......... 21 Table 5. Facilities Producing Fishmeal and Fish Oil
................................ ................................ .................. 35 Table 6. ADFG Regions Corresponding to Petitioning Locations
................................ .............................. 39 Table 7. Estimated Seafood Waste from Regions Surrounding Petitioning Processing Locations in 2008 (tons)
................................ ................................ ................................ ................................ ........................... 40 Table 8. Annual Salmon Waste Generated by Petitioning Areas and Areas of Interest 2005

- 2009
........... 41 Table 9. 2009 Regional Salmon Harvests and Estimated Fishmeal and Oil Production (metric tons)
....... 41 Table 10. Fishmeal and Fish Oil Production Estimates by Petitioning Locations and Additional Locations of Interest
................................ ................................ ................................ ................................ .................... 42 Table 11. Comparing Alaskan and Global Quantities of Seafood By

-products
................................ ......... 42 Table 12. Other Processors Closest to the Processors in Petitioning Locations and Locations of Interest 43 Table 13. Census Characterization of Petitioning Processor Communities from 2000 US Census
........... 45 Table 14 Seafood Processing in the Context of Census Employment and Establishments
........................ 46 Table 15. Seafood Canning and Fresh/Frozen Processor Establishments and Employees [a]
.................... 48PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY 

### LIST OF FIGURES Figure 1. Alaska Fish Production as it Relates to Regional and National Production
................................ .. 5 Figure 2. 2008 Fish Landings and Ex

- Vessel Values by Alaska Fishery
................................ ................... 10 Figure 3. Map of ADFG Harvest Areas with Seafood Processor Locations
................................ .............. 12 Figure 4. Top International Fishmeal Producers 2006

- 2009
................................ ................................ ...... 31 Figure 5. Comparing Global and Alaskan Potential Meal and Oil Production
................................ ........... 43PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

1 **1.0 BA** **CKGROUND 1.1.**  **H ISTORY OF THE**  **R EGULATION**  U.S. EPA is again considering finalizing a response to a petition on a final regulation and amending effluent limitations guidelines including numeric discharge limits on effluents from a subset of seafood processing facilities located in Alaska. This regulation, an effluent limitations guideline, or ELG, was originally promulgated in two phases in 1974 and 1975. In order to understand the regulation, it is necessary to know how the regulation defines the various seafood processing entities and the history of the regulatory process for this industry. The two

-phase rule (begun in 1974 and completed in 1975) (40 CFR Part 408) covers all seafood processors in the United States and has created a number of subcategories within the Seafood Processing C ategory. These subcategories generally relate to a number of factors, including geographic region , the type of processing methods employed, and type of fish or shellfish harvested. In this way, the rule was designed to take into account the unique characteristics of the seafood processing facilities , their locations, a

nd how they process the seafood. Alaska seafood processors are divided into a number of subcategories. These subcategories include: 1

 Non
- remote Alaska Crabmeat Processing

 Remote Alaska Crabme at Processing

 Non
- remote Alaska Whole Crab and Crab Section Processing

 Remote Alaska Whole Crab and Crab Section Processing

 Non
- remote Alaska Shrimp Processing

 Remote Alaska Shrimp Processing

 Alaska Hand

-butchered Salmon Processing

 Alaska Mechanized Salmon Processing

 Alaska Bottom Fish Processing

 Alaska Scallop Processing

 Alaskan Herring Fillet Processing Although, at first glance, it would appear that the terms “non

- remote” and “remote” have a broad geographic definition, in fact, the terms are very specif ic. Non

- remote seafood processors are located only in the following non - exclusive list of locations , or “processing locations :”

 Anchorage

 Cordova

 Ju neau
 Kodiak

 Ketchikan

 Petersburg.

1 The subcategories in which remote and non

- remote are not specified in the subcategory title cover remote and non

remote processors grouped together, but with separate requirements.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

2 These six locations were classified in the regulation as non

- remote locati ons generally on the basis of having greater economies of scale than those areas classified as “remote .” All areas outside of these locations were classified as “remote.” All seafood processors are subject to Best Practicable Control Technology Currently Available (BPT) regulations. For non

- remote processors, BPT provides mass based numeric limit ation s on total suspended solids (TSS) , oil and grease , and a range f or pH. Remote seafood processors are only required to meet size limitations on the wastes discharged with their effluent (that is, the solids in their wastes must be less than 1⁄2 inch in all dimensions prior to discharge). The requirements to meet ELGs cov ering TSS , oil and grease , and pH are based on screening the wastewater
. Best Conventional Pollutant Control Technology (BCT) and New Source Performance Standards (NSPS) are set equal to BPT requirements for both remote and non

- remote seafood processors. Best Available Technology Economically Achievable (BAT) regulations have been replaced by BCT effluent limitations for all of the subcategories. Itm ust be noted that EPA bases its effluent limitations guidelines and standards on a particular technology o r set of technologies but does not require adoption of any particular technology to comply with ELGs. Once the limitations are established, the individual facilities may use any technology or set of technologies to meet the effluent limitations guidelines and standards. In addition, individual facilities can consider opportunities to work together and collectively take advantage of economies of scale. At the time of the original rulemakings in 1974 and 1975, EPA made the distinction between remote and non

- remote processors on the basis that waste disposal alternatives that might be available in some locations would not be available in all areas of Alaska. Furthermore, EPA determined that seafood processors that were not near large population centers or were not located near other seafood processors mi ght be at an economic disadvantage
. The implementation of the rule was held up during a court challenge, in which EPA eventually prevailed. However, shortly after, in 1980, Pacific Seafood Processors Association; Morpac, Inc; Nefco

Fidalgo Packing Company; North Pacific Processors; E.C. Phillips and Son, Inc; Washington Fish & Oyster Company; and Whitney Fidalgo Seafoods petitioned the EPA to reconsider and modify the ELG. All non

- remote regions except Kodiak were represented in this petition ; processors in Kodiak complied with the BPT effluent limitations and thus no Kodiak establishments joined the petition. The petitioners claimed that the costs of achieving the BPT effluent limitations were not in p roportion to the effluent reduction benefits for non

- remote Alaska processing locations
. T he petitioners also requested that EPA suspend the regulations asserting that a record

-breaking salmon season would occur in 1980 , while also not ing the timing for gu ideline implementation could also pose compliance problems for the industry. On May 19, 1980, EPA published a direct final rule suspending the BPT screening requirement for processors (45 FR 32675) , based upon good cause . The suspension was intended to exp ire October 15, 1980. O n June 16, the petitioners filed a supplemental petition for modification, maintaining that Anchorage, Cordova, Juneau, Ketchikan, and Petersburg should be removed from the non

- remote designation and requesting EPA provide further e vidence regarding the costs and benefits of implementing the new BPT requirements. EPA published the supplemental petition in its entirety on August 7, 1980 ( 45 FR 52411 ). In January 1981, EPA proposed to grant the petition for Juneau (removing it from non

- remote status) and deny the petition for the other petitioning communities (46 FR 2544). The proposed response also indicated the suspension of BPT for the petitioning non

- remote Alaska seafood processors (51 FR 24974) would remain in effect until a final decision was reached. EPA also solicited comment on, but did not formally propose, adding Dutch Harbor and the Kenai Peninsula to the list of non - remote locations. EPA has not, however, made a final decision regarding the petition, and, there fore, the remote and non

- remote designations, as well as BPT requirements for non

- remote Alaska seafood processors, remain suspended. The suspension effectively requires all Alaskan seafood processorsPROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

3 covered by the ELGs (with the exception of those in Kodiak) to meet the less stringent BPT effluent limitations based upon grinding for remote seafood processors, that is, waste size limits
. **1.2. C**  **URRENT A**  **DMINISTRATION OF THE ELG**  **IN A**  **LA SKA**  ELGs are administered through a system of permits, known as National Pollutant Discharge Elimination System (NPDES) permits. With the exception of seafood processors in Kodiak and a few others, permits written for seafood processors in Alaska require processors to meet the BPT requirements for remote seafood processors. NPDES permits spell out the limitations specified by the ELGs, unless more restrictive limits are placed in the permits to meet state requirements or water quality needs. Thus, the limits cannot be less stringent than the ELG requirements, which in this case means less stringent than the BPT requirement for remote processors, due to the suspension of the non

- remote designation. Until recently, EPA Region 10 managed the issuance of permits to all discharging facilities in Alaska, including seafood processors. Howeve r, in 2008, EPA transferred authority over the NPDES permitting program to the State of Alaska . As such, the Alaska Department of Environmental Conservation (ADEC) issues NPDES permit to seafood processors discharging into state waters
. EPA retains autho rity to issue permits in offshore federal waters ( i.e., waters more than 3 miles from the baseline). The NPDES permit covering the majority of seafood processors in Alaska is the NPDES General Permit for Seafood Processors in Alaska (AKG

- 52
- 0000), which ex pired in 2006 but which continues to cover shorebased seafood processors until a new General Permit can be issued. This permit applies the remote ELGs which are the less stringent BPT effluent limitations based upon grinding. Permitted seafood processors in Kodiak are authorized to discharge pursuant to the NPDES General Permit for Seafood Processors Operating Shorebased Facilities in Kodiak , Alaska ( AKG528000FP ). The Kodiak permit is based on the non

- remote numeric BPT effluent limitations. Seafood proc essors in Dutch Harbor have been issued individual NPDES permits that contain more stringent limits based on a Total Maximum Daily Limit (TMDL) (including limits for Biological Oxygen Demand (BOD)). In addition, offshore seafood processors ( i.e., processor s operating more than one half nautical mile from shore) are covered by the Alaska Offshore Seafood Processors NPDES General Permit (AKG 523000) which applies the remote BPT effluent limitations based upon grinding. **1.3. R**  **ECONSIDERATION OF TH E**  **A LA** **SKAN S**  **EA FOO**  **D P**  **ROCESSING S**  **UBCATEGORIES** EPA is again considering appropriate amendments to the regulations as described above
. EPA will consider the original propos al and comments received on that proposal , current information (collected from both secondary sources an d recently received responses to a Section 308 survey questionnaire ), and comments that will be received on the notice of data availability (NODA). As indicated in the proposal, EPA is review ing the status of an additional three “remote” locations that might be considered for reassignment to the “non

- remote” classification : Dutch Harbor, Sitka, and the Kenai Peninsula. Additional locations that have similar characteristics to facilities classified as non

- remote, such as Naknek, also could be considered b ased upon data and information submitted with public comments on the NODA. **1.4. O**  **RGANIZATION OF THE I**  **NDUSTRY P**  **ROFILE** The purpose of this industry profile is to provide an understanding of the industry within Alaska as well as its importance within the United S tates and abroad. Section 2 provides an overview of the industry and describes relevant global, national, regional, and state and local economic information. Section 3 provides information on the firms and facilities in the potentially affected non

- remote areas, as well as information on those in the remote areas that EPA is considering adding to the list of non

- remote locations. Section 4 then describes the current industry practices for managing fish wastes through discharge, offshore disposal, and by

-pr oduct recovery, which is discussed in detail. Section 5 discusses the status of by

-product recovery in the petitioning locations and additional locations of interest. Section 6 presents a comparison of potential Alaskan by

-product recovery quantities to th e global availability of by

-PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

4 products. In Section 7, the report discusses the role of species of fish processed and proximity of facilities in locations that may be considered non

- remote in a possible final regulation to those that may remain remote. EPA al so discusses the role of the seafood processing industry in the local economies of the non

remote petitioner communities. **2.0 OVERVIEW OF THE SEA**  **F OOD PROCESSING INDUS**  **TRY 2.1.**  **D ESCRIPTION OF THE**  **I NDUSTRY**  The seafood processing industry is a part of the wider food pr ocessing sector, a major category within the manufacturing sector of the economy. The seafood processing industry acquires fresh fish or shellfish from harvesters, who typically operate as separate businesses within a non

- manufacturing sector (the agriculture, forestry, fishing, and hunting sector), although some seafood processors operate large processing ships, which catch, process, and deliver seafood products as part of one operation. When the processor acquires the fresh seafood from harvesters, the processor removes unwanted f ish parts (such as skeletons, heads , or shells ) before creating secondary, preserved products for both human and non

- human consumption . The processes in which usable fish products are separated from wastes can range from those u sing only hand labor to fully automated mechanical separation processes. The unwanted fish parts become part of the waste stream that the processor must manage. General waste management and by

product recovery practices are reviewed in Section 4. The North American Industry Classification System (NAICS) divides the seafood processing industry into two main categories: Seafood Canning (NAICS code 311711), defined as “establishments primarily engaged in (1) canning seafood (including soup) and marine fats and oils and/or (2) smoking, salting, and drying seafood”; and Fresh and Frozen Seafood Processing (NAICS code 311712), defined as, “establishments primarily engaged in one or more of the following: (1) eviscerating fresh fish by removing heads, fins, scales, bones, and entrails; (2) shucking and packing fresh shellfish; (3) manufacturing frozen seafood; and (4) processing fresh and frozen marine fats and oils” ( U.S. Census Bureau , 2010 , 2010a). The non

- remote Alaska seafood processing facilities are represented within both of these NAICS categories
. **2.2. S**  **IGNIFICANCE OF THE A**  **LA SKA**  **F ISHERIES AND**  **S EAFOOD**  **P ROCESSING**  **I NDUSTRY IN THE**  **G LOBAL**  **, U.S.,**  **AND R**  **EGIONAL E**  **CONOMIES 2.2.1.**  **Fisheries** The Alaska seafood processing industry is an important part of the U.S. industry, and a minor, but measurable , contributor to the global industry. The inputs to this industry; fish, shellfish, and other seafood in terms of production volumes, are an indicator of the seafood processing industry’s importance in Alaska, that region, the United St ates and the world. In 2008 , global fish production (which combines aquaculture and commercial catch [landings]) was more than 142 million metric tons of fish , with commercial landings estimated at nearly 90 million metric tons (NMFS, 2010 ) (see Table 1). In that year, the United States was the fifth largest seafood producer in the world with roughly four million tons of fish produced. Landed seafood is the biggest contributor to U.S. seafood production. Aquaculture makes up the rest of seafood production, contributing less than 10 percent to total production. The top fish

-producing region in the United States was, and continues to be, the Pacific Coast region , which includes the states of Alaska, Washington, Oregon, and California . In 2008, the region land ed 2. 6 million metric tons of seafood, which is about 67 percent of all U.S. landings and more than four times the landings of the second largest fish producing region , the Gulf Coast , which landed 0.6 million metric tons of seafood (throughout the remainder of the document, “tons” are considered to be metric tons, unless otherwise noted). The region’s landings also make up one half of the total value of U.S. landings.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

5 **Table 1. 2008 Fish Production and Processing Overview** 
**Location /Scale**  **Commercial Fish Landings**  **(million tons) Percent of U.S.** 

**Landings Value of** 

**Commercial Fish Landings**  **($ billions) Percent of U.S.** 

**Value of Landings** World 89.74 NA NA NA United States 3.78
-- $4.4

-- Pacific Coast Region 2.55 67% $2.2 50% Alaska 2.06 54% $1.7 39% Source: NMFS, 2010. Alaska is by far the largest contributor to total seafood production in the Pacific Coast Region and in the United States. During the time period 1997

- 2007, Alaska accounted for 51 percent of the nation’s total l andings, by weight, of fish and shellfish (Bimbo, 2008). The state’s landings of 2.06 million tons in 2008 were approximately 8 1 percent of total Pacific Coast seafood landings, 54 percent of all U.S. landings, and about 1 percent of global fish productio n in that year (NMFS, 2010)
. (Fish landings comprise nearly all of Alaska fish production, since aquaculture plays little role in the state’s fishing economy.) 2 In 2008, Alaska le d all states in the amount of fish landings. The next largest contributor to landings was Louisiana, with approximately 0.4 million tons. Alaska also led in the value of those landings ($1. 7 billion) (NMFS, 2010 ). 3 This is 77 percent of the value of landings produced by the Pacific Coast Region and about 39 percent of the value of landings in the United States (see Figure 1). The value of landings per ton of fish landed, however, lags behind the average for the United States , possibly reflecting the cost of transportation to the major lower 48 and Asian markets. **Figure 1. Alaska Fish Production as it Relates to Regional and National Production**

2 Fish production combines the volume of fish landings with volume of fish produced through aquacultur e. In Alaska, unlike other states, finfish farming (raising or cultivating finfish in captivity) is prohibited, and therefore is not a major contributor to the state’s total fish production. Ocean ranching (which involves releasing young fish into open wat ers) as well as non

- finfish farming (such as oysters, clams, and geoducks) are both permitted in Alaska and contribute to total fish production (State of Alaska, 1990). 3 Fish landings are the part of the fish catch that is brought onshore after harvest, o ften providing a record of total catch. NOAA credits landings of some fish, such as Alaska Pollock and other Pacific ground fish, a substantial portion of which are processed at sea, to the state nearest the catch location (NMFS, 2010).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

6 **2.2.2. Seafood Processing**  Much of the fish landed in the United States and abroad undergoes a processing step prior to being marketed. More than half of the world’s fish production (54% ) underwent some form of seafood processing in 2006 (FAO, 2008). In the United States, the primary form of p rocessing for human consumption in 2009 was fresh and frozen (77%), followed by canning (15%), and curing (2%). For non

human consumption, the primary products were bait and animal food (3%) as well as meal and oil (3%) (NMFS, 2010 ). As of 2007, seafood p rocessing plants numbered 652 across the United States and employed about 3 9,000 workers ( U.S. Census Bureau, 2007a) (see Table 2) . The Pacific Coast region, which includes the state of Alaska, is home to 282 seafood processors (or 43 percent of total U.S. seafood processing establishments) . This region also is associated with more than half the U.S. employment and receipts. Nearly half of the establishments located in the Pacific Coast region, 116 facilities, are located in Alaska. These 116 facilities make up nearly 20 percent of the total U.S. seafood establishments (U.S. Census Bureau, 2007a, b)
. 4 Alaska employs nearly 9,000 workers, or about 23 percent of the U.S. total for the industry. 5 Total receipts in Alaska are $2.2 billion, also about 20 percent of total receipts in this industry throughout the United States. The fact that Alaska by itself makes up so much of the seafood processing industry in the United States is notable.

4 The establishment num

bers are believed to include vessel

- based processors, because the Census does collect information from floating “factory ships.” Most vessel

- based processors are subject to offshore or nearshore requirements, not land

- based requirements, although some vessels operate as land

- based processors. EPA is not analyzing mobile land

- based processors (such as barges that might dock or anchor in or near a processing location). 5 Note that employment figures from the Census reflect employment in March, 2007. Few Alaska processing establishments operate in March. Other regions of the United States are also seasonal, but it is likely that if average em ployment during a year were calculated, Alaska employment in the seafood processing industry as a percentage of U.S. em

ployment might be higher than that shown here. National Marine Fisheries Service, 2010.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

7 **Table 2. Alaska Seafood Processing in the Context of Its Region and the U.S. Seafood Processing**  **Industry Geographic**  **Area No. of** 

**Establishmen ts**  **% of U.S.**

**Establishmen ts**  **Number of**

**Employees % of U.S.** 

**Employee s**  **Total**

**Receipts ($**  **billions) % of** 

**U.S. Receipts**  Alaska 116 18% 8,870 23% $2.2 20% Fresh and frozen 98 18% 7,934 22% $2.0 20% Canning 18 19% 936 33% $0.2 20% Pacific Coast 282 43% 21,445 55% $5.9 53% Fresh and frozen 237 42% 18,687 52% $4.9 49% Canning 45 48% 1,689 60% $0.7 70% United States 652 38,968 $11.1 Fresh and frozen 558 36137 $10.0 Canning 94 2,831 $1.0 Source: U.S. Census Bureau, 2007a, b. Does not include non

- employer establishments (33 non

- employer establishments are located in Alaska and more than 217 in the Pacific Coast region). The seafood processing industry in Alaska has changed somewhat in the last decade. In 1997 , there were 31 canning establishments (average March employment per establishment was 40) and 91 fresh and frozen establishments (average March employment of 65) in Alaska, according to the Census
. The canning industry in 2007 consisted of 18 establishments (average employment 52) and 98 fresh and frozen establishments (average employment 81). Thus, the number of canning establishments in Alaska has decreased substantially during the recent decade, with production being concentrated in fewer, larger facilities. Meanwhile , the number of fresh and frozen establishments has grown somewhat since 1997, while the size of those establishments, on average, has become larger (based on average employment). Thus, overall, the number of seafood processing establishments has declined only slightly, but the process has shifted from canning to fresh and frozen and the establishments themselves have become larger over the years (U.S. Census Bureau , 2007 a ; 2000a). **2.3. O**  **VERVIEW OF THE S**  **EAFOOD P**  **ROCESSING I**  **NDUSTRY IN A**  **LA SKA**  Alaska’s 116 seafood processing plants 6 are divided by EPA definitions into direct discharging, indirect discharging (discharging to publicly owned treatment works), or non

- discharging. The facilities are also classified as operating in remote or non

- remote processing locations for regulatory purposes. At this time, 21 facilities are designated as operating in non - remote locations (that is, they are located in or near the cities of Anchorage, Cordova, Juneau, Ketchikan, Kodiak, and Petersburg). However, some of these facilities are currently discharging wastes to publicly owned treatment works and, therefore, are not subject to the BPT requirements for direct dischargers, the focus of EPA’s potential actions 7 . Several others (six establishments) are located in Kodiak and currently are meeting the requirements for non

remote processors. EPA considers a total of 14 facilities with direct discharge to be potentially affected by its decision on the petition and a possible final regulation as discussed in Section 1. The remaining establishments operatin g in Alaska have been considered as being remote land

-based, nearshore, or offshore establishments. The 1 16 seafood processing facilities are owned by an estimated 86 employer firms (U.S. Census Bureau , 2007 b ) 8

. This number includes more establishments than considered by EPA

6 This industry profile focuses on employer firms. The numbers of facilities discussed in this section do not include 33 non
- em

ployer firms. 7 The exact number of establishments discharging wastes to publicly owned treatment works was not determined. 8 The permits number more than the establishments in part because the Census classifies firms by the industry to which the major share of the firm’s revenue is attributable. It is possible that a facility could do some processing butPROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

8 in the ELG, including floating processors, those which have primarily retail operations or some other business with seafood processing as a small portion of the business, and those which have ceased operations. At the national level, approximately 96 percent of firms owning seafood processing establishments are small businesses as defined by the Small Business Administration (SBA), employing on a yearly average fewer than 500 employees ( Federal Register , 2010) . Known large firms owning processing facilities in Alaska include Trident Seafoods, Icicle Seafoods, Ocean Beauty Seafoods, and the Japanese firms Maruha Nichiro Holdings , Nippon Suison Kaisha, and Marubeni. Additional information on thes e firms is presented in Section 3.1.2. A total of six small businesses are estimated to be affected by EPA’s decision on the petition. Section 3.2 discusses how small businesses were identified in these groups of firms. **2.4. T**  **HE M**  **AJOR A**  **LA SKAN**  **F ISHERIES AND**  **THEIR IMPACT ON S**  **EA FOOD**  **P ROCESSING**  **F INANCES**  The seafood processors in Alaska are dependent on their fisheries, which drive the economics of the industry. Alaska has f ive maj or fisheries , which harvest and process particular species of fish. Alaska’s major fisheries include: 1) salmon (such as coho, sockeye, and chum), 2) halibut, 3) herring, 4) shellfish (such as king crabs and tanner crabs), and 5) groundfish (such as pollock, rockfish, flounder, haddock and cod) (Knapp, 2010). Each fishery is managed by the Alaska Department of Fish and Game (ADFG) with the exception of halibut, which is managed by the International Pacific Halibut Commission (IPHC). The volume of seafood production each fishery contributes to the Alaskan fishing and manufacturing industry has varied widely over time. For example, a shellfish boom between 1960 and 1980 turned Kodiak into Alaska’s “crab capital ,” during which time the king crab catch in Alaska totaled about 110,000 million tons , much of it landed in Kodiak
. Beginning around 1980, the king crab catch declined dramatically, decreasing by more than 100,000 million tons by 2002 (Knapp, 2010) . With king crab harvests slow to recover, harvesters have focused more on tanner and snow crab , and the Bering Sea, Aleutian Island, and Gul f of Alaska region is now the center of crab production in the state (ADFG, 2009). Dutch Harbor production is now dominated by pollock. The Alaskan groundfish fishery also has a history of fluctuating volumes and harvesters. Prior to 1972, groundfish prod

uction was flourishing under foreign harvesters who began targeting the pollock fishery. With little regulation of gear or rules to prevent overfishing, contention was high among large, foreign factory boats and the smaller domestic pot fisheries and longl iners. As groundfish production sharply declined after 1972, the United States established the U.S. Exclusive Economic Zone (EEZ), which created a 200

- mile conservation zone. To promote U.S. fisheries, the U.S. government put forth various policies, follow ing creation of the EEZ, such as the American Fisheries Promotion Act. These policies obligated foreign harvesters to meet many more requirements in order to fish within the EEZ (such as the purchasing of U.S. fisheries products and technology transfer rel ating to fishing and boating equipment). In combination with incentive programs such as the NMFS Fisheries Obligation Guarantee Program, which provided loans for U.S. factory trawlers and processors in order to facilitate industry growth, these strategies shifted the once foreign

-based groundfish fishery into domestic hands by the early 1990s (Bechtel, 2010). Several factors shape the financial standing of the Alaskan seafood processing industry each year. On a broad level, financial fluctuations may occur due to consumers’ changing seafood product preferences or the quantity of seafood available to meet those consumer demands. For instance, the ex

vessel pri ce for herring decreased by more than 70 percent from 1995 to 2003 because Japan, one of the main markets for Alaskan herring products, dramatically decreased its purchases of luxury herring products as its economy stagnated ( Knapp, 2007 ). Seafood availability , which can fluctuate by up to 50 the major source of its revenue is another business, such as retail sales of fish products. Also, the General Permit includes floating offshore and nearshore processors, which substantially increase the number.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

9 percent each year , can b e shaped by factors such as fish productivity cycles that can be sensitive to seasonal temperatures, spawning patterns, or species health, as discussed above (Knapp, 2010). The economic crisis experienced by the Alaskan salmon industry in the 1990s provide s one example of the potential financial impacts resulting from fluctuations in seafood availability . During the 1990’s the farmed salmon industry emerged and created a high degree of competition with Alaskan salmon. 9
. Atlantic salmon farmed in Norway, Ch ile, Scotland, Canada (both British Columbia and eastern Canada), and Maine greatly increased the volume of salmon production. As a result of the increased supply from the salmon farms, the price paid to fishermen dropped from $2 per lb to less than $1.00 per lb for most species of salmon except Chinook (Knapp, 2010). Figure 2 shows the ex

- vessel price for the volume of Alaska’s fishery landings in 2008. The ex

vessel price is the price that the processor pays for the seafood when the product leaves the boat. The figure illustrates the relative value of each fishery to Alaska’s economy in 2008 before any processing or value

- added procedures are undertaken. For example, although nearly twice as many tons of herring were landed as halibut, the ex

- ve ssel value of halibut landings was almost $150 million greater than that of the herring (ADFG, 2008).

9 Alaska la ws prohibit s almon farming. The closest farm is a single , solitary salmon farm in Washington State. Alaska has a large fish hatchery industry to increase the number of wild salmon available for harvest (Knapp, 2010).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

10 **Figure 2. 2008 Fish Landings and Ex -**  **Vessel Values by Alaska Fishery**

At the processor level, the fish price negotiated between harvesters and processors can be a critical financial factor . In Alaska, seafood processors operate independently from harvesters . T he p ollock fishery is the exception; it operates primarily from large, offshore processing vessels . As a result, processors can purchase their seafood from anyone, but the fishermen ca n also sell their catch to anyone, subject to contractual or other agreements
. Although processors and harvesters rely on each other in order to generate income from their businesses, part of their financial success depends on the fish prices negotiated between the two parties each season. P rocessors can be very competitive for access to fish , and the level of competition fluctuates depending on th e number of processing plants in the vicinity, the strength of the overall market as well as the value of the fish . For example, during years in which fish quantities are limited, competition between processors may increase, and processors, therefore, may be willing to pay a higher price for fish than in years where is an ample supply of fish. In years in which fish are abundant, processors may limit the number of fish they are willing to purchase from a harvester. Land

-based processors must also keep in mi nd, however, the possibility for floating processors to move into an area during good fish

-producing seasons , potentially decreasing the volume of fish brought to land

-based processors (Knapp, 2010). Because of the uncertainty of the purchasing and process ing arrangement, fishermen and processors will often make an agreement for the fishing season or year. For example, a fisherman might agree to limit the processor’s supply to the quantity of fish that the processor is able to use. In return, the processor agrees to pay the fisherman a certain minimum price
. Additionally, fishermen may seek loans from processors for new fishing vessels and enter into a contractual agreement with the processor t hat requires a specified percentage of the catch to be provided t o that processor. Harvester
-processor agreements are sometimes broken by both parties, and s uspicions of collusion among processors often arise among harvesters. The mobility of the both the producers (harvesters) and, in some cases, the consumers (the pro cessors) can result in a highly competitive environment for an often limited resource. The competition for fish, the volatility of supply, and the res ulting effects on revenues mean that the financial picture at seafood processing establishments can vary w idely from year to year (Knapp, 2010 ).

Source: Alaska Department of Fish and Game, 2010 ; International Pacific Halibut Commission ( IPHC, 2010). Halibut Ex

- vessel Price was calculated by using ADFG average ex

- vessel price for all Alaskan locations. Source: ADFG, 2008.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

11 Beyond the ex

- vessel price, processors also pay a range of taxes. These taxes might include a landing tax 10 , fish business tax, or raw fish tax. For example, seafood processors pay a fisheries business tax “based on th e price paid to the fishermen for the unprocessed fisheries resource” and the value paid depends on the species of fish (ranging from 1 to 5%) as well as the type of processing that will be undertaken (Alaska Department of Revenue , 2010). The state returns half of the collected tax to the community in which the processor is located. Some communities use the fisheries tax revenues for activities related to fishing and seafood processing, while others use the tax revenues in their general funds for the town ( roads, schools, library, etc.) ( Alaska Department of Commerce, Community, and Economic Development (DCCED) , 2010). **3.0 AL**  **AS KA** 

**SEA FOOD**  **PROCESSING FA** **CILITIES A**  **ND FIRMS I**  **N T**  **HE PETITIONING NON**  **- REMOTE PROCESSING LO**  **CA TIONS**  **A ND A**  **DDITIONA L**  **REMOTE PROCESSING LOCA** 

**TI ONS**  **O F INTEREST**  This section discusses the firms and facilities in several smaller areas of Alaska or “seafood processing locations” which could be affected by EPA’s final amended regulations. The primary focus of this section is the 14 facilities in the non

- remote processing locations that are considered by EPA to be “petitioning locations” (see Section 3.1 for the identification of these facilities). As noted, these petitioning locations include Anchorage, Cordova, Juneau, Ketchikan, and Petersburg. While Kodiak is a non - remote location, it is not a petitioning location, and no direct discharge is occurring in Anchorage at this time. Neither of these locations is discussed further in this report. This section also presents profile information on two additional locations currently classified as remote that EPA’s 1981 proposal solicited comment on considering including as non

- remote locations (Dutch Harbor and the Kenai Peninsula) plus one additional location identified during this up date and (Sitka), and which are associated with 16 facilities. These are considered the remote locations of interest. Other possible additional locations are not discussed in any detail. Finally, no nearshore, offshore processing, or floating processors are profiled, because these facilities were not covered by the original effluent limitations guidelines and thus are not within EPA’s focus at this time. However, with the growth of floating processors in Alaskan waters, since the mid

- 1980s the ELGs also hav e been applied to many of these floating processors in a general permit as necessary and appropriate . Information collected by EPA from nearshore and offshore floating processors has provided helpful contextual information to assist in better understanding land

-based processing operations in comparison to the rest of the industry in Alaska. Figure 3 shows the State of Alaska with the petitioning locations and the other locations of interest located on the map. With the exception of Dutch Harbor , salmon repr esents the vast majority (more than 90%) of the seafood processed in each of the processing locations discussed in this section.

10 The Alaska Department of Re venue defines landing tax as a tax levied on fishery resources that are processed outside of the state of Alaska but are first landed in Alaska. The amount paid is based on the unprocessed weight of the resource (A laska Department of Revenue, 2010).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

12 **Figure 3. Map of ADFG Harvest Areas with Seafood Processor Locations** 

Section 3.1 presents an overview of the direct discharging facilities (both petitioners and those in the locations of interest). The section first discusses the facilities in the non

- remote processing locations involved in the petition (Section 3.1.1) and then discusses the facilities in several remote locations of interest that EPA is considering to determine whether they now have attributes similar to non - remote locations (Section 3.1.2). Section 3.2 then presents an overview of the owner firms of the direct discharging facilities, first in the petitioning locations (Section 3.2.1), then in the remote locations of interest (Section 3.2.2). **3.1. O**  **VERVIEW O**  **F F**  **ACILITIES AND F**  **IRMS** This section describes the land

-based seafood processing facilities and firms holding effluent discharge permits in the non

- remote, petitioning processing locations (Section 3.1.1) and remote locations of interest (Section 3.1.2). Table 3 summarizes basic information on the facilities in these two groups of locations. **3.1.1. Petitioning Non**  **- Remote Processing Location Facilities**  This section provides brief summaries of the facilities that are currently located in the non

- remote processing locations that petitioned EPA (see Section 1). Sources for this information are primarily Source: Map with harvest areas taken from ADFG, 2010. Processing locations added by EPA
.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

13 corporate websites unless otherwise cited
. 11 Fourteen distinct discharging facilities are located in the petitioning locations, of which EPA surveyed 11 facilities f rom data received for the nine entities which received information collection requests. The three facilities not surveyed are identified in their descriptions, which are presented below. The information submitted by the respondents to the survey included b oth technical and financial data to support analyses of costs and impacts associated with meeting the requirements for non

- remote seafood processing discharges as described in Section 1. EPA reviewed the financial information submitted for the 11 facilitie s. All of these facilities are considered financially viable as of 2009. Additional financial details from the survey, however, are considered Confidential Business Information (CBI) and are not provided here. See Report to the Record Cost and Economic Im

pact Analysis for Alaska Seafood Processors (Facilities and Firms) 2013, DCN XXXXX. **3.1.1.1. Cordova**  Cordova is the most northerly located petitioning location currently practicing direct discharge. It is located relatively near Anchorage and the Kenai Peninsula (s ee Figure 3). F our direct discharging facilities in Cordova process seafood. One is owned by a small, independent firm, Copper River Seafoods, which also has a facility in Anchorage that does not discharge directly . The other three are facilities owned by large firms that operate nationally, as well as in Alaska (Copper River, 2010; Ocean Beauty, 2010b; Trident Seafoods Corporation, 2010g). **Copper River Seafoods**

—In 1996, Copper River Seafoods took ownership of a 70

- year old processing plant in Cordova wh ere it now processes fresh, frozen and smoked seafood products using a variety of salmon, halibut, cod, and rockfish. The Cordova plant also processes salmon roe into ikura and sujiko 12

. Fresh fish, predominantly salmon, is shipped to Anchorage. Frozen fis h is exported. Copper River Seafoods’ Cordova plant operates from May 15 through September 15 and employs a portion of the company’s 150 seasonal employees
. **Ocean Beauty**

—The Ocean Beauty Cordova plant operates February through September. The plant processe s halibut, black cod, rockfish, and salmon. It is one of the largest producers of Copper River King and Sockeye salmon in Alaska
. **Norquest Seafoods (Trident South)** 

—The Norquest Seafoods (Trident South) plant is owned and operated by Trident Seafood Corporation , which took ownership in 2007
. The facility operates March through September and processes a variety of bottom fish, sable fish, halibut, and salmon. Salmon and halibut comprise the majority of the facility’s finished product
. **Trident Seafood Cannery (Trident North)** 

—Formerly owned by Bear and Wolf, the Trident Seafood cannery processes salmon from May through early September. In 2008, the plant produced more than 20 million lbs of canned salmon.

11 Thes e websites include: Copper River http://copperriverseafoods.com/ ; Ocean Beauty http://www.oceanbeauty.com/ ; Trident Seafoods http://www.tridentseafoods.com/company/history.php ; Alaska Glacier http://www.alaskaglacierseafoods.com/ ; Taku http://takustore.com/ ; Alaska General http://www.akgen.com/index.asp ; E.C. Phillips http://www.ecphillipsalaska.com/ ; Icicle Seafoods http://www.icicleseafoods.com/
12 Ikura is processed and salted roe, and sujiko is salted and cured salmon eggs.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

14

**Table 3. Facility Overview by Petitionin**  **g Locations and Locations of Interest Facility**  **(By location) Owner Firm or Parent**  **Employment Type of Products**  **Type(s) of Seafood Used** Facilities in Petitioning Locations Cordova Copper River Seafoods −Cordova Copper River Seafoods 150 Fresh ,frozen, smoked, and roe Salmon, halibut, cod Ocean Beauty−Cordova Ocean Beauty Seafoods NA NA Halibut, black cod, rockfish, and salmon Norquest Seafoods Trident Seafood Corporation NA NA Bottom fish, sable fish, halibut, and salmon Trident Seafood Cannery Trident Seafood Corporation NA Canned Salmon Ju neau Alaska Glacier Seafoods Alaska Glacier Seafoods 70 Fresh and Frozen (whole and fillet), roe Chum salmon, black cod , halibut, rockfish, crab, spot prawns, sea cucumbers, various ground fish Taku Fisheries Alaska Seafood Holdings (parent) NA Fresh, frozen, and smoked Salmon, halibut, black cod Ketchikan Alaska General Alaska General NA Canned, Fresh and frozen , roe Salmon E.C. Phillips and Son, Inc E.C. Phillips and Son, Inc. NA Fresh and Frozen Salmon, halibut, rockfish, shrimp, cod, herring, sea cucumber and geoduck Pacific Sun Products Coastal Fisheries, LLC NA Fresh, frozen, and canned Salmon Ketchikan Cannery Trident Seafood Corporation NA Canned and roe Salmon Trident Seafoods Trident Seafood Corporation NA Fresh and Frozen Salmon, sea cucumbers, prawns, and crab Petersburg Icicle Seafoods Icicle Seafoods, Inc. (Paine & Partners, parent) 500 Fresh/frozen, canned, and value

- added products Salmon, halibut, cod, crab (various species)PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

15

**Facility (By location)**  **Owner Firm or Parent Employment**  **Type of Products Type(s) of Seafood Used**  Ocean Beauty−Petersburg Ocean Beauty Seafoods 160
- 180 Ikura, Fresh/frozen and canned Salmon Trident Seafoods

− Petersburg Trident Seafood Corporation NA NA Salmon, halibut, black cod, and rockfish Non
- Petitioning Facilities in Locations of Interest Dutch Harbor Alyeska Seafoods Maruha Nichiro Holdings (parent) NA Fresh and frozen Crab Bering Star Fisheries, LLC * Copper River Seafoods and Siu Alaska (Norton Sound Economic Development Corporation) NA NA NA

UniSea Nippon Suison Kaisha (parent) 450
- 950 13 Surimi, fresh, and frozen Cod, halibut, pollock, snow and king crab Westward Maruha Nichiro Holdings (parent) 220 14 NA Pollock, cod, halibut, and crab Kenai Peninsula Inlet Fish Producers Kenai Inlet Fish Producers 200 (total for both facilities) Fresh and frozen Salmon and halibut Inlet Fish Producers Kasilof Inlet Fish Producers NA Fresh and frozen Salmon and halibut Ocean Beauty−Nikiski Ocean Beauty Seafoods NA Fresh and frozen Salmon Pacific Star Seafoods Double E Seafoods, LLC NA Fresh/frozen and smoked products Salmon, sablefish, halibut, cod, and rockfish Salamantof Seafoods Salamantof Seafoods NA NA Cod, rockfish, halibut, and salmon Snug Harbor Seafoods Snug Harbor Seafoods 200 Fresh, frozen, and smoked Sablefish, rockfish, cod, halibut, and salmon

13 Hoovers, 2010d and corporate website. 14 Manta, 2011b. * A processor newly opened after the period of time covered in EPA’s analyses and thus not considred.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

16

**Facility (By location)**  **Owner Firm or Parent Employment**  **Type of Products Type(s) of Seafood Used**  Icicle Seafoods Icicle Seafoods, Inc. (Paine & Partners, parent) 300 Fresh/frozen, canned Black cod, halibut, and salmon Polar Seafoods Polar Equipment NA NA Salmon and groundfish Resurrection Bay Seafoods (Sea Level Seafoods) Pacific Seafoods (parent) NA NA Cod, rockfish, sablefish, and halibut The Fish Factory (City of Homer permit) The Fish Factory 20
- 49 Fresh and frozen NA Sitka Silver Bay Seafoods [a] Silver Bay Seafoods 200 Fresh, frozen, and roe Salmon, halibut, crab, and herring North Pacific Seafoods (Sitka Sound Seafoods) Marubeni Corporation 220 (North Pacific) NA Salmon, halibut, sablefish, rockfish, herring, sea cucumbers, cod, shrimp and Dungeness crab Seafood Producers Cooperative Seafood Produc ers Cooperative NA Fresh, frozen, roe, and bait Salmon, halibut, bottom fish, sablefish and herring Source: Where not cited, information is from corporate websites (see footnote 9). Note: NA represents information that is not publically available. [a] The City/Borough of Sitka is the NPDES permit holder for the outfall used primarily by Silver Bay Seafoods.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

17 **3.1.1.2. Juneau**  Ju neau is located on the mainland of Alaska in the area known as the Inside Passage of the Alexander Archipelago, which is where most of the discharging petitioning location facilities are located (see Figure 3). Juneau is home to two small direct discharging seafood processors. **Alaska Glacier Seafoods**

—The Alaska Glacier Seafood (AGS) plant is located on Auke Bay, about 13 miles north of downtown Juneau. The plant is five years old and processes small volumes of a wide variety of seafood such as fresh an d frozen salmon and crab along with cod, sea cucumbers, halibut, shrimp and prawns. Nearly 80 percent of production goes into making fillets, while the remainder of production is whole fish. AGS operates March through November and processes approximately s even million pounds of seafood a year. The facility employs 70 people during the peak season
. **Taku Fisheries**

—The Taku Fisheries plant is located in downtown Juneau, immediately adjacent to the cruise ship docking area and the Mount Roberts tramway. It was built in 1994 and has a footprint of 44,000 square feet. Taku operates a retail store, mail/Internet sales, as well as wholesale. Taku and Icy Strait Seafoods , the latter of which is located in Washington State , are sister companies and wholly owned subsi diaries of Alaska Seafood Holdings, Inc
. Taku Fisheries produces a variety of frozen, smoked, and value

- added salmon products. The plant operates 10 months per year, processing an average of seven million pounds of seafood annually. About 60 to 70 percent of production is salmon (usually higher value fish such as s ockeye and king and little pink). Taku also processes halibut, black cod, rockfish, and crab ( king, t anner, and D ungeness). Most of the production is whole fish (headed and gutted), frozen and bar ged out to Seattle. In 2010, Taku employed 40 foreign student workers in the United States on J
- 1 visas as well as 30 workers residing in Juneau. This facility and its firm were not surveyed by EPA.

**3.1.1.3. Ketchikan**  Ketchikan, also located in the Alexander Archip elago/Inside Passage region, is at the southern entrance of the Inside Passage (see Figure 3). It is the location of the largest number of direct discharging facilities in the petitioning locations. Five discharging facilities operate here, two of which are owned by Trident. **Alaska General**

— Alaska General’s Ketchikan plant began operating in Ketchikan in 1906 as the New England Fish Company and was later purchased and operated by the Canadian Fishing Company in 1990 under the name of Kanaway Seafoods. The current company, Alaska General Seafoods, was established in 1999 after the assets from Kanaway Seafoods, Nelbro Packing Co. and Alaska General Processors were combined to form Alaska General Seafoods. Today, the plant operates on a seasonal basis from June through mid September. AGS takes the plant out of winter storage in April. Salmon canning operations begin in the 4th week of June and last until the end of August. The plant produces fresh, frozen, and canned salmon and herring products. About 85 percen t of their production is canned pink salmon; the remainder is fresh and frozen salmon

- pink and other species. This facility and its firm were not surveyed by EPA. **E.C. Phillips and Son, Inc.**

—E.C. Phillips has operated in Ketchikan since 1926 (almost 85 y ears).The E.C. Phillips facility processes a variety of fresh and f rozen seafood including salmon, halibut, ling cod, geoduck, spot shrimp, herring, and sea cucumbers. The plant was built in 1950 and operates year round. When sal mon season ends in October, the plant begin s processing dive fish (sea cucumbers and geoduck) and continue s to process salmon that was frozen in the summer months into portions and fillets. The final products from this facility are packaged into boxes and transported in shipping con tainers all over the world. Fish are sold fresh and frozen, whole with head on , headed and gutted, filleted and portioned. The company employs between 200 to 250 workers, with approximately 1 90 positions attributed to summer processing. A seasonal employe e may work 450 to 600 hours in the four

- month season.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

18 **Pacific Sun Products**

—Owned by Coastal Fisheries, LLC, Pacific Sun Products produces fresh, frozen, cured and canned seafood products. The entire variety of fish produced by the facility is not publically available but previously has included salmon and sea urchin roe. This facility and its firm were not surveyed by EPA. **Trident Seafoods (Norquest)**

—One of two plants that Trident owns in Ketchikan, this plant was owned by Norquest Seafoods until 2006. The plant produces primarily salmon, but it also processes a variety of other species such as halibut, geoduck, and cod. Unlike many of the other facilities in the petitioning locations, this facility is open year

- round
. **Trident Seafoods, Ketchikan Cannery**

—Thi s facility primarily processes canned salmon, but it does process sea cucumbers, prawns, and crab as well. The facility operates from June through October.

**3.1.1.4. Petersburg**  Petersburg is located on Mitkof Island, within the Alexander Archipelago’s Inside Passage, roughly between Ketchikan and Juneau, but across one arm of the Passage from these locations (see Figure 3). Three facilities regularly operate in Petersburg, all owned by large firms. **Icicle Seafoods**

—The Petersburg Icicle plant is the oldest seafood processing facility in Alaska. The plant operates February through November, processing salmon, pollock, halibut, cod, and a variety of crab. The facility processes fres h, frozen, canned, and value

- added products such as surimi. Most halibut is sold fresh, and all cod is frozen. Halibut heads are used for bait with 100 percent product utilization. The plant also processes a special form of spring herring roe (roe on kelp) , which is frozen and shipped to Japan. **Ocean Beauty**

—The Ocean Beauty Petersburg facility operates from April to mid

- September, seasonally employing between 160 and 180 workers . The facility produces ikura as well as fresh, frozen, and canned salmon. This plant closed temporarily in 2010 ( Trident , 2010b). **Trident Seafoods (Norquest )** 

—Previously owned by Norquest Seafoods, the Trident Petersburg facility processes salmon, halibut, black cod, and rockfish. The plant processes seafood from March through Novemb er . The Trident Mitkof plant, which was also previously owned by Norquest Seafoods , is associated with this plant. The facility was not operational in 2008 , although in 2007 , it processed salmon durin g the months of July and August. EPA is not analyzing th is facility. **3.1.2. Processing Locations of Interest Currently**  **Classified as Remote** This section provides an overview of the facilities that are located within areas currently designated as remote processing areas but that have a number of processors within geographical proximity of one another. Six of these facilities and their firms were surveyed. EPA reviewed the financial information for those surveyed facilities located on the Kenai Peninsula; the facilities surveyed in this location are considered financial ly viable as of 2009. Additional financial details are not provided here because of confidential business information considerations. The facilities in these locations that were surveyed are identified in their descriptions presented below. The facility d escriptions below are based on information found on corporate websites unless otherwise cited. 15

15 Available corpo rate websites include: Inlet Fish Producers http://www.inletfish.com/ ; Kenai Landing http://www.kenailanding.com/ ; Marubeni Corporation http://www.marubeni.com/division/food.html ; Maruha Nichiro Holdings http://www.maruha

- nichiro.co.jp/english/ ; Nippon Suison Kaisha http://www.nissui.co.jp/english/index.html ; North Pacific Seafoods http://northpacificseafoods.com/component/option,com_frontpage/Itemid,1/PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

19 **3.1.2.1. Dutch Harbor**  Dutch Harbor is remote by geographic standards, being located midway along the Aleutian Islands chain (see Figure 3). It is the port of Unalaska, o ne of Alaska’s larger cities. This harbor is one of the most active and largest (by production) fishing and seafood processing locations in Alaska (NMFS, 2010). There are three existing shore based processors in this location and one that is expected to be operational this year. The three existing facilities are all owned by Japanese firms. **Alyeska Seafoods**

—

Alyeska Seafoods processes fresh and frozen crab in its Dutch Harbor facility. Other facility

- level information is not made publically available. This f acility, its firm, and its parent company were surveyed by EPA. **Bering Star Fisheries, LLC**

—In August 2010, Copper River Seafoods and Siu Alaska Corporation announced that Bering Star Fisheries will be operating the Harbor Crown floating (barge) processing plant in Dutch Harbor beginning January 2011. Bering Star Fisheries was formed by the Dutch Harbor Acquisition LLC, a company comprised of Copper River Seafoods through Western Alaska Ventures LLC, one of its partners, and Siu Alaska Corporation, a wholly

- owned subsidiary of the Norton Sound Economic Development Corporation. The plant will be processing cod, halibut, and crab out of the previous Harbor Crown plant beginning in January 2011. Employee and revenue estimates are not yet available given that it is a start

-up facility. **Westward**

—This Dutch Harbor facility produces 254 million lbs of seafood annually
. Itis a sister facility to Alyeska Seafoods, with the same Japanese firm as its ultimate parent firm. Although the facility focuses on Alaskan p ollock, it also processes c od, h alibut, and a variety of c rab (Westward, 2010a). A total of 220 employees are considered to work at this location (Manta, 2011b). This facility, its firm, and its parent company were surveyed. **UniSea**

—

UniSea processes cod, halibut, pollock, snow and king crab, and surimi as well as white fishmeal and fish oil in its Dutch Harbor facility. The fishing season begins around January for crab, pollock, and cod and runs through mid

-November. The automated processing facility has the capability of processing 60 metric tons of seafood per hour. Information on how many of the company’s estimated 600 to 1200 workers are employed at this facility is not available.

**3.1.2.2. Kenai Peninsula**  EPA has grouped Seward, in the northeastern portion of the Kenai Peninsula, with more southerly and westerly areas near the cities of Kenai, Nikiski, and Homer, AK, to define the Kenai Peninsula processing center (see Figure 3). The ten discharging facilities that operate in this area are mostly relatively small. A few facilities initially identified as permitted dischargers have since been determined to no longer discharge regulated wastewater. Kenai Landing (Scientific Fisheries) is, at this time, operating only as a by

-product recovery plant, and Deep Cree k does not believe it will be subject to discharge permits going forward ( Deep Creek Custom Packing , 2011 ). These two facilities are not discussed further in this report. **Icicle Seafoods**

—The Seward Icicle facility processes black cod, halibut, and salmon i nto fresh, frozen, and canned seafood products. The plant also produces fishmeal. The season for cod and halibut runs from March 8 th through November 15 th , and the salmon season runs from June through the end of August. During salmon season, employment may reach 300 workers. This facility and its firm were surveyed. ; Pacific Star Seafoods http://eefoods.com/pdf/pacific.pdf ; Silver Bay Seafoods www. **silverbayseafoods** .com/ ; Snug Harbor Seafoods http://snugharborsea foods.com/index.html ; The Fish Factory http://www.thefishfactory.net/ ; UniSea http://www.unisea.com/ ; Westward Seafoods http://www.westwardseafoods.com/company.phpPROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

20 **Inlet Fish Producers (Kenai)** 

—Inlet Fish Producers Kenai facility operates from June through early September with the peak season from early July until mid

- August. Approximately 250 seasonal workers are hired to work in the plant to unload, butcher, and freeze the fish (combined with the Kasilof facility employment). This facility and its firm were surveyed. **Inlet Fish Producers (Kasilof)**

—Inlet Fish Producers (Kasilof) operates from June through e arly September, with the peak season from early July until mid

- August. The seasonal workers (counted with the Kenai plant employment) are hired to work in the plant to unload, butcher, and freeze the fish. This facility and its firm were surveyed.

 **Ocean Be auty** 



### —Ocean Beauty’s Nikiski plant processes frozen (and some fresh) c oho , c hum , pink, sockeye, king salmon , s a lmon roe, halibut and c od during a season that generally runs from the beginning of April through the end of October. This facility and its firm were surveyed. **Pacific Star Seafoods**

—Pacific Star processes s almon, sablefish, halibut, cod, and rockfish from more than 50 independent fishermen to produce fresh, frozen, and smoked products. The facility, which is owned by Double E Seafoods, operates fr om May through August. **Polar Seafoods**

—The Polar Seafoods facility, owned by Polar Equipment, processes fresh and frozen seafood. The facility processes groundfish from January through April and salmon from July through September. **Salamatof Seafoods**

— Salamat of Seafoods is affiliated with the Salamatof Native Association, Inc . The facility processes cod, rockfish, halibut, and salmon. **Sea Level Seafoods (Resurrection Bay Seafoods)**

—The Seward Resurrection Bay facility is owned by Sea Level Seafoods, which is b ased in Wrangell and is doing business as Resurrection Bay Seafoods. The parent company is Pacific Seafood Company. The facility processes cod, rockfish, sablefish, and halibut from March through mid

-November.

 **Snug Harbor**

—The Snug Harbor processing facility produces fresh, frozen, and smoked seafood products from sablefish, rockfish, cod, halibut, and salmon. The facility process seafood from March through November or until fish quantities are depleted for the season. Snug Harbor employs approximately 200 s easonal workers. This facility and its firm were surveyed. **The Fish Factory**

—The Fish Factory processes fresh and frozen fish at its facility in Homer, Alaska. The company is estimated to employ approximately 20 to 49 workers, but public information does no t specify whether these workers are all employed at the processing facility. Public information also does not mention types of fish or other processing particulars for this facility. The facility uses the City of Homer fish grinding facility that is owned and managed by the port and Harbor of Homer. The NPDES permit holder for the wastewater discharges is the City of Homer. The facility grinds and discharges fish waste from charter operations, sports fisherman, and The Fish Factory and operates from January through November. **3.1.2.3. Sitka**  Sitka is located on Baranof and Chichagof Islands on the western side of the Alexander Archipelago, about 100 miles from Petersburg, AK (see Figure 3). Of the four discharging facilities EPA initially identified, Absolute Fresh Sea foods appears to be out of business (it did not file discharge reports for 2005 through 2010 with either ADEC or EPA Region 10) and will not be discussed further in this report.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

21 **North Pacific Seafoods**

—The North Pacific Seafood processing plant in Sitka, also known as Sitka Sounds Seafoods, “processes all species of salmon from all gear types, halibut, sablefish, rockfish, herring, sea cucumbers, lingcod, Pacific cod, shrimp and Dungeness crab” (North Pacific Seafoods, 2010a). Processing occurs from March to the end of October, with the major salmon season occurring from mid

- June through September. The facility employs 220 workers during the peak season. **Seafood Producers Cooperative**

—The Seafood Producers Cooperative plant operates year

- round. The facility processes salmon, halibut, bottom fish, sablefish as well as herring bait and roe. **Silver Bay Seafoods**

— Silver Bay Seafoods is the largest seafood processing facility in Sitka, and one of the larger facilities among the discharging facilities in either the locations of interest or the petitioning locations. The facility discharges under a permit held by The City/Borough of Sitka through an outfall located on Saw Mill Road. Silver Bay is currently the primary processor using this outfall as of 2009. During 2 007 and 2008, Silver Bay jointly discharged through this outfall with Baranof Frozen Foods, which is no longer operating. The full variety of seafood processed by Silver Bay Seafoods is unknown, although it does include salmon. During the 2010 salmon seas on, 200 seasonal workers were employed for fish processing and facility maintenance. **3.2. F**  **IRMS O**  **WNING F**  **ACILITIES IN THE P**  **ETITIONING N**  **ON -**  **R EMOTE**  **P ROCESSING**  **L OCATIONS AND**  **R EMOTE**  **L OCATIONS OF**  **I NTEREST**  This section presents information on the firms that own facilities in the petitioning locations (Section 3.2.1) and the additional firms that own facilities in the locations of interest (Icicle Seafoods and Ocean Beauty Seafoods own facilities in both petitioning locations and locations of interest) (Section 3.2.1). T able 4 presents the firms with Alaskan processors discussed in these two subsections (those firms for which the facility information is all that is available, are not repeated here). The table is divided by firms of direct discharging processors in the petitioning locations and the firms with direct discharging processors in the remote locations of interest. Most employment and revenue figures are estimates made by firms that specialize in providing this information; some estimates may be better than other s. For the purposes of this profile, these estimates are considered approximate only. As the table shows, among the potentially affected petitioners, three firms have been identified as small, three firms have been identified as large, and three firms coul d not be identified by size and are presumed small. Among those in the locations of interest, five are identified as small, four are identified as large, and three could not be identified by size and are presumed small. **Table 4. Firms with Potentially Affe**  **cted Petitioning Alaskan Processing Facilities and Those with Facilities in the**  **Location s of Interest**  **Firm Headquarters** 

**Location Facility** 

**Locations Large or** 

**Small Firm Employment**  **Annual Revenue**  **($ millions)** Firms in Petitioning Location s Alaska General Seafoods 16 Kenmore, WA Ketchikan, Naknek Small 700 peak, less than 500 average NA Alaska Glacier Seafoods 17 Ju

neau Ju

neau Small NA NA Coastal Fisheries, LLC N/A Ketchikan NA NA NA

16 Source: Alaska General Seafoods, 2010a. 17 Source: Alaska Glacier Seafoods, 2010a.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

22 **Firm Headquarters** 

**Location Facility** 

**Locations Large or** 

**Small Firm Employment**  **Annual Revenue**  **($ millions)** (Pacific Sun) Copper River Seafoods 18 Cordova and

Anchorage Cordova,

Anchorage Small 175 seasonal $50

- $100 19 E.C. Phillips and Son, Inc
. 20 Ketchikan Ketchikan Small 200
- 250 seasonal NA Icicle Seafoods [a] 21 Seattle, WA Petersburg, Seward ( Kenai Peninsula) Large 500+ $400
Ocean Beauty Seafoods 22 Seattle, WA Alitka, Cordova, Excursion Inlet, Kodiak, Nakn e k, Petersburg, and Nikiski ( Kenai Peninsula) Large 500 $400

Alaska Seafood Holdings (Taku) NA Ju neau NA NA NA

Trident Seafood23 Seattle, WA Cordova, Ketchikan, Naknek, Akutan, Sand Point, St. Paul, Kodiak, Chignik, and Wrangell Large 2,510 $1,000

Additional Firms with Facilities in Locations of Interest Double E Seafoods, LLC 24 Seattle, WA Pacific Star, Kenai and Yakutat Seafoods, Yakutat NA NA $100
Inlet Fish Producers 25 Kenai Kasilof and Nikiski, AK Small 200 NA Maruha Nichiro Holdings (Al y eska and Westward) 26 Japan Alyeska Seafoods, Dutch Harbor, and Westward Seafoods, Dutch Large 14,094 $8,940

18 Source: Copper River Seafoods, 2010a. 19 Source: Manta, 2011a. 20 Source: E.C. Phillips and Son, 2010a. 21 Source: Icicle Seafoods, 2010a; Hoovers, 2010a. 22 Source: Ocean Beauty, 2010b; Hoovers, 2010e. 23 Source: Trident Seafood Corporation, 2010c; Hoovers, 2010f, Trident letter to Bristol Bay Borough, January 24, 2012. 24 Source: Double E Seafoods, 2010a; Hoove rs, 2010. 25 Source: Inlet Fish Producers, 2010. 26 Source: Marua Nichiro, 2010; Hoovers, 2010c.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

23 **Firm Headquarters** 

**Location Facility** 

**Locations Large or** 

**Small Firm Employment**  **Annual Revenue**  **($ millions)** Harbor and Kodiak Nippon Suison Kaisha27 Japan UniSea Seafoods, Dutch Harbor Large 8,801 $5,195 Marubeni Corporation (North Pacific Seafoods) 28 Japan (Seattle,

WA) Sitka, Kodiak,

Togiak, and Pederson Point Large 5,679 (parent) $35,384 (parent) Polar Equipment29 NA Kenai Peninsula , AK NA NA NA Seafood Producers Cooperative Sitka Sitka NA NA NA NA indicates information that is not publicly available
. [a] Icicle Seafoods is owned by parent company, Paine & Partners. [b] North Pacific Seafoods is owned by the Marubeni Corporation.

27 Source: Nippon Suison Kaisha, 2010; Hoovers, 2010d. 28 Source: Marubeni Corporation, 2010; Hoovers, 2010b. 29 Source: Manta, 2010.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

24 **3.2.1. Firms Owning Petitioning Processing Location Facilities**  Nine firms operate the 14 petitioning location facilities discussed above. Trident Seafoods Corporation owns five of the facilities (two in Ketchikan, two in Cordova, and one in Petersburg) and Ocean Beauty owns two (Cordova and Petersburg). The remaining firms operate one facility each in the petitioning locations, even though some of them own other facilities outside the petitioning locations. The facility information for the Alaska Glacier and E.C. Phillips facilities in Section 3.1.1 reflects the information available for the owner firms and is not repeated here. No publicly available information is available for Coastal Fisheries, LLC, the owner firm of the Pacific Sun facility or Alaska Seafood Holdings, which owns Taku. Some additional firm

- specific information is available o n the other six firms operating discharging facilities in the petitioning locations, which is presented below. Of the nine firms, six were surveyed (including Trident, Icicle, Ocean Beauty, E.C. Phillips, Copper River Seafoods, and Alaska Glacier). Based on the survey information provided on the firm

- level finances, EPA has determined that the firms were not in financial distress as of 2009 (U.S. EPA, 2011). EPA cannot provide additional financial details in order to protect confidential business informati on. All information presented here is from corporate websites (see Section 3.1.1) or is cited separately. **Alaska General Seafoods**

— Alaska General is based in Kenmore, Washington and operates two land

based processing locations in Alaska: one in Ketchikan an d the other in Naknek (Bristol Bay, a processing location currently classified as remote). The company also operates a fish camp in Egigek, where housing, food, and boat storage and repair are supplied to fishermen. The company, which employs an estimated 700 workers during peak fish production, produces fresh, frozen, and canned fish products from salmon and herring it purchases from hundreds of fishermen. The products are sold in North America, Asia, and Europe. **Copper River Seafoods**

—In 1996, three Alaska fisherman

- owned and operated companies, Copper River Catch, Copper River Fine Seafoods, and Copper River Wild, collaborated to form Copper River Seafoods. With facilities in Cordova and Anchorage , where the corporate headquarters is located , Copper River Seafoods processes fresh, frozen and smoked seafood products (Copper River, 2010a). The company’s revenues are estimated at $50 to $100 million and seasonal employees total an average of 175 workers between the two locations ( Manta, 2011a).

 **Icicle Seafo od**  **s , Inc** 
. —Icicle Seafoods began in 1965 as a local fisherman

- owned company, Petersburg Fisheries, Inc., in Petersburg, Alaska. The company was an early adopter of year

round processing and the use of floating processors which allowed fishermen to catch and process fish in the more remote areas of Alaska. Today, the company is owned by a private investment firm, Paine & Partners, and has estimated revenues of $400 million. Icicle employs an estimated 500+ year
- round workers at its headquarters in Seattle, WA , its aquaculture facility in Washington, and at its land

-based processing facilities in Seward, Homer, Egegik, Petersburg and Larsen Bay. Icicle also has support sites at Ninilchik, Dillingham, Dutch Harbor, and Naknek (Hoovers, 2010a), but its website l ists 500 employees (probably seasonal) at the Petersburg plant alone. The Petersburg plant is the only direct discharging facility owned by Icicle in the petitioning locations. The company also owns five floating processors
. Icicle processes a variety of fish , including salmon, crab, p ollock , halibut, and cod. Its facilities process fresh, frozen, canned, and value

- added products such as surimi. Icicle markets canned products under private, national, and Icicle

-brand labels (Icicle Seafoods, 2010a).
**Ocea n Beauty** 

—Ocean Beauty Seafoods is based in Seattle, WA and began processing Alaska seafood in the 1930s. Today, the company employs an estimated 500 workers at its headquarters, seven distribution locations separate from its headquarters facility, several processing facilities in the lower 48, and seven processing plants located in Alaska. Those seven processing plants are located in Alitka, Cordova,PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

25 Excursion Inlet, Kodiak, Naknuk, Petersburg, and Nikiski (Kenai). The Cordova and Petersburg plants are dis charging petitioning location facilities (with its Nikiski facility located in the Kenai Peninsula location of interest). The company produces fresh, frozen, canned, and specialty products from a variety of fish specific to each of the company’s seven Alas ka processing locations. Ocean Beauty revenues are estimated at $400 million and its products are shipped to the contiguous United States for national and international distribution (Hoovers, 2010e). **Trident Seafoods Corporation**

—Founded in 1973, Trident S eafoods Corporation operates multiple processing facilities in Alaska and the Pacific Northwest. In Alaska, Trident operates during both winter and summer seasons to produce a variety of fresh, frozen, canned and value added products utilizing crab, salmon , cod , halibut, perch, pollock, rockfish, and sole. The company owns a total of ten processing plants in Alaska. Five are located in the petitioning locations, including two in Cordova, two in Ketchikan, and one in Petersburg, with the remaining five located in locations classified as remote or non

remote non -petitioning [Kodiak]. The primary processing plants include “ a Southeast pink salmon cannery in Ketchikan; Bristol Bay sockeye salmon canning and freezing operations in North and South Naknek; diversi fied processing plants handling Alaska pollock, Pacific cod, Black cod, halibut and crab in Akutan, Sand Point, Kodiak and St. Paul; and groundfish processing in Kodiak. ” Trident also operates four by

-product processing plants, located in Akutan, Chignik ( on the Alaska Peninsula heading out towards the Aleutians), Cordova, and Wrangell (near Petersburg). Another by

-product recovery facility is being built in Naknek. Trident currently employs an estimated 2,510 workers with company revenues reaching $1 billi on (Trident, 2010c; Hoovers, 2010f, Trident 2012) **3.2.2. Other Firms Owning Remote Facilities in Procressing Locations of Interest**  **(Dutch Harbor, Kenai Peninsula, Sitka)** Sixteen firms own discharging facilities in the remote locations of interest. Several of thes e firms, some of which are owned by parent companies, were either surveyed as the owner of a petitioning location facility or as an owner of a facility in a location of interest. Surveyed firms are noted in the discussions below. EPA obtained all informat ion obtained from corporate websites (see Section 3.1.2) unless otherwise cited.

**3.2.2.1. Dutch Harbor**  Four firms own the three existing facilities and one newly opened facility in Dutch Harbor. Three of these firms are, in turn, owned by two large Japanese firms. The newly re

- opened Bering Star Fisheries (formerly Harbor Crown Seafood) floating processing facility [see pg 19] is owned by Copper River and Siu Alaska under their joint venture, Dutch Harbor Acquisitions LLC 30 (Siu Alaska Corporation, 2011). Additional profile information is not readily available for Siu Alaska or the jointly held corporate entity. Although two of these firms, Alyeska and Westward, as well as their parent were surveyed, EPA has not assessed the financial health of these firms at this time. **Maruha Nichiro Holdings (Alyeska and Westward Seafoods)**

**—**One of Japan’s largest seafood producers, Maruha Nichiro was established in 2007 when Nichiro and the Maruha Group merged. The company has four divisions , including fishery operations (fresh, fro zen, and canned products), food operations, meat (chicken, pork, and processed meats), and storage and logistics. Maruha Nichiro has fishing and aquaculture operations in Japan, Alaska, and China. The company has two seafood processing subsidiaries in Alas ka: Alyeska and Westward Seafoods. Maruha Nichiro currently employees approximately 14,094 workers with annual revenues reported at $8,940 million. Top company competitors include Nippon Suison Kaisha, which also operates a seafood processing plant in Alas ka

30 Siu Alaska is a for

- profit, wholly owned subsidiary of the Norton Sound Economic Development Corporation (siualaska.com).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

26 (UniSea). Its subsidiary, Alyeska Seafoods, also processes fresh and frozen crab in its Dutch Harbor facility. This subsidiary employs 340 workers and its annual revenue information is not publically available (Hoover’s 2011). Westward Seafoods also ope rates a processing facility in Kodiak. The main processing plant is its Dutch Harbor facility, which focuses on Alaskan pollock. Its Kodiak location processes a variety of finfish and shellfish from the Bering Sea and Gulf of Alaska. The company employs an estimated 220 workers. Information pertaining to annual revenues is not publically available. Both Alyeska and Westward, along with their parent company and other subsidiaries and facilities owned by Maruha Nichiro, were surveyed. **Nippon Suison Kaisha ( UniSea)** 

— Nippon Suison Kaisha, more commonly known as NISSUI, is the second largest producer of marine products in Japan. Production of fresh and frozen seafood products accounts fo r one - third of the company’s $5.2 b illion annual revenue. The company owns the U.S. fish company, Gorton’s, and is the parent company to Alaska seafood processor, UniSea. NISSUI employs 8,801 workers and, aside from seafood, has business segments involved in chemical and pharmaceutical production, cold

- storage, third

-party logisti cs, engineering services, and shipbuilding and repair. UniSea, its wholly owned subsidiary , processes cod, halibut, pollock, snow and king crab, and surimi 31 as well as white fishmeal and fish oil in Dutch Harbor, AK . It also maintains a cold storage facility in Redmond, WA. The company obtains its catch from a variety of independent Alaskan fisherman and listed 40 vessels as its fleet in 2001. UniSea employs an estimated 600 to 1 , 200 workers . Employment varies according the fishing seasons’ production level s. UniSea products are marketed under the brand titles Uni Sea, Dutch Harbor, and GLS. Fish oil is recovered from the waste and is marketed in Taiwan and Japan and also fuels the processing plant. Information pertaining to annual revenues is not publically available. **3.2.2.2. Kenai Peninsula**  Nine firms own the 10 discharging facilities in the Kenai Peninsula. Three of the firms owning the Kenai Peninsula location facilities are single

- facility firms, including The Fish Factory, Salamatof, and Snug Harbor, which EPA surveyed. The information presented for the facility applies to the firm and is not repeated here. Another two firms, Icicle and Ocean Beauty (also surveyed), were discussed previously. No public information on the owner firm for Polar Seafoods was found. The remaining three firms are discussed here. The details of the financial status of firms owning facilities on the Kenai Peninsula processing location that were surveyed are not discussed to protect confidential business information, but they are not considered to be currently (2009) in financial distress (EPA, 2011). **Double E Seafoods, LLC (Pacific Star)** 

—Based in Seattle, WA, Double E Seafoods focuses on Alaska and North Pac ific Seafood. Also known as E & E Seafoods, the company’s services include fresh and frozen seafood processing, marketing, and import export services. Sales from all Alaskan facilities in 2008 are reported at $100 million (Double E Seafoods, 2010b). Double E Seafoods is the parent company for both Pacific Star and Yakutat Seafoods, which is classified as remote and is located between the northern end of the Inside Passage and Cordova. EPA did not find Double E Seafoods employment numbers in publicly availab le information. **Pacific Seafood Company (Sea Level Seafoods)**

**—**Pacific Seafood Company owns Sea Level Seafoods, which in turn owns the Resurrection Bay facility (EPA’s CBI economic impact results report uses the Sea Level Seafoods name for this facility). P acific Seafood Company reports that it operates processing plants “ stretching along the Pacific Coast from Alaska to Mexico and distribution facilities in Washington, Oregon, California, Utah, Nevad a, Arizona & Texas,” with its headquarters located in Oreg on. EPA did not find information on revenues and employment.

31 Surimi is minced, processed fish used in the preparation of imitation seafood (Freedictionary.com, 2011).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

27  **Inlet Fish Producers**

—Inlet Fish Producers operates two processing plants, one on the Kenai River and the other on the Kasilof River . B oth are considered to be located in the Kenai Peninsula proce ssing location. The plants process salmon from May through September as well as halibut
. Approximately 250 seasonal employees work at these facilities. Annual sales are estimated at $9.6 million (Hoovers, 2010g). This firm was surveyed. **3.2.2.3. Sitka**  Three firms own the three discharging facilities located in Sitka. No firms in Sitka were surveyed. **Marubeni Corporation (North Pacific Seafoods)** 

—The Marubeni Corporation is a Japanese general trading company with 11 divisions including: Chemicals; Energy; Finance, Lo gistics & IT Business; Food; Forest Product; Lifestyle; Metals & Mineral Resources; Real Estate; Plant, Ship & Industrial Machinery; Power Projects & Infrastructure; and Transportation Machinery. The company e mploy ed 5 ,679 workers in 2010 and its revenues are reported to be $35 billion. North Pacific Seafoods is Marubeni’s subsidiary and is h eadquartered in Seattle, WA. With an estimated 800 employees, North Pacific Seafoods has four land

-based processing plants in Alaska that are located in the remote and n on remote processing locations of Sitka, Kodiak, Togiak (west of Bristol Bay) , and Pederson Point (Bristol Bay area) . Focusing on fresh, frozen, and value

- added specialty products, the company catches, processes and distributes a variety of seafood produ cts, including salmon, tuna, halibut, pollock, cod, rockfish, flatfish, crab, shrimp, caviar, squid, sea cucumbers, and roe. **Seafood Producers Cooperative**

—The Seafood Producer’s Cooperative states that the firm focuses on line

- caught halibut, sablefish, sa lmon, rockfish and albacore. Its headquarters are located in Bellingham, WA. The firm claims to be “the largest and most successful fishermen’s cooperative in North America [w]ith more than 500 extraordinary fishermen.” **Silver Bay Seafoods --**  Silver Bay indicates that it is a predominantly fisherman

- owned firm and has additional facilities located in Valdez (near Cordova) and Craig, AK (near Ketchikan); both are in remote locations . The firm’s focus is on salmon, but it also processes herring roe. The Sitka facility serves as corporate headquarters. Revenues at this relatively new firm, established in 2006, are estimated at $16.8 million with a staff of 185 employees, who are most likely seasonal (Manta, 2011). **4.0 CURRENT**  **INDUSTRY PRA CTICES F**  **OR MA NA** **GING WA ST**  **E 4.1.**  **G ENERAL**  **W ASTE**  **M ANAGEMENT**  **P RACTICES**  Researchers estimate that approximately 60 percent of the total weight of processed seafood resources is used for the intended fish product, while the other 40 percent is considered waste (Bimbo, 2008). The processin g waste generated includes unwanted seaf ood parts such as heads, fins, shells, and bones. The amount of waste generated varies by the type of seafood species proces **s** ed as well as the product being produced. Globally, an estimated nearly 60 million tons 32 of seafood processing waste is generated per year. Alaska alone produces more than one million tons of fish processing waste annually33 (Bimbo, 2010). The choice of seafood waste management methods involves economic considerations, with the cost of a disposal method (e.g., grinding and near

- shore discharge of the resulting wastewater or screening and nearshore discharge of resulting wastewater and offshore disposal, or the cost to process the screened solids for reuse in by

-product recovery) taken into account . Fuel and vessel operating prices (e.g., labor), equipment costs (for grinding or secondary processing), and offsetting income from by

-product marketability (and, thus, potential revenue from sale of recovered by

-products offset costs of that
32 Estimate calculated as 40 percent of 2008 global fish production , (142 million tons) being waste (NMFS, 2010). 33 Estimate based on 46 percent waste of average Alaska seafood landing of 2.43 million tons (Bimbo, 2010).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

28 processing), factor into the processors’ disposal decisions. Other, non

- economic, factors also play a role. These include regulations, such as the ELGs, local requirements, and the availability of cooperative, or collective, by

-product processing, where several seafoo d processing facilities make use of by

-product processing facilities operated by other firms. The availability of collective by

-product processing, in turn, contributes to economic decision making. Historically, fish wastes have been disposed of through of fshore disposal or discharge. Emerging markets, however, have begun to capitalize on the beneficial nutrients in fish wastes such as proteins, omega three fatty acids, and phosphorous (species dependent) resulting from fish waste that can be processed into secondary products or by

-products (Bimbo, 2008). The next section begins by describing the principal seafood by

-products including fishmeal, bone meal, fish oil and hydrolyzed protein, plus five others. This is followed by a discussion of the market for b y products, current by

-product facilities in Alaska, and volume of Alaskan seafood by

-products available for future markets. **4.2. S**  **EAFOOD B**  **Y -**  **PRODUCTS 4.2.1.**  **Fishmeal**

“ Fishmeal is a brown powder obtained after cooking, pressing, drying and milling fresh raw fish and/or fish processing waste” (IFFO, 2010). Fishmeal is made most frequently through a wet process where the fish waste is cooked so that the fish oils and wat er in the fish are released, and the proteins start coagulating. The coagulated mixture is then separat ed by pressing the solids into a press cake. Any remaining liquids and solids are placed in a decanter where the oils are separated through centrifugation. The resulting oil is added back to the presscake. The presscake is then dehydrated and milled (FAO, 20 10 )
. Fishmeal is a desirable product because it contains protein (60 % to 2%), omega 3 fatty acids, vitamins, and minerals (Bimbo, 2008; IFFO, 2010). The grade and quality of fish meal depends on the sources and types of fish used to make it. The types of fish used to produce fishmeal are often oily, boney fish (such as menhaden and anchovies) that are not in high consumer demand for consumption. Fish trimmings from whitefish and herring (which have lower oil content) comprise, roughly, 25 perce nt of fishmeal content produced (IFFO, 2010)
. Due to its nutritional value, fishmeal can be used as a feed ingredient for farm animals to balance dietary needs, and more recently, it has been used as feed for fish in hatcheries (although fish cannot be fed fishmeal made from their own species) (Bimbo, 2008; IFFO, 2010). **4.2.2. Bone Meal**  When fishmeal is screened to remove the bones, the resulting bone material can be ground to form the product known as bone meal. Fish bones are often removed during processing to increase the protein content and reduce phosphorus levels of the product being made (Bimbo, 2008). Bone meal may be used as a feed additive or in products such as fertilizers as protein and mineral supplement. Bone meal traditionally has been produced from ruminant s, but since the outbreak of mad cow disease, Canada, the United States, and Europe have prohibited meals made from those sources, creating a market opportunity for fish meals (Finstad et
. al
. , 2010 ). Bimbo (2008) also notes the benefits of using bone meal as a mining and petroleum waste water treatment to remove metals. This potential in

- state use in of bone meal Alaska would also be beneficial because it would help reduce product shipping costs of the bulky material.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

29 **4.2.3. Fish Oil**  Fish oil is extracted from fish processing wastes using several different methods as described by Sathivel et
. a l
. : “(1) ground fish are homogenized with water, the homogenized mixture is centrifuged34 , and fish oil is separated; (2) ground fish (no added water) is heated and centri fuged, and fish oil is separated; (3) fish oil is extracted by rendering 35 ; and (4) ground fish is hydrolyzed using commercial enzymes and the oil collected by centrifugation” ( Sathivel et. al., 2010 ). Fish oils are divided into two main categories: commo dity oils and nutraceutical oils. Commodity oils are bulk oils which themselves are divided into two types: food grade and non

- food grade. Food grade oils must be produced under carefully controlled circumstances (e.g., input materials iced or kept under refrigeration) and are regulated by the Food and Drug Administration. Non

- food grade oils have few handling requirements. Nutraceutical fish oils also go through additional refining processes compared to raw, commodity oils used in feed (Bimbo, 2008). Fi sh oils have several uses, depending on their type. F ish oil s high in Omega 3 fatty acids are used as a dietary supplement in feed for farmed fish. Refined nutraceutical fish oil is used to produce omega - 3 health supplements and oils for human consumption ( IFFO, 2010). In Alaska, non

- food grade fish oil is often mixed with diesel fuel to extend energy sources that help fuel processing facilities (Bimbo, 2008). For example, the Alaska Energy Authority (AEA) reports that UniSea in Dutch Harbor uses fish oil, produced largely from pollock processing waste by its own by

-product recovery facility, to replace about 50 percent of the volume of fossil (diesel) fuel that would be used to generate electricity to operate the processing plant (AIDEA, 2011). Trident’s fa cility at Akutan near Dutch Harbor also uses fish oil to replace diesel fuel used to generate electricity to operate the processing plant. **4.2.4. Hy**  **droly zed Protein**  Hydrolyzed protein, also known as fish hydrolysate, is created through the process of hydrolysis whereby proteins are broken down by adding strong acidic or basic chemicals or enzymes to fish waste in order to facilitate the breakdown process. This method allows the functional proteins of the fish waste to be extracted and converted into a soluble protein that can be integrated into both food and non

- food products. Chemical hydrolysis is a relatively quick and inexpensive way to create a soluble protein; however, the taste can be bitter and cause some loss of the protein’s functionality. This type of hydrolysis is used mainly for fertilizers. Enzymatic hydrolysis, on the other hand, is easier to control than chemical hydrolysis. While it is more expensive, enzymatic hydrolysis may be used to produce products such as sauces, silage, and fish feed. Current studies are gauging the protein functionality, taste, and solubility of products made using the enzymatic method (Sanmartin et. al., 2009). **4.2.5. Montlake Process**  The Montlake Process “combines wet reduction technology, acid stabilization, and drum drying of fi sh waste” to produce high protein

–low ash meal, oil, and gelatin (Nicklason et
. a l
. , 2010). The process de

-bones muscle

- containing fish and then cooks and decants the recovered muscle tissue to produce meal cake and oil. Nicklason et al go on to describe the remainder of the process as follows: “Raw wet viscera are ground and combined with the decanter cake to form a blended meal. The blended meal can be immediately dried on a drum dryer or stabilized with 0.8% formic acid and stored for later drying. The finished meal is high in protein and low in ash, and has good binding properties that allow a rugged feed particle to be extruded with no added gelatinized starch as is

34 A centrifuge works by rotating the mixture around a fixed axis at a speed that causes the large particles to settle at the bottom of the mixture, while the lighter particles rise to the top. 35 “ Rendering is a process in which high heat is used to extract fat or oil primarily from animal tissues. ” The process can be completed using wet or dry products (Sathivel, 2009).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

30 the case with conventional fish meal

– based feeds. In a separate processing line, a crud e gelatin fraction is extracted from the bones by wet heat and straining. The crude gelatin is also dried on a drum dryer. Short

- term storage of material reduces equipment requirements and increases working days for a given amount of material. This, in tur n, allows the design of portable process units that can service more than one fishery and further extend operating days.” (Nicklason et
. al, 2010)
. **4.2.6. Compost and Crop Nutrient**  Fish processing by

-products such as fish and bone meal, hydrolysates and fish oi ls have proven to be beneficial as a compost, fertilizer, and crop nutrient in both Alaska and the broader United States. These by

-products can increase nitrogen and micronutrient (such as calcium and zinc) levels in soils (Zhang e t. al., 2010 )
. **4.2.7. Modified S**  **ilage** Modified silage is created by adding organic compounds to fish waste to slow the breakdown of proteins and bacterial activity. By slowing this process, the modified silage is stable enough for transport to a facility that can process it into fishmeal or oil (Browning, 2010 )
. **4.2.8. Chondroitin Sulfate (CS)**  CS is an important structural component of connective tissues, such as cartilage, and has become a dietary supplement commonly taken for osteoarthritis. Stine et al show that fish heads resulting from sea food processing are a viable source of CS (Stine et
. a l
. , 2010 )
. **4.2.9. Dried Salmon Fish Heads**  A by

-product of fish processing, salmon fish heads contain healthy lipids associated with brain development, decreased cardiovascular disease, and retina development in infants. With annual tons of salmon fish heads numbering near 65,000 tons, researchers have been experimenting with a variety of drying temperature techniques ( Smiley et
. al
. , 2010 ). **4.2.10. Chitin**  Chitin is a natural biopolymer with a chemical structure simil ar to that of cellulose and is recovered mainly from the shells of crabs and shrimp. According to Troger and Niranjan (2010), “i n order to obtain purified Chitin, it must be separated from the proteins, minerals and other components. This separation is achieved in three steps: 1) de

- minerali s ation to eliminate the calcium carbonate, 2) de

proteinisation, and 3) elimination of lipids and decolourisation. ” Chitin can be extracted from these seafood shells chemically or biologically. “Chemical extraction uses inorganic acids for de

mineralisation, alkali for de

-proteinisation and organic solvents for the elimination of lipids and color” while biological extraction involves fermentation and enzyme extraction (Troger and Niranjan, 2010)
. Alaska has not been a maj or player in the chitin industry because financial considerations make it more cost effective to ship the shells to China and to produce products there (FITC, 2010). **4.3. M**  **ARKETS FOR S**  **EA FOOD**  **P ROCESSING**  **B Y**  **- PRODUCTS**  Three by

-product markets are discussed in this section : fishmeal, fish oil, and hydrolysate, because they are the by

-products currently being made in any notable volumes by Alaska by

-product producers. Although established markets for traditional seafood by

-products such as fishmeal and fish oil do exi st, markets for non

- traditional by

-products such as hydrolyzed protein are still emerging (Bimbo, 2008). Fishmeal and fish oil have overlapping market attributes resulting from their co

-production processes (fish oil is a by

-product of fishmea l production**) .**  Markets for products such as hydrolyzedPROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

31 protein, however, are not well quantified in market studies
. This section begins with a discussion of the markets for fishmeal and fish oil, followed by a brief discussion of the hydrolyzed protein market. **4.3.1. Fishmea**  **l** According to the Food and Agriculture Organization (FAO) the demand for fishmeal is one of the drivers of the entire fish sector because 25 percent of capture fisheries enter into fishmeal production (FAO, 2010). More than half of global fishmeal produced is used as feed in aquaculture (FAO, 2010). Aside from aquaculture, premium markets for fishmeal also include feed for early weaned pigs, poultry, and ruminants ; as well as egg production that focuses on increasing Omega 3 content (Bimbo, 2010 ) 36

. Annual global fishmeal production for 2009 is estimated at 6.5 million tons (Bechtel , 2010 ). The main supply of seafood for the current fishmeal market comes from Peruvian anchovies. Other main producer

- exporter countries for fishmeal include Chile, Icela nd, Norway and Denmark. Figure 4 shows the relative production levels between the top fishmeal

-pr oducing and exporting countries (FAO, 2010)
.

**Figure 4. Top International Fishmeal Producers 2006 -**  **2009**

Recently, fishmeal production has been decreasing while its price continues to increase. T wo main factors contributed to the decline in fishmeal production during 2009 and 2010. First, Peruvian fishmeal production has been negatively affected by weather near South America which has increased ocean temperatures , thereby decreasing the fish catch used to create fishmeal. Adding to the decreased fishmeal production on a global scale is the decline in Chilean fis hmeal production that has resulted from a recent earthquake. With Chilean production levels estimated to decrease nearly 200,000 tons in 2010, more production pressure is falling onto the already

- diminished fishmeal quantities generated by Peru (FAO, 2010; IFFO, 2010 ). Fishmeal prices are expected to rise as the result of shrinking quantities of fishmeal production and the increasing product demand by China ( which imports 50 percent of world fishmeal production).

36 D ifferent grades of fish products are reflective of the product’s ingredients . For instance, standard fishmeal, referred to as having "fair average quality" (FAQ) typically has 64% to 67% crude protein with up to 12% fat. Specialty, or premium, products have different amine levels with reflects an increased percentage of fresh, raw fish content. These premium products can fetch a higher dollar amount per ton on the market (IFFO, 2010; Bimbo, 2008)
. Source: IFFO data as published in FAO, 2010. Source: IFFO data as published in FAO, 2010.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

32 T he FAO reports that some Chinese ports are paying record high fishmeal prices of $1,900 per ton for the highly desired product (FAO, 2010). With product supplies uncertain in the future, fishmeal prices are expected to continue rising. In addition to an international market, the United States also presents a potential fishmeal market for Alaskan fishmeal. In 2008, the United States imported more than 38,000 tons of fish meal. The maj ority of fish meal was imported from Mexico (22,000 tons) with Chile (5,500 tons) and Canada (2,000 tons) rounding out the top

- three exporters to the United States (FAO, 2010). S everal potential markets for fishery by

-products exist w ithin the United States
. First, fishmeal can be used as a nutritional supplement in domestic livestock and aquaculture feed production. The United States is the largest producer of animal feeds in the world, and in 2007, leading U.S.

-based feed manufacturers produced more than 53 million tons of animal feed. Bimbo (2008) suggests that fishmeal markets should tap into the country’s livestock hubs such as Pennsylvania, Michigan, and Minnesota which each produced more than two million tons of livestock feed in 2005. Fishmeal could also be used for domestic aquaculture feed and supplements. In 2007, more than 1,800 aquaculture operations produced catfish and trout alone (Bimbo, 2008)
. Bimbo (2008) calculates th e average price of fishmeal during the years 2002 to 2007 using prices from OilWorld. biz . Bimbo’s (2008) price average for meal was $966 per ton, or $866 when subtracting $100 for freight ( as estimated by Bimbo)
. This price is considered a reasonable estimate of the price for Alaskan fishmeal products over the next few years, with some potential for this price to rise over time. **4.3.2. Fish Oil**  Similar to the fishmeal industry, the five countries responsible for exporting the majority of the world’s fish oil are: Peru, Chile, Iceland, Norway and Denmark. Together, these countries exported 530,000 tons of fish oil in 2009

— a 100,000 ton decline fro m the previous year. Chile and Peru both reported a ten percent decrease in fish oil production during 2009, and Scandinavian countries contributed to global declines with a 30 percent decline in oil production . As fish oil production has decreased, its market price has also increased (FAO, 2010). Fish oil prices are often compared to soybean oil because they are competing products in the market place and exhib it similar trends (Bimbo, 2008 ). While fish oil prices were $120 per ton below soybean oil prices in 2009, by March 2010, fish oil prices had ri sen above soybean oil prices, fetching $950 per ton , or twice as much as 2009 prices (FAO, 2010). The FA O attributes this price increase to changes in South American w ater temperatures that have reduced fish st ocks used to produce fish oil (as is the case with fishmeal) (FAO, 2010). FAO (2010) expects prices to continue to rise due to this factor. A fish oil’s composition contributes to its marketability and value. This composition can be affected by a variety o f factors relating to the fish (such as the fish species, its aquatic environment, season al variations in weather, and geographical location) and how the fish is processed (Kim and Mendi s , 2006). These factors contribute to the product’s overall quality an d nutritional properties , such as the percentage of protein or the amount of fat contained in the product. Commodity oils and nutraceuticals often have different compositional requirements. For example, raw commodity oils, such as those used in aquaculture , need to be low in oxidation and contaminants. Although nutraceutical fish oils also have these same requirements , the nutraceutical market also seeks oils that have high levels of omega - 3 fatty acids and come from pristine natural resources. Nutraceutica l oil comprises approximately five to 10 percent of total fish oil production, and U.S. Customs information indicates that the volume of imported nutraceutical oils has more than tripled ( from 4,000 tons to 15,000 tons) from 2002 to 2008 (as cited in NMFS, 2010 ; Bimbo, 2008). Price information for nutraceutical oils, however, is not as readily available as commodity fish oil prices. Due to thePROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

33 variation in quality and refinement beyond raw, commodity oils, nutraceutical oils often achieve a higher price poi nt in the marketplace. Bimbo (2008) notes that prices for nutraceutical oils vary from “lows of one to two dollars per kilogram (kg) up to and exceeding $15 per kg .” This translates to $907 to $13,608 per ton , which is approximately the same as or much mo re expensive than prices for commodity oils ). U.S. Customs estimates that, w ith the increase in the volume of imported oil from 2002 to 2008 , the aggregate value of that oil also rose from approximately $15 million in 2002 to $95 million in 2008 (as cited in NMFS, 2010 ). Fish oil currently also is used as a fuel supplement at processing plant locations where on

- site generation of electricity is necessary where power grid capabilities either may be severely limited or there is no available power at all. Th e Alaska Energy Authority (AEA) notes in its Renewable Energy Atlas , for example in 2009 and 2011 , that many coastal locations offer the opportunity to use biomass (e.g., fish waste and the oil produced from it) as an important supplemental source of fuel to replace a portion of the fossil fuels used for energy generation. For example, all three long

- standing processors in Dutch Harbor use fish oil produced primarily from pollock waste to replace a substantial portion of fossil fuel (diesel) normally used t o generate electric power to run the processing plants. The by

-product recovery facility in Kodiak also uses fish oil generated from pollock waste as the majority of fuel for on

site generation of electric power for that by

-product recovery facility. Bimbo (2008) estimates the average price of commodity oil during the years 2002 to 2007 using prices from Oilworld.biz . Bimbo’s (2008) price average for fish oil was $9 57 per ton, or $8 57 when subtracting $100 for freight (as estimated by Bimbo)
. This price is considered a reasonable estimate of the price for Alaskan oil products over the next few years, with some potential for this price to rise over time. Alaska presents a potential resource for the world’s commodity grade oil and meal markets a s well as the growing market for high quality, refined salmon oil. As noted earlier, companies producing nutraceutical preparations favor fish oils with high levels of omega

- 3 fatty acids from pristine resources, and Alaska’s environment and fish stocks me et those requirements. Alaska salmon and pollock provide a readily available source of high quality fish that, because of the cold water fisheries from which they come, have high levels of o me ga - 3 fatty acids (Bechtel , 2010 ). Additionally, Alaska salmon an d pollock are certified by the Marine Stewardship C ouncil as coming from a sustainable resource ( Bimbo, 2010 ). Bimbo (2008) states, however, that current Alaskan fish oil would need to be refined beyond current processing in order to meet nutraceutical standards. **4.3.3. Hy**  **droly sate**  As mentioned in the beginning of this section on by

-product markets, no established market currently exists for non

- traditional products such as hydrolysate. Bimbo (2008) notes two hydrolysate market considerations , including: 1) “hydrolysates...must be market driven since they are either very high in water content (silage) or bulky thus making transportation costs a key factor”, and 2) “hydrolysates must be further processed to remove bones, oil and insoluble material s before drying. This involves more capital costs, increased energy costs and further disposal issues with the residual by

-product s.” With little to no pricing or market information regarding hydrolysate from Alaskan producers, EPA assumes for the purposes of this profile, that there is a market (albeit currently small) for hydrolysate and that the market price for the product, at a minimum , covers the cost of producing the by

-product. **5.0 AL**  **AS KA**  **N BY -**  **PRODUCT MA RKET CONSI**  **DERA TIONS**  T he financial viability of Ala skan by

-products, such as fish oil, faces several economic considerations in the marketplace. Alaska’s energy costs exceed most energy prices within the contiguous United States, and these costs vary according to particular regions within the state. Capita l costs make building by

-product facilities and certain equipment investments less desirable to potential by

-product producers (Bimbo, 2010 ). By
-product plants are designed to run continuously and flows of fish are notPROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

34 necessarily predictable or continuous (especially due to seasonal variation) (Lane, 2010). Transportation costs associated with fuel and vessel costs might require resulting products to be lighter, less bulky, or able to withstand longer periods of time between processing phases. Additionall y, profit margins reportedly have been thin throughout the state and vary from year to year (ADEC, 2010)
. **5.1. N**  **UMBER OF B**  **Y -**  **PRODUCT P**  **ROCESSING F**  **ACILITIES** Alaska had 17 processors dedicated solely to producing fishery by

-products in 2009 , including 12 fishmeal processors and five fish oil processors (SFS, 2010; DCCED, 2010 ). The types of by

-products produced by the plants include fish protein meal, fish oil, fish bone meal, and stickwater. These by

products are used to make consumer products such as commodity 37 and nutraceutical oils , animal feeds (including fee d used in aquaculture) , and f ertilizer/compost (Bechtel , 2010 ; FITC, 2010). According to Alaska’s Office of Fisheries Development, in 2009 fishmeal processors generated 31,100 tons of product pr oduced fr om all seafood species, with a value of nearly $39 million . Fish oil producers in the same year produced 10,300 tons of oil worth $7.5 million
. The volume of fishmeal produced in Alaska generally has been declining since 2002 , wh en it was more than 59,584 tons, or nearly twice as high as 2009 production levels. The 2009 production level of 31,100 tons is roughly one percent of global fish meal produ ction (DCCED, 2010; FAO, 2010). Alaska’s fish oil market is similarly positioned, with approximately one perce nt of global fish oil produc tion (DCCED, 2010). However, the volume of Alaskan fish oil produced is increasing and has nearly doubled since 2000
. Many of the current fishmeal and fish oil operations in Alaska are the result of ADEC requirements that coinci ded with the Americanization of the groundfish fishery. The 1972 Clean Water Act led to conservation measures such as the Magnuson Fisheries Conservation and Management Act of 1976 and, thereafter, the 200

- mile Exclusive Economic Zone (EEZ). As a result of these measures, seafood processing facilities, predominately in Western Alaska surrounding the Bering Sea and Gulf of Alaska, began processing high volumes of groundfish. ADEC required these operations to integrate by

product recovery systems to process f ish meal and fish oil. Recovery operations with fish types that are harvested year

- round are also able to run recovery operation year round if the total of volume of waste is sufficient (Bechtel, 2010). Currently, eight of the state’s fishmeal operations r emain in the Bering Sea and Gulf of Alaska region, mainly handling pollock, cod, and other groundfish
. For example, Kodiak Fishmeal Company uses approximately 1,000 tons of fish waste per day to produce fishmeal from white fish and salmon , bone meal, and f

ish oil (Kodiak Fishmeal Company, 2010). These waste processing facilities process an estimated 400 ton s of waste per day (SFS, 2010). Several plants also process waste streams from salmon products in coastal communities in the Gulf region (Bechtel, 2010). Alyeska, Unisea, and Westward all operate individual by

-product recovery facilities in Dutch Harbor. Also, Trident operates by

-product recovery facilities at the Akutan processing plant ( U.S. EPA, 2001a) , Chignik, Wrangell, and in Cordova. Trident also is building a new by

-product recovery facility in Naknek. In addition to the recovery operations in the Bering Sea and Gulf of Alaska, seafood processors throughout Alaska use their wastes to produce by

-products, primarily from salmon waste. M any of the by

-p roduct recovery facilities in the non

- remote petitioning locations and locations of interest covered in this profile fall into this category of co

-produced by

-products. These processors operate their by

-product recovery operations mainly during salmon seas on. Although some processors use a variety of fish waste solids to produce meal and oil, other producers focus on certain types of waste, such as fish heads, which have more desirable nutrient levels.

37 Commodity oils may be classified as food grade (such as fish oil used in cooking) or non

- food grade (w hich may be incorporated into animal feeds) (Lane, 2010).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

35 Table 5 provide s by

-product recovery information for fa cilities in the non

- remote petitioning areas as well as the remote areas of interest. The table describes the types of seafood processed by the facility and the resulting by

-products. **Table 5. Facilities Producing Fishmeal and Fish Oil Facility**  **Independent**

**of Seafood Processing**  **Plant? Location**  **By -**  **product(s) Produced [a]**  **Seafood Processed** Alaska Protein Recovery/ Trident Seafoods Yes** Ketchikan (barge, could relocate) Salmon oil (food grade)

Salmon protein hydrolysate Salmon heads (food grade) Salmon waste Alyeska[f] No Dutch Harbor Fish meal 90% pollock waste Icicle Seafoods No Petersburg Salmon oil Salmon meal Salmon waste (mixed, non

food grade) Icicle Seafoods No Seward Salmon oil Salmon meal [c] Salmon (roe stripped) Salmon waste Bottom fish waste Sitka Meal, Oil, and Gelatin Yes Sitka (planned) Salmon oil (food grade)

Salmon meal Crude (6%) chondroitin sulfate

- rich gelatin Salmon waste White fish waste Scientific Fisheries[b] Yes Kenai Salmon oil (food grade) Salmon meal [d] Salmon heads (food grade) Snug Harbor No Kenai Fertilizer (compost) Salmon waste
Trident Seafoods No Akutan, Cordova, Chignik, Wrangell, Naknek [f] Salmon oil (food grade)

Salmon protein hydrolysate [e] Fish meal Salmon heads (food grade) Salmon waste

UniSea No Dutch Harbor Fish meal Bone meal Fish oil Pollock collagen 90% pollock waste Some crab Other fish Westward No Dutch Harbor Fish meal Bone meal Fish oil 90% pollock waste Some crab Other fish Source: U.S. EPA, 2010 *Raw and processed seafood that is managed as food grade is noted as such and is otherwise considered to be non

food grade. ** It should be noted that APR is partly owned by Trident Seafood Corporation. [a] The white fish oil is not a marketed by

- product but, rather, it is typically burn ed in the plant’s boilers (FITC, 2010). [b] Operates plant for Alaska Marine Nutrition. [c] <5% of by

- products are white fish meal. [d] Meal production is planned for 2011. [e] The hydrolysate produced is acid hydrolyzed fertilizer grade and enzyme hydrolyzed animal feed grade and is marketed by Alaska Protein Recovery. [f] U.S. EPA, 2001, U.S. EPA 2001a; Trident letter to Bristol Bay Borough, January 24, 2012; facility not yet operating in NaknekPROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

36 **5.2. C**  **URRENT B**  **Y -**  **PRODUCT P**  **ROCESSING IN T**  **HE P**  **ETITIONING L**  **OCATIONS AND**  **A DDITIONAL**  **L OCATIONS OF**  **I NTEREST**  This section describes the seafood processing facilities within the petitioning locations as well as the locations of interest and their current by

-product recovery efforts. This section highlights which operations c urrently are practicing by

-product recovery, and discusses potential by

-product recovery options for facilities currently not processing by

-products. The facilities are discussed by location. **5.2.1. Status of By**  **- product Recovery**  **in the Petitioning Locations 5.2.1.1.**  **Cord ova**  As noted earlier, four seafood processing facilities are located near Cordova: Copper River Seafoods, Trident Cannery (Trident North), Ocean Beauty Seafoods, and Trident Norquest (Trident South). With only 0.6 miles separating the northernmost and southernmost of these plants, joint by

product recovery in this center is a possibility, assuming corporate cooperation is feasible. Currently, Trident runs a recovery plant that operates only during salmon season and has previously taken waste from other area pro cessors. In 2009, Trident started up a by

-product recovery plant located next door to the Trident Cordova North plant. Trident’s Cordova facility uses Alaska Protein Recovery’s (APR) proprietary process to produce fish oil and fish hydrolysate (Lane, 2010 ; Trident, 2010). The size of the by

-product plant in Cordova was based on the capacity of the Trident cannery , which was 1.5 million lbs of raw fish per day (Lane, 2010). Both the Trident Cordova North and Cordova South plants supply seafood waste to the Trident by

-product recovery plant. Waste is transported from the Trident cannery (Cordova North plant) to the plant through three stainless steel pipes. Fish heads are transported separately from combined guts, frames, and skin (Trident, 2010). In 2010, Trident South trucked all salmon heads to the Trident North by

-product recovery plant, and in 2011, it plans to truck the frames as well (Trident, 2010a). Trident South may also truck black cod heads. Trident Cordova South processes 400,000 to 500,000 lbs of black cod per year, resulting in 40,000 lbs per year of heads (Trident, 2010a). The heads are more than three percent oil, so it may be possible to recover the oil from the cod fish heads profitably38 (Trident, 2010a). The Ocean Beauty plant is adjacent to the Trident recovery plant. Ocean Beauty sent its processing waste to Trident in 2009 and ground and discharged their waste through an NPDES permitted outfall in 2010. Ocean Beauty would like to send waste fish heads to Trident again in 2011 (Ocean Beauty, 2010).

**5.2.1.2. Juneau**  Ju neau has two small direct discharging seafood processing plants that are nearly 14 miles apart. Taku is located in the heart of downtown Juneau and Alaska Glacier is located northwest of the city in an area known as Auke Bay (see Figure 3). Despite the distance, the two seafood processing facilities have access to a good roadway, thus there may be some potential for these processors to establish cooperative by

-product recovery. Currently, Alaska Glacier accumulate s waste in totes on the dock, run s it through a grinder and pump s it into a bow picker (small boat). The boat transports the ground waste to beyond Portland Island where it is pumped out of the boat. The Taku Fisheries plant, which is located immediately adjacent to the cruise sh ip docking area and the Mount Roberts tramway in downtown Juneau, grinds its waste through

38 In 2010, Trident froze a batch of cod heads and will process them at the by

- product recovery plant at the end of the season to determine the effect of freezing on oil quality (Trident, 2010a).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

37 two grinder pumps and discharge s the ground waste through its NPDES
-permitted outfall located approximately 60 feet off the dock at a depth of 60 to 80 feet (Taku, 2010)
.

**5.2.1.3. Petersburg**  Petersburg’s three seafood processors, Icicle, Trident Norquest, and Ocean Beauty Seafoods, are located near each other, with approximately one half mile between the Icicle and Ocean Beauty facilities and the Trident facility loc ated between them. Distance is not an issue for joint by

- product recovery, but currently, Icicle, which has the only existing by

-product processing capability in the location, is not processing other facilities’ seafood wastes. Icicle operates a by

-product facility during salmon season and grinds and discharges waste through a NPDES permitted outfall during the remainder of the operating period. T he by

-product plant produces fish oil and fishmeal , which is used for aquaculture. The fish oil produced cannot be used for human food without additional refining. During salmon season, the plant has no additional by

-product processing capacity, so as currently configured it cannot accept additional waste from its neighbors. The two other plants currently are not re covering any fish waste. The Ocean Beauty plant did not operate in 2010 but is expected to operate during salmon season in 2011. This plant previously ground and discharged its processing waste through an NPDES permitted outfall and has not attempted any b y product recovery. Sitka Meal, Oil, and Gelatin Company (SMOG), a potential by

-product start

-up firm to be located in Sitka (see discussion below in Section 4.4.2) has expressed interest in obtaining the waste from Ocean Beauty for its Sitka

-based recove ry plant (Stitzel, 2010). Trident has refurbished a salmon cannery in nearby Wrangell (less than 30 miles away), and the Petersburg plant has the potential to close to consolidate operations in Wrangell (Stitzel, 2010). If the Petersburg plant were to remain open, a recovery plant that could utilize the waste from both Trident operations potentially could be constructed, but no plans are underway.

**5.2.1.4. Ketchikan**  The five seafood processors in Ketchikan are located within a two mile area. Two processors

— Trident N orquest, and E.C. Phillips

— are located slightly west of downtown Ketchikan, as is the by

product processor, Alaska Protein Recovery (APR). The remaining three processors are just to the east of downtown: Alaska General, Pacific Sun Products, and the Trident salmon cannery. Approximately 1.8 miles separates the two most distant processors. Cooperative by

-product recovery is occurring to some extent in this location. The downtown area of Ketchikan and the cruise ship docks are located between these two groups of processors. The available by

-product recovery processing capabilities in Ketchikan are represented by APR, a by

-product recovery plant that is partly owned by Trident Seafood Corporation
. The plant produces salmon oil and hydrolyzed fish protein. It i s located o n a barge moored at the Trident dock and operates during the salmon season . The barge leaves when the season is over to deliver products to the Northwestern part of contiguous United States, and, more specifically, in 2010, hydrolysate to a buye r in California. Nearly all of the Ketchikan facilities use APR for some or all of their wastes. The two major contributors to the waste stream processed by APR are the Trident Cannery and Alaska General. Alaska General is the only non

- Trident facility to send virtually all of its processing waste solids (exclusively salmon via a pipeline) to APR, sending its wastewater through a NPDES

-permitted outfall. The Trident cannery also processes virtually all of its waste at APR. Trident Norquest send s its fish heads, which are managed as food grade, to APR during salmon season. The remainder of the fish waste is ground and discharged through a NPDES permitted outfall.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

38 E .C . Phillips also removes fish heads and packs them on ice to be sent to APR for by

-product re covery , and its remaining waste is ground and discharged shoreside (APR, 2010)
. Only Pacific Sun Products does not provide any waste to APR. Currently, Pacific Sun discharges its fish waste through a NPDES

-permitted outfall (APR, 2010; EPA, 2010). **5.2.2. Status**  **of By -**  **product Recovery in the Locations of Interest**  **5.2.2.1. Dutch Harbor**  As noted in section 5.1, eight of the state’s fishmeal operations are located in the Bering Sea and Gulf of Alaska region, mainly handling pollock, cod, and other groundfish
. These waste processing facilities process an estimated 400 ton s of waste per day (SFS, 2010). Three by

-product operations are located in Dutch Harbor (See Figure 3 ). As shown in Table 5, Alyeska, UniSea, and Westward generate a range of by

-products, primarily from pollock. The three operations produce fishmeal, bone meal, and/or fish oil. UniSea, additionally, produces pollock collagen.

**5.2.2.2. Kenai Peninsula**  The Kenai Peninsula location encompasses several communities, including the cities of Kenai, Seward, and Homer. Ten discharging seafood processors are located in the Kenai Peninsula, including Ocean Beauty Seafoods in Nikiski, Snug Harbor Seafoods, and Icicle

- Seward Fisheries. Although Ocean Beauty and Snug Harbor Seafoods are relatively near one another geo graphically, Ocean Beauty Nikiski and Icicle

- Seward Fisheries are more than 100 miles apart with inter

- connecting year

- round roads. The major by

-product processing capability is associated with the Icicle Seward facility. Similar to the Icicle plant in Pet ersburg, Seward Fisheries operates a recovery plant during salmon season. Although Icicle has taken waste from other processors in the past, it no longer does so (U.S. EPA, 2010; Jo rdan, 1979). P rocessors from the Kenai Peninsula and Anchorage previously drove their processing waste to the Icicle by

-product recovery plant in Seward for disposal. Scientific Fisheries Systems (SFS), a plant devoted to by

-product processing (not seafood processing) is operating a salmon oil plant at Kenai Landing. This small scale, food grade salmon oil by

product operation is being operated by SFS for Alaska Marine Nutrition, LLC . The operation is within driving distance of the Kenai Peninsula seafood processing facilities, and the plant does not operate during the winter mo nths. The recovery operation is currently taking waste from Snug Harbor Seafoods and, possibly, other area processors. In 2010, Snug Harbor provided Scientif ic Fisheries with 210,943 lbs (105 U
. S
. tons) of food grade fish heads. This represents about five percent of Snug Harbor’s total waste (U.S. EPA, 2010). Snug Harbor reported that it also produce s fertilizer onsite from seafood processing waste using a composting operation. Seafood processing waste is taken from the processing line, mixed with wood chip s, and is placed in furrows on a fenced field next to the seafood plant. Snug Harbor placed about 30 tons of the waste

- wood chip mixture into furrows in 2007 and has continued to place about 10 tons per year thereafter
. The remainder of the processing wast e is ground and discharged under a NPDES permit. **5.2.2.3. Sitka**  The primary direct discharging processors in Sitka are Silver Bay and two other smaller plants (North Pacific Seafoods and the Seafood Producers Cooperative), which process approximately 15 million lbs of seafood per year (U.S. EPA, 2010). The longest distance between processors is the nearly six miles from the Seafood Producers Cooperative to Silver Bay Seafoods.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

39 No by

-product recovery currently is occurring in Sitka. One possible by

-product recovery option for Sitka and, perhaps, certain other producers in nearby Inside Passage petitioning locations or elsewhere in Southeast Alaska, is the Sitka Meal, Oil, and Gelatin (SMOG) plant under consideration for construction. If it is built, the company intends to recover meal, oil, and gelatin from salmon waste. The plant would produce crude (6%) chondroitin sulfate gelatin by passing salmon heads through a bone separator and recovering chondroitin

- rich cartilage (Stitzel, 2010). It is not yet known whether this by

product facility will materialize and become a viable by

-product recovery option for nearby processors, however (Stitzel, 2010). The largest seafood processor in the location, Silver Bay Seafoods, currently is not interested in sending its waste for by

-product recovery to such a plant if it were to be built due to a contract to sell a portion of its waste, with the remainder being ground and discharged (with waste hauling for offshore disposal as a backup method if it were to exceed permitted discharge volumes) (Stitzel, 2010; AIDEA, 2011). **5.3. T**  **OTAL W** **ASTE A**  **VA ILABLE IN**  **P ETITION**  **P ROCESSING**  **L OCATIONS**  Statewide, processing waste in Alaska ranges from an estimated 40 to 66 percent of the total weight of the fish being processed (Bimbo, 2008; Bechtel, 2010). The amount of seafood processing waste generated and available for the production of by

-products varies by the type of seafood species processed as well as the seafood produ ct being produced. For example , salmon that are only headed and gutted (H& G ) retain about 65 percent of their weight for end products, while a considerably smaller percentage of pollock’s total weight is retained. When these fish are used to produce fillets, about 50 percent of the salmon (by weight) and 20 percent of the pollock, are retained as product (FITC, 2010). For purposes of the processors covered in this profile, the main type of waste considered for by

-product recovery is salmon processing waste. In order to estimate the total salmon waste available by the processors in the petitioning locations , the amount of raw seafood being processed must be ob tained first
. EPA consulted the two main sources of public information pertaining to the quantity and type of fish being processed in Alaska for this report
. The first is the annual commercial catch numbers collected by the Alaska Department of Fish and Game ( ADFG ) . Each year, AFDG records the volume of catch for herring, groundfish, salmon, and sh ellfish commercial fisheries. The volume of seafood (or landings), however, is recorded a ccording to geographic regions which are not identical to the processing locations discussed in this profile
. To estimate the volumes of seafood landed in petitioning areas, this analysis used ADFG regions that encompassed the petitioning processing location s 39
. The processing location s and their corresponding ADFG regions are listed in Table 6. The other consideration in estimating the volume of fish landed for the peti tioning locations using ADFG information is that halibut is excluded from the ADFG catch calculation because it is under the jurisdiction of the International Pacific Halibut Commission (IPHC). Although this profile is considering only salmon waste generated by the processing locations of interest, the IPHC areas best representing the petitioning areas have also been included in Table 6 to help illustrate the complexity of determining total processing waste by processing locations in Alaska. **Table 6. ADFG Regions Corresponding to Petitioning Locations**  **Processing Locations ADFG Region**  **IPHC Area [a]** Ju neau Southeast 2C Ketchikan Southeast 2C Petersburg Southeast 2C Cordova Prince William Sound 3A Source: ADFG, 2010; IPHC, 2010 [a] International Pacific Halibut Commission (IPHC)

39 Anchorage was not included because currently it has no land

- based processors with EPA ELG permits considered in this profile (See Section 3.0 ).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

40 Table 7 shows possible volumes of fish waste based on the volume of landings reported for entire ADFG regions and IPHC areas that correspond to the petitioning processing areas. Three cautionary points regarding the numbers in Table 7 are:

 The percentages of regional processing waste corresponding to each petitioning processing location are unknown and, therefore, the numbers presented in the table indicate only the relative waste volumes from particular species within processin g locations.

 The percentage of waste per volume of landings captured by ADFG and IPHC was calculated using percentages of species waste estimated by Bechtel (2010). These percentages of waste may fluctuate by the form of processing, as Bechtel notes, so the numbers are only an estimate of potential waste.

 Table 7 v alues were calculated using data from 2008 because this was the most recent year of complete data across species and entities. Fish volumes also fluctuate each year, so these values provide a sn apshot of waste availability for a given time period. **Table 7. Estimated Seafood Waste from Regions Surrounding Petitioning Processing Locations in 2008 (tons)** 

Table 7 does highlight, however, that salmon constitutes the major source of seafood processing waste in the petitioning locations. The second data source is the National NPDES permit annual reports. The NPDES annual reports are completed each year by processors holding NPDES permits and sent to the EPA. The reports include a variety of processing information, such as the volume of raw seafood utilized by the processor, the quantity of product made by the processor with that raw seafood, and the volume of wastewater discharged through the NPDES permitted outfall. Because the NPDES annual reports are completed by each permitted processor , the reports provide a reliable source of data for raw seafood and waste volumes of particular processors and processing locations, which are specific to ADFG regions (although a comparison of salmon waste generated in 2008 as presented in Table 7 and Tab le 8 reveals that the waste totals are fairly comparable). Table 8 shows the volume of salmon waste generated by the petitioning areas and areas of interest. The petitioning areas processor totals were obtained from the EPA questionnaire and aggregated t o mask facility level information in communities with only a small number of facilities. The annual totals for the processors in the locations of interest who were not surveyed, were calculated using the information provided in the EPA NPDES annual reports
. **Location Halibut**  **Groundfish Salm**  **on TOTAL**  **Lingcod Pacific** 

**Cod Rockfish**  **(all types) Sablefish**  **Walleye**

**Pollock Misc.**  **Groundfish** Prince William Sound Cordova 3,051[a] 5 2 15 28 411 0 38,822 42,334 Southeast Ketchikan Petersburg 776 43 136 102 337 0 4 32,109 33,506 TO TAL 3,827 48 138 117 365 411 4 70,931 75,840 Source: ADFG, 2008; IPHC, 2008. [a] IPHC data for Cordova is not for the ADFG Prince William Sound region, but rather area 3A (See Table 2)PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

41 **Table 8. Annual Salmon Waste Generated by Petitioning Areas and Areas of Interest 2005 -**  **2009 Total Waste (m**  **etric tons) Location**  **2005 2006**  **2007 2008**  **2009 Average Annual**  **Waste (m t)**  Petitioning Locations [a] 98,138 67,956 102,591 74,940 77,436 84,212 Additional Locations of Interest [b] 230,476 227,861 199,072 159,061 124,791 188,252 Total Annual Waste 328,613 295,817 301,662 234,001 202,227 272,464 Source: EPA, 2010 [a] Petitioning Areas include Anchorage, Cordova, Juneau, Ketchikan, and Petersburg, but because Anchorage does not have any direct discharging processors, it is not included in this calculation. [b] Additional locations of interest may include: Dutch Harbor, the Kenai Peninsula, and Sitka. Facilities in Western Alaska around the Bering S ea, such as those in Dutch Harbor, are already required by The Alaska Department of Conservation to implement by

- product recovery technologies (Bechtel, 2010). **5.4. W** **ASTE UTILIZATION EST IMA** **TES** Bimbo (2008) estimates quantities of fishmeal and fish oil based on a percentage of fish 46 percent waste to total landings. Bimbo suggests that a 5:1 conversation ratio can be used to estimate total fishmeal production from the total volume of fish waste. He also suggests that fish oil is approximately two percent of the total fish waste. Using these calculations, Bimbo posits that Alaska could generate more than 200,000 tons of fishmeal and more than 22,000 tons of fish oil per year based on the state’s annual average of 2.43 million tons of seafood landings (Bimbo, 2 010). Table 9 shows the volume of salmon harvested in 2009 by ADFG regions that encompass processing locations. The volume of fish waste generated by the salmon harvest as well as an estimate of potential fishmeal and fish oil production are also provided
. **Table 9. 2009 Regional Salmon Harvests and Estimated Fishmeal and Oil Production (metric tons) Region**  **Salmon Harvest Volume of Fish**  **Waste[d] Potential** 

**Fishmeal [e] Potential** 

**Fishmeal[f]** Southeast [a] 98,285 39,314 7,863 786 Central [b] 139,202 55,681 11,136 1,114 Westward [c] 89,441 35,776 7,155 716 Source: EPA calculation using ADFG regional harvest totals. [a] Includes processing locations such as Juneau, Ketchikan, and Petersburg
. [b] Includes processing locations such as Naknek, Cordova, and Kenai
. [c] Includes processing locations such as Kodiak and Dutch Harbor
. [d] Estimated as 40 percent of total fish weight (ADFG, 2010)
. [e] Estimated as 5:1 ratio of quantity of fish waste to meal (Bimbo, 2008). [f] Bimbo estimates fish oil by

-product as two percent of waste (Bimbo, 2008).
Table 10 uses the estimated volumes for salmon waste in the petitioning location s and additional location s of interest to calculate potential volumes of fishmeal and fish oil. The values in Table 10 are based on Bimbo’s (2008) methods for calculating potential volumes and prices of by

-product in Alaska. Due to the annual fluctuations in seafood harvests and c ommodity prices, Bimbo uses average values from the time period from 2002 to 2007 to calculate average by

-product prices (see table footnotes) (Bimbo, 2008).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

42 **Table 10. Fishmeal and Fish Oil Production Estimates by Petitioning Locations and Additional Lo**  **cations of Interest**

**6.0 COMPA**  **RING POTENTIA L**  **AL AS**  **KA N**  **AN D GLOBA**  **L Q UA**  **NTITIES OF BY**   ** PRODUCTS** Alaska’s potential production levels of fishmeal and oil are minor in comparison to global quantities produced. Global quantities are used for comparison because the fishmeal and oil markets are global in scope. Using Knapp’s (2008) model for estimating global quantities of fishmeal and fish oil based on 2008 world fish prod uction, it is estimated that the global volume of fish waste ranges from 17

- 51 million tons. Applying Knapp’s (2008) by

-product estimates to this waste volume results in a combined 1.7 to 2.8 million tons of fishmeal and fish oil being produced globally 40

. Applying Bimbo’s (2008) by

-product ratios to Knapp’s volume of waste results in the figures presented in Table 11 below. **Table 11. Comparing Alaskan and Global Quantities of Seafood By -**  **products**

**Alaska [a] Worldwide [b]**  **Average annual**  **waste (tons) [c]**  **Potential**

**Fishmeal using 5:1 ratio**  **(tons) Potential Fish** 

**oil 2% of waste (tons)**  **Seafood waste**

**(m illion tons)**  **Potential**

**Fishmeal using 5:1 ratio**  **(m illion tons)**  **Potential Fish**

**oil (2% of waste) (m** **illion tons)** 272,464 54,493 5,449 17
- 51 3
- 10 0.3
- 1 [a] Alaskan totals are comprised of quantities from processors in petitioning areas as well as areas of interest. [b]Worldwide fish production was taken from FAO (2008) and applied to by

- product model waste totals from Knapp (2008). [c] Based on average annual wa ste as calculated in Table 10.

40 Knapp (2008) estimated global quantities of fishmeal and oil by multiplying the volume of world fish production by the percentage of food fishery products used to make by

- products (30 to 60 percent). The resulting volume range is then multiplied by 40 to 60 percent to calculate the volume range of total by

- product yield from the fish processing. The resulting by

- product quantities are then multiplied by the percentages of those by

- products that may be turned into meal or oil (0. to

- 0.25 percent). **Location Average** 

**annual salm**  **on waste**  **(tons) [c] Potential** 

**Fishmeal using 5:1**  **ratio (tons)**  **Fishmeal**

**Value (using 2002**  **- 2007 average)**  **($ m illions) [d]**  **Potential**

**Fish Oil 2% of**  **waste (tons)**  **Fish Oil Value**

**(using 2002 -**  **2007 average) ($**  **mi llions)**  **[d] Current Oil** 

**Value ($950 per ton)**  **($ m illions)**  **[e]** Petitioning Locations [a] 84,212 16,842 $1.5 1,684 $1.4 $1.4 Additional Locatioins of Interest [b] 188,252 37,650 $32.6 3,765 $3.2 $3.2 Total 272,464 54,493 $47.2 5,449 $4.7 $4.6 Source: U.S. EPA, 2010 [a] Petitioning Areas include: Anchorage, Cordova, Juneau, Ketchikan, and Petersburg. Because Anchorage does not have and direct discharging processors, it is not included in this calculation. [b] Areas of interest include the Kenai Peninsula and Sitka. [c] Average waste calculated from EPA questionnaire and NPDES annual report totals. [d] Averages prices from 2002

- 2007 were taken from Bimbo (2008). Average price for meal was $966/ton. Average price for oil was $957/ton. Bimbo (2008) used OilWorld.biz prices to calculate five

- year averages. [e] Current day prices for oil taken from FAO (2010).PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

43 Table 11 shows that worldwide production of fishmeal and oil is in the millions of tons while estimates of quantities that potentially could be generated by Alaskan processors do not even reach 60,000 tons (or about three percent of the global estimated total). Therefore, the incremental amount of by

-product that could potentially be recovered is probably much less than three percent of global quantities (see also Figure 5). Because Alaska by

-product production is so minimal in comparison to global production, the entry of these additional produc ts into the market should not affect the global market price of meal and oil the way that other, larger, by

-product

-producing areas, such as the Peruvian anchovy fishery, have the potential to affect the by

-product industry and pricing (see Section 4.3 ).

**Figure 5. Comparing Global and Alaskan Potential Meal and Oil Production**

**7.0 OTHER F**  **AC TORS A**  **FFECT ING**  **PROCESSORS IN NON -**  **REMOTE PROCESSING LOCA**  **TIONS** This section discusses how revised discharge requirements may affect non

- remote processors compared to other seafood processors without similar discharge requirements. Two topics are highlighted in this sectio n: 1) the main species harvested (and therefore, potentially processed) by location, and 2) the proximity of non

- remote processors that may possibly be subject to a revised effluent regulation to processors that may not be subject to the regulation. Refer to section 3.1 of this Profile for information and data on species of fish processed. Table 12 shows the distance between the seafood processing locations that have permitted direct discharging seafood processors and those that are classified as remote (an d not one of those within a location of interest). Because many of the locations are not connected by roads, the distances are provided in nautical miles (NM). For each location, the table also highlights the nearest processing locations. **Table 12. Other Processors Closest to the Processors in Petitioning Locations and Locations of**  **Interest Processing**  **Location Location #/Distance in Nautical Miles (NM)** 

**1 (NM) 2 (NM)**  **3 (NM) 4 (NM)**  **5 (NM)**NonRemote Anchorage Whittier 60 Big

Lake 64 Seward 127 Source: Knapp, 2008 and EPA calculation
.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

44 **Processing Location**  **Location #/Distance in Nautical Miles (NM)**

**1 (NM) 2 (NM)**  **3 (NM) 4 (NM)**  **5 (NM)** Cordova Valdez 40 Whittier 89 Petersburg Wrangell 28 Kake 34 Ju neau Excursion

Inlet 32 Hoonah 34 Pelican 61 Haines 65 Ketchikan Metlakatla 13 Craig 52Remote Dutch Harbor King

Cove 134 Cold

Bay 155 St. Paul 232 Kenai [a] Homer 27 Soldotna 26 Nikiski 36 Anchorage 81 Whittier 90 Sitka Kake 45 Pelican 62 Hoonah 64 Petersburg 79 Source : Potential p rocessors resulted from EPA, Region 10, ADEC (2010) permit listings and ADFG (2011) land

-based processor listing. Latitude and Longitude Coordinates from Google Maps ( Google.com, 2011) were entered in Straight Sailing Marine Distance Calculato r ( CSGnetwork, 2011). [a] The first three locations

—Ho mer, Soldotna, and Nikiski

—are on the Kenai Peninsula, while the nearest processors not located on the Kenai Peninsula are in Anchorage and Whittier. As Table 12 shows, several non

- remote processors affected by effluent guideline regulations are near processors without similar discharge restrictions. The table also shows that processors within close geographical proximity are also likely to process similar types of seafood. For example, Wrangell and P etersburg both process similar types of fish, such as salmon, and are only 28 NM apart. See Section 3 for discussion of fish species processed by location. T he communities that are home to the non

- remote, petitioning seafood processors and the facilities i n the additional remote processing locations of interest have varying economies and population demographics. This section begins with demographic information for the communities in the petitioning locations and locations of interest in order to help provid e some context to the discussion afterward about the role of seafood processing in local processing economies. Demographic information for the petitioning processor communities and additional locations of interest from the U.S. Census Bureau is provided i n Table 13. The geographic areas surveyed as U.S. census areas do not directly match each municipality in Alaska. For example, as shown in Table 13, Petersburg is part of the Wrangell

- Petersburg census area, Cordova statistics are combined with those of V aldez, and Dutch Harbor is included in the Aleutians West census area. Because some communities’ population and economic information have been aggregated beyond the individual municipality level of interest, the census information included in this section provides only an overall sense of the characteristics of some areas and should not be used for direct community comparisons.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

45 **Table 13. Census Characterization of Petitioning Processor Communities from 2000 US Census**

**Census Characteristic**  **Non -**  **Remote Proces sor Communities**  **Remote Locations of Interest** 

**Ketchikan Wrangell** ****

**Petersburg Valdez** 

**Cordova Anchorage**  **Juneau**

**City and Borough**  **Aleutians**

**West (Dutch**  **Harbor) Sitka**  **Kenai**

**Peninsula (including**  **Sew ard)**  Total Population 14,070 6,684 10,195 260,283 30,711 5,465 8,835 49,691 Labor Force 7,772 3,406 5,043 143,350 17,623 3,788 4,934 23,116 Median Household Income [a] 51,344 46,434 48,734 55,546 62,034 61,406 51,901 46,397 Percentage of Individuals Below Poverty Line 6.5% 7.9% 9.8% 7.3% 6.0% 11.9% 7.8% 10.0% Population of American Indian and Alaskan Native 2,109 1,074 1,351 18,941 3,496 1,145 1,641 3,713 Source: U.S. Census Bureau, 2000. [a] Median Income was based on U.S. Census data for 1999. The seafood processing industry has varying effects on the petitioning communities and additional locations of interest because it plays proportionally different roles in each of the local economies. In order to help understand the community impacts of the seafood processing industry, EPA obtained economic and ind ustry information for the petitioning areas and areas of interest from the U.S. Census County Business Patterns (CBP) for 2008 41 . CBP statistics were used rather than the 2007 Economic Census because nuanced, local level information often was withheld in th e 2007 Economic Census, given the small number of seafood processors in some locations and the proprietary nature of the information. Even within the County Business Patterns, some communities’ information is represented by a range (for example, 1

- 19 emplo yees) so as not to be able to identify individual companies when there are few processors in a particular area. Also, as mentioned in Section 2.2.2, employment figures from the Census are not recorded during peak fishing and processing season in Alaska, so employment in the seafood processing industry might be higher than that shown here. Within County Business Patterns, as well as the 2007 Economic Census, seafood processing falls within the broader manufacturing sector. In order to help highlight the rel ative importance of seafood processing in each of the communities’ local economies, Table 14 compares employment and establishment information from the each community with employment and establishment statistics from the manufacturing sector and the seafoo d processing industry within that manufacturing sector. Income and expenditures were not included in the table because the information was not publicly available for the seafood processors. Similar to Table 13, the information in Table 14 also combines co mmunities into U.S. census areas, so the industry statistics for Petersburg and Cordova as well as the remote areas of Dutch Harbor and the Kenai Peninsula are aggregated beyond individual petitioning areas and areas of interest.

41 2008 is the most recent year for which the US County Business Patterns information is available.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

46 **Table 14 Seafood Proces sing in the Context of Census Employment and Establishments** 

**Census Area Non**  **- Rem**  **ote Petitioning Locations Rem**  **ote Locations of Interest**  **Total Anchorage**  **Juneau Ketchikan** 

**Gateway Valdez**  ****

**Cordova Wrangell**  ****

**Petersburg Dutch** 

**Harbor**   ** Aleutian** **Bay Kenai** 

**Peninsula Sitka** 
Establishments Total

- All sectors 8,486 1,106 565 405 265 134 1,953 391 13,305 Percent of Total Establishments in Seafood Processing 0.08 0.27 0.71 2.47 3.40 6.72 1.02 2.05 0.53 Total

- Manufacturing 195 28 16 14 13 14 62 17 359 Percent of Manufacturing Establishments in Seafood Processing 3.59 10.71 25.00 71.43 69.23 64.29 32.26 47.06 19.50 Total

- Seafood Processing 7 3 4 10 9 9 20 8 70 Em ployment [a] Total

- All sectors 140,981 10,868 4,938 2,516 1,510 4,686 13,090 3,185 181,774 Percent of Total Em ployees in Seafood Processing Lo w 0.01 0.19 2.43 0.83 11.13 67.09 1.70 5.87 2.15 High 0.08 1.09 7.05 4.69 12.32 67.09 1.84 5.87 2.45 Total

- Manufacturing 2,353 253 357 139 197 3,236 618 248 7,401 Percent of Manufacturing Em ployees in Seafood Processing Lo w 0.89 8.30 33.61 15.11 85.28 97.16 36.08 75.40 52.76 High 0.08 46.64 7.05 4.69 12.32 67.09 1.84 5.87 2.45 Total

- Seafood Processing Lo w 21 21 120 21 168 3,144 223 187 3,905 High 118 118 348 118 186 3,144 241 187 4,460 Source: U.S. Census Bureau (2008) (County Business Patterns). Em ployment figures from Census do not reflect em ployment during peak fish processing periods in Alaska due to the seasonal nature of the work. Alaska employment in the seafood processing industry may be higher than that shown here. [a] Employment statistics for seafood processing appear as a range in CBP, and a low and high employment estimate were calculated from the ranges provided. Table 14 shows the relative impact that seafood processing has on number of establishments and employment in non

- remote petitioning locations as well as the additional remote locations of interest. Although some census areas encompass more than one communi ty, the information presented in Table 14 suggests that seafood processing plays a larger role in some local economies (such as Wrangell

Petersburg) relative to others (such as Anchorage). The very large Trident processing facility in Akutan is a standalon e and self sufficient community. The table also shows the relative role of the seafood processing industry in the remote areas of interest as compared to the non

- remote, petitioning areas.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

47 For a more detailed understanding of the composition of th e seafood processing industry in each of the communities, Table 15 divides seafood processing into canning and fresh and frozen production as defined by the North American Industry Classification System (NAICS) code.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

48

**Table 15. Seafood Canning and Fresh/Fr ozen Processor Establishments and Employees [a]** 

**Census Area State** 

**of Alaska**  **Non -**  **Remote Petitioning Locations Remote Locations of Interest**  **Petitioning Locations and**  **Additional Locations of**  **Interest Combined**  **Total Anchorage**  **Juneau Ketchikan** 

**Gateway Valdez**  ****

**Cordova Wrangell** **** **Petersburg Total**  **Dutch**

**Harbor**   ** Aleutian** **Bay Kenai** 

**Peninsula Sitka**  **Total** CANNING (NAICS 311711) Establishments 18 1 1 2 1 4 9 NA 1 NA 1 10 Employees [b] Low 936 1 1 20 1 1 24 NA 1 NA 1 25 High 19 19 99 19 19 175 NA 19 NA 19 194 FRESH/FROZEN (NAICS 311712) Establishments 98 6 2 2 9 5 24 9 19 8 36 60 E mployees [b]* Low 7,934 20 20 100 20 167* 327 3,144* 222* 187* 3,553 3,880 High 99 99 249 99 167* 713 3,144* 222* 187* 3,553 4,266 Source: US Census Bureau (2008) , U.S. Census Bureau (2007b) [a] Data for the State of Alaska was taken from the 2007 US Economics Census (U.S. Census Bureau, 2007b) while figures for all other categories were taken from County Business Patterns ( U.S. Census Bureau, 2008)
. [b] Employment statistics for seafood processing appear as a range in CBP, and a low and high employment estimate were calculated from the ranges provided
. Employment statistics for seafood processing appear as an aggregate to tal in the U.S. Economic Census information (U.S. Census Bureau, 2007a) used for the state
. NA: NA indicates that the type of processing does not apply to the census area. * Indicates actual number of employees reported instead of range.PROFILE OF THE ALASKA SEAFOOD PROCESSING INDUSTRY

49 **8.0 REFERENCES**  Alaska Department of Commerce, Community, and Economic Development (DCCED), 2010. Revenue Sharing Programs website. <http://www.commerce.state.ak.us/dcra/LOGON/srs/srs

- fish.htm>. Alaska Department of Environmental Conservation (ADEC), 2010. In P erson Meeting between ADEC Officials and Betsy Bicknell, ERG, and Lindsay Guzzo, EPA. August 9, Juneau AK. Alaska Department of Fish and Game (ADFG). 2011. 2010 Preliminary Processor Buyers (Intent to Operate) Listing as of January 13, 2011. Alaska Department of Fish and Game (ADFG), 2010. Commercial Fishing Website. <http://www.adfg.alaska.gov/index.cfm?adfg=fishingcommercial.main>. August 2, 2011. Alaska Department of Fish and Game (ADFG), 2009 . 2008 Statewide Shellfish Summary . Accessed at: < http://www.adfg.alaska.gov/index.cfm?adfg=fishingCommercial.main>. August 21. Alaska Department of Fish and Game (ADFG), 2008. 2008 Alaska Fisheries ExVessel Price . ADFG Division of Commercial Fisheries. Juneau, AK Alaska Department of Revenue, 2010. Fishe ries Related Taxes. <http://www.tax.alaska.gov/programs/programs/help/faq/faq.aspx?60620>. October. Alaska General Seafoods, 2010a. Website. <http://www.akgen.com/index.asp>. December. Alaska Glacier Seafoods, 2010a. Website. <http://www.alaskaglacierseafo ods.com/>. December. Alaska Industrial Development and Export Authority (AIDEA). 2011. Board Meeting Minutes. <http://www.aidea.org/BoardMaterials/Board%20Minutes/2011_3

- 31_AIDEA.pdf.>. December. Alaska Protein Recovery (APR). 2010. ERG site visit to Alas ka Protein Recovery, Ketchikan, AK. August 13. Bechtel. P.J., 2010. Enhancing Utilization of Alaska Fish Processing Byproduct Parts. In: P.J. Bechtel and S. Smiley (eds.), A Sustainable Future: Fish Processing Byproducts. Alaska Sea Grant, University of Al aska Fairbanks. Bimbo, A.P. 2010. 2008 Update on Potential Products, Markets, and Competing Products. In: P.J. Bechtel and S. Smiley (eds.). A Sustainable Future: Fish Processing Byproducts. Alaska Sea Grant, University of Alaska Fairbanks, pp. 9

- 25. doi:10.4027/sffpb.2010.02. Bimbo, A.P., 2008. Alaska Seafood By

-products: Potential Products, Markets and Competing Products. Prepared for the Alaska Fisheries Development Foundation. Browning, J., 2010. From Sustainability to Full Utilization. In: P.J. Be chtel and S. Smiley (eds.), A Sustainable Future: Fish Processing Byproducts . Alaska Sea Grant, University of Alaska Fairbanks, pp. 5
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51 Hoo vers, 2010c. Maruha Nichiro Holdings. Company Information Search < http://www.hoovers.com/company/Maruha_Nichiro_Holdings_Inc/hthfxi

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