1 Site Visit Report Alaska Seafood Processing Industry Petition Response

Lindsay Guzzo Environmental Engineer U.S. Environmental Protection Agency Region 10 Permits Division guzzo.lindsay@epa.gov

206-553-0268 Betsy Bicknell Senior Environmental Engineer Eastern Research Group, Inc. (ERG) betsy.bicknell@erg.com

703-633-1612

Plant Name Alaska General Seafoods

Plant Address Ketchikan, Alaska

NPDES Permit # AKG 520090

Date of Visit Thursday, August 12, 2010 People Contacted Gordon Lindquist, Vice President, General Manager Company Website http://www.akgen.com/

Seafood processed Salmon, mostly pink some other salmon species

Products Canned salmon

Fresh and frozen salmon

Salmon roe Range of annual production volume 10 – 12 million pounds in 2010 (forecast) Months of operation June - September Discharge type Pipe solids to Alaska Protein Recovery via Trident Discharge screened wastewater through permitted

outfall

The New England Fish Company started seafood pr ocessing operations at this site in the south end of Ketchikan about 100 years ago. Alaska General Seafood (AGS) rebuilt the plant in 1994 and made further modernizatio ns in 1999. About 85% of their production is canned pink salmon; the remainder is fresh a nd frozen salmon - pink and other species.

AGS is one of two large canneries in Ketchi kan. The other, immediatel y adjacent to their facility, is operated by Trident Seafoods. Al aska Protein Recovery (APR) [Confidential Business Information (CBI), removed from this report] operates a seafood by-products recovery plant on a barge moored at the Trident dock. AGS began sending 100% of its

waste to APR in the 2010 season.

At the time of the visit, Gordon Lindquist, th e AGS General Manager, forecast that they would process 10 to 12 million pounds of salmon in the 2010 season. Mr. Lindquist

commented that ADF&G had estimated Sout heast Alaska’s 2010 pink salmon harvest at 19 million fish, so it appeared that their forecast was low.

AGS takes the plant out of winter storage in April. Salmon canning operations begin in

the 4 th week of June and last until the end of August. AGS also operates a cannery in Bristol Bay, for a short, one-month season r unning from mid-June to mid-July. AGS has verbal contracts with fishermen. Among the se rvices they provide the fishermen is to2 send out tenders to bring the catch into the processing plant. This allows the fishermen to remain in the fishing gro unds and continue fishing.

Figure 1 shows three HDPE plastic transfer pi pes, two for waste and one for CIP (cleaning in place 1 ) wastewater that [CBI, removed from this report]

1. Food grade waste, which has never touc hed the floor (mostly heads). [CBI, removed from this report]

2. Frames, skin, guts, and other trimmings. Th is is waste that has touched the floor from the cannery fish house, the cannery, and the fresh frozen lines. [CBI, removed from this report]

Fish heads, pumped to APR in the 6-inch HDPE pipe, are not dewatered. Waste traveling

in the 6-inch line includes all of the water. Wa ste traveling in the 4-inch line is dewatered on a 0.100 inch mesh rotary screen.

AGS operates five canning lines. [ CBI removed from this report]

After cans are sealed, they are stacked and lo aded into retorts (c ylindrical pressure cookers) and cooked at 246°F for 75 minutes. Th e hot water is drained and the cans are cooled to 110°F. The cooled, dry cans are stack ed onto pallets. These pallets of unlabeled cans, known as “bright stacks” are packed into 20-foot vans and shipped to Seattle. In Seattle they are labeled for various customers.

In addition to canning, AGS produces frozen whole salmon. After cleaning, the salmon are placed on freezing racks and blast frozen fo r 5 to 6 hours. The frozen fish are glazed

and boxed or toted.

AGS also process salmon roe . Figures 2 and Figure 3 show employees sorting and cleaning roe skeins. The roe is brined and sepa rated into individual eggs to produce Ikura. This frozen product is so ld in Asia and Europe.

During salmon season, the plant operates seven days/week, from 8AM to 11:30 PM followed by a cleaning shift. The processing equipment is cleaned-in-place and the wastewater is discharged through the outfall line.

Plant wastewater drains to a common su mp, equipped with a Vaughn grinder pump. This type of pump is used throughout the Alaska seafood processing industry. Screened solids are piped to Trident/APR while the wastewat er is discharged through the AGS outfall.

Waste Management History. The 2010 salmon season was the first year that AGS sent 100% of its waste to APR. Waste management has changed over the last several years.

1 Clean-in-place is a method of cleanin g the interior surfaces of pipes, vessels, process equipment, filters, and associated fittings, without disassembly.3  2001-2002 – grind and discharge via permitted outfall in Tongass Narrows; however, the zone of deposit exceeded the allowable size, so EPA required at-sea disposal.

 2003-2009 – grind and discharge at sea. Wast e was loaded into the hold of an old fishing boat, and then pumped out. Disc harge at sea is allowed in the NPDES General Permit. Grinding is required.

 2010 – All waste is transferred to APR.

Grinding waste to less than 0.5 inch in any di mension required several steps. Heads were ground in a hammermill. The ground heads combined with other waste then passed through the Vaughan chopper pump, Muffin M onster, dewatering screen, and Autio grinder, and was then pumped into the boa t. Dewatering was accomplished with a rotary screen, 0.100 inch mesh size. Dewatered waste was pumped to the vessel using a progressive cavity pump after it passed th rough the Autio grinder. In 2009, waste was hauled daily during the salmon season to Bold Island by the Western Pioneer or Chichagof Shuttle vessel. These vessels ha ve a capacity of 180,000 pounds each (in terms of pounds of waste). Waste was pumped from the vessels. Cost for waste disposal in 2009 was $139,553.

The disposal vessel traveled about 12 miles out, to Bold Island. One trip required about

an hour and a half to travel to the disposal site and about 1 hour to unload the boat and an

hour and a half to return. The boat made one trip per day.

When AGS converted from discharging ground up solid waste through its Tongass Narrows outfall to hauling it to Bold Island, th ey installed a concrete pad on land with waste disposal equipment at a capital cost of $165,000. No alte rations or expansion to the existing dock were required.

[CBI removed from this report]

Discussion . Mr. Lindquist mentioned that AGS opera tes another cannery in Bristol Bay.

He noted that it would not be feasible to install a by-produc ts recovery plant at Bristol Bay, due to the very short (one month) s eason. Ms. Guzzo and Ms. Bicknell assured Mr. Lindquist that EPA was not cons idering changing the classifi cation of Bristol Bay to nonremote, so there would be no change in discha rge limits for the AGS plant in Bristol Bay.

Mr. Lindquist summarized the challenge of the seafood processing business as “we are price takers, not price makers.” He meant he was not in control of the price, due to fluctuations in supply and demand and internat ional currency value. He noted that the size of the harvest varies considerably y ear-to-year. When they don’t have a large harvest, they don’t make money because th ey are using less than design capacity. Seafood processors need deep pockets. Mr. Lindquist suggested that for the economic analysis, EPA must use data from multiple years.

When asked the biggest problem with hauling waste for off shore disposal, Mr. Lindquist

mentioned the cost of the vessel and its main tenance. He noted that because the plant4 can’t operate without a means of disposing of its waste, when they were hauling their waste off shore, they should have had two vessels to provide redundancy. They operated with only one vessel, however because they could not afford a second.

Mr. Lindquist also opined that grinding the waste prior to disposal is nonsense. First, it is impossible to get to <0.5 inch in all dimens ions for some materials, for example fish stomach linings. He noted that large animals w ill eat heads and frames, but not the finely ground waste. In his opinion, this results in a build up of finely ground waste on the sea

bottom.

Although hauling the waste off shore is pr oblematic, he would not truck the waste because there is too much waste and it pres ents significant materials handing problems. Further, trucking large volume s of waste is not practical in Ketchikan because of the cruise ship passenger pe destrian traffic.

Figure 1. Pipes transferring wast e from Alaska Glacier to Trident for transfer to Alaska Protein Recovery.5 \\ Figure 2. Roe processing

Figure 3. Roe processing