### 1 Site Visit Report Alaska Seafood Processing Industry Petition Response

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

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

703-633-1612

Plant Name Trident Seafoods Corporation

Plant Address Petersburg, Alaska

NPDES Permit # AK-G52-0475

Date of Visit Sunday, August 15, 2010 People Contacted Dave Ohmer Plant Manager

dohmer@tridentseafoods.com

907-772-3333 Nick Ohmer Fleet Manager

nohmer@tridentseafoods.com

907-772-3333 Company Website www.tridentseafoods.com

Seafood processed Salmon, halibut, black cod, other groundfish Products Frozen whole fish (headed and gutted) Fresh whole fish (h&g) Frozen roe skeins (sujiko) Range of annual production volume 4 to 11 million pounds per year 13 million pounds in the largest year Months of operation March - November Discharge type Grind and discharge

Dave Ohmer provided some history of the plant. Mr. Ohmer’s grandfather started the business as

Alaska Glacier Seafoods in 1916. The business was subsequently bought by Norquest and then by Trident, the current owner. The Trident/Norqu est plant processes fish from March to November, with no work in December, January, or February. March starts with longline season. Waste is processed through a grinder system located under the plant and discharged into the Wrangell Narrows, which has a strong 3 – 5 knot tidal flow.

Lindsay Guzzo provided a history of the Alaska seafood processing industry petition and EPA’s current project. Mr. Ohmer noted that Sitka and Dutch Harbor, both with large production volumes, are not included in the list of non-remo te processing centers. Mr. Ohmer also noted that the Cordova, Ketchikan, and Dutch Harbor processi ng plants discharge into relatively still waters, resulting in accumulation of discharged solids in th eir zone of deposit (ZOD). In contrast, Trident Petersburg discharges into the Wrangell Narro ws, which has a strong current. Ms. Guzzo explained EPA’s schedule for the petition respon se and encouraged Mr. Ohmer to comment on EPA’s NODA when it is published in early 2011.

Mr. Ohmer noted that the neighboring Icicle Petersburg Fisheries processing plant operates a waste reduction plant that sometimes gives off a strong odor. The Trident/Norquest plant once provided waste to Icicle, including shrimp and crab sh ells. At first, they were paid for the waste. Then they paid Icicle to take the waste. Then , Icicle said we don’t want the Trident/Norquest waste. In the 1990s, the Norquest production was predominantly shrimp and crab. They took

### 2 shrimp and crab waste into Petersburg sound each night. In 2005 Trident/Norquest got out of the shrimp business. Now, they grind all waste to <0.5” in every dimension and discharge it through

their outfall.

Mr. Ohmer explained that in 2010 the Pete rsburg seafood processing industry employed 500 fewer workers than it had in previous years. Th is is a result of Ocean Beauty not opening its Petersburg plant and other processors employ ing fewer workers. Trident has moved a considerable amount of production from the Peters burg plant to a new plant in Wrangell. The town is very concerned about the loss of employment. Even though the processing plant

workers are seasonal and often from outside the ar ea, they bring economic activity to the town.

Mr. Ohmer said he thought an appropriate co mmunity solution [to the loss of seafood processing jobs] was needed. He explained that the Icicle and Norquest Petersburg plants had developed a local relationship. Icicle and Trident have a different relationship on a corporate level.

Mr. Ohmer noted that if byproduct recovery presents an opportunity to make money, Trident will

look at it.

Mr. Ohmer estimated that the largest volume of fi sh the Trident/Norquest plant had produced was 11 million pounds/year. He estimated they would do 4-5 million pounds in 2010. He noted that Trident made corporate decisions on where to put its fish. Some of the catch that in previous years would have come to Petersburg has gone to Wrangell instead.

Mr. Ohmer explained that Norquest had grown its gill net fleet from 8 to 82 boats, the largest fleet in the southeast. Now only 50% of the cat ch from these boats goes to Petersburg while the rest goes to Wrangell and Juneau. The loss of th e landings in Petersburg means a loss to the community of the landed fish tax 1

.

The Petersburg Community Economic Developm ent group wanted Mr. Ohmer to endorse a policy: buy local, sell local. Mr. Ohmer said he couldn’t get behind that. From a business perspective, he had to buy inputs at the lowest cost, even if they were not local.

Mr. Ohmer noted changes to the southeast Alaska fi sheries in 30 years. He noted the new plants in Sitka and Craig. Petersburg has more comp etition. When asked what advantages Petersburg has over other processing centers, he noted the re lationships with fishermen. Processors commit to “take care of” fisherman. For example, provi ding quality ice, tender service, and loans as needed. He noted that in Cordova, fishermen sell on the fishing grounds to tenders that transport the catch to processors. They use a different or ganization than at Petersburg. As far as the Trident/Norquest plant in Petersburg, Mr. Ohmer noted that it can more easily run mixed catch than Wrangell, which is designed for salmon.

Mr. Ohmer noted that the Petersburg conditions ha d posed a challenge to an EPA inspector (on a previous visit). The inspector saw foam near the dock that was from the pump-out from tender. The tender had to pump out to ensure vessel stability.

1 At the end of the meeting, Mr. Ohme r explained that the landed fish tax is assessed on the gross value of fish purchased by the seafood processor. The tax is 3% of the price paid by the processor. The state takes half of the tax and returns 50% to the community. Pete rsburg puts the revenue from the landed fish tax in the general fund; in Wrangell the revenue is used to de velop the harbor. In Petersburg, the fish revenues are comparable in scale to sales tax (Petersburg sales tax is 6%).

### 3 The Trident/Norquest plant processes about 800,000 pound/year of halibut. Waste from halibut processing includes heads which sometimes contai n stainless steel fish hooks. Mr. Ohmer noted that their waste passes through three grinders (Autio, Muffin Monster ® , and a Vaughan chopper pump). He noted that the Autio grinder is sensitiv e to metal pieces in the waste, while the Muffin

Monster ® could grind with some metal. Mr. Ohmer asked what environmental concerns result from local dumping. He noted that in the old days they dumped waste off the dock and it attracted a lot of herring. The community fished for herring near the dock. Now, they discharge ground waste through the outfall (about 60 feet from shore) . It sustains a large sea urchin population in the Wrangell Narrows. He explained that this population demonstrates “high fecundity.”

Even with the three stages of grinding (Autio, Muffin Monster ® , Vaughan), Mr. Ohmer noted that the ground waste is not consistently less than 0. 5” in any dimension and he does not think that such a grind is technically achievable.

When asked, Mr. Ohmer stated that taking the w aste solids offshore would be possible. They did so in the past, using a 38 foot boat. Solids we re collected in totes and the totes were dumped overboard, 4 -5 miles from shore. He noted this w as dangerous in rough water. He also noted that when they processed shrimp, they separate solids with a fine screen and the screened water had a pink color.

Plant Tour

Nick Ohmer escorted Ms. Guzzo and Ms. Bicknell on a tour of the plant, starting at the fish offloading area. Trident/Norquest is equipped with a fish pump. Figure 1 shows the flexible hose used to pump fish out of tender holds. The pumpe d fish/water mixture goes to a dewatering box. Nick Ohmer explained that the fish pump operator manages the amount of water in the holds. When there is too much water, some will end up in the outfall. When there is too little, the operator must return some to the hold to facilita te fish pumping. Effluent from the dewatering box goes to the outfall, but bypasses the grinder system. Figure 2 shows the sump under the dock that is equipped with grinders.

Fish that are not fed directly into production are stored in iced totes. Figure 3 shows a collection

of totes on the dock.

Figure 4 shows the sump and grinders located under the dock. The holding sump is on the right. The green vertical shaft is the Muffin Monster ® chopper pump. Discharge from the plant is the large, white pipe to the left. Trident/Norqu est recently expanded the sump and added a new

Muffin Monster ® . Previously, the sump was unders ized and sometimes overflowed.

Fish processing starts with a guillotine header. As a safety precaution, the guillotine operator has

handcuffs so he can’t reach under the blade. On the pocket line, operators slit the belly, remove guts, and remove the collar. Operators sort the gut s and the roe. Guts flow to an Autio grinder (shown in Figure 5 ). The headed and gutted fish is furt her cleaned by vacuuming out the gut cavity, scraping, and washing in a high flow wash er (city water) to rinse off any particulates adhering to the fish.

Fish are sorted by species, size, and grad e and placed on trays for freezing. If necessary for product flow, the cleaned fish are stored in iced totes. It takes six hours to freeze salmon, longer for halibut because it is a larger fish. The frozen fish are taken from the freezer to the breakout table, where they are removed from the freezer tray.

### 4 Frozen fish are double glazed (glazing adds a thin coating to the frozen fish to reduce dehydration, i.e., freezer burn). Figure 6 shows half of the double glaze tank. The frozen glazed fish are packed in 1,100- to 1,300-pound boxes, st ored in freezer trailers, and shipped by barge to Seattle or other ports.

Roe skeins (sujiko) are packed in la rge boxes and frozen in a plate freezer. Figure 7 shows the box for bulk roe. Frozen products are loaded into fr eezer vans and shipped by barge. Fresh fish is shipped on the ferry system.

Closing discussion. After the tour, discussion with Mr. Dave Ohmer resumed. He noted that his plant’s largest production day in 2010 was 125,000 to 150,000 pounds, considerable reduced from previous years. They have been downsi zed because Trident has moved operations to Wrangell.

When asked to speculate about the future of seafood processing in Petersburg, Mr. Ohmer noted that Ocean Beauty, which is not operating in 2010, might resume operations next year if 2011 is a big salmon year, as predicted. In his opinion, Ocean Beauty is the weakest of the three processors in Petersburg. The Community Development Quota Program 2 bought into Ocean Beauty. When asked what Petersburg has going for it, Mr. Ohme r said it is access to fishermen. He noted that Petersburg fishermen have the largest share of halibut quota in southeast Alaska. In his assessment, Petersburg fishermen can supply mo re fish than one plant can process.



### Ms. Bicknell asked how Ohmer’s plant would respond more st ringent discharge requirements. Ohmer stated that they did not have space for an oil plant.

Figure 1 Trident Petersburg fish unloading hose

2 The CDQ Program is a federal program to develop Alaska fisheries.

### 5 Figure 2 Trident Petersburg under dock

Figure 3 Trident Petersburg totes

### 6 Figure 4 Trident Petersburg Muffin Monster ® & sump

Figure 5 Trident Petersburg Autio grinder

### 7 Figure 6 Trident Petersburg glazing tank

Figure 7 Trident Petersburg freezing pack