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

Plant Address Ketchikan, Alaska

NPDES Permit # AKG520002

Date of Visit Thursday, August 12, 2010 People Contacted John Webby, General Manager Southeast Operations Company Website www.tridentseafoods.com

Seafood processed Salmon, mostly pink some other salmon species

Products Canned salmon

Frozen salmon roe Range of annual production volume Months of operation June - September Discharge type Pipe solids to Alaska Protein Recovery Discharge screened wastewater through permitted

outfall

Mr. Webby worked at this plant from 1972 to 1986, before it was owned by Trident. He returned to the plant after Trident bought it in 1995. Seafood processing operations began on the site in 1904. The plant was rebuilt in 1946 and again in 1966.

Operations are limited to canning pink salmon and freezing salmon roe. Although they produce filets for their skin less boneless canned product, th ey transport higher value salmon species by tender to the Trident/NorQues t plant on the north side of Ketchikan. The Trident/NorQuest plant specializes in ma king fresh and frozen products and operates

a small smoked salmon line.

Alaska Protein Recovery (APR), which is co-owned by Trident, operates a seafood byproducts recovery plant on a barg e moored at th e Trident dock.

Waste Management History. Prior to 2001, Trident ground waste from the plant and discharged it into Tongass Narrows through their NPDES permitted outfall. The original permit was for a zone of deposit of less than one acre. Over time, the waste expanded into three piles totaling more than 1 acre. Al so, the solids became anaerobic, generating methane gas. Accumulated gas was released in pile eruptions. To comply with a consent

decree issued after an EPA enforcement ac tion, Trident and their neighbor, Alaska General Seafood (AGS) stopped discharging solids and instead hauled them off shore for disposal. Between 2001 and 2006, Trident contract ed with a tender with large holds to2 haul their waste off shore. They also re mediated the pile by dragging to aerate and

consolidate the solids.

In 2007, APR began operations in Ketchikan. Trident transferred its waste to APR’s barge, while ground bones were returned to Tr ident for outfall discharge. In 2008 Trident became a partner of APR. Chuck Bundrant, owner of Trident Seafoods, invested $600,000 to connect the Trident Ke tchikan cannery to the barg e. This includes a system to manage heads as food grade product and pump them to the barge.

APR now takes 100% of the waste from AGS and Trident Ketchikan (south) which are located adjacent to the barge. Waste is pum ped from AGS to Trident and then from Trident to the barge. APR also processe s the salmon heads from Trident NorQuest (Ketchikan north) and E.C. Philips, two small plants located on the other side of Ketchikan. At present, APR can’t take the gu ts from the two small plants because they decompose too quickly. Waste volume proce ssed at APR is made up of heads (about 60%) and guts (30-40%).

Mr. Webby explained that APR is taking a bout the waste water from Salmon, about 800,000 lb/day of and could handle 1.3 to 1.5 million pounds/day.

The agreements with the other seafood pro cessors differ. The agreement with E.C. Philips is open-ended, meaning Trident can stop taking E.C. Philips fish heads at will. The agreement with AGS required Trident to take the AGS waste even if the APR process is not operating. Mr. Webby explained Trident took all of AGS ’s waste two years ago, none last year, and are taking all of their waste this year.

The less the waste is ground, the better, in orde r to preserve the quality of the oil. Also, the more the waste is ground the more solubl e BOD in the screened wastewater stream discharged through Trident’s ou tfall into Tongass Narrows.

Mr. Webby recalled that Ladd McCauley tried a hydrolysate process in Juneau in 1997 but it was not economically viable. APR makes hydrolysate, but he noted that the key for success of the APR process is th e high price they can get for their food grade salmon oil.

The barge (including product) is towed to S eattle in the winter and anchored in fresh water. While the barge is moored in Ketchi kan, Trident supplies the barge with water, power, and takes off the sewage. The process coul d be built on shore at the cannery site if land was available. Mr. Webby is hoping to put another building on his site, but this will require approval of the fire marshal. He not ed that there is only a limited amount of heavy industrial property in Ke tchikan. A mile of the harbor has been dedicated to the cruise ship berths and re lated docks. Other sites for possible expansion are limited. Gravina Island, on the other side of Tongass Na rrows, has no electricity or water supply.

Ward Cove is an industrial site north of to wn where Louisiana-Pacific used to operate. Unfortunately, Ward Cove is an impa ired water body and Superfund site, with16,000 logs on the bottom. Clean up costs were es timated at $200 million. L-P settled at $27 million. It is unlikely that other industria l activities will locate at Ward Cove.3 Cannery Operations. The cannery operates 24 hours per day, 191⁄2 hours of production The rest of the time is for meals and clean-up. Figure 1 shows the dock area where the fish are offloaded from boats into the plant. After tenders are emptied, they are filled back up with slush ice ( Figures 2 and 3 ).

The cannery uses city water, adding extra chlorine to the water used in the canning retorts. Mr. Webby noted that canned salmon is an inspected, ready-to-eat product and must meet food safety requirements.

The traditional product puts 66% of the fish into the can. In the last few years consumers

are interested in skinless boneless canned salm on. This product puts only 25% of the fish into the can. At Trident, the difference becomes waste, because they have not made satisfactory mince. They put in a mincer but b ecause the blood is still in the frame did not produce an acceptable product. In making surimi, the fish is washed multiple times. If salmon is washed, the typical salmon color is lost and the produc t is unappetizing.

Mr. Webby explained the key to success in hi s industry is canning quickly when the fish are running. Figure 4 shows the fish holding tanks wh ere fish are kept immediately before canning.

Waste Transfer . Waste is transferred from AGS through three HDPE pipes. Trident/APR received permission from ADEC to use HDPE rather than stainless steel for

transfer of salmon heads destined for food grade oil production. The three lines are:

1. guts

2. heads and skins

3. cleaning-in-place 1 (CIP) wastes.

Occasionally, the transfer lines are flushed with caustic and sanitizer. Flush water is discharged through the NPDES permitted outfall.

Heads come from E.C. Philips and Trident/NorQ uest in refrigerated totes. The heads are

mixed with heads from Trident and AGS and pumped with a peristaltic pump to the barge. The other wastes are dewate red and transferred to the barge in a separate

conveyance system.

Trident has equipment to grind waste that cannot be processed on the barge. This equipment includes two Vaughan chopper pumps (one is a backup) and two Autio grinders.

Trident monitors its discharge for grind size. They have not measured the O&G or TSS

concentration in the screened solids disc harge and don’t know if their discharge would meet the BPT limits for non-remote Alaskan seafood processors.

1 Clean-in-place is a method of cleanin g the interior surfaces of pipes, vessels, process equipment, filters, and associated fittings, without disassembly.4 Plant operations. Trident operates Seven canning lines. In addition to lines for standard size cans, they have a line for large, institutional-sized cans and another for small cans. Customers are requesting new products. Fo r example, Costco demands “oriented” skinless boneless salmon (looks like canned al bacore tuna). This is a relatively new product. This line was idle this year.

At the butchering line, the heads are managed separately from the other wastes. Heads go

to a common tank and then are taken across to APR. The waste produced from a fish butchered for canning is 17% h ead; for frozen, 15% head.

The plant is built on pilings. Hot water released from the retorts drains directly under the dock and is mixed with the tides. Mr. Webby me ntioned that refriger ation condensation is

another wastewater that is not discharged through the outfall.

The retorts use extra-chlorina ted city water. Extra chlorine is added for food safety reasons. Trident’s retorts use 2500 gallons pe r cook and they can run up to 66 cooks per day. Hot cans removed from the retorts are taken to the can cooling area. The through time from the fish entering the building to the cooled can is about 6 hours.

Mr. Webby explained that they can’t sell the canned salmon in Alaska because it hasn’t been through all the required food safety inspections. Those occu r in Seattle. Seafood producers association tests th e product in Seattle.

In addition to canned salmon, the plant pr oduces frozen roe (ikura). Major markets include Russian communities in Bellevue, WA and in the east coast of the U.S.

Figure 5 and Figure 6 shows the roe being pr ocessed through a brine washer and Figure 7 shows workers picking imperfect eggs from the roe.

Discussion. Even with the barge, there is some solids discharge. APR must remove the bone from the protein hydrolysate and does not have a cost effective way to produce a bone meal product. For this reason, the bone is currently discharged at sea as a solid waste. Also, in the event the APR process goes down, Trident will grind its waste (and the waste it receives from AGS) and haul it for off-shore disposal.

Mr. Webby noted that Trident invested in the APR system but would not have done so if EPA had not prohibited discharging solids th rough their outfall in the Tongass Narrows. He noted that hydrolysate production covers operating costs, but doe sn’t make a profit. Salmon oil production is profitable, with the current oil prices.

Trident built a by-product recovery plant in Co rdova. This plant uses the APR process, with a slightly different evaporator technology.

Ms. Bicknell asked if the city of Ketchi kan had an adequate electricity supply for Trident’s operations. Mr. Webby explained th at the city’s electricity is supplied by5 hydroelectric generating plants at four dams. The plants have adequate capacity but need some infrastructure to tie the systems together. Mr. Webby thought the city had no shortage of water or treat ment capacity. The Trident operation uses about 1.5 MGD of city water.

If screening is required, Mr . Webby noted some available screening devices: rotary screens, parabolic screens, mesh belt.

Figure 1. Fish Offloading Area6 Figure 2. Adding ice to tender

Figure 3. Ice in tender7 Figure 4. Fish holding tanks

Figure 5. Scooping roe from brine8 Figure 6. Roe processing9 Figure 7. Roe picking