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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.
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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
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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.
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•M <0
3 0)
+j —
a ~
o
oo"
o'
o-
(0
4
o
o-
<
o
CM
I
o-
UJ
-I
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Figure 2. Map of the United States
illustrating the geographic coverage of
investigations for the Section 74 study.
13
-------
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
-------
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
-------
Figure 6: Salmon waste dredged from the bottom in the
vicinity of a salmon cannery outfall, Port Baily, Kodiak Island,
Alaska.
22
-------
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.
-------
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
-------
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
-------
«/ ^""fj*
"T. ~t t^l
Figure 11: Salmon & crab waste below processing facility, Cordova, Alaska.
29
-------
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).
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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
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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.
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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.
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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,
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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.
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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.
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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.
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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.
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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.
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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
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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
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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,
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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.
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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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