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Water: Industry Effluent Guidelines

Fact sheet for Alaskan Seafood Processors

The U.S. Environmental Protection Agency (EPA) is sending questionnaires to owners and operators of several seafood processing facilities in Anchorage, Cordova, Juneau, Ketchikan, Petersburg, Dutch Harbor and the Kenai Peninsula. The answers will help determine whether seafood waste disposal practices should be changed in certain areas of Alaska.

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Why Is EPA Concerned About Seafood Processing Waste Disposal In These Areas?

Seafood processing waste can harm the environment. Adverse environmental effects associated with seafood processing wastewater discharges can include:

  • Accumulations of waste sludge and whole fish parts in near-shore locations.
  • Generation of toxic hydrogen sulfide gas.
  • Increased gathering of scavengers in discharge locations.
  • Noxious conditions caused by odors, bacteria and waste decomposition.

What Will EPA Do With The Seafood Waste Disposal Information?

EPA will analyze the questionnaire responses so that it can respond to petitions that were submitted to EPA in 1980 by a portion of the Alaskan seafood industry. EPA will also analyze the responses as part of its consideration of whether to apply different effluent limitations guidelines to seafood processing facility discharges in Dutch Harbor and on the Kenai Peninsula.

Future phases will include the publication of a Notice of Data Availability by which EPA will make data available for public review and comment.

The notice will solicit public comment on how EPA should use the data in responding to the 1980 petitions and considering different effluent limitations guidelines for seafood wastewater discharges in Alaskan locations. EPA will announce the Notice of Data Availability and final regulatory action in the Federal Register.

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Background

In the mid-1970s, EPA published effluent limitations guidelines (ELGs) for seafood processing. ELGs are regulations that establish national technology-based effluent limitations for a specific industrial category or subcategory. The seafood ELGs provided for two groups of subcategories for Alaskan processors, depending on whether a processor operates at a “remote” or a “non-remote” location.

“Non-remote” facilities were those facilities located in “population or processing centers.” The regulations provided a non-exclusive list of Alaskan locations considered to be “non-remote,” including Anchorage, Cordova, Juneau, Ketchikan, Petersburg and Kodiak.

In “non-remote” locations, the ELGs are based on the screening of the processing solids from the seafood processing wastewaters and disposing of the screened solids by means other than discharging in the facility’s effluent. In “remote” locations, the ELGs are based merely on grinding the processing solids to reduce the size of the waste pieces (not to exceed one-half inch in any dimension), which could then be discharged into navigable waters as a part of the facility’s effluent.

Members of the Alaskan seafood processing industry submitted two petitions in 1980. The first petition requested that EPA suspend the applicability of the ELGs to provide an opportunity for the industry to submit new information. In response to the first petition, EPA temporarily suspended the original regulations applicable to five “non-remote” locations (Anchorage, Cordova, Juneau, Ketchikan and Petersburg) and published a notice of this suspension in the Federal Register (45 Federal Register 32675, May 19, 1980). The effect of the EPA suspension was to temporarily relieve seafood processing facilities in those five locations from the ELG effluent limitations based on screening solids from their effluent streams, and instead, subjected these facilities to the less stringent ELGs applicable to “remote” locations (grinding the solids in the process wastewater and discharging the ground waste into adjacent navigable waters).

The second petition requested a new rulemaking to modify certain Alaskan “non-remote” ELGs affecting seafood processing wastewater discharges in Anchorage, Cordova, Juneau, Ketchikan and Petersburg. Kodiak was not included in this petition. In the second petition, the petitioners maintained, in part, that the costs of screening associated with the “non-remote” ELGs were wholly out of proportion to the effluent reduction benefits achieved and that screening was not a practicable technology.

In response to the second petition, EPA published its proposed response and amendments to the ELGs for public comment in the Federal Register (46 Federal Register 2544, January 9, 1981). EPA proposed to grant the petition to reclassify Juneau as “remote” and to deny the petition to delete the locations of Anchorage, Cordova, Ketchikan and Petersburg from the group of “non-remote” ELG subcategories. EPA also proposed to add Ward’s Cove (as part of Ketchikan) to the list of “non-remote” areas. Finally, EPA’s notice indicated that it was considering, but not proposing at that time, the addition of Dutch Harbor and the Kenai Peninsula as “non-remote” locations.

EPA’s notice stated that the suspension would remain in effect until EPA made a final decision. However, EPA has not issued a final response to the petition.

EPA’s proposed response was based in part on EPA’s analysis of industry data submitted in 1980. EPA’s preliminary conclusion was that the number and size of processors, the quantity of wastes produced, the length of the processing season and other factors made it possible to process the screened wastes into saleable by-products, such as fish meal and fish oil.

EPA noted that the petition failed to adequately account for the potential effluent reduction benefits where reduction facility operations could result in lower total amounts of pollutants being disposed in the receiving waters and reduced overall cost of waste disposal.

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Why Is EPA Requesting Information Now?

In 2001, EPA proposed the reissuance of the General National Pollutant Discharge Elimination System (NPDES) Permit No. AK-G52-0000 for Alaskan seafood processors. During the public comment period, EPA received comments about the suspended ELGs and about technological advances since 1981 that provided reasonable alternatives to the discharge of seafood processing wastes.

EPA responded that it did not have sufficient information about the feasibility of alternative disposal or re-use options.

EPA committed to update the information regarding the five locations addressed in the 1980 petitions and other Alaskan locations. EPA’s current informational gathering efforts are consistent with its 2001 commitments despite the delay in initiating that effort.

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For More Information

Contact Donald F. Anderson at the EPA Engineering and Analysis Division at 202-566-1021 or anderson.donaldf@epa.gov, or Lindsay Guzzo at EPA NPDES Permits Unit at 206-553-0268 or guzzo.lindsay@epa.gov.

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