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vvEPA
             United States
             Environmental Protection
             Ajuncy
             Effluent Guidelines Division
             WH-552
             Washington, DC 20460
September 1980  /?
             Water and Waste Management
Report to Congress
             Section 74
             Seafood Processing Study
             Executive  Summary
                           440180020

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 SECTION 74 SEAFOOD PROCESSING STUDY


          EXECUTIVE SUMMARY
     A REPORT TO THE CONGRESS OF
          THE UNITED STATES
           prepared by the
U.S. ENVIRONMENTAL PROTECTION AGENCY
    EFFLUENT GUIDELINES DIVISION
       WASHINGTON, D.C.  20460

            September 1980

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                                NOTICE


This report has been reviewed by  the  Effluent  Guidelines  Division,
Office  of  Water  and Waste Management, U.S. Environmental Protection
Agency and approved  for  publication.   Mention  of  trade  names  or
commercial  products does not constitute endorsement or recommendation
for use.
                                   11

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     «   UNITED STATES ENVIRONMENTAL  PROTECTIQ^I AGENCY
                           WASHINGTON. D.C.  204GO
                                     2 4 1980
                                                      THE ADMINISTRATOR
Honorable Walter F. Mondale
President of the Senate
Washington, D.C.  20510
Dear Mr. President:
     In accordance with the provisions of Section 74 of the Clean Water Act
of 1977 (P.L. 95-217) , the Environmental Protection Agency  (EPA) is hereby
submitting a report entitled Section 74 Seafood Processing Study.  The
report consists of an executive  summary with various appended studies and
supporting material.

     The  report presents  the results of extensive data collection efforts
to determine the ecological consequences of marine disposal of  seafood
processing wastes.  Also  included  in the study  is an assessment of technologies
for control of seafood waste discharges and for utilization of  the nutrients
contained in the wastes.  The  work conducted during this  study  has covered
a wide variety of seafood commodities  and processing locations  and includes
field sampling in Alaska  and Oregon, site visits  to a variety of seafood
processing  locations  and  review of pertinent  literature and  industry-supported
studies.

      In conducting  the  study  required  by Section  74, EPA  enlisted  aid  from
a variety of sources,  including academic  institutions, consulting  firms and
Federal and State agencies.   In addition, EPA has worked  in close  cooperation
with  the  seafood  industry throughout the study effort.   Industry  representatives
were  consulted during the initial  planning  phase  of  the  study  and  they have
been  given the opportunity to review and comment  upon  the major study  documents.

      It  is apparent from the  information collected during this study that
 the ecological  impacts of seafood  waste discharges are highly  variable and
 not easily predicted.  In light of this,  the conclusions presented in  the
executive summary do not contain any specific recommendations   for  management
of these  wastes.

      I  hope that this report will  be useful to you in development of any
 future  policy  or legislation regarding the seafood processing   industry.  I
 appreciate this  opportunity to be  of service to you.

                                       '     s
                                       icerely yours,
                                            M. Costle

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     I   UNITED  STATES ENVIRONMENTAL PROTECTION  AGENCY
     *                      WASHINGTON.  DC  20460
                               SEP 24 1980
                                                      THE ADMINISTRATOR
Honorable Thomas P. O'Neill Jr.
Speaker of the House of Representatives
Washington, D.C.  20515

Dear Mr. Speaker:

     In accordance with the provisions of Section 14 of the Clean Water Act
of 1971 (P.L. 95-217), the Environmental Protection Agency (EPA)  is hereby
submitting a report entitled Section 74 Seafood Processing Study.  The
report consists of an executive summary with various appended studies and
supporting material.

     The report presents the results of extensive data collection efforts
to determine the ecological consequences of marine disposal of seafood
processing wastes.  Also included  in the study is an assessment of technologies
for control of  seafood waste discharges and for utilization of the nutrients
contained  in the wastes.  The  work conducted during this study has covered
a wide variety  of  seafood commodities  and processing locations and includes
field sampling  in  Alaska and Oregon, site visits to a variety of seafood
processing locations  and review of pertinent literature and  industry-supported
studies.

     In conducting the study required  by Section 74, EPA enlisted aid  from
a variety  of sources,  including academic institutions, consulting firms and
Federal and  State  agencies.  In addition, EPA  has worked  in  close cooperation
with the  seafood industry  throughout  the study effort.  Industry representatives
were consulted  during the  initial  planning  phase of the study and they have
 been given the  opportunity to  review  and comment upon  the  major  study  documents.

      It is apparent from the  information collected  during  this 'study that
 the ecological  impacts of seafood  waste discharges  are highly variable and
 not easily predicted. In light of this,  the conclusions  presented  in  the
 executive summary do not contain  any  specific  recommendations  for management
 of these  wastes.

      I  hope that this report  will be  useful to you  in  development  of any
 future policy or legislation  regarding the  seafood  processing  industry.   I
 appreciate this opportunity to be of ^frvice  to you.

                                              yours
                                            M. Costle

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VI

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                            TABLE OF CONTENTS


I          INTRODUCTION	      1

II         CONCLUSIONS	      3

III        ECOLOGICAL INVESTIGATIONS 	      9

      1.    STUDY OBJECTIVES AND METHODS 	      9

      2.    BACKGROUND AND HISTORICAL STUDIES	     12
           A.    Dutch Harbor 	     16
           B.    Other Alaskan Sites 	     20

      3.    EPA SECTION 74 STUDIES 	     21
           A.    Dutch Harbor 	     21
           B.    Cordova 	     23
           C.    Kenai 	     27
           D.    Yaquina Bay	     30
           E.    Pathogenic Bacteria Study 	     35

      4.    LOS ANGELES HARBOR STUDY 	     35
           A.    The Part 12 Study 	     37
           B.    The Part 16 Study 	     39

      5.    EPA SITE VISITS	     46
           A.    New England 	     47
           B.    Mid-Atlantic and Southeast
                Coasts 	     47
           C.    Gulf Coast	     48

IV         TECHNOLOGY ASSESSMENT 	     49
      1.    Waste Control and Treatment 	     50
           A.    In-Plant Controls 	     50
                1.    Non-Alaskan	     50
                2.    Alaskan 	     50
           B.    End-of-Pipe Treatment  	     50
                1.    Non-Alaskan	 .     50
                2.    Alaskan 	     51
      2.    Seafood Waste Utilization and
           Disposal  	     51
           A.    Sources and Alternatives  	     51
                1.    Non-Alaskan 	     52
                2.    Alaskan 	     54

V          REFERENCES 	     59

VI         Additional Background References	     61

VII        APPENDICES A THROUGH H 	     63
                              VII

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                            LIST OF TABLES


 Table No.            Title                                   Page No,

   1     Geographical Coverage of the Section 74 Seafood
         Processing Study 	     15


                           LIST OF FIGURES


Figure No.           Title                                   Page No.

   1     Location of Alaskan Sampling and Study Sites ...     11

   2     Map of the United States Illustrating the
         Geographic Coverage of the Ecological Investi-
         gations for the Section 74 Study 	     13

   3     Photograph of Typical Development of Dock
         Processing Operations in Alaska 	     14

   4     Location of Seafood Processors in Dutch Harbor
         Alaska	     17

   5     Photograph of Bottom Sample Taken from Dutch
         Harbor, Alaska, Showing Bubbles of Hydrogen Sul-
         fide and Other Noxious Gases Evolving From De-
         caying Sludge and Absence of Benthic Life	     19

   6     Photograph of Salmon Waste Dredged from the
         Bottom in the Vicinity of a Salmon Cannery
         Outfall, Port Baily, Kodiak Island, Alaska	     22

   7     Hydrographic Water Chemistry, Sedimentological,
         and Biological Sampling Grid in Dutch Harbor,
         Alaska 	     24

   8     Location of Sampling Sites at Cordova,
         Alaska 	     25

   9     Photograph of Accumulations of Whole Fish Parts
         Taken from Bottom of Orca Inlet, Cordova,
         Alaska 	     26

  10     Photograph of Accumulation of Crab Shells,
         Cordova, Alaska  	     28
                                 Vlll

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11     Photograph of Salmon and Crab Waste Below
       Processing Facility, Cordova, Alaska 	     29

12     Location of Sampling Sites in the Vicinity
       of the Kenai River, Alaska 	     31

13     Photograph of Seafood Waste Accumulations Near
       Seafood Processors Outfall, Kenai, Alaska 	     32

14     Photograph of Accumulation of Whole Fish Parts on
       Kanai River Bank Immediately Downstream from
       Cannery Outfall 	     32

15     Map of West Coast United States Sampling
       and Study Sites 	     33

16     Location of Survey Stations in the 1978 Los
       Angeles Harbor Study 	     36

17     Disposal/Utilization Options for Waste
       Resulting From Waste Management Practices 	     53
                                ix

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                           ACKNOWLEDGEMENTS


A number of technical  studies  contributed  to  preparation  of  this
report as follows:

SCS  Engineers,  Inc.,  Long Beach, California, under the direction of
Mr. Michael A. Caponigro, conducted a  biological  and  water  quality
study in Kenai and Cordova, Alaska.

The  EPA Corvallis Environmental Research Laboratory, Marine and Fresh
Water Ecology Branch, Newport, Oregon, under the direction of  Michael
Swartz, conducted a biological and water quality study  in Yaquina Bay,
Oregon.

The   Institute  of  Marine  Science  at  the  University  of  Alaska,
Fairbanks, Alaska, under the direction of Mr. David Burrell, conducted
a study of  biological  aspects  of  crab  processing   waste  disposal
practices,  and, under the direction of Mr. Howard Feder, a biological
and water quality study at Dutch Harbor, Alaska.

Development Planning and Research Associates, Manhattan, Kansas, under
the direction  of  Mr.  Thomas  Eyestone  and  Mr.  Robert  Buzenberg,
conducted  a  market  feasibility  study of seafood waste reduction in
Alaska.

The Edward C.  Jordan,  Company,  Inc.,  Portland,  Maine,  under  the
direction  of  Mr. David B. Ertz and with the assistance of Mr. George
Murgel, evaluated technology for seafood  processing  waste  treatment
and utilization.

The  Institute  for  Marine  and  Coastal Studies at the University of
Southern California, Los Angeles, California, under the direction  of
Dr.  Dorothy Soule, evaluated the ecology of the outer  Los Angeles and
Long Beach harbors and the potential for "bioenhancement"  by  seafood
wastewaters.

Brown  and Caldwell Consulting Engineers, Inc., under the direction of
Mr. Steve Bingham and Mr.  Tony  Harber,  conducted  studies  of  crab
processing waste disposal alternatives for Dutch Harbor, Alaska.

Mr.   Ken   Dostal   of  the  EPA  Industrial  Environmental  Research
Laboratory, Cincinnati, Ohio, and Mr. Terry Brubaker of EPA Region IX,
both provided valuable assistance by participating  in  and  reviewing
contributing  technical  studies,  and  in preparing this report.  Mr.
Jack Cooper, of the National Food  Processor's  Association,  Mr.  Roy
Martin  and  Mr. Gustave Fritchie of the National Fisheries Institute,
and Mr. Roger DeCamp of the Pacific Seafood  Processor's  Association,
all  provided  valuable  inputs throughout the course of these studies
and during the preparation of a draft of this Executive Summary.   All


                                  xi

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of  the  seafood  processor's that cooperated with and participated in
the various studies at  the  locations  covered  in  this  report  are
gratefully acknowledged.

The  following  served  on  a  review panel for the Los Angeles Harbor
"bioenhancement" study  performed  by  Dr.  Soule:  Mr.  Jim  Slawson,
National  Marine  Fisheries  Service;  Jack Fancher, Fish and Wildlife
Service; Howard Wright,  California  Water  Resources  Control  Board;
Larry   Espinosa,  California  Department  of  Fish  and  Game;  Louis
Schinazi, Los Angeles Regional Water Quality Control Board.

Mr. John E. Riley and Mr. Jeffery D. Denit of the Effluent  Guidelines
Division  provided  valuable  guidance  in preparing the final report.
Mr. Calvin Dysinger, also of the Effluent Guidelines Division,  served
as the Project Officer for the entire Section 74 study and coordinated
the  direction  and  input  of  all  the  contributing  studies.   Mr.
Dysinger's extensive efforts over the period of this project have made
a major contribution to the successful completion of this report.

Word processing and editorial assistance were provided  by  Ms.  Nancy
Zrubek, Mrs. Kaye Storey, and Ms. Carol Swann.
                                  xii

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                              CHAPTER I

                             INTRODUCTION

Section  74  of the Clean Water Act of 1977 requires the Environmental
Protection Agency (EPA)  to  investigate  the  ecological  effects  of
seafood   waste   discharges  and  to  identify  treatment  and  waste
utilization technologies applicable to seafood processing  operations.
This section reads as follows:

         "Sec.  74.   The Administrator of the Environmental
         Protection Agency shall conduct a study to  examine
         the   geographical,  hydrological,  and  biological
         characteristics of marine waters to  determine  the
         effects  of  seafood  processes  which  dispose  of
         untreated natural  wastes  into  such  waters.   In
         addition,  such  study  shall  examine technologies
         which may be used in such processes  to  facilitate
         the  use  of  the  nutrients  in these wastes or to
         reduce the discharge of such wastes into the marine
         environment.  The results of such  study  shall  be
         submitted    to    Congress    not    later    than
         January I, 1979."

Under the Section  74  mandate,  EPA  developed  a  study  plan  which
included   summarizing  existing  information  as  well  as  new  data
collection.  Work conducted during this  study  covers  a  variety  of
major   seafood   processing   locations  and  processing  situations.
Ecological effects investigations include sampling efforts  in  Oregon
and  Alaska,  site  visits to New England, the Atlantic Coast, and the
Gulf Coast and an in-depth assessment of a study conducted in southern
California  (Los   Angeles   Harbor).    Similarly,   the   technology
assessments  performed  as part of the study include processors in all
locations.

In performing  these  investigations,  EPA  enlisted  support  from   a
variety  of  sources,  including the University of Alaska Institute of
Marine Science, EPA research personnel, experts in the  industry,  and
several  consulting firms.  In addition, EPA requested the cooperation
of a number of Federal and state agencies in a review and critique  of
the  Los  Angeles  Harbor  study  submitted  by  the  tuna  processing
industry.

In terms of waste control, the Nation's seafood processing  facilities
have  improved  during  the  past  decade.   The  majority  of seafood
processors  are  discharging  significantly  less  waste   solids   to
(primarily)  coastal  receiving  waters than was common ten years ago.
Because of influences in the marketplace  and  awareness  of  resource
conservation, the industry has been encouraged to use these solids for

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by-product  manufacturing.   Many locations now produce pet food, fish
meal and fish oil.

Although there has been considerable improvement in  the  availability
of  technologies  to  process  seafood  wastes,  the  seafood industry
contends that in  many  geographical  areas  treatment  of  wastes  is
unnecessary.   This  is  based  in  the  belief  that these wastes are
natural and pose no threat to the marine  environment,  and  moreover,
the  nutrients  supplied  by  these wastes have a generally beneficial
effect on the marine ecosystem.  This thesis is presented in detail in
the Los Angeles Harbor study report submitted to EPA by the  industry.
EPA  has  devoted considerable effort to an assessment of the data and
concepts presented in this study.

The information and conclusions contained in this document  have  been
developed  specifically  to satisfy the Section 74 requirement and are
entirely separate from the ongoing  development  of  technology  based
regulations  for  the  seafood  industry.   Because  the  technologies
identified during this study are in various stages of development  and
applicability,  no  technology  alternatives  are being recommended in
this report.

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                              CHAPTER II

                             CONCLUSIONS

A.  Ecological Effects

This research study and the available literature  indicate  that  some
coastal  areas  can  assimilate  or  disperse  large  amounts of waste
without serious effect, while other areas are  adversely  impacted  by
seafood  waste  discharges.  The observations of impact-free discharge
sites in areas of favorable currents  are  consistent  with  generally
accepted   concepts   that  problems  associated  with  soluble  waste
components can be avoided with  adequate  dispersion  at  the  source,
however,  these  observations  cannot  be  generalized with respect to
settleable  particulates.   Initial  dispersion  sufficient  to  avoid
seabed  accumulation  at  the  discharge  site does not guarantee that
particulates might not subsequently accumulate in  downcurrent  seabed
depressions,  bays, or tidal flats.  It is evident that the ecological
impact from seafood waste disposal is not a  simple  phenomenon.   The
following  sections discuss specific findings, the nature of the waste
discharges, the types of effects documented and  variable  factors  at
discharge  sites affecting the observed impacts.  Finally, the concept
of "bioenhancement" is discussed.

Site-Specific Effects

The most severe effects were documented at Dutch Harbor, Alaska  where
processors  discharge  many  tons  of shellfish waste solids annually.
EPA investigations revealed that these wastes are accumulating on  the
bottom  from season to season and that they are smothering most bottom
life across broad areas in the vicinity of the  discharge  points.  In
contrast,  another  field  study  conducted  at Cordova, Alaska, where
processors  also  discharge  untreated  waste  solids,  detected  less
ecological  damage;  the  effects  noted  in this study were generally
limited to the immediate vicinity of the discharge point.  Studies  at
Kenai,  Alaska  (untreated  wastes) and Yaquina Bay, Oregon (partially
treated wastes) revealed little detectable impact on the environment.

Variability of Waste Discharges

Seafood processing operations are by no means uniform in the nature of
their wastewater discharges to marine waters.   Investigations  during
this  study  reveal that Alaskan processors generally discharged whole
or ground waste solids, while  processors  in  the  contiguous  states
generally  employ  wastewater  screening  prior  to  discharge,  which
results in relatively small particles of waste solids  being  released
to  the  marine  waters.   Some  of  the larger seafood canners in the
contiguous states, such  as  tuna  processors,  employ  dissolved  air
flotation  treatment  systems  prior  to  wastewater  discharge.  This
treatment results in the removal  of  a  significant  portion  of  the

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seafood  waste solids and oil and grease generated by these processing
operations.

Seafood processing wastewater characteristics also vary with the  type
of species processed.  A major distinction may be made between finfish
and  shellfish;  finfish  wastes are characterized as high in protein,
while shellfish wastes contain lesser amounts of protein along with  a
high  percentage  of the polysaccharide, chitin.  Finfish wastes, such
as salmon wastes, are generally more easily dispersed or  degraded  by
receiving  waters  than  shellfish wastes.  Seafood commodities may be
further distinguished by their oil content.   Some  species,  such  as
sardine,  contain  high  levels of oil, while others, including shrimp
and bottom fish, contain relatively small amounts of oil and grease.

Types of Effects Documented

Waters receiving seafood  wastes  vary  widely  with  respect  to- the
observable  effects  caused  by the waste discharges.  As noted above,
some areas are able to assimilate significant quantities of  untreated
wastes  while  other  areas  show serious ecological damage from these
wastes.  The types of  harmful  effects  detected  during  this  study
include the following:

1.  Solids accumulation - Excessive amounts of waste solids can result
    in their accumulation on the bottom which, in turn, leads  to  the
    physical  smothering  of  bottom  dwelling organisms with possible
    negative effect on the quality of the water above.  This  type  of
    impact was detected at Dutch Harbor, Alaska.

2.  Excessive Oxygen Demand - Seafood wastes discharged  in  any  form
    may  exert a heavy demand on the available oxygen in the receiving
    waters.   This  oxygen  demand  is   the   result   of   bacterial
    decomposition  of the wastes.  Areas with limited tidal or current
    movement are most susceptible to this type of problem.

3.  Excessive Oil Discharge - The  processing  of  certain  commercial
    species  results in the discharge of  large quantities of fish oil.
    Rather than mixing uniformly with the receiving waters,  this  oil
    generally  floats  on  the  surface and may result  in a variety of
    problems including damage to marine birds, shoreline property  and
    boats.    Several   sardine   processing    locations  periodically
    experience these problems.

4.  Aesthetic Effects - Discharge of seafood wastes  can  result   in   a
    variety  of  aesthetic  problems   including   visible floating fish
    parts  and  oil,  attraction  of  scavenger  birds   and  malodorous
    conditions.

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Major Factors Relating to Observed Impacts

In   conducting   ecological   effects   studies  and  evaluating  the
literature, EPA has attempted  not  only  to  define  the  effects  of
seafood  waste disposal at individual sites, but also to delineate the
site-specific factors.  The two most significant site-specific factors
identified  by  EPA  are  the  amount  of  waste  discharged  and  the
hydrological  conditions of the receiving waters.  It is apparent that
most seafood processing locations are capable of assimilating a  small
amount of waste without ecological damage.  Areas with strong tidal or
current  flushing  are  able  to  disperse relatively large amounts of
waste material as compared to areas  where  water  movement  is  slow.
Generally,  enclosed  bays,  bayous,  and  slow moving rivers are most
susceptible to solids accumulations or oxygen depletion.

Other  site-specific  variables  influence  to  a  lesser  extent  the
observable  effects  at  individual sites.  First, the type of seafood
commodity processed has some  relationship  to  the  observed  effect.
Generally,  shellfish  waste  is less easily dispersed than is finfish
waste.  The processing of oily species  often  results  in  a  residue
formed  on  receiving  waters  near  the  discharge point.  Second, in
addition to hydrological conditions, there are  other  characteristics
of  the  receiving  waters  affecting  to some extent their ability to
assimilate wastes.  The most  significant  of  these  are  the  native
marine  species  present  and  the  chemical  characteristics  of  the
receiving  waters.   Generally,  species  which  have   the   greatest
tolerance  for  depressed  dissolved  oxygen  levels  are best able to
survive near the outfall locations and, in some cases, to utilize  the
wastes as food.  Regarding water chemistry, areas where both dissolved
oxygen  levels  are  near saturation and nutrient levels are generally
low are much better able to assimilate waste discharges than are areas
with naturally low oxygen levels or high nutrient levels.

Bioenhancement

"Bioenhancement" is a concept advanced by the seafood industry,  which
in  effect  states  that  the  discharge  of  seafood  wastes provides
nutrients which can be utilized  by  marine  species  to  increase  or
"enhance"  aquatic  populations.   EPA, in conjunction with scientists
from other Federal and state agencies, has conducted an assessment  of
this  concept  as  presented  in  a document submitted by the industry
relating to the effects of tuna processing  waste  discharges  in  Los
Angeles Harbor (Appendix E-l).

It  is  well known that seafood wastes and many other types of natural
wastes,  contain  potentially  valuable  nutrients.   However,  it  is
apparent  from  the  inter-agency review of the industry document that
"bioenhancement"  is  a  highly  controversial  concept  among  marine
scientists.  Scientists generally agree that the nutrients supplied by
seafood  wastes  can  potentially cause an increase in certain aquatic

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populations.  They do not concur,  however, that such  an  increase  is
desirable  and  point  to  evidence  that  increases  are mainly among
pollution-tolerant "scavenger" populations.  They also point out  that
the  Los  Angeles  Harbor  report  does  not address a large number of
potential  adverse  effects  from  the  waste  discharges,   including
increased fish disease, and increased accumulations of toxic compounds
and  metals  already  present  in the harbor (from other discharges or
caused by runoff).

It appears, then, that "bioenhancement" is  a  poorly  understood  and
controversial  concept.   Additional,  longer term, research by marine
biologists is necessary in order to understand fully  the  effects  of
seafood waters enrichment of marine ecosystems.  Current  knowledge of
this  subject  is  incomplete  and could not be effectively and safely
incorporated into a waste management policy.  A detailed review of the
Los Angeles Harbor study is presented later.

B.  Technology Assessments

Treatment Technology - Non-Alaskan

For  non-Alaskan  seafood  processing  facilities,  applicable   waste
control  technology includes modifications within the processing plant
to reduce waste generation at the  source  and  end-of-pipe  treatment
systems   to   remove  solids  from  wastewater  prior  to  discharge.
Applicable end-of-pipe systems include simple screens for  small  non-
mechanized  facilities  and  relatively  more  elaborate dissolved air
flotation systems for larger  or  mechanized  facilities.   Biological
treatment  systems,  popular treatment for other types of food wastes,
are not applicable for most seafood facilities  for  several  reasons.
First,  these systems are best suited for digesting a continuous waste
discharge; seafood  operations  are  often  intermittent  which  would
require  frequent,  difficult start-up and shut-down of these systems.
Second,  biological  systems  typically  require  more  land  than  is
available at many seafood processing locations.

Treatment Technology - Alaskan

There  are  fewer  feasible  waste  control technologies available for
Alaskan processors than  for  processors   in  the  contiguous  states.
Alaskan   seafood   processors  are  different  from  the  non-Alaskan
processors because of their geographic isolation, weather  conditions,
high  construction  and  transportation  costs and other factors.  In-
plant modifications  with  wastewater  screening  for  solids  removal
provide a measure of waste control for Alaskan facilities.

A  limited  amount  of experimental work has been done to evaluate the
effectiveness of outfall diffuser  systems  and  near-shore  discharge
systems   as  a  means  of  effectively  dispersing  waste  particles.
Continued  research  on  these   systems   may   show   them   to   be

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environmentally  acceptable  alternatives  to end-of-pipe treatment in
some areas.

Waste Utilization Technology - Non-Alaskan

Technologies are available to seafood  processors  in  the  contiguous
states  to  utilize  most   waste solids in secondary products and by-
products.  The tuna  industry  currently  manufactures  a  variety  of
products  from  wastes  including pet foods, fish meal and oil.  Other
segments of the industry are less advanced  in  their  production  and
marketing  techniques.   For  a  few large integrated processors, fish
meal is a profitable and well-established by-product.

A problem persists regarding shellfish waste  utilization.   The  only
established  by-product  process applicable to these wastes (generated
by wastewater screening) is drying  for  meal  production.   Shellfish
meal  is  considerably  lower in value than finfish meal and marketing
the meal is often difficult.  In fact, many shellfish meal plants  are
operating  at a deficit.  Consequently, major research and development
is needed to develop chitin (a polysaccharide common to all shellfish)
production as a feasible industry.  In particular,  the  research  and
development  should  explore  the potential uses of chitin and develop
improved production techniques and markets for the product.

Waste Utilization Technology - Alaskan

Waste utilization technologies are less established in Alaska than  in
the contiguous states.  EPA's analysis of prospective fish meal plants
in  Alaska  shows that the majority of plants would be unprofitable if
built.  This is due to high construction and transportation  costs  in
Alaska and to competition from alternative products.

Shellfish meal production is even less economically feasible in Alaska
than   in   the  contiguous  states,  due  to  higher  production  and
transportation costs as well as the low value of this product.  Chitin
production, however, is potentially profitable in  Alaska  because  of
the  enormous  amount  of  shrimp  and  crab  waste solids.  Continued
research in this  area  may  eventually  make  large-scale  production
feasible.

Until a profitable by-product process is developed for Alaska, barging
of  wastes  for  deep  water  disposal  remains  the  least  expensive
alternative in many  areas  for  processors  that  operate  wastewater
screens to remove seafood solids.

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                                  CHAPTER III

                           ECOLOGICAL INVESTIGATIONS


1.  STUDY OBJECTIVES AND METHODS

EPA  initiated  an  assessment  of  the effects current waste disposal
practices in the seafood processing industry have  on  marine  waters.
The   assessment  also  includes  a  rather  detailed  examination  of
alternative  technologies  which  could  help  reduce  seafood   waste
discharges by utilizing nutrients present in the waste material.  (See
Chapter IV).

To  this  end,  EPA's  first  obligation  was  to identify the effects
attributable  to  the  disposal  of  raw,  untreated   seafood   waste
discharges   to  marine  or  estuarine  waters.   Historical  evidence
indicates that these effects are usually site-specific;  in  light  of
this,  EPA  has  also  attempted to identify any factors governing the
relative severity of the effects.  Mitigating factors might range from
something as elementary as the quantity of waste  discharged,  to  the
more  complex  relationship  between  the  type  and  amount  of waste
discharged  and  the  assimilative  capacity  of  the  surface   water
receiving the waste.

Because  of the intricacy of the interrelationship among site-specific
factors, EPA has not developed a set of criteria for management of the
wastes.   EPA  has,  however,  developed  a  detailed  and  consistent
methodology  for  measuring  the  ecological  effects from the wastes.
This methodology, as outlined in the  follo.wing  paragraphs,  includes
visual  inspections,  analyses  of  water quality and nutrient levels,
analyses of sediment samples and benthic (bottom dwelling marine life)
sampling.

A principal element of EPA's investigations was on-site inspection  of
waste disposal sites and practices to obtain first-hand information on
excessive accumulations of waste solids or to make visual evaluations.
Observations were made both on and below the surface.

Investigations  also  included  an  analysis  of  water  and  sediment
quality.  The water quality  parameters  monitored  include  dissolved
oxygen  concentrations,  hydrogen  sulfide  levels,  nutrient  levels,
temperature, and salinity.  Similar tests were conducted  on  sediment
samples.  A deficiency in dissolved oxygen, i.e., the amount of oxygen
present  in  water  as  a  dissolved  gas, is an historically accepted
indication   of   accelerated   biological   activity   (i.e.,   waste
decomposition).   Hydrogen  sulfide is a toxic gas emitted as a result
of the  decomposing  process  in  the  absence  of  dissolved  oxygen.
Concurrent with the water quality investigations at each Alaskan site,

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sediment samples were analyzed to determine the presence of pathogenic
bacteria growing in the accumulations of seafood waste.

Because  of  the  short-term  nature  of  the site investigations, the
studies included sampling  of  the  macrobenthic,  or  large,  bottom-
dwelling organisms in order to determine whether or not waste material
was unduly taxing any species.  Organisms of this sort are long-lived,
permanent  residents  of an area and are particularly useful in short-
term ecological studies.  They can be employed  as  indicator  species
for  a disturbed area because they tend to remain stationary, react to
long-range environmental changes, and, by their presence  or  absence,
generally reflect the biological health of local marine waters.

Section  74  specifies  that  EPA focus its study efforts on untreated
seafood waste discharges.  This most commonly occurs in Alaska; unlike
seafood processors in  the  contiguous  states,  most  Alaskan  plants
simply  grind their wastes before discharging them into marine waters.
A small number of processors in Alaska  have  installed  equipment  to
capture solids for separate disposal.  Following consultation with the
seafood  industry,  three  Alaskan  sites, each having processors dis-
charging untreated waste, were selected for investigation  during  the
study.   These  sites,  Dutch  Harbor,  Cordova,  and Kenai  (Figure 1)
reflect a variety of circumstances and differ according to the type of
seafood processed (shellfish versus finfish),  number of  plants  dis-
charging,  quantity  of  wastes  discharged,  and types of marine life
indigenous to outfall areas.

These sites also provided for an opportunity  to  assess  hydrological
conditions (tidal changes and current strength) which vary from active
(Kenai),   to   moderate  (Cordova),  to  negligible   (Dutch  Harbor).
Hydrological activity (flushing action)   is  important  chiefly  as   a
means  for  waste  dispersion,  and may dictate the amount of waste an
area assimilates.  For example, a processing plant situated  near water
with active, highly mobile currents may discharge its waste  and  rely
on  the  current  to  disseminate  it,  thereby  minimizing  localized
effects.  Another facility, located  near  water  with  little  or  no
circulation or flushing action, may discharge waste in an amount equal
to  that  of  a facility near water with  active currents and find that
the weaker currents  allow  a  harmful  build-up  of  waste  near  the
discharge point.

As  an  additional  field  investigation  site, Yaquina Bay,  Oregon was
selected both for general comparisons with the Alaskan  situation  and
to   provide   details  applicable  to  the  Pacific   Northwest.   All
processors in Yaquina Bay have installed  screens to remove most solids
from processing effluents prior  to discharge.

The  field  sampling  information  was  further  complemented   by    a
literature  review  of  historical  studies, including earlier work on
                                  10

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Alaskan sites dealing with the effects of  seafood  wastes  discharged
into receiving waters.

In addition to the Alaska and Oregon studies, EPA has reviewed a long-
term study which was conducted in Los Angeles Harbor by the University
of Southern California.  Also, a number of other processing areas have
been visited, including New England, the mid-Atlantic and Southeastern
states  and  the  Gulf  Coast.   The  objective of these visits was to
identify and document waste  generation  and  disposal  practices  and
effects  and any local or site specific problems and issues of concern
(see Figure 2 and 3 and Table 1).

In summary, a rather wide range of locations  and  circumstances  have
been investigated.  This gives reasonable assurance that entirely site
specific  conditions  can  be  properly  assessed  as  to relevance in
general comparisons; general comparisons are made  where  similarities
of commodity, waste controls, hydrology, etc., warrant.

2.  BACKGROUND AND HISTORICAL STUDIES

The  authors  of  the  University  of Alaska's report on Dutch Harbor,
Alaska expressed considerable concern about  the  lack  of  background
data  on  the  condition  of  the water and benthic environment at the
individual plant locations.  Because much of EPA's Section 74 work  is
unprecedented  (i.e.,  no background data exists), this concern proved
exceedingly relevant to  the  situation  which  confronted  EPA  while
conducting  the  Section  74  study.   The  Agency's  objective in the
ecological portion of the study has been to provide details about  the
ecological  status  of  marine  environments receiving raw, untreated,
seafood processing wastes.  The site studies  described  below  should
not  be  regarded as definitive and unchanging; rather, they should be
viewed as indicators of existing conditions at waste  disposal  sites,
and  used  to  forecast  the  type  of conditions likely to persist or
worsen in the event that the discharge of untreated waste continues.

The following paragraphs  summarize  the  limited  number  of  studies
conducted  in  the  past  to evaluate seafood waste discharge effects.
Following this summary, section 3 presents the new  studies  conducted
in response to Section 74.
                                  12

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                      Figure 2.  Map  of the United States

                    illustrating the  geographic coverage of

                    investigations  for the Section 74 study.
                                        13

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Figure 3:  Typical development of dock processing operations in Alaska.
                                    14

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                                    TABLE 1

                    GEOGRAPHICAL COVERAGE OF THE SECTION 74
                           SEAFOOD PROCESSING STUDY
Site Location_

Dutch Harbor
(Alaska)

Kenai
(Alaska)

Cordova
(Alaska)

Yaquina Bay
(Oregon)

Alaska
_Type  of  Study_
Authors
  Ecological-EPA
  Sponsored

  Ecological-EPA
  Sponsored

  Ecological-EPA
  Sponsored

  Ecological-EPA
  Sponsored

  Pathogenic-EPA
  Sponsored
Los Angeles Harbor Ecological-Industry
                   Sponsored
New England
(Maine)
  Site  Visit
Mid-Atlantic Coast Site Visit
(Georgia)
Southeast Coast
(Florida)

Gulf Coast
(Louisiana)
  Site Visit
  Site Visit
 University of Alaska


 SCS Engineers


 SCS Engineers


 EPA Corvallis Research
   Laboratory

 University of Alaska
 Appendix
_Reference

     A-2
     B-l


     B-l



     C-l

     D-l
 USC Harbors Environmental
   Projects                 E-l

 EPA, Effluent Guidelines
   Division                 F-5

 EPA, Effluent Guidelines
   Division                 F-l

 EPA, Effluent Guidelines
   Division                 F-4

 EPA, Effluent Guidelines
   Division                 F-3
                                 15

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A,  Dutch Harbor

Because  of the volume of processing activity, its relatively confined
receiving waters, and its potential to exhibit ecological instability,
Dutch  Harbor  is  a  site   frequently   chosen   for   environmental
investigations.  Unlike most major seafood processing areas, for which
little   historical   data  exists,  a  substantial  amount  of  data,
describing Dutch Harbor's topography and water quality, is available.

Researchers from the University of Alaska  conducted  the  first  such
study in 1968.  Their efforts were directed toward determining how and
to  what  extent the decaying of organic seafood processing wastes has
affected the quality of receiving waters.  For purposes of comparison,
they sampled nearby water not receiving waste effluent, and  found   it
was typical of unenriched seawater.  But water taken from Iliuliuk Bay
and  Harbor   (see  Figure  4),  nearer to the outfall points, had high
ammonia concentrations (a product of protein decomposition) and/or low
dissolved oxygen concentrations.   (Dissolved oxygen is consumed in the
decomposition process.)  Both symptoms were believed to be a result  of
the seafood waste build-up and can be hazardous to marine life.1

The first time EPA conducted research in the Dutch Harbor areas was  in
1975 when researchers from Region X conducted a water  quality  survey
in  response  to the post-1970 escalation in processing activity.  Data
were gathered in this  effort  to  provide  a  foundation  for  future
comparison.   Another  more  comprehensive  study  was  scheduled  for
October 1976.  Together, these investigations would serve as  a  basis
for   assessing   the  processors'  compliance  status  with  National
Pollutant Discharge Elimination System (NPDES) permit requirements.

According to  the combined studies, Dutch Harbor's  water  quality  was
generally  poor.  Low dissolved oxygen concentrations, along with high
ammonia and   phosphorous  concentrations,  were  pervasive.   In  some
areas,  large waste accumulations were observed.  Researchers believed
that these waste accumulations were responsible for the low  dissolved
oxygen  and   high  ammonia  and phosphorous condition.  They concluded
that the waste had amassed because  tidal  currents  in  the  enclosed
portion  of   the  harbor,  where   several  outfalls  are located, were
insufficient  to disperse the waste.2

In 1977, EPA  again conducted a water quality survey in  Dutch  Harbor.
This  study   was  designed  to  gain more information about changes  in
shellfish waste accumulations from one processing season to the  next.
Researchers   set  out  to measure  hydrogen sulfide levels,  a toxic by-
product of  waste  decomposition,  in  both  aging  and  recent  shell
deposits.3

For  the most part, researchers found waste accumulation still greatly
exceeded the  rate of dispersion or decomposition.  In  certain  cases,
sludge   beds were  creating   adverse   conditions  for  marine  life.


                                  16

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                                         LEGEND
                             MARCH 1979

                             Q PROCESSO*
                             • DISCHARGE
NAUTICAL  MILES
 I.  M/V ROBERT E. RESOf F
   M/V SEA ALASKA
   M/V SEA PRODUCER
 2. M/V THERESA LEE
 3. PAN ALASKA
   M/V ROYAL ALASKA*
 4. M/V EAST POINT
 5. WHITNEY- FIDALGO
 6. VITA  FOOD PRODUCTS
   M/V VICEROY
 7.  M/V UN ISC A
   M/V GALAXY
 8  PACIFIC PCAflL
 9  PACIFIC PCAML
10. M/V YAMOAMM KNOT
        Figure  4. Location  of  Seafood processors
                 in Dutch Harbor, Alaska.
                            17

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Shellfish waste deposits were most prominent within a 30-meter  radius
of the discharge site.   In this area,  the waste smothered all immobile
organisms;  in  other  areas,  shallower  deposits had equally adverse
effects on  clams.    Hydrogen  sulfide  levels  greatly  exceeded  the
concentration reported to constitute a hazard for aquatic life (Figure
5).

Also  in  1977,  researchers from the University of Alaska returned to
Dutch  Harbor  under  the  auspices  of  the  Association  of  Pacific
Fisheries, this time to conduct a hydrographic survey.  In addition to
evaluating  water  quality,  the  hydrographic  study  was designed to
record the area's physical characteristics (i.e. high  and  low  water
marks,   bottom   composition,   and   current  speed)  so  that  some
determination could be made regarding  the  suitability  of  the  area
between Hog and Amaknak Islands as a location for a waste outfall.4

After  considering  current  speed  and  direction,  along  with other
relevant data, the researchers concluded that the northern portion  of
the   channel  between  Hog  and  Amaknak  Islands  would  be  a  more
satisfactory location for an outfall than those presently in use along
the shore.  They suggested as another alternative  a  deep  water  (42
foot)  discharge  disposal  site  near  the  northeast side of Amaknak
Island (Figure 4).

In response to growing evidence and concerns about waste accumulations
from EPA Region X,  Dutch Harbor  crab  processors  engaged  Brown  and
Caldwell  Consulting  Engineers  in 1978 to explore the feasibility of
shore area waste outfall/diffuser systems.  It  was  felt  that  these
systems  would  effectively  eliminate  any massive buildup of shells.
Such systems were purported to  provide  for  better,  more  efficient
waste dispersion by exploiting wind and wave activity.

In  their  exploration  of  waste  disposal  alternatives,  Brown  and
Caldwell postulated that an outfall/diffuser system in the shore  area
off  the  west  and  northeast  sides  of  Amaknak  Island  would be a
promising solution.  Observations of the area revealed strong,  active
currents  necessary  for  dispersing  significant  amounts  of  waste.
Although their study concluded  that  it  remained  uncertain  whether
dispersal  sufficient  to  meet  NPDES requirements could be achieved,
they recommended that a test system be constructed.5

In 1979, Brown  and  Caldwell  continued  in  their   investigation  of
alternative  disposal  systems in Dutch Harbor.  Principal among their
undertakings was the operation of an outfall/diffuser test  system  on
the  west  side  of  Amaknak  Island.   The report indicates that this
method is promising as a disposal option.

All of Brown and Caldwell's work, while addressing the  importance  of
site-specific   factors,  emphasize  shore  outfall/diffuser  systems,
properly  located in turbulent waters, as the most desirable  of  waste


                                 18

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Figure 5:  Photograph of bottom sample taken from Dutch Harbor, Alaska, showing bubbles of
noxious gases evolving from decaying sludge and absence of benthic life.
                                 19

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disposal  alternatives for the Dutch Harbor region.  Furthermore, they
recommend that waste be ground to one-quarter-inch particles and  that
existing  outfalls  be  modified  and,  where  possible,  relocated to
maximize waste dispersal.

Brown and Caldwell considered  two  other  means  of  waste  disposal:
barging  and deepwater discharge from fishing vessels.  In both cases,
the waste material must be screened and loaded for  disposal  in  deep
water  (42+  feet),  away  from  shore areas.  Either of these methods
would prevent shore build-ups, but there may be some problems inherent
in each.  In the case of barging, seafood processors would be required
to operate a tug and barge  or  dump  scow.   Discharge  from  fishing
vessels  eliminates  the  expenses  associated  with barging, but this
study indicates that storage difficulties and  fishermen's  resistance
make this alternative less attractive.*

B.   Other Alaskan Sites

In  the  last  ten years, both EPA and the seafood processing industry
have funded several studies which focus on the  effects  of  untreated
waste  disposal  in  Alaska.   Collectively, these studies support the
contention that the severity of any one site's waste disposal  problem
depends  primarily  on  the amount of processing activity in the area,
and on the flushing capacity of the receiving waters.

In 1970, the Fisheries Research Institute  (FRI) of the  University  of
Washington  (Seattle)  performed  a  preliminary  ecological survey of
Bristol Bay and Kodiak   Island,  Alaska.   This  was  done  after  the
northwest  canning  industry  expressed  concern  over  the effects of
salmon  processing  waste  discharges  on  receiving  waters  in   the
northwest.

The  FRI  study indicated that, though there were temporal depressions
in dissolved oxygen  concentrations,  waste  from  processors  had  no
serious  or  significant  effect on marine organisms.   The study noted
further that these dissolved oxygen depressions were confined  to  the
discharge  area and were eliminated by a twice-daily flushing from the
tides.  Similar results  at seven processing  sites  in British  Columbia
were also reported.7

In   1971  EPA  Region  X  reported  on  the  problem created by seafood
processors' waste  discharged  in Kodiak Harbor, St.  Paul  Harbor,  and
Gibson  Cove,  Alaska.   These three  embayments,  in an  area having the
highest concentration of seafood  processing   in   the   state,  receive
waste   from  15  processing  plants   in  or  near  the  city of Kodiak on
Kodiak  Island.  In this  study, EPA researchers found  that  the  waste
had  exerted a substantial negative effect  on the  water  quality so  that
they  believed  these conditions might upset the  ecological balance or
pose a  severe threat to  marine  life.   Additionally,  they  noted   a
massive  accumulation  of  waste  on  the  bottom.  They estimated  that


                                 20

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these sludge-like  deposits  covered  52  acres.   Samples  of  bottom
sediment  near  processor  outfalls  contained  no benthic life, while
those collected away from the  outfall  areas  did.8  Figure  6  is  a
photograph  of salmon waste dredged from the bottom in the vicinity of
a salmon cannery outfall at Port Bailey, Kodiak Island, Alaska.

In 1971, the National Canners  Association  and  Petersburg  Fisheries
funded  a  study to evaluate any impacts resulting from waste disposal
in Petersburg,  Alaska.   Essentially,  the  findings  indicated  that
processors' wastes did not have a major effect on water quality during
this  particular  time; dissolved oxygen concentrations were standard.
Scavenging fish and birds fed heavily on  waste.   Other  data  showed
that  the  remainder  of  the  waste  was  eventually dispersed by the
currents.»

In contrast, laboratory studies by Nakatani and Beyer,  assessing  the
effects  of  salmon  processing  waste  effluent  on  juvenile salmon,
indicated that a prolonged exposure could prove fatal.   Approximately
20  hours  of exposure to diluted waste effluent solutions were enough
to result in fatalities.10

3.   EPA SECTION 74 STUDIES

A.  Dutch Harbor

Of the several sites sampled by EPA during the Section 74 study, Dutch
Harbor exhibited conditions which were substantially worse than any of
the others.  University of Alaska scientists, who were conducting  the
study,  again  found that "processing wastes are accumulating adjacent
to outfalls off Amaknak Island, and existing  water  currents  do  not
provide  sufficient energy for adequate dispersal of wastes" (Appendix
A-2, page 8).  Here, the wastes place  an  inordinate  demand  on  the
oxygen  supply,  and overload the ecological system.  Essentially, the
decaying, undispersed wastes absorb oxygen from the water,  making  it
difficult, if not impossible, for indigenous marine life to survive.

Researchers also found during their study that waters in some areas of
Dutch Harbor and Iliuliuk Bay may have a tendency "to go anoxic" (lose
dissolved  oxygen)  naturally  in  the  fall months, because of little
flushing action for most of the summer.  Overloading the  system  with
processing  waste  only  accelerates and prolongs this condition.  The
stress from processing waste discharges severely reduces the number of
species in this area.  Those organisms  not  killed  by  the  lack  of
oxygen  may  be smothered by fresh processing waste; the weak currents
cannot  transport  the  decaying  material  sufficiently  to   prevent
serious, harmful accumulations.

Sediment  samples  and televised underwater observations revealed that
Dutch Harbor  and  Iliuliuk  Bay,  along  with  the  area  immediately
adjacent  to  processors'  outfalls  on  the  opposite side of Amaknak


                                 21

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Figure 6:  Salmon waste dredged from the bottom in the
vicinity of a salmon cannery outfall, Port Baily, Kodiak Island,
Alaska.
                              22

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Island, were the most severely affected by  seafood  processing  waste
disposal.  Sediment in the Dutch Harbor/Iliuliuk Bay Basin was gray to
black  in  color,  and  emitted  a  strong  sulfide odor.  Sediment at
sampling stations near processors' outfalls was composed  entirely  of
processing waste in various stages of decomposition.

Sulfide  concentration  was greatest in an area located within the old
shellfish disposal area of several years ago (Station OUT 01A) (Figure
7).  The ten bottom-dwelling organisms  present  here  were  primarily
stress-tolerant  polychaete  worms.   High sulfide concentrations were
common throughout Dutch Harbor and Iliuliuk Bay, and  also  along  the
shore outfalls on the opposite side of Amaknak Island.

In  summary,  adverse  impacts from seafood processing discharges were
found in both the current disposal areas and in the old disposal sites
which  have  not  been  used  for  several  years.   It  appears  that
ecological damage to this region might be long-term because the wastes
are   accumulating  year-to-year  and  winter  storms  and  tides  are
insufficient to remove these wastes.

The University of Alaska scientists recommend  that  studies  in  this
area  be  continued  to  develop  a  more precise picture of the waste
impacts on the marine ecosystems.   At  the  same  time,  this  report
expresses  concern that continued discharge of wastes will cause added
degradation and will eventually "...cover much of the nearshore bottom
with serious sanitary and ecological problems to be expected."   These
scientists go on to recommend that "current seafood disposal practices
be  improved  so  that gross solids are either removed or dispersed by
discharging effluent into areas of well-mixed waters" (Appendix A).

B.  Cordova

EPA's study of the Cordova processing area (Figure 8) marked the first
such effort.  Much like the Dutch Harbor study, the Cordova study  was
designed  to  identify important site-specific factors which determine
the nature  of  ecological  impacts  resulting  from  untreated  waste
discharges from seafood processing operations.

Seafood  processing at Cordova is less extensive than at Dutch Harbor.
Four  processors  (Dutch  Harbor  has  15)  discharge   their   waste,
principally  ground  shells  and fish parts, into Orca Inlet.  Current
movement  in  the  inlet,  while  greater  than  Dutch  Harbor's,   is
insufficient  at  two  discharge  sites  to  disperse waste adequately
(Figure  9).

Researchers found surface discoloration and floating debris  near  two
processors'  docks.   At  one, where floating debris was excessive, it
appeared that whole crab shells and appendages had  been  dumped  from
the  dock.   At the other, a white-yellow discoloration on the surface
                                 23

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                                                                                            i«*>r
to
                  o-i*
                          /\ HATER COLUMN SAMPLE
                          • QUANTITATIVE BENTHIC SAMPLE
                              COLUMN SAMPLES
                           X QUALITATIVE BENTHIC SAMPLE
                           O STO ONIV
                           A QUALITATIVE BENTHIC AND STD

                          ^ QUALITATIVE BENTHIC AND
                              WATEH COLUMN SAMPLES
                                                                                                                     u*tr
                                             Figure 7.   Hydrographic water  chcnistry,
                                          sedimentological and biological  sampling  grid
                                                        in Dutch  Harbor,  Alaska.

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                                                                  ORCA
                                                   SAMPLING SITES
                                                  OUTFALL  STATIONS
                                               0	600	1 .200


                                               SCALE  (IN  METERS)
                              UDSV

                              DDDCCORDOVA
Figure 8.  Location of a tripling  sites
         at Cordova, Alaska.

-------
Figure 9:  Accumulations of whole fish parts taken from bottom of Orca Inlet, Cordova,
Alaska.
                                    26

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water resulted  from  intermittent  cannery  discharges.   Patches  of
floating debris had drifted over 45 meters from the discharge point.

Underwater  photography revealed a waste accumulation directly beneath
one processor's docks.  All crab wastes  had  apparently  been  dumped
from the dock (Figure 10).  The wastes extended out from the dock in a
semicircle  for  a distance of five meters.  Piles of waste were found
up to 25 to 30 centimeters (10 to 12 inches) deep.  Several fish heads
and crab shells were observed near one cannery outfall.

At another outfall waste discharges had cut a trough in the bottom  of
the  harbor  approximately  three  meters  wide  and  six meters long.
Because of the considerable amount of debris in it,  its  depth  could
not be determined, though divers estimated it to be one meter.  Ninety
percent  of  the waste appeared to be crab exoskeletons; the remainder
fish tails and heads  (Figure 11).

In comparison to the waste previously noted,  processing  waste  at  a
third  outfall  was  more finely ground and evenly distributed.  Waste
was restricted to a circular area extending 12 to 16 meters  from  the
discharge point.  No distinct piles were observed.

Bottom  films  of two outfall areas near the fourth processor, who was
not operating during the study   (1978),  showed  no  evidence  of  any
accumulation from past years.

Despite  accumulations  of waste in some areas, chiefly as a result of
waste being dumped from processors' docks, Cordova's water quality was
generally healthy.  No test  stations  exhibited  depressed  dissolved
oxygen  concentrations;  the  benthic community(bottom dwelling marine
life) generally showed signs of being stable and diverse,  except  for
localized areas near discharge sites.

In  a  related  bacteriological  investigation of crab waste in Alaskan
waters, University of Alaska scientists isolated Vibrio anquillarum, a
pathogenic strain of bacterium common in intestinal  tracts  of  fish,
from  a  Cordova sample.  Vibrio anguillarum is discharged into waters
with waste material and is nourished by  the  waste  in  waters  where
temperature  exceeds  10°C.  Researchers noted that, "current disposal
practices, in light of the growth of Vibrio  anquillarum  under  these
conditions,  may  be  assumed to  create hazards to fish and susceptible
marine fauna" (Appendix D-2, page 2).

C.  Kenai

The  Kenai  study,  like  the  one  at  Cordova,  was   a   first-time
undertaking.    In  examining the Kenai area, the intent was to observe
the effects of waste discharges on a marine environment different from
the other two Alaskan sites  (i.e., Dutch Harbor and Cordova) in  terms
of  processing  operations  and  hydrological conditions.  Unlike these


                                 27

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Figure 10:  Accumulation of crab shells, Cordova, Alaska.
                                    28

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                «/ ^""fj*
               "T. ~t t^l




Figure 11:  Salmon & crab waste below processing facility, Cordova, Alaska.
                                       29

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other processing sites, the  four  processors  at  Kenai  are  several
hundred  meters  apart  and  discharge into fast-moving waters (Figure
12).

Generally, tests showed water quality in this area to be unaffected by
processing waste discharges.  Surface dissolved oxygen values  at  all
sampling  stations  were  at  or  near saturation.  Among the selected
indicators, only salinity varied substantially and this variation  was
linked to changes in tidal and current flow.

Researchers   did   observe   some   water  discolorations  and  waste
accumulations at one processor's two outfalls.  In one instance,  this
was because waste was discharged above the low-water level (Figures 13
and  14);  in  the  other,  the processor was simply discharging waste
beneath the plants' dock.  In both cases, the combination  of  current
movement and tidal fluctuation flushed the river sufficiently each day
to disperse these deposits.

Nutrient  concentrations  in the Kenai River were very low; variations
among them were negligible and, in many cases,  the  concentration  of
several nutrients was below minimum detection levels.

The  benthic  community  here  was  poorly  developed;  however, waste
discharges were apparently  not  responsible  for  this.   Researchers
concluded   that   sediment   type,   tidal  scourings,  and  salinity
fluctuations are factors  which,  most  likely,  have  influenced  the
sparse development of aquatic organisms.

The   U.S.  Fish  and  Wildlife  Service,  in  pointing  out  possible
shortcomings of both the Kenai and  Cordova  investigations,  believed
the  studies  were  too  brief  and  localized  to  formulate definite
conclusions.  They suggested that long-term  ecological  trends,  away
from discharge sites, need to be monitored before ultimate conclusions
can  be  drawn.   They warned further that an escalation in processing
activity may result in   increased  ecological  impact,  and  cautioned
against  ignoring the effects of industry expansion (Appendix B-4).

D.  Yaquina Bay

As part of the Section 74 study, EPA initiated an investigation of the
biological,  sediment, and water conditions near processor outfalls  in
Yaquina Bay, Oregon  (Figure 15).  Processing operations in  this  area
are  substantially  similar  to  those   in  Alaska  except  that these
processors all employ screens to remove  solids  from  waste  effluent
before  discharge.   In  a  broad  sense,  this  study was  intended  to
provide  a  comparison between the Alaskan sites which receive untreated
waste, and waters which  receive a screened or treated effluent.

For the most part, researchers  found that processing effluent   effects
on  water  and  sediment quality in Yaquina Bay were restricted to the


                                 30

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                      Marth
KENAI RIVER, ALASKA
                                         Manh
                                                                                     YDS
                                                       INSET A
                                                       Kanai Ri*«r Stmpllni Station* Off Kanai P»di«n CanMfy
                                                                                    Mkrth
                                                       INSET B
                                                       Kcnal RiMr Samplinfl Station Off Columbia W»rd Fliharla*
                          Figure 12.   Location of sampling sites
                       in the  vicinity of the Kenai  River, Alaska.

-------
Figure 13:  Evidence of Seafood waste accumulations near seafood processor's out-
fall, Kenai, Alaska.
 Figure 14:  Accumulation of whole fish parts on Kenai River bank immediately
 downstream from cannery outfall.
                                   32

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            ASTORIA

     YAQUINA BAY
LLJ
O
o
O

u_

 O
 <
 Q.
      SCALE
           LOS  ANGELES
              HARBOR
  0 2550   10  160 miles
     Figure  15. Map  of  West Coast United States
              sampling  and study sites.
                           33

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immediate vicinity of processors'  docks.  The effluent plume was quite
turbid and contained high nutrient  concentrations.   Because  of  its
initial  low  salinity,  the effluent remains on the receiving water's
surface where it mixes rapidly with estuarine water and  is  dispersed
by  strong  tidal  currents.  The quality of water at the bottom along
the immediate outfall areas was similar to that of other areas in  the
bay.   Dissolved  oxygen  concentrations  at  both the surface and the
bottom approached, in all cases, saturation.

In  this  area  researchers  found  a  diverse  and  abundant  benthic
community,   the  presence  of  which  they  attributed  to  screening
practices and rapid current movement.  The rapidly flowing current did
not allow larger, incidentally unfiltered waste particles to amass  on
the  bottom  and  smother  benthic  life.  Television observations and
dredged samples confirmed the effectiveness of wastewater screening in
this area, and they revealed no accumulations of shells or other waste
material.

Researchers also noted that their findings in  Yaquina  Bay  resembled
those  of  Beyer,  Nakatani  and  Staude  (1975)  during  a  study  of
environmental  conditions  near   salmon   processors'   outfalls   in
Petersburg,  Alaska.11  Dissolved  oxygen concentrations were close to
ambient values; turbidity was high in the immediate outfall area.  The
chief difference between the two areas was that  Petersburg  effluents
were  unscreened, and their discharge produced temporary accumulations
of fish parts.

To an extent, current movement mitigated the effects of waste build-up
in the Petersburg area; but at the opposite extreme,  in  cases  where
solid  waste  is  discharged  into confined waters, the effects can be
disastrous for benthic life.  In a 1959 study of  Los  Angeles  Harbor
and  Newport  Bay,  California, where waters are relatively quiescent,
Reish12 and Barnard and  Reish13  found  that  Capitella  capitata,  a
widely  recognized  pollution  indicator  species,  accounted  for  90
percent  of  the  benthic  population.   In  the  Yaquina  Bay  study,
Capitella  capitata  comprised  only 7 percent of species' population,
which led researchers to  conclude  that  no  "significant  ecological
alteration is indicated by the presence of an opportunistic species in
the   midst  of  such  an  abundance  and  variety  of  other  benthic
invertebrates" (Appendix C-l).

Although pelagic  (i.e., migratory) species were found in the  vicinity
of  processors'  outfalls, their presence does not indicate that waste
discharges are an integral part of the food  chain.   Aside  from  the
fact that the Yaquina Bay study was a short-term one, during which EPA
did  not monitor species' movement, EPA recognizes that as a transient
species, the fish feeding near the discharge area  would  likely  feed
elsewhere should the attractant cease being available.
                                 34

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E.  Pathogenic Bacteria Study

In  conjunction  with Section 74 studies at Dutch Harbor, Cordova, and
Kenai, University of Alaska scientists attempted to isolate pathogenic
bacteria of  the  genus  Vibrio  from  sediment  samples  obtained  at
processing  waste  disposal  sites.   They also attempted to determine
whether or not certain pathogenic bacteria would utilize crab waste as
a nutrient source in sea water with temperatures  approximating  those
found at the disposal sites.

Temperature  and  nutrient  availability  are  the chief factors which
either permit or prohibit  bacteria  growth.   Vibrio  parahemolyt i cus
could  use crab meal as a nutrient source, producing growth at 25° and
37°C, but not at 5° or 10°C.  It does not appear to be a health hazard
in  receiving  waters  where  temperature  remains  below  10°C.    As
mentioned  previously, Vibrio anquillarum, a similar parasitic strain,
was isolated from one Cordova sample.  It appears capable  of  feeding
on crab meal and propagating at 5°C.

The  researchers  note  that  current  disposal  practices may lead to
hazards to fish and other fauna which may be vulnerable to Vibrio.

4.  LOS ANGELES HARBOR STUDY

Four fish canneries located in Terminal Island,  California  for  many
years  have  discharged  wastewater  to  Los  Angeles  Harbor.   These
discharges have been associated with water quality  problems  in  this
area.   State and Federal efforts to clean up the harbor have resulted
in progressive improvements in waste treatment by the canners.   Prior
to  1974,  the canners practiced only minimal waste treatment..  During
the period from January 1974 to September 1975, the canners  installed
dissolved air flotation (DAF) systems to provide primary treatment and
in  1978  the  cannery  effluents were diverted to the newly completed
Terminal  Island  Treatment  Plant   (TITP)  which  provided  secondary
treatment of the wastes.

The  corpus  of  material  currently  referred  to as the '"Los Angeles
Harbor Study" has an extensive  and  somewhat  complex  history.   The
University of Southern California Harbors Environmental Projects  (HEP)
has  been  conducting studies of the Harbor since 1971.  These studies
began as an attempt to develop a baseline inventory of the biology  of
the  Los  Angeles Harbor area (Figure 16) and have been supported over
the years by a variety of sources, including the  tuna  industry,  the
City of Los Angeles and the U.S. Office of Sea Grant Programs.

The  HEP  work has resulted in two different study documents submitted
to EPA concerning the effects of seafood processing discharges to  the
Harbor.  The first, entitled "Marine Studies of San Pedro, California,
Part  12, December 1976," was submitted in 1976 in support of the tuna
industry's application for an exception to  the  requirements  of  the


                                 35

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                                              SOU II HILtS
                                         1978 SURVEY STATIONS
Figure 16, Location of  Survey  Stations
 in the 1978 Los Angeles Harbor Study.

-------
California   Bays   and   Estuaries   Policy.   The  second  document,
"Ecological Changes in Outer Los Angeles-Long Beach Harbors  Following
Initiation  of Secondary Waste Treatment and Cessation of Fish Cannery
Waste Effluent" (also known as Part 16 of the Marine  Studies  of  San
Pedro Bay) was submitted to EPA in 1979 to be evaluated as part of the
seafood study conducted under Section 74.  These two, Part 12 and Part
16, documents are discussed separately below.

A.  The Part 12 Study

The Part 12 study was completed by HEP in 1976 and  was  submitted  to
EPA by the Terminal Island canners in support of their application for
exemption  from  the requirements of the California Bays and Estuaries
Policy (BEP).  The BEP is  an  approved  State/Federal  Water  Quality
Standard, pursuant to Section 303 of the Clean Water Act, and provides
that  all municipal and process wastewater discharges "shall be phased
out at the earliest practicable date," unless it can be shown  that  a
discharge  is  non-toxic  and  "enhances" the quality of the receiving
water.  Unfortunately, a  definition  of  "enhancement"  of  receiving
waters  was  not  specified  by  the  BEP.  Toxicity test criteria are
specified and require that undiluted wastewaters be  used  in  96-hour
bioassay  tests  using standard test species, resulting in a specified
percent survival rate for the test species individuals.   In  summary,
the  BEP  sets forth two criteria (enhancement and non-toxicity) which
must be met to permit continued discharge of wastewaters.

The Part 12 document, which was reviewed in the  context  of  the  BEP
provisions,  was  the result of work by various HEP personnel over the
period from 1971 to 1976.  This document consisted of  seven  separate
papers  tied together by a summary.  The research areas covered by the
papers included feeding habits of marine organisms, species population
studies, measurements of proteins and amino acid levels in the Harbor,
mathematical modeling of dissolved oxygen (DO) levels in the water and
toxicity bioassays.

The investigators proposed the term "bioenhancement" as a  measure  of
the  enhanced  biological  quality  of receiving waters.  Although the
study did not formally define this  term,  the  investigators  assumed
that  any  increase  in  biomass  is  improvement  and  measure "total
biomass" as an indicator of bioenhancement.   The  basic  premises  of
bioenhancement  are  that the cannery process wastes (characterized as
high in BOD,  proteinaceous  suspended  solids  and  oil  and  grease)
provide  nutrients  necessary  to  the  sustenance  of  a  large  fish
population in the harbor.

The general consensus of the various papers  in the study was that  the
Harbor could be divided into three zones of biological activity:

1)  The area immediately in contact with the effluent  discharge  (the
"zone  of  mortality");  this area showed low biological diversity and


                                 37

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productivity, high BOD and low DO.  It  was  in  this  area  that  the
effluents showed greatest toxicity.

2)  The area where the effluents had been more thoroughly mixed;  this
area  was  an  area  of  higher population value and a greater species
diversity  than  the  first.    This  "zone  of   bioenhancement"   was
attributed to the nutrients from the waste.

3)  The outer area of the harbor which was less directly  affected  by
the effluent loading in the harbor due to the greater proportional mix
of water to effluent.  Population values in this area were in the mid-
range of those in the other two areas.

The  authors  of  the  study  contended  that  the installation of DAF
treatment systems by the canneries (in 1974) had sufficiently  reduced
the  loadings  of  oxygen-demanding  wastes to ensure that the massive
fish kills that had happened in previous years would no longer  occur.
Further,  the  authors  contended that, through the use of the study's
dissolved oxygen model, the amounts of oxygen-demanding  wastes  could
be optimized to allow maximum bioenhancement without adverse results.

Review by EPA

This study was determined in 1977 by EPA to be insufficient to support
a  finding  of enhancement of the Harbor by the DAF-treated effluents.
The document was reviewed by a variety of EPA personnel which concerns
are delineated below:

1)  Methodology and Approach

The study presented no  baseline  data  concerning  the  Harbor  water
quality   and  species  characteristics  before  commencement  of  the
discharges.  Without such data for comparison purposes, there  was  no
basis to conclude that the Harbor had been enhanced by the discharges.
The  reviewers  felt  that  the  baseline data problem could have been
mitigated to some extent through the use of control data collected  at
a  nearby  unpolluted  site, rather than rely on data from outside the
Harbor breakwaters where there was little similarity to  the  interior
of  the  Harbor  in  terms  of  hydrographic conditions and indigenous
species.

2)  The Bioenhancement Conclusion

The authors of the summary for the Part 12 document concluded that the
harbor  (in 1976) was in a  state  of  bioenhancement  because  of  the
cannery  effluents.   However,  this strong conclusion contrasted with
the tentative results presented by the various authors  of  the  seven
individual  study papers who were more cautious and whose statments of
results frequently contained such qualifiers as "appears to", "maybe",
and "perhaps." In addition, the assumption  that an  increase in biomass


                                  38

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is beneficial must include a caution that there are also various well-
known adverse effects commonly occurring in nutrient-enriched systems.
These adverse effects are evidenced by increased  disease  among  fish
populations,  the  proliferation of pollution-tolerant species and the
potential for increased accumulation of toxic  substances  through  an
enriched food chain.

3)  Management of Waste Discharges

The Part 12 study contained a proposed  oxygen  model  for  use  as  a
management  tool.   From  the  model an optimum nutrient optimum level
could be calculated for the Harbor.  EPA review of the model  revealed
that  the  model  could  not  accurately simulate the Harbor even at a
steady state, or be able to predict  accurately  the  consequences  of
variations in nutrient discharges.

4)  BEP Toxicity Criteria

As noted earlier, the BEP set criteria which provide minimum  toxicity
standards  to  be  attained  by an undiluted wastewater discharge as a
necessary requirement for a finding of enhancement.  For the  Part  12
study  the  HEP  researchers  used  diluted  effluents for most of the
bioassays rather than the usual undiluted  effluents.   However,  even
the  diluted wastewaters (collected from the outfall boils) were found
to be highly toxic to the test organisms.  This result  was  a  strong
indication  that  the  wastes  did not enhance the harbor's water (See
Appendix E).

To conclude, the Part 12 study  did  not  lend  much  support  to  the
assertion  that  bioenhancement was occurring in Los Angeles Harbor in
1976.  Unfortunately, to a great extent the information  contained  in
the document showed considerable evidence of damage to the harbor.  Of
particular  note  was  the existence of a "zone of mortality" near the
discharges and  the  increased  incidence  of  fish  disease  and  the
toxicity of the effluents.

B.  The Part 16 Study

As described earlier, the Part 16 study was submitted to EPA  in  1979
.to  be evaluated as part of the work conducted under Section 74 of the
Clean Water Act.   The  report  contains  data  collected  by  various
researchers during the years 1971 to 1978 when the canneries gradually
upgraded  waste  treatment  practices  to  DAF  (in 1974 and 1975) and
finally to the secondary treatment provided by the TITP.

This work expands upon the hypothesis presented in the Part 12  study;
the  cannery  wastes  supply  nutrients  necessary  to sustain a large
marine population in the harbor.  The study  contains  data  on  fish,
benthic, plankton and bird populations.  The authors conclude that the
maximum  bioenhancement  occurred  before the canneries improved waste


                                 39

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treatment practices by installing DAF  treatment;  according  to  this
view,  the  upgrading  of waste treatment has caused a decrease in the
enhancement effect.  This is different from the earlier Part 12  study
where  the  improved waste treatment was viewed as necessary to reduce
oxygen demand and stress in  the  Harbor.   The  Part  16  study  also
differs  from  the  earlier  study  in  that  the newer study does not
address the polluted "mortality zone" in the vicinity of the outfalls.

Similar to the Part 12 study,  the  Part  16  study  proceeds  on  the
assumption  that  an  increase  in biomass is improvement and measures
numbers  of  species,  numbers  of  organisms  and  total  biomass  as
indicators  of  bioenhancement; the type of organisms prevalent (i.e.,
pollution-tolerant species) and  measurements  of  water  quality  (DO
levels) are of lesser importance.

Review Board

In  order to conduct a thorough and unbiased assessment of the Part 16
study, EPA requested review help from a number  of  different  Federal
and  State of California agencies.  The agencies were asked to provide
scientists knowledgeable in  marine  studies  and  familiar  with  Los
Angeles  Harbor  who  could  comment  on  the  Part 16 study approach,
methodology  and  conclusions.   The   review   panel   consisted   of
representatives  from  the National Marine Fisheries Service, the U.S.
Fish and Wildlife Service,  the  California  Water  Resources  Control
Board, the California Department of Fish and Game, and the Los Angeles
Regional Water Quality Control Board as well as the EPA.

Review Board Findings

The reviewers criticisms were similar to EPA's original concerns about
the Part 12 study.  The major concerns are delineated below:

1)  Methodology

The reviewers were concerned that a lack of comparative  control  data
which  might  characterize a healthy harbor without cannery discharges
would render the conclusions based on the data collected  speculative.
Another methodology problem cited was the failure to consider physical
water  quality data during the study; the cleanliness of the water and
the  oxygen  availability  should  have  been  part  of   the   marine
assessment.   Other  factors which should have been considered  include
long-term fish population  cycles,  weather  patterns,  other  nutrient
sources  to  the   harbor,  and variable  field conditions during sample
collection  (i.e.,  salinity, air  and water temperature, etc.).

2)  Data Collection and Results

Although the data  collection  methods  used   in   the  study  were  not
clearly  explained,   it  was  apparent   to  the  review scientists that


                                  40

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collection methods used to sample fish  and  bird  populations  varied
extensively  from  year  to  year.   This inconsistent data collection
makes it very  difficult  to  determine  whether  observed  population
changes are due to effluent discharge changes or to the differing data
collection techniques.

The  reviewers  were seriously concerned there were not enough data to
support any conclusions regarding population trends.

3)  The Bioenhancement Conclusion

Because of their concerns about methodology and data,  most  reviewers
were  not  convinced that cannery wastes promoted the growth of marine
species  populations  in   Los   Angeles   Harbor.    Even   if   some
cause-and-effeet   relationship  could  be  demonstrated  between  the
effluent discharges and the numbers of organisms present in the  "zone
of  enhancement",  the  reviewers disagreed that increased populations
represented "enhancement."

Several reviewers felt that the surveys  reflected  an  attraction  of
fish  from the far side of the Harbor to the area where effluents were
discharged rather than enhancement.

Also, the reviewers felt  that  even  if  the  data  reflected  actual
population increases, there was little indication that these increases
were beneficial to the area.  The majority of the increases attributed
to  untreated  cannery  wastes (i.e. prior to advanced treatment) were
reported for such  species  as  bacteria,  bottom-dwelling  worms  and
scavenger fish (such as the white croaker); the proliferation of which
would not be considered enhancement.

The  following  section  briefly presents some of the specific Part 16
study findings by section along with pertinent review board comments.

C.  Part 16 Findings and Review Board's Comments

    1.   Fish Populations.

    a.   Part 16 Findings

    According to trawl surveys in the outer areas of Los  Angeles  and
    Long  Beach Harbors, the fish population dropped four-fold between
    1973 and  1978,  while  party-boat  catches  outside  the  harbors
    doubled.   Two  fish species, reported to be the most common, were
    noticeably affected:  white croaker and  anchovy.   White  croaker
    population,  previously  the  fish  caught  most  often  by  shore
    anglers, dropped between 10 and 20-fold.  Anchovy population  fell
    100-fold.    A   survey  of  fishermen's  catches,  taken  by  two
    California Department of Fish and Game (DFG) personnel at  various
    locations  around  the  harbor, indicated that fish population was


                                 41

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greatest in the area of the TITP  sewage  outfall.   HEP  believed
this  to  be  the  only  remaining  area  in  the harbor with high
nutrient concentrations.
                •
b.   Review Board Comments

The California Department of Fish and Game  (DFG)  commented  that
trawl  surveys  reflect  merely incidental catches, and not actual
populations.  They also felt sampling techniques  and  efforts  in
collecting data were inadequate (Appendix E-4).

The  DFG  cited as a further criticism the lack of supporting data
or  consideration  of  other  factors  such  as  salinity,   water
temperature,  and  other  physical/chemical tests which would have
allowed a comparison of population dynamics inside and outside  of
the harbor  (Appendix E-4).

The  U.S.  Fish  and Wildlife Service (USFWS) noted that the trawl
survey lacked a  control  standard.   To  compensate,  they  claim
researchers  should have incorporated into the study findings from
other pertinent research programs  (Appendix E-6).

The USFWS commented also that the seasonal trend of fish abundance
inside the harbor, with or without  cannery  discharges,  has  its
peak  in  the  summer,  which  coincides  with pertinent discharge
events.  Thus, the USFWS believed that, since the two  events  are
concurrent,  the  role  of  waste  discharges  in determining fish
population remains unknown.  The  USFWS  also  pointed  out  that,
because  the original decline in fish population predated upgraded
treatment, th.e drop-off cannot be solely the  result  of  effluent
changes  (Appendix E-6).

The National Marine Fisheries Service (NMFS) noted that while some
differences  exist  in  pre-  and post-cessation survey results of
fish populations, these  cannot  be  entirely  attributed  to  the
removal   of  untreated  waste  from  the  harbor.   Many  factors
influence   fish  distribution  and  population,  notably,   yearly
species   failures   and  fishing  pressure.   The  census,  which
supposedly  showed diminished success of shore anglers, may have in
fact  shown  a  dispersal  of  fish  because  no  attractant   was
available.

The  DFG  noted  that the disparity which exists between off-shore
(fourfold decrease) and harbor (100-fold decrease) anchovy density
is not,  necessarily, reflective of changes in  the  harbor.   Data
collected by the DFG in 1976 indicated that a reproductive failure
caused   a   scarcity  throughout Southern California harbor waters.
This same type of reproductive failure could  easily  account  for
the  depleted  juvenile anchovy population in the harbor  (Appendix
E-4).


                             42

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The entire review panel agreed that the  fish  population  studies
were  inconclusive.   They  stressed,  as  major considerations in
their  determination,  a  lack  of  references  to  other  sources
(Southern California Edison - Long Beach Report and USFWS Studies)
which  have indicated a growth in fish population since 1978.  The
reviewers conjectured that the Part  16  fish  population  studies
reflected  merely  a  redistribution  of  fish  within  the harbor
because waste outfalls  had  been  cut  off  and  were  no  longer
offering an attractant source to the fish (Appendix E-7).

2.   Bird Populations.

a.   Part 16 Study Findings

Observations  in  the  harbor area indicated that bird populations
were approximately 40 percent lower than the 1973-1974 level.  The
changes were noted during the fall  and  winter  months  when  the
staff made a majority of the observations.

According  to  the  survey,  the gull species, sighted most often,
decreased more than any other (nearly three-fold).  Several  other
species were scarcer; however, the endangered Least Tern and Royal
Tern increased between 1973-1974 and 1978.

Researchers  speculated  that changes in bird populations may have
resulted, wholly or in part, from the removal of floating  solids,
or  from  there being substantially fewer anchovies in the harbor.
In either case, researchers believed bird populations were altered
by the absence of a food source.

b.   Review Board Comments

The DFG believed that without data from years  between  the  1973-
1974  survey and the 1978 survey, bird population trends could not
be  characterized  accurately.   They  commented  that  the  avian
population  was  healthy  and  stable,  and that, with fewer gulls
preying on the eggs of the Least Tern, the Least  Tern  population
increased (Appendix E-4).

The  USFWS commented that the drop in the number of gulls, who are
known scavengers, may have been  a  result  of  the  cessation  of
processing  effluent  disposal.   More  generally, the USFWS noted
that portions of the studies, especially the bird survey, lacked a
control-site (Appendix E-6).

3.   Phytoplankton Resources.

a.   Part 16 Study Findings
                             43

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    Phytoplankton*  productivity,   chlorophyll  a,   and   assimilation
    ratios  in  the  Los  Angeles   Harbor  area.were monitored before,
    during,   and  after  processing  wastes   were    given   secondary
    treatment.    Productivity  values  reflect  the  ability  of  the
    phytoplankton present to produce organic matter photosynthetically
    under ambient conditions.  Chlorophyll a values are a  measure  of
    the  size  of  the phytoplankton population present.   Assimilation
    ratios were calculated by  dividing  productivity  values  by  the
    chlorophyll a concentrations.

    Chlorophyll  a  values  showed that growth patterns were unchanged
    during  each  period.   This  indicated,  in  general,  that   the
    changeover   to   secondary   treatment   had  not  disrupted  the
    phytoplankton  population.   But  productivity   and   assimilation
    ratios  were greatly reduced,  presumably as a result of inhibition
    by  predator  species,  or  a  loss  of  nutrients  (which  limits
    phytoplankton's ability to photosynthesize).

    b.   Review Board Comments

    The  DFG  was  concerned  that HEP did not include in their report
additional data concerning phytoplankton and zooplankton resources  in
the  inner Los Angeles Harbor area.  The information is available in a
report prepared by  consultants  to  the  Southern   California  Edison
Company.   The  report  addresses  results stemming from environmental
monitoring similar to that which HEP used in assessing changes  in  an
environment resulting from a warm water point-source discharge.

    4.   Zooplankton Resources.

    a.   Part 16 Study Findings

         The  study  found zooplankton** resources were least affected
    by the treatment alterations.   Much of it  circulates  with  tidal
    fluctuations  and  is  not  capable  of  moving  about  of its own
    volition.  Because fewer  fish  were  preying  on  the  organisms,
    species  diversity   increased,  though  the  number  of  organisms
    present varied greatly.  Researchers noted that species  diversity
    had   increased,   most   likely,  because  of   the  reduced  fish
    population, and not because the ecosystem had been enhanced.

    Other samples indicated  zooplankton were present in large  amounts
    only  outside  the   harbor  and  near  the  TITP  outfall,  a fact
    accounted for possibly by  a  reduction  in  nutrients  elsewhere.
*phytoplankton - passively floating or  weakly  mobile  aquatic  plant
    life.
**zooplankton  -  microscopic  animals  that  swim  weakly  or   float
    passively in water currents.


                                 44

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    Researchers  noted that species'  composition altered, indicating a
    response to treatment conversion.

    b.    Review Board Comments

    The review panel found that the data  presented  was  inconclusive
    and  that  no significant effects evidenced.  The changes observed
    were within the bounds of natural variability (Appendix E-7).

    While the report mentioned that the density  of  fish  eggs,  fish
    larva,  and ichthyoplankton* was substantially greater in 1978 than
    1974,  reviewers  felt researchers did not consider a more obvious
    possibility:  that the  conversion  to  secondary  treatment,  not
    reduced   predation   by  fish,  may  have  been  responsible  for
    eliminating the stress on these resources.  Bioassay results  from
    the Part 12 Study support this explanation (Appendix E-7).

    Comments on the phytoplankton section were that the HEP report did
not include the data from the Edison report (Appendix E-7) in carrying
out the study.

    5.    Benthic Resources.

    a.    Part 16 Study Findings

    Since  1976,  the  principal  trends seem to be, first, a sizeable
    decrease in the benethic (bottom-dwelling) population,  especially
    among  the  usually abundant species, and second, a decline  in the
    variety of species.  The distribution of the benthic organisms did
    not change appreciably from 1975 to 1978.

    Samples taken by HEP's research vessels  in  October  1978   showed
    faunal  (animal  organisms) changes both inside and outside  of the
    harbor.  Contrary to expectation, the drop in predator  population
    did  not produce an increase in diversity or population of benthic
    organisms.  (Other studies  have  shown  benthic  worms  to  be  a
    principal  food  for  bottom fish, crustaceans, birds, and others.
    It had been postulated that  a  variation  in  benthic  population
    would produce a corresponding change in predator population).

    b.    Review Board Comments

    The  entire  review panel agreed that, though this section was the
    study's strongest, the data was insufficient to use as a basis for
    speculating on factors influencing fish population.
*ichthyoplankton - microscopic fish which move  passively  in  aquatic
    ecosystems.


                                 45

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    The USFWS commented that the data seemed to indicate  the  benthos
    was  influenced more significantly by unnatural conditions (waste)
    than by natural ones (tides).  In particular,   the  study  clearly
    indicated  a  zone  of  mortality near the outfall, the effects of
    which must be weighed against any enhancement claim.

    A reviewer from EPA's  Corvallis  laboratory  commented  that  the
    description  of  survey  and experimental methods were incomplete.
    Missing are details describing  sampling  apparatus,  grab  sample
    sizes,  and  the number of replicates at each station.  The report
    also does not offer a statistical analysis of the benthic data; it
    is  restricted  to  graphs  of  temporal  patterns   and   benthic
    densities.   Only  the  dominant  species  at  a  few stations are
    identified (Appendix E-5).

    The Part 12 and 16 studies and review comments  are  presented  in
    Appendix E of this report.

5.  EPA SITE VISITS

In  an  effort  to address the Section 74 mandate more completely, EPA
supplemented its water quality studies  and  the  industry-funded  Los
Angeles  Harbor  Study  with  site  visits.  EPA representatives noted
waste treatment practices, and documented obvious visible  effects  of
waste  disposal  on  receiving  environments  in  several major United
States seafood processing areas  (e.g., New England,  Mid-Atlantic  and
Southeast  Coasts,  and  the  Gulf  Coast).   Though  the discharge of
untreated waste is restricted primarily to Alaska, several  processing
facilities  in the contiguous states discharge amounts of fish oil and
shellfish waste that the receiving environment  may  be   incapable  of
assimilating.   EPA  representatives  noticed that in some cases, even
where waste was being screened, solids build-up in waters with  little
flushing  action  seemed  excessive.  But without sampling the precise
effects  of  these  conditions  on  receiving   environments   remains
undetermined.

Depending on the type of seafood processed, and on the location of the
plant,  wastewater characteristics and applicable treatment technology
vary.  Waste treatment and disposal practices are governed by Federal,
State and/or  local  restrictions  as  well  as  the  utilization  and
disposal options afforded by the geographical location.   Maine sardine
canneries,  for  example,  have a relatively low volume of wastewater,
but their discharge usually contains high levels of oil and grease and
BOD.  Sardine waste solids generated by  screening  does  not  pose   a
disposal  problem.   It  may be  used, for instance, as lobster bait or
sold to a reduction facility for the  production  of  fish  meal.   In
contrast,   shrimp   processors   along  the  Gulf  Coast  generate   a
substantially greater volume of wastewater, usually with  a  high  BOD
level  and  a significant amount of shell fragments.  Shrimp heads and
hulls, depending on a plant's proximity to potential  disposal  sites,


                                 46

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may  be  used as fertilizer, dried for use as an animal feed additive,
or simply buried in a landfill area.  As a  general  rule,  processors
look for the most direct and economical means of disposal.

A.  New England

Although   previous   EPA  work  has  characterized  sardine  effluent
discharges in some detail, no precise, comprehensive  studies  of  the
Maine  Coast  have been done to determine the impact of these effluent
discharges on receiving waters.  Sardine cannery discharges  generally
have  profuse  amounts  of  fish  oil  in them which, after discharge,
covers the surface of the receiving water.  Much of this oil and other
floating materials have been minimized by the installation of  screens
and  oil  separation  units,  but  in  some  areas,  effects  of these
discharges are still noticeable.  Solids generated  by  screening  are
either  sold  to  local  lobstermen as bait or to a reduction facility
where they are processed into fish meal and oil.

B.  Mid-Atlantic and Southeast Coasts

Processors on Key West  and  Stock  Island  (Florida)  process  mostly
shrimp,  along  with  moderate  amounts of lobster, crab, and finfish.
Shrimp heads and hulls are the most prevalent type of waste generated.

Coastal waters around Key West and  Stock  Island  receive  discharges
from  a number of sources in addition to seafood processors, including
sewage treatment plants and power plants, along  with  commercial  and
private boats.  The surface of the waters near seafood waste discharge
points appear murky and oily, and contain some floating debris.  While
seafood wastes are not entirely responsible for these conditions,  they
are contributing to the continuous degradation of the waters.

Further  north,  the  Georgia  Department  of Environmental Protection
(DEP) has recently required a major processor on the Georgia coast  to
achieve  85  percent  BOD removal prior to discharging its wastewater.
To  do  this,  the  company  has  installed  dry  cleanup  procedures,
screening,  and has begun discharging a portion of its wastewater  into
the local, publicly-owned treatment works where secondary treatment is
provided.  Prior to these control measures, wastes had been discharged
into a shallow ship  slip,  an  area  that  receives  little  flushing
action.   Shells  accumulated  during  this  period, which resulted in
numerous complaints about the pungent odor emanating from the decaying
material.  As another of the renovations, the company  has  moved  its
waste outfall into deeper water.

This   processor   has   expressed  dissatisfaction  with  the  strict
enforcement of water quality standards by the Georgia DEP,  but  state
officials  maintain  that  water  quality  standards  are necessary to
ensure  the  continued  well-being  of  coastal  waters  which   yield
harvestable species, including shrimp.


                                 47

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C.  Gulf Coast

There  are  approximately  15  to  20 shrimp canneries along the bays,
rivers, and bayous of the Gulf Coast.  Also in this area are a  number
of shrimp freezers and oyster processors.

Because  of  the  diversity  which  exists  among  plant locations and
receiving waters here, it is difficult to give a detailed  account  of
waste  disposal  problems.  Almost all wastewater emanating from these
facilities has a high BOD level.  Receiving waters in some  areas  are
stagnant  and  murky;  in  other  areas, currents are strong enough to
dissipate wastes.  Heavy solids (i.e., shells) pose  a  major  problem
relative  to waste dissipation.  Although some drying of shrimp shells
is practiced, outlets  for  the  dried  by-product  are  difficult  to
identify.   In  the  event  that  landfills are also unavailable, some
processors have been permitted  to  discharge  solids  into  receiving
waters.   Industry  representatives acknowledge the need for continued
research to develop alternatives, but  claim  such  endeavors  require
investment capital which many processors presently cannot obtain.
                                  48

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                                  CHAPTER IV

                             TECHNOLOGY ASSESSMENT

To  present  a  more  comprehensive  image  of  the seafood processing
industry, and to comply fully with the Section 74 stipulation, EPA has
examined current seafood processing waste control practices,  as  well
as  those  which might be initiated to further reduce discharges where
ne'cessary.  EPA has  also  explored  waste  utilization  and  disposal
alternatives.   Generally,  these  involve by-product manufacturing or
disposal either on land or in the ocean.

With the exception of larger tuna and fish meal processing facilities,
the industry consists of many  small,  seasonal  operations,  most  of
which  process  intermittently  depending  on weather and raw material
supply.  Although some processors  make  an  effort  to  maximize  raw
material usage and minimize water and waste contact, most have adopted
rather limited and simple waste management practices.

Because  tuna processors approach complete raw material utilization by
year-round processing and by-product recovery, this segment should  be
assessed  separately  from  the  rest  of the industry.  Many of these
plants recover by-products on-site, thereby minimizing the  amount  of
waste  entering treatment facilities and, subsequently, marine waters.
At present, most  major  tuna  processors  have  wastewater  treatment
technology in-place.

Existing  waste management practices for the remainder of the industry
are limited.  Recovery  of  wasted  raw  material  and  more  complete
resource  utilization  depend  on providing processors with the proper
incentives,  (profitability) as well as identifying new by-products and
developing markets  for  them.   By-product  generation  can  increase
profits  by  reducing treatment costs and providing seafood processors
with additional earnings.

Some of the most applicable approaches to waste control  are  in-plant
modifications  to  reduce  the  amount  of wastes requiring treatment,
wastewater screening, and dissolved  air  flotation*   (DAF).   Seafood
processing  wastewaters  can  be  treated  biologically,  but the land
required for this technology precludes its widespread  application  in
.the industry.
*dissolved air flotation - a process in which air  is  compressed  into
the  waste  effluent,  mixed  to  super-saturation,  then  released to
generate minute air bubbles.  As bubbles rise, they  carry  with  them
waste particles which can then be removed.


                                 49

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1.   WASTE CONTROL AND TREATMENT

A.   In-Plant Controls

    1.    Non-Alaskan.

    For  the  tuna  industry, thaw water recycling systems and reduced
    water consumption in other processing areas are efficient me.ans of
    eliminating much wastewater.   Some  canneries  presently  recycle
    water   used   in   the   thawing  stage  which  helps  to  reduce
    significantly the volume of wastewater requiring treatment.

    In fish meal plants, preventing spills and  curtailing  water  use
    during  clean-up are ways in which wastewater generation and waste
    loads can be reduced.  Some plants have begun recycling water used
    to unload raw material from boats.  This  water  can  be  combined
    eventually  with  a more concentrated waste stream (stickwater) to
    form a salable by-product.

    For the remaining segments of the seafood processing industry, the
    general approach to proper waste  management  remains  consistent.
    The most effective in-plant measures for reducing waste discharges
    focus  on  controlling water use, limiting use of water for clean-
    up, and reducing the amount of raw materials  entering  the  waste
    stream.   Such  measures  result  in  reduced treatment costs.  In
    cases where by-products are  produced  these  measures  result  in
    additional income which can either partially or totally offset the
    costs associated with wastewater treatment.

    2.   Alaskan.

    Seafood  processors  in  Alaska have taken a much simpler approach
    toward  processing  waste  management  than  have  those  in   the
    contiguous  states.   Currently,  grinding  of waste materials for
    ocean discharge  is the most prevalent disposal practice.   Because
    it  is  so  convenient  and  inexpensive, ocean discharge provides
    little incentive for processors to employ in-plant controls.

B.   End-of-Pipe Treatment

    1.   Non-Alaskan.

    The most common  and  basic  end-of-pipe  treatment   is  screening,
    where  gross  solids  are  removed  prior  to  effluent discharge.
    Other,  more  advanced  technologies,  including   dissolved   air
    flotation,   biological  treatment   (i.e.  activated  sludge)  and
    filtration, are  available but are not widely used by  the  seafood
    processing industry.
                                  50

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    Except  for  major  tuna  and  fish  meal processors, the industry
    employs simple,  treatment technologies.   Screening, in conjunction
    with in-plant controls,  is the  most  affordable  and  appropriate
    technology for seafood processing plants which generate low-volume
    waste   flows   from   manual   operations   (hand-butchering  and
    filleting).  In  automated  (mechanical)  plants,  which  generate
    larger  volumes  of  waste,  dissolved air flotation systems may be
    used after screening.  Currently, dissolved air flotation is being
    used in a number of tuna canneries in California, Puerto Rico, and
    American Samoa.   Its effectiveness has also been demonstrated  for
    effluents  from  salmon  processing,  shrimp  canning,  and oyster
    canning.

    Catfish processing facilities, usually  located  inland,  can  use
    biological   treatment   systems  (e.g.,  aerated  lagoons)  where
    effluent can be stored and aerated until waste  constituents  have
    been  effectively  removed.   Land for such systems is more readily
    available than in the coastal areas.

    All of  these  end-of-pipe  technologies  have  been  demonstrated
    effectively in seafood processing plants both in the United States
    and abroad.

    2.   Alaskan.

    Alaskan   seafood   processors   practice   unsophisticated  waste
    treatment technologies.   Most plants  discharge  untreated  wastes
    (i.e., whole or ground waste solids) to receiving waters.  Several
    plants,  located  in processing centers, simply screen solids from
    waste effluent,  and transport them to a by-product manufacturer.

    A combination of factors, including  geographical  location,  land
    scarcity,  adverse  climate,  and  high  construction  costs makes
    treatment   technologies   more   sophisticated   than   screening
    inapplicable to Alaskan processing operations.

2.   SEAFOOD WASTE UTILIZATION AND DISPOSAL

A.   Sources and Alternatives

The  application  of  the  various  wastewater  treatment technologies
discussed above generates solid wastes.  The problem of  disposing  of
these  wastes,  especially shellfish wastes, has grown more serious in
recent years because of the increased processing of shellfish, and the
implementation of water pollution control regulations.  Although  most
seafood  processing waste is proteinaceous,  seafood processors are not
always equipped to make use of their waste because  it  is  often  not
profitable  to  do  so.   In the past, the industry has had convenient
disposal options (e.g., direct ocean discharge) which have discouraged
attempts to use the  waste  as  a  by-product.   Unfortunately,  these


                                 51

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convenient  disposal methods have adversely affected water quality and
marine life in some areas.   Only a very few  proposed  solutions  have
proved  to  be  both  economically  viable  and  environmentally sound
(Figure 17).

    1.   Non-Alaskan.

    Tuna canners have installed separate processing lines  to  produce
    petfood  from  fish  portions inappropriate for human consumption.
    In addition, they  also  collect  viscera  and  scraps  which  are
    subsequently processed into meal, oil and solubles.

    Tuna   processors  that  use  dissolved  air  flotation  to  treat
    wastewater  are  faced  with  the  problem  of  disposing  of  the
    resulting  sludge.   Currently,  the  sludge is landfilled but the
    possibility of using the sludge as an animal food additive (if  it
    meets  FDA  regulations),  or  as  a  lowgrade fertilizer is being
    explored.

    Production of fish meal from whole fish (menhaden  and  anchovies)
    generates  a  concentrated  waste  stream  called  stickwater.  At
    modern facilities, stickwater is mixed  with  unloading  water  to
    make  solubles.   This  product  can  be  used to enhance the meal
    product or it can be marketed separately.

    For  the  remaining  segments  of  the  industry,  prudent   waste
    management  requires increased utilization of solids gathered from
    processing  lines,  screens,  biological  treatment  systems,  and
    dissolved  air flotation systems.  These sources provide potential
    raw materials for animal feeds,  nutrient  products,  fertilizers,
    and other useful materials.

    Secondary  products, products suitable for human consumption which
    are not  integral to the production process, offer  an  opportunity
    for  seafood  processors  to  use  raw  materials more completely.
    Development of secondary products can generate  extra  income,  as
    well  as  reduce  the  amount  of  waste  requiring  treatment  or
    disposal.   The  feasibility  of  secondary  product   development
    depends   on   plant   location,   species   processed,  equipment
    availability, and market conditions.  It is noteworthy that as the
    cost of waste treatment  increases, so too does the  incentive  for
    secondary product manufacturing.

    In most  cases, secondary product manufacturing involves additional
    flesh    separation   after   primary  product  production.    Flesh
    separator  machines  are  available  for  finfish  and   shellfish
    processors  which  recover   37   to  60  percent  of  minced flesh.
    Compared to conventional finfish filleting techniques, which  yield
    only 25  to  30 percent, this  is a substantial reclamation.
                                  52

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                          PRIMARY
                          PRODUCTS
                          GROSS  SOLIDS
                          3 CONCENTRATED
                          WASTE STREAMS
                          SCREENED SOLIDS
DAF
TREATMENT
UNITS
BIOLOGICAL
TREATMENT
UNITS
                          DAF FLOAT
                                  SECONDARY
                                   PRODUCTS
                                                                                               BYPRODUCTS
                                                                                                                                  DISPOSAL
FISH STICKS, CftK£S, ETC-
SEPARATES ROE
F*SH PROTEIN SPREAD
POTENTIAL KICK SHADE PROTEIN
                                                                                         F(*H HEAL.
                                                                                         f is* FEEDS,
                                                                                                 GRIND a OISCHARGS
                                                                                                 tA«e erarasftL
                                                                                                 o«*> SEA DISPOSAL
                                                                                                       FSEO
                                                  \
                            FABRICATED MEAT PRODUCTS
                            CLAM JUICE PRODUCTS
                            DRY FLAVOR INGREDIENTS
                            CONCENTRATED BROTH
                                   MEAL PRODUCTS
                                   FERTILIZER
                                   AQUACULTURE FEED SUPPLEMENT
                                   ANIMAL FEED
                                   CHITIN/CHITOSAN
                                   PEPTONES FOR MICROBIO. MEDIA
                           r\
                                                                                                                           GRIND 8 DISCHARGE
                                                                                                                           LAND DISPOSAL
                                                                                                                           DEEP SEA DISPOSAL
/
                                                                                             MC*U,OIU, SOUIBtES
                                                                                      ^       C
                                                                                        *>• - -^
                                                                     l.ft«> OtSPOSAL
                                                                         S€A OlSPOSAL
                                                                                     \
                                                               MEAL PRODUCTS, FERTILIZER
                                                               AOUACULTURE FEED SUPPLEMENT
                                                               ANIMAL FEED
                                                               CHITIN/CHITOSAN
                                                                                                                           LAND DISPOSAL
                                                                                                                           DEEP SEA DISPOSAL
                                                            C
                                                           -^
                                                                                         (SUBJECT WFOA Af>l>«eVAU
                                                                                     \
                                                               ANIMAL FEED ADDITIVE
                                                               (SUBJECT TO FDA APPROVAL)
                                                               FERTILIZER
WASTE ACTIVATED SLUDGE
                                                            /  SOU. AMENDMENT
                                                               ANIMAL. FEED
                                                                                                                           LANDFILL
                                                                                                                           AGRICULTURAL SPREADING
                                                                                                                           $«IL ENRICHMENT
                                                                                         SOIL AMENDMENT
                                                                                         ANIMAL FEED
                                                                                                 LANDFILL
                                                                                                 SOIL ENRICHMENT
                                    Figure 17,   Options for  disposal/utilization  of
                           wastes  resulting from implementing waste management practices.

-------
In addition to flesh recovery processes, liquid secondary products
can also be recovered from isolated waste streams.  The Sea  Grant
Institution has recently investigated the development of a product
similar  to  clam juice from minced clam washwater and found it to
be  economically   advantageous.     Researchers   also   noted   a
significant  concurrent  reduction  in  the  plant effluent's BOD5
waste load.

Solids not converted into secondary products or  by-products  must
be  disposed  of  on  the  land  or  in  the ocean.  Land disposal
requires that a suitable site be available  where  seafood  wastes
may  be  incorporated  into  the  soil to enhance nutrient levels.
While this method does not yield a profit, to date processors have
elected to bury wastes  in  a  landfill  as  a  means  of  simple,
economical disposal.  In the future, processors may be required to
seek   other   disposal   alternatives   because   landfills   are
increasingly less available because of  local  public  health  and
odor problems.

2.   Alaskan.

Waste  categorization  and disposal options for seafood processors
in  Alaska  are  more  limited  than  in  the  contiguous  states.
Landfills  are  unavailable  for  seafood wastes, leaving only by-
product manufacturing and ocean disposal as  alternatives.   Given
the  potential  for  environmental  problems created by near-shore
ocean disposal, barging seafood wastes to  off-shore,  deep  water
sites  remains  an acceptable disposal alternative for the seafood
industry.  In addition to barging, by-product manufacturing is  an
environmentally  acceptable  option.   However,   it is less easily
accomplished in Alaska than in the contiguous states.  This method
represents the most environmentally sound manner  of disposing with
solid waste because, first, it eliminates the discharge  of  large
volumes  of wastes into the environment and, second, it transforms
waste material into a marketable commodity.  At the present  time,
by-product  facilities  are  being operated in three Alaskan areas
(Kodiak, Petersburg and Seward) to produce fish   meal,  fish  oil,
and/or shellfish meal.

Fish  meal,  made  from  fish  processing  waste  (salmon, herring,
bottom fish), may be used, among other things, as a protein source
in animal  feeds.   However,  national  demand  for  fish  meal  is
currently  quite  low.    (It accounts for less than one percent of
the total  processed feeds produced  in  the  United  States.)    Its
chief  competition  is  soybean  meal;  others  are oil-seed meal,
animal protein, and grain protein.

Shellfish  meal is produced from shrimp or crab  processing  wastes
and has a  lower protein content than fish meal.   The processors in
Dutch  Harbor  could supply the raw material to produce 50 percent


                             54

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of the United States supply of shellfish meal.  However,  the  low
protein   content   of  this  product  makes  marketing  the  meal
difficult.
                         •
Another potentially  viable  product  is  chitin.   Chitin  is  an
abundant,  natural  polysaccharide  found  in  crustacean  shells,
insect exoskeletons, fungi, and certain other plants and  animals.
Its  derivative,  chitosan, is a deacetylized form of chitin which
currently has no established  major  markets  but  many  potential
uses,   including   wastewater  treatment  (coagulation  and  ion-
exchange), adhesives, and wound-healing sutures.

In addition to chitin, shellfish wastes  are  composed  of  water,
protein,  and  calcium  carbonate.   Briefly stated, the steps for
producing chitin from raw shellfish waste are: 1)  the  mechanical
separation  of  loose  protein;  2)  the  demineralization  of the
residual shell with dilute acid;  3)  the  deproteination  of  the
remains  with  dilute  alkali; and 4) the deactylization of chitin
with caustic soda (which produces chitosan).  Protein is the major
by-product  of   chitin/chitosan   manufacturing,   and   has   an
established market as an animal feed supplement.  Chitin's complex
extraction  process makes it a more expensive commodity to produce
than shellfish meal.  As part of the  Section  74  work,  EPA  has
addressed  the  economic feasibility of chitin/chitosan production
in Alaska (see next section).

Alaskan Market Feasibility Study

To investigate further the possibility of  using  the  substantial
amount  of  wastes generated by Alaskan processing facilities, EPA
conducted a detailed  economic  assessment  of  hypothetical  meal
production or chitin production plants in this region (Appendix H-
2).   Alaska  is  different  from the contiguous states because of
limited land availability and  high  construction,  operation  and
transportation costs.  Raw material for by-products is  inexpensive
and  plentiful,  but  the  high  production and shipping costs put
Alaskan manufacturers  at  an  economic  disadvantage  with  other
producers.

The major portion of this study focused on the feasibility of meal
production,  a  proven  technology  for seafood waste utilization.
The study compared meal production with barging, the other  proven
waste  handling  option for Alaskan processors.  Hypothetical meal
producing plants  (in addition to the already existing  facilities)
were developed for each of the major processing areas.

The   study   showed   meal   production  to  be  an  economically
unattractive waste handling option  (when compared to barging)  for
most  areas  given   1977   prices  and  production  levels.  Major
problems  were  underutilization  of  plant   capacity   (due   to


                             55

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seasonality  of  processing waste generation) and the low value of
shellfish meal that would be produced by some areas.

The  study  also  indicated  that  meal  production  could  become
economically   preferable  to  barging  in  some  other  areas  if
production  were  expanded  to  include  other  types  of  seafood
products, such as bottomfish.

Feasibility of Chitin/Chitosan Production

In addition to shellfish meal production, researchers examined the
feasibility   of   producing   chitin/chitosan   from   low-value,
seasonally plentiful shellfish waste (Appendix  H-2).   Currently,
the  technology  for  producing chitin and chitosan is only in the
formative  stage,  but  the  numerous  properties  and   potential
applications of the product make commercial production a realistic
possibility  in  the  near  future.  Presently, there is one small
manufacturer  of  chitosan  in   the   United   States   (Seattle,
Washington);  most  of the world's supply originates from a single
Japanese manufacturer.

For  purposes  of  this  study,  two  hypothetical   plants   were
developed:  one on the east coast and the other on the west coast.
Accordingly,  the  west  coast plant would process shellfish (crab
and shrimp) waste from Alaska and Puget Sound, and  would  produce
1.25  million  pounds of chitin per year; the east coast facility,
which  would  process  blue   crab   processor's   wastes,   would
manufacture one million pounds of chitin annually.

Because  of  the  difficulty  and  expense   in  shipping chemicals
necessary for chitin manufacturing to Alaska, researchers examined
the feasibility of completing  the  extraction  and  stabilization
portions of the process in Alaska, and then  shipping the extracted
chitinous  material  to  Seattle  for further chemical processing.
Despite construction and operation cost  disparities  between  the
two  plants,  the  limited  data  available  to  this study showed
chitin/chitosan  production  to  be   an   economically   feasible
alternative  for  shellfish waste disposal (when the selling price
ranged from $1  to  $2  per  pound).   Presently  lacking  in  the
development of full-scale production plants  are a sustained market
and  consistent quality control.  But because of chitin/chitosan's
range  of  uses  and  seafood   processors'   need   to   identify
economically and environmentally acceptable  disposal alternatives,
research  will  continue  toward  perfecting the   chitin/chitosan
manufacturing process.

Seafood  processing  researchers  recommend  that   work   actively
continue   in the area of seafood wastes solids recovery processes.
Research   is  needed  to  develop  more  secondary   product   and
by-product   processes  as  well  as extensive market research for


                             56

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these products.  Specific needs include  uses  for  dissolved  air
flotation  sludge  (currently not accepted by the FDA as an animal
feed additive) and shellfish waste  utilization  techniques,  with
major emphasis on the chitin process.
                             57

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58

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                                   CHAPTER V

                               CITED REFERENCES
1.  Brickell,  David  C.  and  John  J.  Goering,  "The  Influence  of
Decomposing  Salmon  on Water Chemistry" Univ. of Alaska, Institute of
Water Resources, Report 1WR-12, College, Alaska, 1971.

2.  Stewart, R.K. and D.R.  Tangarone,  "Water  Quality  Investigation
Related  to  Seafood Processing Wastewater Discharges at Dutch Harbor,
Alaska,"  U.S.  Environmental  Protection  Agency  (October  1975  and
October 1976).

3.  Kama, D.W., "Investigations of Seven Disposal Locations  Used  by
Seafood  Processors  at  Dutch  Harbor,  Alaska,"   U.S. Environmental
Protection Agency (October 1976 and October 1977).

4.  Colonell, J.M. and S.W. Reeburgh,   "An  Investigation  of  Certain
Aspects  of  Marine  Disposal of Crab Processing Wastes: Dutch Harbor,
Alaska, "Institute of Marine  Science,  Univ.  of  Alaska,  Sea  Grant
Report #78-6, February 1978.
5.  Brown and Caldwell Consulting Engineers,
Waste Disposal Alternatives," March 1979.

6.  ibid.
"Investigation  of  Crab
7.  Fisheries Research Institute, University  of  Washington,  "Salmon
Cannery  Waste  Study,  Bristol Bay and Kodiak Island, Alaska  (1970)."
Final Report to National Canners Association, 1971.

8.  Provant,  S.G.,  W.T.  McFall,  and  R.K.  Stewart,   "Studies   on
Industrial  Effluent  and Its Effects on Water Quality in St.  Paul and
Kodiak  Harbors,  and  Gibson  Cove,"  U.S.  Environmental  Protection
Agency, Region X, Anchorage, Alaska, 1971.

9.  Nakatani, R.E., D.L. Beyer and C.P. Staude, "The Effects of Salmon
Cannery Wastes on Water Quality and Marine  Organisms  at  Petersburg,
Alaska,"   Fisheries  Research  Institute,  University  of  Washington
(Seattle), 1971.

10. Nakatani, R.E. and D.L. Beyer,  "The  Effects  of  Salmon  Cannery
Waste  on  Juvenile  Salmon  in  a  Closed System," Fisheries  Research
Institute, University of Washington (Seattle).

11. Beyer, D.L., R.E. Nakatani and C.P.  Staude.   Effects  of  Salmon
Cannery  Wastes  on  Water  Quality  and  Marine  Organisms.   In Water
Pollution Control Federation 47:1857-1896, 1975.
                                 59

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12.  Reish, D.J., "An Ecological Study of Pollution in  Los  Angeles
Long Beach Harbors, California," Allan Hancock Foundation, 1959.

13.  Barnard, J.L. and D.J. Reish.  Ecology of Amphipoda and Polychaeta
of Newport Bay, California.  Allan  Hancock  Foundation.   Publ,  Occ.
Paper 21, 1959.
                                  60

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                                  CHAPTER VI

                       ADDITIONAL BACKGROUND REFERENCES


1.  Letter to Mr. Lloyd  Reed,  Director  Enforcement  Division,  U.S.
Environmental  Protection Agency, Region X; Comments on Working Papers
No. EPA 910-8-78-101: "The Dutch Harbor Studies", from Jerry Reinward,
Deputy Commissioner, Department of Environmental Conservation, Juneau,
Alaska, January 1978.

2.  Letter to Mr. Calvin Dysinger, Effluent Guidelines  Division  (WH-
552),  U.S.  Environmental Protection Agency, Washington, D.C.; Review
of the Brown and Caldwell Study "Investigation of Crab Waste  Disposal
Alternatives",  from  Roger  A.  DeCamp, Director, Technical Services,
Pacific Seafood Processors Association, Seattle, Washington, April 16,
1979.

3.  "Bioenhancement Studies of  the  Receiving  Waters  in  Outer  Los
Angeles Harbor", Marine Studies of San Pedro Bay, California, Part 12,
by  Harbors  Environmental  Projects,  Dr.  Dorothy Soule and Mikihiko
Oguri editors, University of Southern California, Los Angeles, 1976.

4.  "You  Can  Tailor  Effluent  BOD  to   Fit   the   Receiving-Water
Ecosystem...And  Enhance  the  Environment",  by  Dorothy F. Soule, M.
Oguri, and John  D.   Soule.   Reprinted  from  the  Bulletin  of  the
California  Water  Pollution Control Association, Vol. 15, No. 1  (July
1978) .

5.  Letter to Director, Enforcement Division, EPA, Region  IX;  Review
of  the Marine Studies of San Pedro Bay, California, Part 12 edited by
Dr. Dorothy Soule, from William C. Blackman, Jr., Assistant  Director,
Technical   Programs,   Office   of  Enforcement,  U.S.  Environmental
Protection Agency, Denver, Colorado, March 16, 1977.

6.  Memorandum to the Files by T.A. Kramer reviewing the  Los  Angeles
Harbor  Tuna Canneries - "Enhancement" Finding; Water Section, Permits
Branch, Enforcement Division, U.S.  Environmental  Protection  Agency,
May 26, 1977.

7.  Memorandum to the Files by P.T. Brubaker, Summarizing the  Reviews
of  the  L.A.  Harbor Enhancement Study, U.S. Environmental Protection
Agency, September 26, 1977.

8.  Undated Memorandum  from  the  Director,  Water  Division  to  the
Director, Enforcement Division concerning the Divisional Review of the
L.A.  Harbor, Enhancement Study; U.S. Environmental Protection Agency.

9.  Report to Mr. R.L. O'Connell  (Attn:  Mr. Terry Brubaker)  Director
Enforcement Division, Region  IX EPA, San Francisco, California; Report


                                 61

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Review,  L.A.   Harbor  Enhancement  Study, from Mr. D.J. Baumgartner,
Marine and Freshwater Ecology Branch, Corvallis Environmental Research
Laboratory, U.S.  Environmental Protection Agency, April 8, 1977.

10. Unspecified Memorandum from the  files,  October  5,  1977;  EPA's
Response  to the Star-Kist presentation on the issue of enhancement of
September 29, 1977.

11. Memorandum to Mr. R.L. O'Connell, Director, Enforcement  Division,
EPA,  Region IX; Assessment of Impact of Cannery Wastes in L.A. Harbor
after meeting with Star-Kist Representatives September 29, 1977,  from
R.C.  Swartz,  Corvallis Environmental Research Laboratory, Marine and
Freshwater  Ecology  Branch,  U.S.  Environmental  Protection  Agency,
September 30, 1977.

12. Memorandum to Director,  Enforcement  Division,  EPA,  Region  IX;
comments  on  Meeting  with  Star-Kist  Representatives, September 29,
1977, pertaining to the Los  Angeles  Harbor  Bioenhancement  Studies,
from  David  L. Brooman Process Control Branch, Office of Enforcement,
U.S. Environmental Protection Agency,  Denver,  Colorado,  October  3,
1977.

13. Undated Package of Terminal Island Briefing Materials consisting  of;
         a.   Background  information
         b.   Summary of  the Bays and Estuaries policy
         c.   Chronology  of events
         d.   Summary of  study documents
         e.   Summary of  criticisms
         f.   Other pertinent information

14.  "Reassessment of Effluent Limitations Guidelines  and  New  Source
Performance  Standards for the Canned and Preserved Seafood Processing
Point Source Category", draft final report prepared by the  Edward  C.
Jordan  Co.,  Inc.,  for  the Environmental Protection Agency, December
1979.
                                  62

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                             CHAPTER VII

                        APPENDICES A THROUGH H


                              APPENDIX A

             DUTCH HARBOR SECTION 74 STUDIES AND COMMENTS


A-l      Letter to Mr. Jeffery D. Denit, Effluent Guidelines  Division
         (WH-552),  U.S.  Environmental Protection Agency, Washington,
         D.C.; Comments from  the  National  Fisheries  Institute  and
         National  Food  Processors  Association  on  the scope of the
         Section 74 study;  authored  by  Jack  L.  Cooper,  Director,
         Environmental  Affairs; M. Kathryn Nordstrom, Fishery Affairs
         Coordinator; Roy E. Martin, Director, Science and- Technology;
         and  Gustave  Firtschie,  Director,   Government   Relations,
         Washington, D.C., July 14, 1978.

A-2      Feder, Howard M. and David  C.  Burrell.   "Final  Report  to
         Environmental  Protection  Agency  Impact  of Seafood Cannery
         Waste on the Benthic  Biota  and  Adjacent  Waters  of  Dutch
         Harbor,  Alaska."  Institute of Marine Science, University of
         Alaska, Fairbanks, Alaska, April 1979.  Grant No.  4  803922-
         03-2.

A-3      Letter to Mr. Albert J.  Erickson,  Acting  Deputy  Assistant
         Administrator   for   Water   Planning  and  Standards,  U.S.
         Environmental Protection Agency  (WH-551),  Washington  D.C.;
         Comments  on  the  report: Impact of Seafood Cannery Waste on
         the Benthic Biota and Adjacent Water at Dutch Harbor, Alaska,
         from Terry L. Letzell, Assistant Administrator for Fisheries,
         National Marine Fisheries Service, October 5, 1979.

A-4      Letter to Mr. Calvin Dysinger, Effluent  Guidelines  Division
         (WH-552),  U.S.  Environmental Protection Agency, Washington,
         D.C.; from Roger  A.  De  Camp,  Pacific  Seafood  Processors
         Association, Seattle, Washington, April 16, 1979.

A-5      Letter  to  Mr.  Robert  B.  Schaffer,   Director,   Effluent
         Guidelines  Division,  U.S.  Environmental Protection Agency,
         Washington, D.C.; Comments on Working Papers No.  EPA  910-8-
         77-100  and  910-8-78-101:  "The  Dutch Harbor Studies,," from
         Michael J. Spear, Associate Director, U.S. Fish and  Wildlife
         Service, Washington, D.C., August 31, 1979.

A-6      Letter  to  Mr.  Denton  Sherry,  President,  Whitney-Fidalgo
         Seafood,  Inc.,  Seattle,  Washington; discussion of "remote"
         and  "non-remote" site status, from C. Deming  Cowles,  Deputy


                                 63

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         Commissioner,   State  of  Alaska  Department of Environmental
         Conservation,  Juneau,  Alaska, June 20, 1979.

A-7      Letter to Mr.  Calvin Dysinger, Effluent  Guidelines  Division
         (WH  552),  U.S. Environmental Protection Agency, Washington,
         D.C.; Review of "Impact  of  Seafood  Cannery  Waste  on  the
         Benthic  Biota  and  Adjacent Water at Dutch Harbor, April 1,
         1979," from Roger A. De Camp, Director,  Technical  Services,
         Pacific  Seafood Processors Association, Seattle, Washington,
         August 17, 1979.

A-8      "Biological and Water Quality Implications  of  Current  Crab
         Processing Waste Disposal Practices in Dutch Harbor, Alaska,"
         Timothy  J.  Bechtel,   Ph.D.,  Consulting  Biologist, Pacific
         Seafood Processors Association,  Seattle,  Washington,  March
         1979.
                                  64

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                                  APPENDIX B

                 OTHER ALASKAN SECTION 74 STUDIES AND COMMENTS
B-l
B-2

B-3

B-4
B-5
"Benthic Macrofauna, Sediment and Water Quality near  Seafood
Cannery  Outfalls in Kenai and Cordova, Alaska," Final Report
by  Michael  A.   Caponigro,  SCS  Engineers,   Long   Beach,
California  for  the  U.S.  Environmental  Protection Agency,
Contract No. 68-03-2578, February 15, 1979.

See A-3

See A-4

Letter  to  Mr.  Robert  B.  Schaffer,   Director,   Effluent
Guidelines  Division,  U.S.  Environmental Protection Agency,
Washington, D.C.; Review of Appendix  B-l,  from  Michael  J.
Spear,  Associate  Director,  U.S. Fish and Wildlife Service,
Washington, D.C., August 31, 1979.

Report to Director, Fish and  Wildlife  Service,  Washington,
D.C.;  "Report  of  Field Investigations of Finger Cove, Adak
Island, January 15-22, 1979,"  from  Leroy  W.  Soul,  Deputy
Alaska  Area  Director,  Environmental  Assessment  Division,
National Marine Fisheries Service, Juneau, Alaska,  July  16,
1979.
                                 65

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                                  APPENDIX C

                  NON-ALASKAN SECTION 74 STUDIES AND COMMENTS


C-l      "Benthic Macrofauna, Sediment and Water Quality near  Seafood
         Cannery  Outfalls  in  Yaquina  Bay,  Oregon,"  by Richard C.
         Swartz, Donald W. Schults, Waldeman H. DeBen,  and  Faith  A.
         Cole,   Marine   and  Freshwater  Ecology  Branch,  Corvallis
         Environmental   Research   Laboratory,   U.S.   Environmental
         Protection Agency, Newport, Oregon, September 11, 1978.

C-2      See A-3

C-3      See A-4

C-4      See A-5
                                 67

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                                  APPENDIX D

                 MISCELLANEOUS SECTION 74 STUDIES AND COMMENTS


D-l      "Trip Report, Section 74 Seafood  Processing  Study,  Alaskan
         Water  Quality  Investigations,  July  25  through  August 3,
         1978," by  Peter  M.  Maher,  Edward  C.  Jordan  Co.,  Inc.,
         Portland, Maine.

D-2      "An Investigation of Certain Aspects of Crab Processing Waste
         Disposal Practices:  In Situ and In Vitro Responses of Vibrio
         Parahemoliticus  and  Vibrio  Anguillarum,"  by  H.M.  Feder,
         Institute of Marine Science, University of Alaska, Fairbanks,
         Alaska  and S.A. Norrell and K. Babson, University of Alaska,
         Anchorage, Alaska, undated.

D-3      See A-3

D4       See A-4

D-5      See A-5
                                 69

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                                  APPENDIX E

                     LOS ANGELES HARBOR STUDY AND COMMENTS


E-l      "Ecological Changes in Outer Los Angeles - Long Beach Harbors
         Following  Initiation  of  Secondary  Waste   Treatment   and
         Cessation  of Fish Cannery Waste Effluent," Marine Studies of
         San Pedro Bay, California, Part 16, by Harbors  Environmental
         Projects,  Dr.  Dorothy  Soule  and  Mikihiko Oguri, editors,
         University of Southern California, Los Angeles, April 1979.

E-2      Letter  to  Mr.  L.  Frank  Goodson,   Project   Coordinator,
         Resources  Agency,  Sacramento,  California;  Review of Draft
         Environmental Impact Reports  (EIR's), State Clearinghouse No.
         79051509A, For City of Los Angeles, Terminal  Island Treatment
         Plant, Project No. 1202; by Neil Dunham,  Division  of  Water
         Quality, California State Water Resources Control Board, June
         13,    1979;   with   interspersed   responses   by   Harbors
         Environmental Projects as consultants  to  the  City  of  Los
         Angeles, June 29,  1979.

E-3      Letter  to  Mr.  L.  Frank  Goodson;   Project   Coordinator,
         Resources  Agency,  Sacramento,  California;  Review of Draft
         Environmental Impact Report  (EIR),  State  Clearinghouse  No.
         79051509A,  for  Marine  Studies  of  San  Pedro Bay Part 16,
         Ecological Changes in Outer Los Angeles - Long Beach  Harbors
         Following   Initiation   of   Secondary  Waste  Treatment  and
         Cessation of Fish  Cannery Waste Effluent; from  Neil  Dunham,
         Division  of  Water Quality,  California State Water Resources
         Control Board, July 2, 1979.

E-4      Letter to Mr. Jeffery D. Denit, Chief, Food   Industry  Group,
         U.S.  E.P.A.,  Washington, D.C.; Review of the Marine Studies
         of San Pedro Bay,  California, Part 16 study,  edited  by  Dr.
         Dorothy  Soule,  from  Robert G.  Kaneen, State of California
         Department of Fish and Game,  May 22, 1979; with  interspersed
         responses  by  Harbors  Environmental Projects, July 5, 1979;
         and errata sheet dated May 24, 1979 by Robert Kaneen.

E-5      Memorandum of review of the Marine Studies of San Pedro  Bay,
         California,  Part  16 study, edited by Dr. Dorothy Soule; from
         Mr.  Richard  C  Swartz,  Environmental   Protection   Agency
         Research  Laboratory,  Newton,  Oregon,  March 28, 1979; with
         additions in June  1979.

E-6      Letter to Mr. Robert Schaffer  (WH-552), Director of  Effluent
         Guidelines  Division,  U.S.   E.P.A.,  Washington, D.C.; Draft
         Review of the Marine Studies  of San  Pedro  Bay,  California,
         Part  16  study edited by Dr. Dorothy Soule,  by Jack Fancher,


                                 71

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         U.S. Fish and Wildlife Service,  Laguna  Niguel,
         October 19, 1979.

E-7      Memorandum to the Files by P.T. Brubaker summarizing f::<«dj:ij:
         and comments at an informal workshop convened April  5,   -  *9
         to review the Part 16 Los Angeles Harbor Study, May 1,  ? ".

ET8      Memorandum attachment to E-7  illustrating  the  Los  A;.-;- ,,o
         Harbor  Enhancement  Study  Review Criteria to be util ,£";.  iy
         reviewers in evaluating the Part 16 study.

E-9      Letter to a mailing list agenda and the City of Los  Angeles1
         report to the California Regional Water Quality Control Board
         for  an  Interagency/ Fish Cannery Workshop on Issues related
         to the Discharge  of  Municipal  Effluent  and  Fish  Cannery
         Wastes  to  Outer  Los Angeles Harbor, compiled by Raymond  M.
         Hertel, Executive Officer, California Regional Water  Quality
         Control Board, October 1, 1979.

E-10      Response to letter in E-7 by Mr.  Raymond  M.  Hertel  dated
         October   1,  1979;  by  Clyde  B.  Eller,  Region  IX,   U.S.
         Environmental Protection Agency, San  Francisco,  California,
         October 2, 1979.

E-ll      Letter to Mr. Calvin Dysinger, Effluent Guidelines Division,
         U.S.  E.P.A., Washington, D.C.; Personal Review of the Marine
         Studies of San Pedro Bay, California, Part 16  study,  edited
         by  Dr.  Dorothy  Soule, from Howard 0. Wright, Environmental
         Specialist, Division of Water Quality, California State Water
         Resources Control Board, August 7, 1979.

E-12     Letter to Mr. Calvin Dysinger, U.S. E.P.A., Washington, D.C.;
         Review of the Marine Studies of San  Pedro  Bay,  California,
         Part  16  study,  edited by Dr. Dorothy Soule; from Rimmon  C.
         Fay, Pacific Bio-Marine Labs,  Inc., Venice, California,   June
         14, 1979.

E-13     Letter to Mr. William MacDeish, Bureau of  Engineering,   City
         of  Los  Angeles,  San Pedro,  California; Review of the Draft
         Environmental Impact Report on the Terminal Island  Treatment
         Plant  (TITP)  Unit  II-C,  Harbor  Outfall;   from  Donald  B.
         Bright,  Environmental  Feasibility  Studies,  Los   Angeles,
         California, July  11, 1979.

E-14      Letter  to  Mr.  L.  Frank  Goodson,  Project  Coordinator,
         Resources  Agency,  Sacramento,  California;   Review   of  SCH
         7951509A-DEIR Terminal   Island  Treatment  Plant  Unit   II   C
         Effluent   Disposal System  and  Harbor Outfall;  from California
         State Department  of  Fish  and  Game,  June   7,   1979;   with
                                  72

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         interspersed  responses  by  Harbors  Environmental Projects,
         undated.

2-15      See A~3

£-16      See A-4

5-17      "Critique on California Department of Fish and  Game  report
         to  EPA  on  Dr.  Soule's  Marine  Studies  of San Pedro Bay,
         California, Part 16 study," by Rear Admiral O.D. Waters, Jr.,
         U.S.N. (Ret), North Indialantic, Florida, June 30, 1979.

£-13      Letter to Dr. Dorothy Soule reviewing  the  Part  16  study,
         from   Willard  Bascom,  Southern  California  Coastal  Water
         Research Project, El Segundo, California, June 13, 1979.

E~19     Letter to Mr. Calvin Dysinger, U.S. Environmental  Protection
         Agency,  Washington,  D.C.;  Comments and observations on the
         Harbors Environmental Projects  Part  16  report;  from  Dave
         Batlands,  General Manager of Engineering Services, Star-Kist
         Foods, Inc., Terminal Island, California, September 13, 1979.

£-20     Letters to Mr. John P. Mulligan,  Tuna  Research  Foundation,
         Inc., Washington, D.C.; Comments on the Harbors Environmental
         Projects  Part  16  study; from Larry B. Simpson, Gulf States
         Marine Fisheries Commission, Ocean Springs, Mississippi, July
         2, 1979;  Melbourne  R.  Carriker,  University  of  Delaware,
         Lewes,  Delaware,  August  2, 1979; James V. Chambers, Ph.D.,
         Sciences and Extension  Specialist,  Purdue  University  Food
         Sciences  Institute,  West  Lafayette, Indiana, September 10,
         1979; Wayne E. Swingle, Executive Director,  Gulf  of  Mexico
         Fishery  Management  Council,  Tampa, Florida, June 27, 1979;
         June Lindstedt Siva, Senior  Science  Advisor,  Environmental
         Sciences,  Atlantic  Richfield  Company,  Los  Angeles, Cali-
         fornia, October 3, 1979.

E-2I     Letter  to  Mr.  Calvin  J.  Dysinger,  Effluent   Guidelines
         Division  (WH-552),  U.S.  Environmental  Protection  Agency,
         Washington, D.C.; Comments on the Marine Studies of San Pedro
         Bay,  California,  Part  16  study;  from  Jack  L.   Cooper,
         Director,  Environmental  Affairs,  National  Food Processors
         Association, Washington, D.C., September 14, 1979.

         Undated excerpt from an unpublished manuscript comparing  the
         Harbors Environmental Projects data with data from a Southern
         California Edison Report.

          Memorandum to the files by P.T. Brubaker,  EPA,  Region  IX,
         which  summarizes  the  issues  pertaining to the L.A. Harbor
         Enhancement Study, September 26, 1977.


                                 73

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                                  APPENDIX F

                                EPA SITE VISITS


F-l      EPA  Site  Visit  to  Brunswick,  Georgia  Shrimp  Processing
         Facility.

F-2      Observations on the Disposal of Shrimp Heads into Shem Creek,
         Mt. Pleasant, South Carolina by G.A. Rhame for the EPA.

F-3      Site Visits to Louisiana Shrimp Canneries by Calvin Dysinger,
         Project Officer.

F-4      EPA  Site  Visit  to  Southern  Florida  Seafood   Processing
         Facilities.

F-5      EPA Seafood Study - Site Visits to Maine Sardine Canneries.
                                 75

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                                  APPENDIX G

                             TECHNOLOGY ASSESSMENT


G-l      "Technology  for  Seafood  Processing  Waste   Treatment    and
         Utilization,  Section  74  Seafood   Processing  Study",  final
         report prepared by the Edward C. Jordan  Co.,   Inc.,   for  the
         Environmental Protection Agency, March,  1980.

G-2      "Improving the Economics  of  Crustacean-Waste  Disposal"   by
         Peter  M.  Perceval  and  W.E.  Nelson,  CHI-AM International,
         Inc., 1979.

G-3      See A-3

G-4      See A-5

G-5      Letter to Mr. Calvin Dysinger, Effluent  Guidelines   Division
         (WH-552),  U.S.  Environmental Protection  Agency,  Washington,
         D.C.; Comments on Appendix G-l from  Jack L. Cooper,   National
         Food  Processors  Association,  Washington,   D.C.,   April  17,
         1979.
                                       *U S GOVERNMENT PRINTING OFFICE: 1980 341-085/3922
                                  77

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                                  APPENDIX H

                           MARKET FEASIBILITY STUDY


H-l      "Market Feasibility  Study  of  Seafood  Waste  Reduction   in
         Alaska",  draft  report  prepared  by  Development Planning &
         Research Associates, Inc. for  the  Environmental  Protection
         Agency, February 1979.

H-2      Letter to Mr. Sammy K. Ng, Office of Analysis and  Evaluation
         (WH-586),  U.S.  Environmental Protection Agency, Washington,
         D.C.; Comments on  the  February  1979  Draft  Report  titled
         Market Feasibility Study of Seafood Waste Reduction  in Alaska
         from   Dr.   Lawrence   Van   Meir,  Director  Economics  and
         Statistics, National Food Processors Association,  April  16,
         1979.

H-3      See A-3
                                 79

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