Date: September 14, 2001

NPDES Permit Number: AK-003730-3

The U.S. Environmental Protection Agency (EPA)

Plans To Reissue A Wastewater Discharge Permit To:

Trident Seafoods, Inc. (the "permittee")

5011 Jewell Lake Road

Anchorage, Alaska 99502

EPA Proposes NPDES Permit Reissuance.

EPA proposes to reissue a National Pollutant Discharge Elimination System (NPDES) permit to 

Trident Seafoods Corporation, Inc. The proposed permit sets conditions on the discharge of

pollutants from the Trident - Akutan facility to Akutan Harbor, Alaska. In order to ensure

protection of water quality and human health, the permit places limits on the types and amounts

of pollutants that can be discharged and places other conditions on the facility.

This Fact Sheet includes:

- the tentative determination of EPA to issue the permit,

- information on public comment, public hearing, and appeal procedures,

- a description of the facility and proposed discharge,

- a map and description of the discharge location,

- a listing of past and proposed effluent limitations, schedules of compliance, and other 

conditions, and 

- technical material supporting the conditions in the permit.

EPA Invites Comments on the Proposed Permit. 

EPA will consider all substantive comments before issuing a final NPDES permit. Those

wishing to comment on the proposed permit may do so in writing by the expiration date of the

Public Notice. After the Public Notice expires and the public comments have been considered,

EPA Region 10’s Office of Water Director will make a final decision regarding permit

reissuance.

If no substantive comments are received, the tentative conditions in the proposed permit will

become final and the permit will become effective upon issuance. If comments are received,
Trident - Akutan facility AK-003730-3

Fact Sheet page 2 of 31

EPA will respond to the comments and the permit will become effective 30 days after its

issuance date, unless a request for an evidentiary hearing is submitted within 30 days.

Documents Are Available for Review.

The proposed NPDES permit and related documents can be reviewed at EPA’s Regional Office

in Seattle between 8:30 a.m. and 4:00 p.m., Monday through Friday. To request copies and

other information, contact the NPDES Permits Unit at:

United States Environmental Protection Agency, Region 10

1200 Sixth Avenue, OW-130

Seattle, Washington 98101

(206) 553-1214 or 

1-800-424-4372 (from Alaska, Idaho, Oregon and Washington)

The fact sheet and proposed permit are also available at:

Alaska Department of Environmental Conservation

Attn: Division of Wastewater Discharge

555 Cordova Street

Anchorage, Alaska 99501

(907) 269-7500

and

Alaska Department of Environmental Conservation

Attn: Division of Wastewater Discharge

410 Willoughby Avenue, Suite 303

Juneau, Alaska 99801

(907) 465-5302.
Trident - Akutan facility AK-003730-3

Fact Sheet page 3 of 31

TABLE OF CONTENTS

page

1 APPLICANT ........................................................... 5

2 TYPE OF FACILITY AND ACTIVITY ......................................... 5

2.1 Facility Location and Description ........................................ 5

2.2 Process Description ................................................. 5

2.3 Facility History and Performance ........................................ 5

3 PROPOSED DISCHARGE ................................................ 6

3.1 Nature, Amount, and Composition of Discharge ............................ 6

3.2 Treatment of Wastewater Prior to Discharge .............................. 7

4 RECEIVING WATER ..................................................... 7

4.1 Nature of Akutan Harbor .............................................. 7

4.2 Beneficial Uses of Akutan Harbor ....................................... 7

4.3 Climate ........................................................... 7

4.4 Water Column ...................................................... 8

4.5 Seafloor .......................................................... 8

5 BASIS FOR EFFLUENT LIMITATIONS AND MONITORING ...................... 9

5.1 General Approach ................................................... 9

5.2 Summary of Effluent Limitations, Past and Proposed ....................... 10

5.3 Technology-based Evaluation ......................................... 11

5.4 Mixing Zone and Other Variances to State Water Quality Standards ........... 12

5.5 Water Quality-based Evaluation ....................................... 12

5.6 Summary of Effluent Monitoring ....................................... 14

6 BASIS FOR BEST MANAGEMENT PRACTICES PLAN ......................... 15

7 BASIS FOR ENVIRONMENTAL MONITORING ............................... 16

8 BASIS FOR ANNUAL REPORT ........................................... 16

9 PERMIT CONDITIONS FOR COMPLIANCE, RECORDING, REPORTING, AND OTHER

GENERAL PROVISIONS ................................................ 17

10 OTHER LEGAL REQUIREMENTS ......................................... 18

10.1 State Water Quality Standards and Certification ........................... 18

10.2 Endangered Species Act ............................................. 18

10.3 Fishery Conservation and Management Act .............................. 19

10.4 Coastal Zone Management Act ........................................ 19

10.5 Pollution Prevention Act ............................................. 19

10.6 Oil Spill Requirements ............................................... 19
Trident - Akutan facility AK-003730-3

Fact Sheet page 4 of 31

11 MODIFICATION OF PERMIT LIMITS OR OTHER CONDITIONS .................. 20

12 PERMIT EXPIRATION ................................................... 20

13 GLOSSARY OF TERMS AND ACRONYMS .................................. 20

14 REFERENCES ........................................................ 25

APPENDIX A - Location of the Trident - Akutan facility ............................. 26

APPENDIX B - Diagram of the Trident - Akutan facility ............................. 27

APPENDIX C - Synopsis of Modeling the Discharge of Settleable Solid Seafood Residues . . 28
Trident - Akutan facility AK-003730-3

Fact Sheet page 5 of 31

1 APPLICANT

Trident Seafoods Corporation [Business Office]

5303 Shilshole Road

Seattle, WA 98107

Trident Seafoods Corporation, Inc., requested the reissuance of NPDES permit

no. AK-003730-3 for its Akutan shore-based processing facility on December 26, 2000.

2 TYPE OF FACILITY AND ACTIVITY

2.1 Facility Location and Description

Trident Seafoods Corporation owns, operates, and maintains the Trident - Akutan facility, a

facility which conducts seafood processing and seafood meal reduction. Trident - Akutan

facility is located on Akutan Harbor, Alaska. The facility lies at approximately 54o08'' N,

165o47' W, in Akutan Island of the Fox Island group in the easternmost Aleutian Islands,

USGS hydrologic unit number 19030102. The map in Appendix A shows the location of

the Trident - Akutan facility. The diagram of the grounds of the facility in Appendix B

shows the lay of the building, docks and outfall lines. The facility consists of (1) a large

onshore facility which houses crab, finfish and surimi processing lines and a meal

reduction facility, (2) product warehouses, (3) residential buildings, (4) a power house,

(5) tank farm, and (6) docks.

2.2 Process Description

Trident - Akutan facility processes surimi, minced and filleted pollock, headed/gutted and

filleted Pacific cod, frozen crab (king, bairdi, and opilio) sections, frozen (bait) herring,

black cod, and miscellaneous rockfish. Trident takes receipt of the seafood catch from

fishermen along its dock, offloading the catch in large vacuum lines or baskets. Seafood is

butchered by machine and by hand in any of several processing lines throughout the

facility. Processing wastes (i.e., heads, offal, unusable tissue parts) are flumed to

dewatering conveyors where they are transported to the meal plant for reduction to fish

meal, a marketable secondary product. Water used in butchering, processing, and fluming

is collected before final discharge and passed through a screening process to recover

residual tissue pieces. Screened solids are returned to the meal reduction plant. 

Wastewater is discharged without further treatment through a subsurface outfall. The

facility processes in excess of 200 million pounds of raw seafood annually, of which over

90% is pollock.

2.3 Facility History and Performance

The Trident - Akutan facility’s NPDES permit expired May 30, 2001. The facility’s

screening treatment of its effluent was installed in the early 1990's in order to capture

finfish and crab offal for reduction to meal thereby both producing a marketable by-product

and decreasing discharges of biochemical oxygen demand (measured as BOD5 and
Trident - Akutan facility AK-003730-3

Fact Sheet page 6 of 31

affecting the amount of dissolved oxygen, or DO, in the receiving water), total suspended

solids (TSS), settleable solid seafood residues, and floating process residues to Akutan

Harbor. The screen system was upgraded to a finer mesh in the mid-1990s. Trident has

contracted with vessels for the conveyance and at-sea disposal of stickwater and surimi

wastewater (effluents which do not contain screenable solids) in order to meet its effluent

limits during high-volume summer fisheries. 

The facility processes in excess of 200 million pounds of raw seafood annually. A review

of the facility’s discharge monitoring reports shows that the facility’s average flow is as

much as 7 million gallons per day (MGD), of which 3 MGD is non-contact wastewater. 

Sanitary wastewater (50,000 gal/day) is discharged to Akutan Harbor. The effluent

discharge ranges in temperature from a low of 6°C in the winter to a high of 17°C in the

summer; pH ranges from 6.5 to 7.6. 

The discharge monitoring reports indicate that the facility has reported compliance with its

permit effluent limits for the period of permit issuance to the present. Trident Seafoods has

provided information on the pollutant loads of the effluent leaving its processing lines and

including pollutants removed through screening and subsequent reduction. The facility has

reported an average monthly discharge of 148,933 lbs TSS/day and a maximum daily

discharge of 787,805 lbs TSS/day based upon 62 analyses. The facility has reported an

average monthly discharge of 23,358 lbs oil and grease/day and a maximum daily

discharge of 66,906 lbs oil and grease/day based upon 33 analyses. The facility reported

a monthly average BOD5 discharge of 115,314 lbs BOD5/day and a maximum daily

discharge of 594,047 lbs BOD5/day based on 140 analyses over a one-year period. 

During the summer monitoring period (August through October), when effluent limits

applied (May through October), the facility reported a monthly average BOD5 discharge of

73,956 lbs BOD5/day and a maximum daily discharge of 134,907 lbs BOD5/day based on

81 analyses conducted over the three-month period (August through October). The facility

has not detected total residual chlorine (TRC) in its effluent discharge.

3 PROPOSED DISCHARGE

3.1 Nature, Amount, and Composition of Discharge

Trident - Akutan facility discharges seafood processing wastewater consisting of relatively

high levels of biochemical oxygen demand (BOD5), total suspended solids (TSS),

settleable solid processing residues, floating residues, fish oils, and scum. The effluent

discharge may also contain traces of disinfectants. These wastewater streams can be

several degrees warmer than the receiving waters. The plant also discharges various noncontact cooling wastewaters from an air treatment scrubber, electrical generators and

refrigeration condenser units which may be as much as 5°C above ambient temperatures

and may contain trace amounts of other pollutants.
Trident - Akutan facility AK-003730-3

Fact Sheet page 7 of 31

3.2 Treatment of Wastewater Prior to Discharge

The Trident - Akutan facility treats its final effluent wastewater with 0.5 x 5 millimeter

slotted wedgewire screening, recovering all residual waste particles to one-half millimeter

width prior to discharge. This screening and meal reduction reduces the facility’s effluent

discharges of BOD5 (estimated decrease of more than 75%), TSS (estimated decrease of

more than 97%), settleable solid process residues (estimated decrease of more than 98%),

and floating solid process residues (estimated decrease of more than 98%).

4 RECEIVING WATER

4.1 Nature of Akutan Harbor

Akutan Harbor is located on the east side of Akutan Island in the Fox Islands group of the

eastern Aleutian Islands. It lies at roughly 54°08' N latitude, 165°46'W longitude. The

harbor is about 710 miles southwest of Anchorage.

Akutan Harbor is a glacially-formed fjord approximately 3.5 nautical miles (nm) long and

0.5 (head) to 2.0 (mouth) nm wide (Figure 1). Its area is approximately 3.8 nm2. The

northern and southern shorelines are generally rocky and steep. Elevations of 1,082 ft

(330 m) are reached in under 0.6 mile (1 km) along both sides of the fjord. The head of

the fjord is a flat valley with a gradually increasing slope as it curves around to a high ridge

to the northeast.

4.2 Beneficial Uses of Akutan Harbor

Designated beneficial uses for Alaska’s marine waters are established by regulation and

are found in the State of Alaska Water Quality Standards [18 AAC 70]. For marine waters

of the state, these designated uses include: (1) water supply, (2) water recreation, (3)

growth and propagation of fish, shellfish, other aquatic life, and wildlife, and (4) harvesting

for consumption of raw mollusks or other raw aquatic life [18 AAC 70.020(a)(2)]. 

4.3 Climate

The eastern Aleutian Islands are characterized by a maritime climate. Low-lying fog,

overcast skies, rain, and drizzle dominate weather conditions along the islands. Average

annual precipitation in the area is estimated to be about 30 inches, some of which falls as

snow. Fog occurs frequently in the summer. Normal summer air temperatures range from

50 to 60oF while normal winter air temperatures range from 25 to 35oF.

Local weather data indicate moderate to strong winds throughout the year. Winds in winter

and during storms are usually strong. Limited meteorological data, collected by Trident

Seafoods, show that westerly winds predominate, occurring about 70% of the time, and

that winds seldom exceed 20 knots.
Trident - Akutan facility AK-003730-3

Fact Sheet page 8 of 31

4.4 Water Column

EPA studied the oceanography of Akutan Harbor in 1983, 1992 and 1993 (Jones and

Stokes 1983, 1992; TetraTech 1993). The waters of the harbor transition from estuarine at

its head to marine at its mouth. Salinities are generally typical of coastal Alaskan waters

except at the surface of the head of the harbor.

Akutan Harbor in predominantly unstratified throughout most of the year (Jones and

Stokes 1983, 1992). During the summer, however, the water column becomes

progressively stratified from May through early September and then rapidly returns to an

unstratified condition in October (Tetra Tech 1993).

Current meter records indicated that tidal currents are weak (1 to 2 cm/sec) and drive a

relatively minor portion (< 10%) of the harbor's hydrodynamics. Winds, especially

intermittent wind events, are the primary forces generating currents in Akutan Harbor. 

Wind-generated currents may have velocities of 5 to 20 cm/sec, with storms producing the

higher velocity currents.

Winds vary in both direction and velocity, producing circulation patterns of varying

directions and velocities. The hydrodynamic model of Akutan Harbor indicates that the

surface currents along the center of the outer harbor align with the wind sheer and that

compensatory flow occurs along both the north and south boundaries and along the

bottom. When the wind blows from the east into Akutan Harbor, currents move into the

harbor at mid-channel and out along the outer harbor shores. When the wind blows from

the west out of Akutan Harbor, currents move out of the harbor at mid-channel and into the

outer harbor along its shores.

Akutan Harbor appears to have three cellular circulation patterns: (1) an outer harbor cell

from the mouth to roughly 165°45'45" W longitude (0.2 nautical mile east of Akutan

village), (2) a mid-harbor cell from the outer cell to roughly 165°47' W longitude (the

easternmost part of the Trident onshore facility dock), and (3) an inner harbor cell from the

middle cell to the head of the harbor. Circulation and current velocities decrease and

turnover or replacement time increases from the outer to the inner harbor.

Several small streams discharge freshwater to Akutan Harbor. Three streams are known

to support runs of anadromous salmonids: two at the head of the harbor and one along its

southeast margin. A number of streams on the northern slopes of the fjord are

impounded and/or diverted for domestic use and seafood processing.

4.5 Seafloor

Akutan Harbor's subsurface topography, or bathymetry, is relatively simple. The

submarine slopes along the sides of the harbor are steep, with water depths of 60 ft

reached within 480 ft from shore (8:1 slope). The harbor's seafloor is relatively flat and

gradually deepens from 88 ft at the head of the harbor to 200 ft at its mouth. The harbor

has a slight sill at its mouth which rises approximately 20 ft above the outer harbor basin

before descending to depths of greater than 300 ft. As a depositional basin, the seafloor is

predominantly a silty habitat which has an increasing component of sand, gravel, and rocks

near shore.
Trident - Akutan facility AK-003730-3

Fact Sheet page 9 of 31

5 BASIS FOR EFFLUENT LIMITATIONS AND MONITORING

5.1 General Approach

EPA followed the Clean Water Act, state regulations, and EPA’s 1991 Technical Support

Document for Water Quality-Based Toxics Control (TSD) to develop the proposed effluent

limits. 

In general, the Clean Water Act requires that the effluent limit for a particular pollutant be

the more stringent of either the technology-based or water quality-based limit. This

proposed permit includes both technology-based and water quality-based limits. 

Technology-based limits are established based upon the level of treatment that is

achievable using available technology. Water quality-based limits are designed to prevent

exceedance of the Alaska Water Quality Standards (AWQS) in the receiving water. 

Appendix C contains more detail about how EPA established these water quality-based

limits on settleable solid seafood residues.
Trident - Akutan facility AK-003730-3

Fact Sheet page 10 of 31

5.2 Summary of Effluent Limitations, Past and Proposed

Table I: Comparison of Permit Limits

Parameter 1996 Permit Limits Proposed Limits 

Seafood Processing Wastewater

BOD5, lbs/day Monthly Average 129,000 (May 1 to Oct. 31) 129,000 (June 1 to Oct. 31)

Daily Maximum 206,000 (May 1 to Oct. 31) 206,000 (June 1 to Oct. 31)

Settleable Solids Maximum particle

size

0.5 mm (process residues) 1 mm (finfish wastes)

0.5 inch (crab wastes)

Settleable Solids Annual load - 1 acre

zone of deposit 

no limit 2,700,000 lbs/yr @ 1mm

14,400,000 lbs/yr @ 0.5 in

pH, standard units Range 6.5 to 8.5 6.5 to 8.5

Non-contact Scrubber, Condenser and Cooling Wastewater

TSS, lbs/1,000 lbs Monthly Average 1.5 no limit

Daily Maximum 3.7 no limit

Oil and Grease, 

lbs/1,000 lbs

Monthly Average 0.76 no limit

Daily Maximum 1.4 no limit

BOD, lbs/1,000

lbs

Monthly Average 3.8 no limit

Daily Maximum 6.7 no limit

pH, standard units Range 6.5 to 8.5 no limit

Temperature Daily Maximum no limit 20°C

Sanitary Wastewater

BOD5, mg/L Monthly Average 30 30

Weekly Average 45 45

Daily Maximum 60 60

TSS, mg/L Monthly Average 30 30

Weekly Average 45 45

Daily Maximum 60 60

pH, standard units range 6.0 to 9.0 6.5 to 8.5
Trident - Akutan facility AK-003730-3

Fact Sheet page 11 of 31

Proposed permits limits for settleable solids are based on the proposed zone of deposit of

one acre. 

The proposed permit requires that finfish processing wastes shall be screened to

approximately one millimeter (1 mm) in width and that crab processing wastes shall be

ground to one half inch (0.5 in) width prior to discharge through on-site outfalls. The

proposed permit further provides that all seafood processing solid waste residues shall be

ground to one half inch (0.5 in) width prior to discharge at sea in depths greater than 120 ft

MLLW and at a distance of one mile from shore. The proposed permit also prohibits

discharges of waste streams that are not part of the normal operation of the facility, as

reported in the permit application.

5.3 Technology-based Evaluation

Section 301 of the Clean Water Act requires particular categories of industrial dischargers

to meet technology-based effluent limitation guidelines. The intent of a technology-based

effluent limitation is to require a minimum level of treatment for industrial and municipal

point sources across the country based on currently available treatment technologies while

allowing a discharger to choose and use any available pollution control technique to meet

the limitations. Where EPA has not yet developed guidelines for a particular industry, EPA

can establish permit limitations using Best Professional Judgment (BPJ; 40 CFR

§§ 122.43, 122.44 and 125.3).

EPA has determined that discharges of seafood processing wastes shall not exceed one

half inch (0.5 in) width when processed and discharged in remote Alaskan locations. In the

case of seafood processors discharging large quantities of solid seafood waste residues

which produce persistent deposits of more than one acre on the sea floor, EPA has made

a BPJ determination that finfish wastewater must be screened to approximately one

millimeter (1 mm) width prior to discharge. In order to reduce the pollutant load, solid

residues must be either screened, collected, and reduced to meal or transported for

disposal from an underway vessel to offshore waters as designated by EPA and the State

of Alaska.

EPA has previously required in-plant technology-based limits for individual process lines

based upon national effluent guidelines for bottomfish, salmon, and herring processing. In

administering the permit EPA has found that the separation, collection, and on-site

utilization and burning of fish oils and the commingling of the various effluent streams for

screening and final discharge through a single outfall support the use of more stringent

water quality-based limits for biochemical oxygen demand (BOD5) and waste residues.

Average weekly and monthly BOD5 and TSS effluent limits for the sanitary wastewater

discharge are based on secondary treatment standards (40 CFR § 102) as summarized in

the following table.
Trident - Akutan facility AK-003730-3

Fact Sheet page 12 of 31

Parameter Average Weekly Average Monthly Daily Maximum

BOD5 45 mg/L 30 mg/L 60 mg/L

SS 45 mg/L 30 mg/L 60 mg/L

Daily maximum effluent limits for BOD5 and TSS of 60 mg/L are based on state regulation

18 AAC 72.990 relating to wastewater disposal. These limits are the same as those of the

1996 permit.

5.4 Mixing Zone and Other Variances to State Water Quality Standards

The State of Alaska, through ADEC, can authorize a number of site-specific variances to

the Alaska Water Quality Standards. Variances to AWQS include site-specific water

quality criteria (18 AAC §§ 70.220 and 70.235), a mixing zone wherein AWQS may be

exceeded (18 AAC § 70.240), a zone of deposit wherein the AWQS criteria for settleable

residues may be exceeded (18 AAC § 70.210), and short-term variances from the antidegradation policy standard or the water quality criteria (18 AAC § 70.200). In addition,

ADEC may exercise enforcement discretion in determining whether to initiate an

enforcement action on a water quality violation (18 AAC § 70.900).

In the case of this permit, Trident is applying for (1) mixing zones of 100 ft radius around

the outfalls of Discharges 001A -B for temperature, color, turbidity, residues, and pH, (2) a

mixing zone of 100 ft radius around the outfall of Discharge 003 for fecal coliform, color,

turbidity, residues, and TRC, (3) a mixing zone 230 ft wide and 12,200 ft long for the at-sea

Discharge 004, and (4) a one acre zone of deposit on the sea floor around Outfall 001A -B

for settleable solids seafood processing residues. ADEC has indicated that it will approve

such areas in its State certification of the NPDES permit. No mixing zone is required for

Discharge 002.

5.5 Water Quality-based Evaluation

Water quality-based limits are derived from the Alaska Water Quality Standards to protect

the water quality and beneficial uses of Alaskan waters. The NPDES regulation at 40 CFR

§ 122.44(d)(1) requires that permits include limits for all pollutants or parameters which

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

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

narrative criteria for water quality.” The limits must be stringent enough to ensure that

Alaska water quality standards are met, and must be consistent with any available

wasteload allocation established in the assessment of a total maximum daily load of

pollutant discharges to a receiving water. Based upon Trident’ monitoring of its effluents

and its receiving waters, water quality-based limits are justified for four pollutants:

biochemical oxygen demand (BOD5), settleable solid seafood processing residues,

temperature, and pH (a measure of the acidity or alkalinity of the wastewaters). 

EPA Region 10 completed an assessment of the TMDL for settleable solids seafood

processing residues for Akutan Harbor, predicting wasteloads which would produce waste
Trident - Akutan facility AK-003730-3

Fact Sheet page 13 of 31

piles of different sizes on the sea floor around an outfall. This TMDL provides the

foundation for water quality-based limits of residues in this permit. Trident has requested

that the permit limits for settleable solid residues provide for a discharge of a combination

of both screened finfish wastes and ground crab wastes. EPA has completed an

assessment of allowable discharges of both screened and ground wastes for a zero acre,

one acre and two acre zone of deposit (Table 1, above; Appendix C). At the publication of

this draft permit, ADEC has tentatively approved a one acre zone of deposit. The permits

limits are based on modeling results for a one acre zone of deposit, allowing for a safety

factor.

EPA previously completed TMDL determinations for the discharge of biochemical oxygen

demand into Akutan Harbor and developed appropriate water quality-based limits on

discharges of BOD5 at the facility. The facility has been able to meet these limits and

water quality monitoring of Akutan Harbor indicates that these limits have been protective

of the Alaska Water Quality Standard for dissolved oxygen. The average monthly and

maximum daily limits on BOD5 have been sustained in the current permit reissuance.

The most stringent State criteria for pH are those for the growth and propagation of fish,

shellfish, and other aquatic life: pH may not be less than 6.5 or greater than 8.5, and may

not vary more than 0.1 pH unit from natural conditions in the receiving water. Based on

these criteria, the permittee may not discharge effluents for which the pH is less than 6.5 or

greater than 8.5.

The most stringent State criteria for temperature are that the temperature of a discharge

may not exceed 15°C or cause the weekly average to increase by more than 1°C. State

criteria exist for color, turbidity, and floating residues... pollutants characteristic of the

wastewater plume of seafood processors. It is EPA’s best professional judgment that the

Alaska water quality criteria for temperature, color, turbidity, and floating residues will be

met outside of the mixing zones. The EPA is proposing a maximum temperature limit of

20° C for non-contact cooling water, based on a past 401 Certification from ADEC for a

similar type discharge.

Antidegradation of Water Quality. In proposing to reissue this permit, EPA has considered

the State’s antidegradation policy [18 AAC 70.015]. This policy states, in part, that in

Alaska: “the existing water uses and the level of water quality necessary to protect the

existing uses must be maintained and protected (and), if the quality of a water exceeds

levels necessary to support propagation of fish, shellfish, and wildlife and recreation in and

on the water, that quality must be maintained and protected unless the department

(ADEC)... allows the reduction in water quality...”. The permit, as stated above, allows and

limits effluent discharges of temperature, pH, and residues. The limits in the draft permit

are consistent with and protective of the State water quality standards and the water quality

of the receiving water. EPA believes that the draft permit is consistent with the State’s

antidegradation policy.
Trident - Akutan facility AK-003730-3

Fact Sheet page 14 of 31

5.6 Summary of Effluent Monitoring

The Clean Water Act requires that monitoring shall be included in permits to determine

compliance with effluent limitations. Monitoring may also be required to gather data for

future effluent limitations and to monitor effluent impacts on the receiving water. The

Permittee will be responsible for conducting the monitoring and for reporting the results to

EPA. Table II presents the proposed monitoring requirements based on the minimum

sampling necessary to adequately monitor the facility’s performance. For comparison

purposes, the table also shows the monitoring requirements in the past permit.

TABLE II. Comparison of Monitoring Requirements

Parameter 1996 Permit 

Frequency and Sample Type 

Proposed Permit

Frequency and Sample Type 

Seafood Processing Water - Summer

Monitoring Months August, September, October July, August, September,

October

Flow (mgd) daily, record daily, meter

BOD5 (mg/L; lbs/day) 2/week, 24-hr composite 2/week, grab or composite

TSS (mg/L; lbs/unit) 2/week, 24-hr composite 1/week, grab or composite

Settleable Solids (mg/L;

lbs/day)

2/week, 24-hr composite 1/week, grab or composite

Oil and Grease,(mg/L; lbs/unit) 1/week, grab no monitoring

pH 1/week, grab 1/week, grab

Seafood Processing Water - Winter

Monitoring Months January, February, March February

Flow (mgd) daily, record daily, meter

BOD5 (mg/L; lbs/day) 1/week, 24-hr composite 1/week, grab or composite

TSS (mg/L; lbs/unit) 1/week, 24-hr composite 1/week, grab or composite

Settleable Solids (mg/L;

lbs/day)

1/week, 24-hr composite 1/week, grab or composite

Oil and Grease,(mg/L; lbs/unit) 1/month, grab no monitoring

pH 1/month, grab 1/week, grab

Non-contact Scrubber, Condenser and Cooling Wastewater - Summer and Winter

Monitoring Months January, February, March,

August, September, October

February, July, August,

September, October

Flow (mgd) daily, record daily, record

Production Levels daily, record no monitoring
Trident - Akutan facility AK-003730-3

Fact Sheet page 15 of 31

TABLE II. Comparison of Monitoring Requirements

Parameter 1996 Permit 

Frequency and Sample Type 

Proposed Permit

Frequency and Sample Type 

BOD5 (mg/L; lbs/day) 1/week, 24-hr composite no monitoring

TSS (mg/L; lbs/unit) 1/week, 24-hr composite no monitoring

Oil and Grease,(mg/L; lbs/unit) 1/month, grab no monitoring

pH 1/month, grab no monitoring

Temperature none daily, grab or probe

Sanitary Sewer - Summer and Winter

Monitoring Months January, February, March,

August, September, October

February, July, August,

September, October

Flow (mgd) daily, record daily, record

BOD5 (mg/L) 1/week, 24-hr composite 1/week, grab or composite

TSS (mg/L) 1/week, 24-hr composite 1/week, grab or composite

Fecal Coliform (colonies/100

mL)

5/month, grab 5/month, grab

Total Residual Chlorine (μg/L) monthly, grab no monitoring

pH 1/week, grab 1/week, grab

The permit requires weekly effluent monitoring of pollutant parameters for which a limit or

condition exists within the permit (40 CFR §§ 122.41 and 122.44). Monitoring is conducted

during five of the twelve months per year as sufficient to collect representative samples

which quantify both concentrations and mass loading for the facility; the sampling months

coincide with fishing seasons and attendant high levels of pollutant discharge. 

Representative Sampling. The proposed permit requires sampling whenever a bypass,

spill, or non-routine discharge of pollutants occurs, if such a discharge could cause a

violation of an effluent limit.

6 BASIS FOR BEST MANAGEMENT PRACTICES PLAN

The Clean Water Act and federal regulations authorize EPA to require best management

practices, or BMPs, in NPDES permits. BMPs are measures for controlling the generation

of pollutants and their release to waterways. For many facilities, these measures are

typically included in the facility Operation & Maintenance plans (O&M) plans. BMPs are

important tools for waste minimization and pollution prevention. EPA encourages facilities

to incorporate BMPs into their O&M plans and to revise them as new practices are

developed.

The proposed permit requires Trident to develop and implement a BMP plan within 180
Trident - Akutan facility AK-003730-3

Fact Sheet page 16 of 31

days of permit issuance. The Permittee must develop a materials balance assessment

(i.e., a flow diagram) of its process, treatment and discharge lines and quantify the input

and output streams of water and pollutants. The Permittee must consider the optimization

of product recovery and chemical use, staff training aimed at controlling the discharge of

pollutants to the receiving waters, spill prevention and control, and water conservation. 

The Permittee must document this assessment as a working document known as a BMP

plan in accordance with the requirements of the permit.

7 BASIS FOR ENVIRONMENTAL MONITORING

The proposed permit requires Trident to monitor the receiving water for the discharge and

accumulation of residues on the sea floor, sea surface and shoreline and for the

degradation of dissolved oxygen concentrations in the water column. The purpose of this

monitoring is to verify the assumptions made in developing permit limits regarding

receiving water conditions and the effectiveness of permit limits. Based on the results of

this study, EPA will determine whether or not to revise these permit limits when the permit

is renewed. 

Ambient monitoring of the residues on the sea surface and sea floor and of dissolved

oxygen within the water column are important in monitoring the effect of the Trident plant

on the receiving waters. Daily surveys and records of the sea surface and sea shore for

scum and other residues are required in the permit. Monitoring of settleable residues on

the sea floor is required as an annual sea floor survey in the area around the outfall. 

Water quality monitoring of the receiving waters is required in the second and fourth years

of the permit, and will verify the continue protection of the State water quality standard for

dissolved gases in the bay and the efficacy of permit limits.

The proposed permit requires the Permittee to submit study plans to EPA and ADEC for

approval. The plan must address issues such as appropriate sampling location, variability

in the receiving water, appropriate sampling and analytical methods, analytical variability,

and quality assurance/quality control for sampling and analysis.

8 BASIS FOR ANNUAL REPORT

The proposed permit requires the Permittee to complete and submit an annual report

which compiles effluent and environmental monitoring data and reports permit violations,

upset conditions, by-pass conditions, plant or process changes, and corrective actions

undertaken to improve wastewater treatment and pollution prevention at the facility. The

annual report provides a comprehensive record of wastewater discharge at the facility and

its effect on the receiving water. The annual report supports improved understanding and

management of the discharges and discussion of these discharges by the applicant and

government representatives. Title 40 of the Code of Federal Regulations provides the

regulatory basis for this requirement at sections 122.41 (“Conditions applicable to all

permits”), 122.44(i) (“Monitoring requirements”), and 122.48 (“Requirements for recording

and reporting of monitoring results”).
Trident - Akutan facility AK-003730-3

Fact Sheet page 17 of 31

9 PERMIT CONDITIONS FOR COMPLIANCE, RECORDING, REPORTING, AND OTHER

GENERAL PROVISIONS

Sections § VI through VIII of the draft permit contain standard regulatory language that is

required to be in all NPDES permits. The following sections of the permit are based largely

upon 40 CFR Part 122, subpart C, “Permit Conditions” and on other referenced laws and

regulations.

- Duty to Comply from 40 CFR § 122.41(a),

- Proper Operation and Maintenance from 40 CFR § 122.41(e),

- Duty to Mitigate from 40 CFR § 122.41(d),

- Toxic Pollutants from 40 CFR § 122.41(a)(1-2), § 122.44(b, e), and § 125.3,

- Removed Substances from 40 CFR § 122.41(a)(1) and (o) and CWA § 405(A),

- Need to Halt or Reduce Activity not a Defense from 40 CFR § 122.41(c),

- Bypass of Wastewater Treatment from 40 CFR § 122.41(m),

- Upset Conditions from 40 CFR § 122.41(n),

- Inspection and Entry from 40 CFR § 122.41(i),

- Penalties for Violations of Permit Conditions from 40 CFR § 122.41(a)(2-3),

- Duty to Provide Information from 40 CFR § 122.41(h),

- Records Contents from 40 CFR § 122.41(j)(3),

- Submittal of Reports from 40 CFR § 122.41(h, j, and l),

- Retention of Records and Reports from 40 CFR § 122.41(j)(2),

- On-site Availability of Records and Reports from 40 CFR § 122.41(i)(2),

- Availability of Reports for Public Review from 40 CFR § 122.1(e) and § 122.7(1) and

40 CFR § 2.101,

- Planned Changes from 40 CFR § 122.41(l)(1),

- Changes in the Discharge of Toxic Substances from 40 CFR § 122.42(a),

- Anticipated Noncompliance from 40 CFR § 122.41(l)(2),

- Reporting of Noncompliance from 40 CFR § 122.41(l)(6-7) and § 122.44(g),

- Permit Actions from 40 CFR § 122.44(c) and 40 CFR § 122.61 - § 122.64,

- Duty to Reapply from 40 CFR § 122.41(b),

- Incorrect Information and Omissions from 40 CFR § 122.41(l)(8),

- Signatory Requirements from 40 CFR § 122.41(k),

- Property Rights from 40 CFR § 122.41(g),

- Severability from 40 CFR § 124.16,

- Transfers from 40 CFR § 122.41(l)(3),

- Oil and Hazardous Substance Liability from 40 CFR § 125.3, 40 CFR part 300, 33 CFR

§ 153.10(e), and section 311 of the Act,

- State Laws from 40 CFR § 122.1(f) and section 510 of the Act, and

- Reopening of the Permit from 40 CFR § 122.41(f) and § 122.44(c).
Trident - Akutan facility AK-003730-3

Fact Sheet page 18 of 31

10 OTHER LEGAL REQUIREMENTS

10.1 State Water Quality Standards and Certification

EPA is requesting State officials to review and provide appropriate certification to this

NPDES permit pursuant to 40 CFR § 124.53. Since State waters are involved in the

draft permit, the provisions of Section 401 of the Clean Water Act apply, requiring EPA

to seek State certification that the permit is protective of the State Water Quality

Standards before issuing a final permit. This certification by the State ensures that

federally issued permits are in compliance with the laws of the State (see 40 CFR

§ 124.55). In particular, ADEC must provide written stipulation for a water quality study

of the receiving water and authorization of mixing zones and a zone of deposit in its

certification of the permit. In accordance with 40 CRF §124.10(c)(1), public notice of the

draft permit has been provided to the State agencies having jurisdiction over fish,

shellfish and wildlife resources, and over coastal zone management plans.

10.2 Endangered Species Act

Endangered species found in the vicinity of the discharge include Eskimo curlew

(Numenius borealis), American peregrine falcon (Falco peregrinus anatum), Aleutian

shield-fern or Aleutian holly-fern (Polystichum aleuticum), short-tailed albatross

(Diomedea albatrus), humpback whale (Megaptera novaeangliae), right whale

(Eubalaena glacialis), and blue whale (Balaenoptera musculus). Threatened species

found in the vicinity of the discharge include Spectacled eider (Somateria fischeri),

Steller's eider (Polysticta stelleri), Aleutian Canada goose (Branta canadensis

leucopareia), and Steller sea lion (Eumetopias jubatus). Pursuant to 40 CFR

§ 122.49(c), EPA has concluded that, with the exception of the Steller's eider, the

localized effluent discharges authorized by this permit will have no effect on the

continued existence of these endangered or threatened species and will not adversely

affect their critical habitat. 

The EPA has concluded that the localized effluent discharges authorized by this permit

are likely to adversely affect Steller’s eiders. EPA has initiated consultation with USFWS

on the potential effects of this permit action on Steller’s eiders, and is applying the

conclusions and reasonable and prudent measures developed in the Service’s biological

opinion on the permitting of seafood processors throughout Alaska (USFWS 01/17/01;

Attachment A to draft permit). EPA will initiate additional consultation with NMFS or

USFWS should new information reveal impacts not previously considered, should the

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

activities affect a newly listed threatened or endangered species.

The draft permit, fact sheet and consistency determination will be submitted to the U.S.

Fish and Wildlife Service (USFWS) and the National Marine Fisheries Service (NMFS)

for review at the time of public notice. EPA is requesting concurrence from USFWS and

NMFS on the draft permit, and will consider their comments in the final permit decision. 
Trident - Akutan facility AK-003730-3

Fact Sheet page 19 of 31

10.3 Fishery Conservation and Management Act

The Magnuson-Stevens Fishery Conservation and Management Act requires EPA to

consult with NMFS with respect to the reissuance of this NPDES permit concerning its

impacts on any essential fish habitat and to provide a description of the measures

proposed to avoid, mitigate, and offset the impact of this permitted discharge on such

habitat. EPA finds that the permitted discharge will comply with Alaska Water Quality

Standards outside of the authorized zones of variance, that decreases in marine life

within these zones will be compensated by increases in the abundance of marine life in

surrounding zones of organic enrichment, and that issuance of this permit is not likely to

adversely affect any species in the vicinity of the discharge. EPA provides this fact

sheet to describe the discharge, the draft permit, and the permit’s limits, conditions, and

measures of mitigation.

10.4 Coastal Zone Management Act

The applicant has certified that the activities authorized by this draft permit are

consistent with the Alaska Coastal Management Plan. The draft permit, fact sheet and

consistency determination will be submitted to the State for review at the time of public

notice. Pursuant to 40 CFR § 122.49(d), requirements for State coastal zone

management review and approval must be satisfied before the permit may be issued.

10.5 Pollution Prevention Act

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

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

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

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

manner. The Permittee will discharge at the facility in accordance with best

management practices which will address the provisions of the Pollution Prevention Act.

10.6 Oil Spill Requirements

Section 311 of the Clean Water Act prohibits the discharge of oil and hazardous

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

excluded from the provisions of Section 311 because these discharges are limited to

amounts and concentrations which are deemed to be protective of State water quality

standards. However, this permit does not preclude the institution of legal action or

relieve the Permittee from any responsibilities, liabilities, or penalties for other

unauthorized discharges of toxic pollutants which are covered by Section 311 of the Act.
Trident - Akutan facility AK-003730-3

Fact Sheet page 20 of 31

11 MODIFICATION OF PERMIT LIMITS OR OTHER CONDITIONS

When EPA receives information that demonstrates the existence of reasonable cause to

modify the permit in accordance with 40 CFR § 122.62(a), EPA may modify the permit. 

“Reasonable cause” includes alterations or additions to the facility or activity, new federal

regulations or standards, new state water quality standards, the completion or

modification of total maximum daily loads or wasteload allocations for the receiving water

of the facility (also, see 40 CFR § 122.44(d)((1)(vii)(B)), failure of the permit to protect

state water quality standards, a change in a permittee’s qualification for net limits, any

relevant compliance schedule, the need to incorporate or revise a pretreatment or land

application plan, when pollutants which are not limited in the permit exceed the level

which can be achieved by technology-based treatment, the correction of technical

mistakes and legal misinterpretations of law made in determining permit conditions, and

the receipt of new information relevant to the determination of permit conditions. Minor

modifications to a permit may be made by EPA with the consent of a permittee in order

to correct typographical errors, change an interim compliance schedule, allow for a

change in ownership, change a construction schedule, or delete an outfall. Pursuant to

40 CFR § 122.63, such minor modifications may be made without public notice and

review.

12 PERMIT EXPIRATION

This permit will expire five years from its effective date. In accordance with 40 CFR

§ 122,6(a), the conditions of an expired permit continue in force under 5 U.S.C. § 558(c)

until the effective date of a new permit when a permittee submits an application for

permit reissuance 180 days before the expiration of the permit. Permits which are

continued because EPA has not reissued a new permit remain fully effective and

enforceable.

13 GLOSSARY OF TERMS AND ACRONYMS

§ means section or subsection.

AAC means Alaska Administrative Code.

ADEC means Alaska Department of Environmental Conservation.

Average monthly discharge means the average of “daily discharges” over a monitoring

month, calculated as the sum of all daily discharges measured during a monitoring

month divided by the number of daily discharges measured during that month. It may

also be referred to as the "monthly average discharge."

Best management practices (“BMPs”) means schedules of activities, prohibitions of

practices, maintenance procedures, and other management practices to prevent or

reduce the pollution of “waters of the United States.” BMPs also include treatment
Trident - Akutan facility AK-003730-3

Fact Sheet page 21 of 31

requirements, operating procedures, and practices to control plant site runoff, spillage or

leaks, sludge or waste disposal, or drainage from raw material storage.

BOD5 means biochemical oxygen demand, five-day.

Bypass means the intentional diversion of waste streams from any portion of a

treatment facility.

°C means degrees Celsius.

CFR means Code of Federal Regulations.

Cooling water means once-through non-contact cooling water.

CWA means the Clean Water Act, (formerly referred to as the Federal Water Pollution

Control Act or Federal Water Pollution Control Act Amendments of 1972) Public Law

92-500, as amended by Public Law 95-217, Public Law 95-576, Public Law 96-483 and

Public Law 97-117, 33 U.S.C. 1251 et seq.

Daily discharge means the discharge of a pollutant measured during a calendar day or

any 24-hour period that reasonably represents the calendar day for purposes of

sampling. For pollutants with limitations expressed in units of mass, the "daily

discharge" is calculated as the total mass of the pollutant discharged over the day. For

pollutants with limitations expressed in other units of measurement, the "daily discharge"

is calculated as the average measurement of the pollutant over the day.

Daily maximum discharge means the highest allowable "daily discharge" and is also

referred to as the "maximum daily discharge."

Discharge of a pollutant means any addition of any "pollutant" or combination of

pollutants to "waters of the United States" from any "point source" or any addition of any

pollutant or combination of pollutants to the waters of the “contiguous zone” or the

ocean from any point source other than a vessel or other floating craft which is being

used as a means of transportation.

Discharge Monitoring Report (“DMR”) means the EPA uniform national form, including

any subsequent additions, revisions, or modifications for the reporting of self-monitoring

results by permittees. DMRs must be used by “approved States” as well as by EPA. 

DO means dissolved oxygen.

Effluent limitation means any restriction imposed by the Director on quantities, discharge

rates, and concentrations of “pollutants” which are “discharged” from “point sources” into

“waters of the United States,” the waters of the “contiguous zone,” or the ocean.

EPA means U.S. Environmental Protection Agency.
Trident - Akutan facility AK-003730-3

Fact Sheet page 22 of 31

ESA means the Endangered Species Act.

°F means degrees Fahrenheit.

Facility or activity means any NPDES “point source” or any other facility or activity

(including land or appurtenances thereto) that is subject to regulation under the NPDES

program.

lb means pound.

Maximum means the highest measured discharge or pollutant in a waste stream during

the time period of interest.

Maximum daily discharge limitation means the highest allowable “daily discharge.”

MGD means million gallons per day.

mg/L means milligrams per liter.

Mixing zone means the zone of dilution authorized by ADEC under 18 AAC 70.032

wherein pollutant concentrations may exceed the criteria of the Alaska Water Quality

Standards for the proscribed pollutants.

MLLW means mean lower low water.

mg/L means milligrams per liter.

ml means milliliter.

NMFS means National Marine Fisheries Service.

National Pollutant Discharge Elimination System (“NPDES”) means the national

program for issuing, modifying, revoking and reissuing, terminating, monitoring and

enforcing permits, and imposing and enforcing pretreatment requirements, under

sections 307, 402, 318, and 405 of CWA.

OW means EPA’s Office of Water.

P.L. means (U.S.) Public Law.

Point source means any discernible, confined, and discrete conveyance, including but

not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container,

rolling stock, concentrated animal feeding operation, landfill leachate collection system,

vessel or other floating craft from which pollutants are or may be discharged. This term

does not include return flows from irrigated agriculture or agricultural storm water runoff.
Trident - Akutan facility AK-003730-3

Fact Sheet page 23 of 31

Pollutant means dredged spoil, solid waste, incinerator residue, filter backwash,

sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials,

radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and

industrial, municipal, and agricultural waste discharged into water.

Process wastewater means any water which, during manufacturing or processing,

comes into direct contact with or results from the production or use of any raw material,

intermediate product, finished product, byproduct, or waste product.

QAPP means quality assurance project plan.

Schedule of compliance means a schedule of remedial measures included in a “permit'',

including an enforceable sequence of interim requirements (for example, actions,

operations, or milestone events) leading to compliance with the CWA and regulations.

sp. means species.

Sanitary wastes means human body waste discharged from toilets and urinals.

Seafood means the raw material, including freshwater and saltwater fish and shellfish,

to be processed, in the form in which it is received at the processing plant.

Seafood process waste means the waste fluids, organs, flesh, bones, and chitinous

shells produced in the conversion of aquatic animals and plants from a raw form to a

marketable form.

Settleable solid process residues means process waste solids that gravimetrically settle

out of the process wastewater and accumulate on the bottom of a wastewater discharge

collection sump (which typically has a residence time of 15 minutes).

Severe property damage means substantial physical damage to property, damage to

the treatment facilities which causes them to become inoperable, or substantial and

permanent loss of natural resources which can reasonably be expected to occur in the

absence of a bypass. Severe property damage does not mean economic loss caused

by delays in production.

Technology-based limit means a permit limit or condition based upon EPA’s technologybased effluent limitation guidelines or EPA’s best professional judgment.

TSS means total suspended solids.

USFWS or FWS means U.S. Fish and Wildlife Service.

Upset means an exceptional incident in which there is unintentional and temporary

noncompliance with permit effluent limitations because of factors beyond the reasonable

control of the permittee. An upset does not include noncompliance to the extent caused
Trident - Akutan facility AK-003730-3

Fact Sheet page 24 of 31

by operational error, improperly designed treatment facilities, inadequate treatment

facilities, lack of preventive maintenance, or careless or improper operation.

Variance means any mechanism or provision under section 301 or 316 of CWA or under

40 CFR part 125, or in the applicable ``effluent limitations guidelines'' which allows

modification to or waiver of the generally applicable effluent limitation requirements or

time deadlines of CWA. This includes provisions which allow the establishment of

alternative limitations based on fundamentally different factors or on sections 301(c),

301(g), 301(h), 301(i), or 316(a) of CWA.

Water depth means the depth of the water between the surface and the sea floor as

measured at mean lower low water (0.0).

Water quality-based limit means a permit limit derived from a state water quality

standard or an appropriate national water quality criteria.

Waters of the United States or waters of the U.S. means:

(a) All waters which are currently used, were used in the past, or may be susceptible to

use in interstate or foreign commerce, including all waters which are subject to the ebb

and flow of the tide;

(b) All interstate waters, including interstate wetlands;

(c) All other waters such as intrastate lakes, rivers, streams (including intermittent

streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa

lakes, or natural ponds the use, degradation, or destruction of which would affect or

could affect interstate or foreign commerce including any such waters:

(1) Which are or could be used by interstate or foreign travelers for recreational or other

purposes;

(2) From which fish or shellfish are or could be taken and sold in interstate or foreign

commerce; or

(3) Which are used or could be used for industrial purposes by industries in interstate

commerce;

(d) All impoundments of waters otherwise defined as waters of the United States under

this definition;

(e) Tributaries of waters identified in paragraphs (a) through (d) of this definition;

(f) The territorial sea; and 

(g) Wetlands adjacent to waters (other than waters that are themselves wetlands)

identified in paragraphs (a) through (f) of this definition.

Zone of deposit (ZOD) means an area of the bottom in marine, coastal, or estuarine

waters in which ADEC has authorized the deposit of residues in exceedence of the

water quality criteria of 18 AAC 70.020(b) and the antidegradation requirement of

18 AAC 70.0101(c).
Trident - Akutan facility AK-003730-3

Fact Sheet page 25 of 31

14 REFERENCES

Enviro-Tech Diving. 2000. Diver survey of the Trident outfall, 2000. Enviro-Tech

Diving, Inc., 1127 NW 45th Street, Seattle, Washington.

USEPA. 1991. Technical support document for water quality-based toxics control. 

Office of Water, Washington, D.C. EPA/505/2-90-001.

USEPA. 1993. Guidance manual for developing best management practices (BMP). 

Office of Water, Washington, D.C. EPA/833/2-93-004.

USEPA. 1996. NPDES permit writers’ manual. Office of Wastewater Management,

Washington, D.C. EPA/833/B-96-003.

TetraTech. 1996. Total maximum daily load (TMDL) for seafood residues in the waters

of Alaska. USEPA Region 10, Office of Water, 1200 Sixth Avenue, Seattle,

Washington. September 30, 1996.
Trident - Akutan facility AK-003730-3

Fact Sheet page 26 of 31

APPENDIX A - Location of the Trident - Akutan facility
Trident - Akutan facility AK-003730-3

Fact Sheet page 27 of 31

APPENDIX B - Diagram of the Trident - Akutan facility
Trident - Akutan facility AK-003730-3

Fact Sheet page 28 of 31

APPENDIX C - Synopsis of Modeling the Discharge of Settleable Solid Seafood Residues

TECHNICAL BRIEF FOR EXPANDED SEAFOOD MODEL RUNS

Gary Braun, Senior Scientist

Tetra Tech, Inc, 15400 NE 90th Street, Suite 100, Redmond, WA, 98052

September 30, 1996.

In support of the development of a general NPDES permit for shore-based, near shore, and

offshore seafood processors, Tetra Tech prepared an ocean discharge criteria evaluation

(ODCE) report in July 1994. The report concentrated on characterizing the effluent being

discharge from the covered facilities and its potential effect on receiving waters. The report

also developed preliminary modeling predictions for the deposition of solid seafood waste

residues on the sea floor.

Technical directive No. 12 directed Tetra Tech to expand the modeling assessment of the

deposition of settleable solid seafood waste residues from processors using different particle

size assumptions. Tetra Tech was also directed to determine endpoints for maximum

discharges which produce deposition areas of zero, one, and two acres using the case

scenarios defined in the previous ODCE.

To accomplish this task, three general cases were modeled (i.e., 0.5 inch, 0.38 inch, and

0.04 inch maximum particle size) and the results are presented in Tables 1, 2, and 3,

respectively. No changes in the WASP5 model were required to perform these model

simulations, however, the input files used for each model run were modified as needed and are

described below. Results of the predicted areal coverage of solid wastes for both the WASP

output, based on the number and area of grids, and SURFER, based on contours of depth

accumulation, are reported. In general, the determination of the endpoints for maximum

discharges that produce zero, one, and two acre waste piles are based on the areas estimated

by SURFER, the 3-dimensional contouring software.

Table 1 depicts the area and thickness of a waste pile which results from discharging seafood

waste solids that have been ground to a maximum particle size of 0.5 inch. The assessment

assumes that 60% of the loading mass of particles is 0.5" in diameter, 20% is 0.25", and 20% is

0.125".

Table 2 depicts the area and thickness of a waste pile which results from discharging seafood

waste solids that have been ground to a maximum particle size of 0.375 inch. The assessment

assumes that 60% of the loading mass of particles is 0.375" in diameter, 20% is 0.188", and

20% is 0.094".

Table 3 depicts the area and thickness of a waste pile which results from discharging seafood

waste solids that have been ground to a maximum particle size of 0.04 inch (= 1 mm). The

assessment assumes that 100% of the loading mass of particles is 0.04" in.
Trident - Akutan facility AK-003730-3

Fact Sheet page 29 of 31
Trident - Akutan facility AK-003730-3

Fact Sheet page 30 of 31
Trident - Akutan facility AK-003730-3

Fact Sheet page 31 of 31