U.S. Environmental
       Protection Agency
Effluent Guidelines Division
         Washington, P. C.
          SECTION 74
     PROCESSING STUDY
           AUGUST 198O

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  EPA  SITE  VISIT TO BRUNSWICK,  GEORGIA SHRIMP PROCESSING FACILITY
 I.   General
On  2/12/79  an  EPA representative visited the King Shrimp facility in
Brunswick,  GA.   This  facility produces breaded and non-breaded shrimp
and discharges wastewater to the Brunswick River.  The purpose of the
^'sUjjiastg, document conditions aj; tJhjsJfacjHtY and to meet with J.R.
Duggan,  the plant manager,  and Dr.  Wayne Bough, of the University of
Georgia  Marine Extension Service.

II.   Wastewater  Characteristics and Existing Waste Treatment

King Shrimp is a large facility that discharges approximately 360,000
gallons  of  wastewater per day.   Aj  for all shrimp process lflg_OB£ca_tiojis «
s"oTjds7   Georgia water quality standards  require that the dissolved
oxygen  (DO)  levels  of receiving waters  be maintained at an average of 5
parts per million  (ppm)  and  at a minimum  of 4 ppm.   In efforts to maintain
the  Brunswick  River waters at this  level, the^Gwr^la_Dep_artn]ent_of
Environmental JYotection- .(DEP.) .. has, requi red J__tp_ a
s_hip..slip 6'rTthe .Brunswick River hear the plant. Ac£ordin_g_tp__the
^5PJ^ia..^E£J_thJ_s__aj_e'a" Deceives li.ttle  flushing and significant "accumulations
of shell  occurred.  The  local  health  department received a number of
complaints about "the  odors in this  area at low tide.  As noted above,
this facility  has recently achieved 85% BOD removal  and, in addition,
the  discharge  outfall  has been relocated  to a deeper part of the river
v^eTe j:ufnejits"2W^                 the  wastes.   Although a portion of
fhT"6uiTdFp~o'f~wastes~ in ~th1Ts'hip" slip "still  "remains, conditions have
improved  and fewer  complaints have  been received regarding this facility.

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  Other Information

  Of major concern to King Shrimp are the  Georgia  water quality  standards
  which require that waters be maintained  with  an  average dissolved  oxygen
  (DO)  content of 5 ppm and a minimum of 4 ppm  at  any time.   These standards
  are the basis of requiring secondary treatment (or the equivalent) for
  all point sources.   The water quality-based treatment requirements are
  more stringent than the national  technology based standards currently in
  effect for this industry.  Currently, King Shrimp is the only  major
  Georgia seafood processor that does not  practice secondary treatment of
  its entire waste flow.

  Mr. Duggan stated that these water quality standards as applied stringently
  to the discharge of seafood wastes are unfair.   Mr.  Bough indicated
  that, in his opinion, a minimum DO standard of 4 ppm is not suitable for
  coastal estuarine waters and that even in unpolluted pristine  coastal
^waters the DO sometimes falls below 4 ppm.  Mr.  Duggan felt that Georgia's
(' strict environmental  policies have contributed to the economic decline
  of the seafood processing industry in this area; he indicated  that other
  nearby states impose less stringent environmental controls on  seafood
  processors.

 /The Georgia Department of Environmental  Protection indicates that  the
( water quality standards are necessary to protect the coastal waters
  which serve as spawning grounds for various harvestable species, including
 , shrimp.  Thus, the standards are viewed  as necessary to protect the
( seafood industry.

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                                  (1)                  G. A. Rhame

OBSERVATIONS ON THE DISPOSAL OF SHRIMP HEADS INTO SHEW CREEK,
MT. -PLEASANT, SOUTH CAROLINA
     The writer was requested by the management of the Mt. Pleasant,

S. C.,  Water and Sewer Commission  (1) to make a study of the pro-

blems of shrimp head disposal from shrimp processing plants located

on Shem Creek in Mt. Pleasant, South Carolina.

     Shrimp processing plants within this area are devoted to the

simple  operation of heading, washing, grading and icing for distri-

bution. There is no peeling, breading or canning on site. Heads are

the most important component of waste, with some discards. Business

is quite brisk in good years.

Summary and Conclusions

     Disposal of shrimp heads from the Shem Creek processors by local

waste treat plants, hauling to landfill, complete destruction or

production of by-products would impose a crippling financial burden
    I           "
on the  processors. There may be some future to the by-products system,

     Disposal to the local city sewage treatment plant would cause

a BOD overload. Dangers of health hazards and DO depletion from dis-

posal to Shem Creek appear to be exaggerated. Care would be needed  to

prevent aesthetic objections. The present system of barging to a

nearby  harbor channel has worked well at moderate cost. It should be

continued until problems connected with other possible systems are

eliminated.

Analytical Studies

     Some local shrimp heads were obtained and subjected to the BOD^

determination in the laboratory of the Mt. Pleasant sewage treatment

plant.  Heads were weighed wet to avoid ]oss of volatile organic com-

ponents, broken up in a household blende?" contain:! ng 1000 ml of

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                                                      G. A. Rhame
distilled water. BOD^ of the resulting mixture was determined


according to Standard Methods  (2). After a few unreasonably low re-


sults all. incubation bottles were seeded with 0.5 ml of fresh


settled sewage. DO was measured by the Sodium Azide-Winkler method.


A number of runs were aborted  for various reasons. Results are shown


in Table 1. The results in Table I work out to 150 Ibs. of BOD5 per


1000 Ibs. of shrimp heads.


     A letter from John M. Knox of the South Carolins BHEC states


that the department's laboratory at Charleston, S. C. , found 170 Ibs.
             i

of BOD^ per 1000 Ibs. of "shrimp or shrimp fragments". Most of the


organic matter in shrimp is in the part used for food -- the tail.


     Development Documents (4) for the EPA "Guidelines and Standards


for Canned and Preserved Seafood" show that a considerable study was


made, but none on operations like those at Mt. Pleasant. One opera-


tion showed a BODt^ of 46 Ibs.  per 1000 Ibs. of shrimp processed.  (The


only one where BOD was measured) . The above shows a BOD-organic ni-


trogen ratio of 4. 6/1. The ratio for "normal" sewage is considerably


higher.


Quantity of Waste


     Data obtained from the South Carol.! na Wildlife and Marine Re-


sources Department is shown in table II. The figures in parentheses


were calculated by the writer.


     From table II it can be expected that on the basis of 25 working


days per month, upwards of 8,000 Ibs. of heads per day would be wasted


and that this would represent  about 35% of the weight of shrimp


landed.


     From the analytical, data  and table II it can be expected that a


waste load of 'about 1,200 Ibs. BOD 15 would be qenor<-\ tod on n maximum

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                                  (3)                   G.  A.  Rhame




operating day at Shem Creek.


Waste Disposal Alternatives


Disposal to Sewer


     Sewers of the City of.Mt. Pleasant Water  and  Sewer Commission


are abailable to the Shem Creek processing plants  and  probably  have


adequate hydraulic capacity.         •  ;


     Previous experience with disposal to sewer  has  shown that
                                                       ,   V,"
                 \
shrimp heads rapidly clog sewers. The peculiar "prickly"  shape  of

             .:         ..""     '      .  '               v  •
the heads probably caused "them to ball up. Passage thru a grinder


eased this problem. Shem Creek sewers discharge  to the city's main


plant, which has a capacity of 1.1 mgd.  or about 11-,000 f*rf*. BOD^ /day


     The addition of 7,000'P<&s. BOD-per' \3ay during the busy  season


would result in an unmanageable load. The effect of  off-peak loads


would not be good. If, by some presently impractical technical  process


the shrimp-head load could be discharged to the  sewage treatment plant


at a steady rate throughout the year there would still be an unde-


sireable reduction in the allowable household  connections.


     Service charges for use of the system would presumably  by  set on


an equivalent per-capita basis. Cost to the processors would be sub-


stantial .


Disposal by Private Treatment Plant


     Development Documents for the EPA Guidelines  (4)  contain  a


considerable discussion of proposed methods of treating shrimp  pro-


cessing wastes from breading a-^d canning plants.


     Collina and Tenney  (6)  (7) present some interesting  ideas  on


simplified analytical control of seafood processing  waste treatment

          ,*
plants. Arfelaborate cal.ihrnt.ion process is required  and might  bo


useful for application to SOW£KIC treatment plant: control.

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                                  (4)                  G. A. Rhame


     Brenninf leld, Winn and Phillips  (8) Discuss .seafood waste

treatment  (without reference to shrimp) and make a pertinent ob-

servation': "The wastewater treatment cani tal costs in almost all

cases exceed the present capital  investment in the processing plant

and facilities". The combination  of relatively high capital costs,

seasonal operation, need for skilled operators and small areas of

land available near shrimp processing plants would make local waste

treatment systems a bankruptcy burden on processors.

Conversion tb Salable By-Products or Complete Destruction
                                   \,
     The S. C. Wildlife and Marine Resources Department (5) re-

ported on a considerable study of the problems and economics of

conversion to a salable by-product and complete destruct by incinera-

tion. Transportation to a regional conversion or destruction plant

was an essential assumption of the study. Thi.s adds a substantial

cost. The study presents no conclusions or recommendations, but the

general attitude is not encouraging.

     The EPA Development Document  (4) describes on page 171 a waste

screen built onto a hydraulic ram which compresses the screenings.

This device greatly reduces the bulk and water content of  the waste,

which would reduce transportation cost and fuel needed for drying

or incineration. Refrigeration while holding for transportation

might become practical.

     To the writer's knowledge the only by-products plant  in the

state is that of the Blue Channel Corporation at Port Royal, S. C.

The system is used primarily for  crab residues and is reported to
                                out
have handled shrimp residues wi th/jdif f iculty. (Conversation with

Will Lacey).  (5)

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                                  (5)                  G. A. Rhame



Disposal to Landfill


     This procedure was tried by  the Shorn Creek processors. Decom-


position of the shrimp heads during accumulation and transportation


generated.highly unpleasant odors. Complaints led to stoppage of


this practice. Compression and refrigeration of wastes during holding,


if adequate refrigeration capacity is available, would improve this


situation.


Disposal Into Shem Creek


     Shem Creek is a small tidal estuary of the Charleston, S. C.,

                                   V
harbor. Average tidal range is about 5 feet. The estuary is bridged


by U. S. 17 (Coleman Blvd.) in Mt. Pleasant, S. C. That portion of


the creek on the harbor side of the bridge has a dredged depth of


7 feet. It is narrow, bordered by shrimpers docks, mostly on the East


side, and has a considerable salt marsh and a large tributary tidal


drainage ditch on the West side.


     The portion of the estuary on the landward side of U. S. 17


rapidly tapers off to very shallow depths at lov; tide and becomes very


narrow. It is surrounded by a considerable area of lightly flooded


salt marsh with tidal drainage ditches serving highly populated areas.


Dry-weather inflow is negligible.


     Attempts to sutdy disposal of shrimp heads into Shem Creek


immediately ran into a frustrating situation - there is no data on


water flow in and out of the creek.


     The SC WMR and DHEC departments  (9) made a joint study of this


situation at a time when there were no shrimp heads or other formal


effluents reaching the creek. Their results show a rapid dispersal


of dye  into the harbor. Some moved out of the creek in a very short


time, some moved very slowly" -- as usual. DO concentrations were

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                                  (6)                  G. A. Rhame


normal for such a body of waiter  in  summer, averaging about  5.5 ppm.
                                          i

Unfortunately, their current meter  malfunctioned.

     The main channel between the bridge  and the harbor was measured

during the above effort. Dimensions found were:

                  Length   -  5300  feet
                  Width    -  150   feet
                  Depth    -  12  feet at  high tide
                              7   feet at  low tide
                  Volume   -  9.5 x 10& cubic ft. at high tide
                           -  5.0 x 106 cubic ft. at low tide
                           -  500 x 106 Ibs. water at high  tide

     A rough (tracing wa's made of  both parts of the creek from an
                                                            V
aerial photograph. The graph paper  overlay method indicated that

the area of channel and marsh on  the landward side of the bridge was

at least 25 times that of the channel on  the harbor side of the

bridge -- which would receive all of the  shrimping waste. If the

average flooding depth of the landward marsh is considered  to be one

inch (the marsh is very irregular)  the total volume of water passing

through the channel to the landward marsh would be 1/6 the  volume

of the channel. A complete tidal  cycle in the Charleston area takes

about 12.5 hours.

Estimation of oxygen consumption

     Assume "standard" rate of demand exertion for lack of  other

data.

                  Ultimate BOD    =   1.5 x BOD5
                  BOD5            =   0.11 x ultimate
                    °''             -   0.11 x 1.5 x BOD5
                                      0.11 x .1 .5 x 1200 Ibs.
                                  =   200 Ibs. if all waste released
                                               in one tidal cycle
                                  =   200  = 0.4 ppm for channel volume
                                      500
     Demand would be less in practice since two shifts would last

longer than one tidal cycle. Effects on DO from a peak day  operation

of 16 hours would be cyclical and minimal.

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                                 (7)                  G. A. Rhame


     Possible health hazards were not evaluated for lack of data.

Note that the creek is not well adapted to swimming or water skiing

due to lack of access, narrow channels landward of the bridge and

considerable shrimp boat traffic during warm weather in the dredged

channel.

     It appears possible that the unsightly appearnace of shrimp

heads in the creek and marshes could be eliminated by grinding and

underwater discharge. This would have to be verified by on-side ex-

periment.
Acknowledgements:

     The writer wishes to express his thanks to the following for

help in acquiring information:

     Charles R. Jeter, Chief, Bureau of V?astewater and Stream Control,
     SCDHEC, and Staff

     Charles M. Bearden, Director, Office of Conservation, Management
     and marketing, SCWMRD,  and Staff

     Carl Dysinger, Project Officer, Food Industries Branch, EPA

     Barbara A Bassuener, Manager of Public Affairs, WPCF

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                                 (8)                  G. A. Rhame
References
(1)   Mt. Pleasant Water and Sewer Commission, Mt. Pleasant, S. C.,
     Ronald E. Bycroft, Manager

(2)   Standard Methods for the Examination of Water and Wastewater,
     14th Ed., WPCF, AWWA and APHA

(3)   Knox, John N., Compliance Section, SCDHEC, letter of 12/13/78
     to G. A. Rhame

(4)   Development Documents for EPA "Effluent Guidelines for Canned
     and Preserved Seafood"  (4) GFR 48 8, FR 23134, as amended.
     Section on Southern Non-Breaded Shrimp

(5)   Lacey, Wl H., III., report to Dr. E. B. Joseph, Director, Marine
     Resources Center, SCWMRD, "Shrvimp Head Disposal"

(6)   Collins, .J. and Tenney, R. D. —  "Fishery Wast Effluents: A
     Method to Determine Relationships Between Chemical Oxygen De-
     mand and Residue". Fishery Bulletin, 74, 4,  (1976)

(7)   Collins, J. and Tenney, R. D. —  "Fishery Waste Effluents: A.
     Method for Determining and Calculating Pollutant parameters"
     Fishery Bulletin, 7_5, 2  (1977)

(8)   Brenninfield, R. B., Winn, P. N.  and Phillips, D. G. —
     "Characterization Treatment and Disposal of Wastewater from
     Maryland Seafood Plants" - Journal WPCF, ^0, 1943  (1978)

(9)   Lacey, W. H. Ill, "Shem Creek Study" June, July and August,
     1977') SCWMRC and SCDHEC

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                                  (9)                  G. A.  Rhamo
                              TABLE I
Weight Shrimp                mgq BOD per I,             Grams  per
Head - Grams                 of Mixture                1000 gr  head
4.74
7.07
4.85
9.27
15.14
7.66
5.14
4 6 5
1100
660
1480
2600
115^0
700
100
153
136
159
170
150
136
                                                 Average    149

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                                (10)
G. A.  Rhamo
                              TABLE IT
             Monthly Landings CL Shrimp at Shem Creek

                                1.975
Month
April
May
June
July
August
September
October
November
December

April
May
June
July
August
September-
October
November
December
Lbs. - Heads Off
--
94,010
192,061
208,798
126,834
234,913
196,331
110,595
83,912

3,422
107,364
213,906
319,322
183,206
207,787
156,073
196,262
13,919
Lbs. - Hea<
--'
144,859
305,917
357,306
199,667
362,149
302,350
170,317
129,224
1976
5,270
165,728
340,013
512,726
286,717
320,487
240,353
302,242
19,895
                                                       Lbs. - Heads   (5)
50,849
113,849
148,508
72,833
127,235
106,019
59,722
45,312
1,848
58,364
126,107
193,404
103,511
112,700
84,280
105,980
6,976
(34)
(37)
(41)
(.36)
(26)
(36)
(35)
(35)
(35)
(36)
(37)
(37)
(36)
(35)
(35)
(35)
(35)
Source: Fisheries Statistics Section, SCWMRD

(numbers in parentheses inserted by the writer!

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              SITE  VISITS  TO  LOUISIANA SHRIMP CANNERIES
                 Calvin  Dysinger, Project Officer
 I.   General
 The  Gulf  Coast  shrimp canning industry consists of approximately 15-20
 canneries  located along bays, rivers and bayous.  In addition, a number
 of shrimp  freezing and oyster processing operations are located in this
 area.   EPA representatives visited several canneries during the period
 11/8/78-11/9/78 to document existing waste treatment practices and
 visable aesthetic conditions resulting from waste discharges. Plant
 managers  provided additional information.

 The  following facilities were visited:

 Facility                                   Discharge Point

 Violet  Packing,  Violet, LA                 Mississippi River
 Cutcher's  Canning Co., Westwego, LA        Mississippi River
 Robinson Canning Co., Westwego, LA         Mississippi River
 Gulf Coast Packing, Dulac, LA              Grand Caillou Bayou
 Grand Caillou Packing Plant, Dulac, LA     Grand Caillou Bayou

 II.  Process Description

 Shrimps are caught along the continental shelf and are unloaded at
 receiving  stations.  The shrimp are packed into crates and trucked to
 the processing  plants.

As the  shrimp arrive at the plant, they are unloaded into a tank where
 shell,  rocks and other debris are mechanically removed.  The shrimp are
 transported into the plant by conveyor and are visually inspected to
 further remove  debris.  The shrimp are then mechanically sorted by size.

 Processing consists of freezing or canning; some facilities operate both
freezing and canning processes.  Shrimp may be frozen either unpeeled or
after peeling and may be breaded prior to freezing.  Shrimp are also
peeled  prior to  canning.  The entire process of preparing peeled shrimp
for canning consists of mechanical peeling, agitation (to remove pieces
of shell), mechanical deveining (optional), steam cooking, grading for
size, final inspection, filling the cans, addition of brine water,
sealing and retorting.

 III.   Wastewater Characteristics

A Gulf Coast shrimp cannery generates approximately 100,000-250,000
gallons of wastewater per day.   This water contains significant amounts
of biochemical oxygen demanding wastes as solids or soluble material.
The major  sources of wastewater and solids are the peeling and deveining
machines.   In facilities where breading occurs, this operation generates
additional biodegradable wastes.

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 IV.  Existing Haste Treatment and Recovery Operations

 In-Pi ant Controls

 A large variation in waste management practices was observed at the
 facilities visited.   As a portion of an EPA demonstration project,  a
 considerable effort has been made in the Violet Packing facility to
 implement in-plant changes to reduce water use (with concurrent reduction
 in waste loads).   These changes include replacement of flumes with  dry
 conveyors and modification of valves and nozzles to decrease water  use
 in cleaning the product and machinery.   The other facilities, particularly
 those in the Dulac,  LA area, were less  sophisticated with regard to
 water conservation,  and generally.in efforts to minimize waste discharges.

 End-of-Pipe Treatment and Haste Solids  Handling

 Violet Packing,  Cutcher's Canning Co.  and Robinson Canning Co.  all
 operated screens  to  remove gross solids from their wastewaters.   Both
 Violet Packing and Robinson Canning  Co. also operate dryers which
 produce shrimp meal  from the wet solids retained by the screen.   The
 plant managers indicated that the market value of the meal was low  and
 that the greatest advantage to meal  production was to reduce the volume
 of solids requiring  disposal.   Cutcher's Canning Co.  does not operate a
 dryer.   The solids generated at this facility are mechanically partially
 dewatered (to reduce their volume) and  hauled away to be used as fertilizer
 or to be landfilled.

 The Gulf Coast Packing  and Grand Caillou Packing facilities operate no
 end-of-pipe treatment.   The plant managers  indicated  that there were no
 available means of disposal  for screened solids.   The local water table
 was too high  to permit  landfilling of seafood wastes.

 V.   Receiving Water  Effects

 Violet  Packing Co.,  Cutcher's  Canning and Robinson Canning Co.  - These
 facilities  discharge screened  effluent  to the Mississippi  River.  The
 particulates  and  soluble wastes discharged  by these facilities  did  not
 have  a  readily apparent  effect on this  large body of  receiving  water.
 The potential  exists  for these discharges,  in combination with other
 point sources, to  impact both  water  quality and biota.   A sampling
 program would  be  required  to fully assess the impact  on the benthic
 assemblages.

 Gulf Coast  Packing and Grand Caillou Packing Co.  - These facilities
 discharge untreated wastes  to  the Grand Caillou bayou.   Although this	
 small,  slow_mqving body  of  water^ has been,.classified,as.water-quality
limited' by  the state  of  Louisiana, these plants have  been allowed to
 disclha^rge_tjieir_wasj.esLjvi thput;_ treatment because of_diffi.cul.ty ,.in
disposing _of_screened_.so.lids.   According  to the plant managers,  these
facilTtie's will eventually  receive municipal  treatment upon completion
of  construction of a  local  treatment works.

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The receiving water in the vicinity of these facilities appeared very
stagnant and murky.  It appears that the water movement in the bayou is
insufficient to disperse the untreated discharge by these plants. The
surface waters appeared oily and foamy.

VI.  Other Information

A major problem for the shrimp industry in this area is solids disposal.
Conventional solids recovery techniques (i.e. shrimp meal production)
are not generally profitable in this region.  The market demand for this
low protein meal is quite low.  Industry representatives recognize the
need to conduct research on alternative solids recovery technologies,
but they indicate that the industry has insufficient money to devote to
such work.

The canners contend that pollution control requirements beyond screening
(such as dissolved and flotation) are environmentally unnecessary and
are overly expensive for the industry.   They estimate that installation
of DAF treatment will  result in a net price increase of five percent per
case of shrimp produced.

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EPA Site Visit to Southern Florida Seafood Processing Facilities


I.  General

There are a large number of small seafood processing plants
located in southern Florida along the keys.  The major commodity
processed in this area is shrimp, with lesser amounts of
lobster, crab and finfish.  During 2/15/79 - 2/17/79 an EPA
representative visited several processing plants located on
Key West and Stock Island.  The Florida Department of Environmental
Regulation Marathon Office provided additional information.

The following plants were visited:

       Singleton Packing Corp., Key West

       Singleton Packing Corp., Stock Island

       Coral Shrimp Co., Stock Island

       King Shrimp Co., Stock Island

       Morgan Shrimp Packers, Stock Island

       Key Tex Shrimp Inc., Stock Island

II.  Process Description and Waste Characteristics

Shrimp arrive at the plants by boat.  The heads are removed
at the plant and the shrimp may be manually or mechanically
peeled before packing.  No canning is done at the plants in
this area; seafood commodities are either frozen or packed
in ice for shipping.

Shrimp heads and shells constitute the major source of waste
solids generated by these facilities.  Total pounds of waste
(as shrimp heads) generated per year has been estimated for
some of these facilities.  The following information is
supplied by the Florida Department of Environmental Regulation.

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                           -2-
                                 Ib/year shrimp heads
            Facility                 discharged

  Singleton Packing, Stock Island              315,000

  Coral Shrimp Co., Stock Island                20,000

  King Shrimp Co., Stock Island                 20,000

  Morgan Shrimp Packers, Stock Island          100,000

  Key Tex Shrimp Inc., Stock Island             15,000

All wastes are currently discharged without treatment at
these facilities.

III.  Receiving Water Conditions

The coastal waters around Key West and Stock Island are
polluted by a number of different sources including sewage
plants, power plants and commerical and private boats in
addition to the seafood waste discharges.  The surface waters
near the seafood plant discharge points appeared murky and
oily with bits of floating debris.  Although the seafood
discharges are not wholly responsible for the conditions in
the harbor, they appear to be contributing to degradation of
these waters.

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               EPA Seafood Study-Site Visits to Maine Sardine Canneries


       I.   General

       The Maine sardine canning industry consists of 15 canneries found
       at various locations on or near the Maine coast including bays,
       inlets and estuaries.  As part of the Section 74 Study, I visited
       a number of processing locations during the period 10/17/78-10/20/78
                            waste_trea,tmejit_jractices. and visible aesthetic
                           	waste discharges.  In addTtTon,"! discussed
W- \   th~ese~and other issuesTwith va~rious~pTanirmanagers and with a repre-
       sentative of the Maine Department of Environmental Protection.

       The following facilities were visited:

—		"   Facility      	"   '	"            Discharge Point

            Stinson Canning Co., Bath, ME                Kennebec River

            Holmes Packing, Rockland, ME                 Rockland Harbor

            North Lubec Canning Co., Rockland,  ME        Rockland Harbor

            Port Clyde Packing, Rockland, ME             Rockland Harbor

            Stinson Canning Co., Prospect Harbor, ME     Prospect Harbor

            Sea-pro, Rockland, ME (reduction facility)


       II.  Process Description

       Sardines arrive at the processing facility either by boat or by
       truck.   The fish may be pumped to storage bins or may be processed
r-      directly.  These storage bins contain refrigerated brine (a salt	
       solution) to preserve the fish until they are processed.  Within
       the plant, fish (and waste) are transported to and from the
       processing tables either by flumes or by conveyors.  Conveyor systems
       minimize water contact and thus generate less waste than the fluming
       systems.

       Processing generally consists of removing heads and tails, packing
       into cans, precooking, addition of packing oils or sauces, sealing
       the cans, retorting and cooling.   Most of these steps generate waste
       of various types.  Cans are packed manually.  In some cases, steaking
       machines are used to cut the tail sections into small pieces, which
       are then manually packed into cans.  Precooking occurs before the cans
       are sealed.  This operation partially cooks the sardines and removes
       undesirable fish oils.  Packing sauces or oils are added automatically
       by the sealing machine.  The subsequent  washing process removes any
       waste or oils which may adhere to the cans.  The cans are then automatic-

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ally loaded into the retort, where the final cooking process is com-
pleted at 235°F for one hour.  Fina'
washed again and packed into cases.
pleted at 235°F for one hour.  Finally, the cans are water cooled,
III. Wastewater Characteristics

Sardine canneries are characterized by a relatively low wastewater
flow (10,000-20,000 gallons per day).  However, these facilities
generate significant amounts of biochemical oxygen demanding wastes
(BOD), suspended solids and especially grease and oil.  Specific
processes which contribute a large portion of the waste are head and
tail removal (or steaking) and the steam precook operation, which is
a major source of fish oil.
IV.  Existing Waste Treatment and Recovery Operations

Generally, between 40 and 60 percent of the raw sardine product is
actually canned as a final product.  The remaining 40-60 percent
consists of waste - heads, tails, meat and oil.  A significant amount
of this waste is recovered and is npj^j^cbarged_tp the^loca-l—r-&c.eiyijTg
waters.

The major means of waste collection observed in these facilities
are as follows:

     (1)  Dry collection of heads and tails in the plant before
          they enter the waste stream.

     (2)  Use of rotary or tangential screens to remove small
          particles of waste from the waste stream.

     (3)  Use of oil separator units to recover oil from the
          steam cook process water.   .

Solids generated by screening are either sold to local lobstermen
as bait or sold to a reduction facility (i.e. Sea-pro) where they are
processed into fish meal and oil.  Fish oil collected from the oil
separator units is also sold to the reduction facility for purification.

At several facilities, a portion of the waste stream is segregated
and pumped to the local municipal system.  This generally includes
only the fresh (non-saline) water such as the steam cook water (after
oil separation) and the sanitary waste water.  This fresh water con-
stitutes only about 5 percent of the total waste streams for a typical
facility; the remaining 95 percent of the waste stream (mostly salt
water) is discharged directly (after screening to remove solids).

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c/
v/
 Although  the  existing waste collection technologies (screens and oil
 separators) are  quite simple  in concept, some of the plant managers
 reported  problems  in practical operation of this equipment.  Most
 notably,  one  facility's screen required nearly continuous cleaning
 to prevent clogging.

 Additional information regarding waste recovery processes is pre-
 sented  in the technology and  waste handling sections of this report.


 V.    Receiving Water Effects

 Although  previous  EPA work has characterized the sardine cannery
 effluent  discharges in some detail, no formal ecological effect
 studies have  been  done along  the Maine coast to determine the impact
 of these  effluent  discharges  on the receiving waters.  Hence, the
'information presented here is limited to observations and informa-
 tion  supplied by industry and Maine Department of Environmental
 Protection (DEP) personnel.

 Stinson Canning Co., Bath. Me - This facility discharges screened
 wastewater directly to the Kennebec River (excluding cooker water,
 which is  sent to the local treatment plant).  The outfall discharges
 under a dock  along the shore  of the river where some pieces of waste
 up  to 1/2" could be seen.  However, most of the waste particles were
 very  fine and were mixed with air bubbles introduced by the discharge
 pump.  At high tide, when the water was relatively slack, the cannery
 discharge produced a visible  discoloration of the river water ex-
 tending about thirty feet from shore with some oil visible on the
 surface of the river.  In contrast, during the outward tidal flow,
 the wastewater discharge was  rapidly dispersed.  The plant manager
 indicated that the discoloration from the discharge was due to the
 air bubbles pumped out with the wastewater and that this problem could
 be  solved through  installation of a wastewater holding tank and exten-
 sion  of the outfall.  He further reported that he had received no
 complaints from the surrounding community regarding the effluent
 discharge.

 Holmes Packing, North Lubec Canning Co., and Port Clyde Packing. Rock!and, ME
 These facilities (along with  several local freezing facilities) dis-
 charge screened effluent to Rockland Harbor (excluding cooker water,
 wash  down and can  wash water  which are sent to the municipal treatment
 works).  Although  relatively  little processing was occurring at these
 facilities during  the visit,  a small amount of oil was visible on the
 surface of the harbor (near the discharge points).

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   The plant managers of these facilities feel strongly that the present
   level of treatment (screening with oil separation) is more than
   adequate to protect the environment from adverse effects.  They
   indicated that since the implementation of screening and oil  sepa-
   ration there has been less visible grease on the surface of the harbor
   near the canneries.  However, the plant managers also stated that
   the removal of these wastes (with their nutrients) resulted in fewer
   fish and lobster in the area.  They further indicated that the twelve
   foot tides at Rockland prevented any accumulation of wastes in the
   harbor.

   Maine DEP personnel indicated that the canners have caused some
   environmental problems in Rockland Harbor.  Most notably, there are
   reports of seagulls being coated with oil (floating on the surface)
   and drowning.  In addition, there have been some complaints about
   the oil which tends to coat rocks and adhere to boats in the area.

   Stinson Canning Co.. Prospect Harbor - This facility is located in
   a more remote area than the other sites visited.  Most of the process
   wastewater passes through a screen and is discharged directly.
   The outfall extends about forty feet from shore and discharges the
   effluent into a depth at low water of ten feet.  At this facility,
   the cooker water is not pumped to a municipal treatment works; rather,
   this waste stream passes through an oil separator and is discharged
   directly, resulting in a greater discharge of fish oil than at the
   other plants visited.  The Maine DEP has documented problems  due to
   the floating oil in Prospect Harbor.  This cannery has installed a
   boom on the surface of the harbor above the outfall as a means to
   help contain the fish oil floating on the surface.  The plant manager
   indicated that, since the installation of the boom, they had received
   substantially fewer complaints about the oil.
   VI.  Other information
   JJjeJ1ajn^EP_reqorts_that the..jjlstalJLatlon__pf^ screens_and oil  separator
   units hasj^esulted in irmproved water qual^Uy^ajfiOjBAthetijfs^   Tfiejnajjir
   rem|TnTng~proble^ isTEel-ClJ^JLiiiOis'h oii^which_ is not_always dissi-
   pat^7Diy^UrTenti~and tidaljnovemen£S-»  Existing" oTTTepafator units
/  treat only Ifhe highly oily cooker water; the oil  generated by other
^ processes in the plant is not currently removed.   Technically, it appears
 i that the application of air flotation would substantially decrease
   the amount of oil discharged by the canneries.

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APPENDIX G

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            TECHNOLOGY FOR
  SEAFOOD PROCESSING WASTE
  TREATMENT AND UTILIZATION

                 SECTION 74
  SEAFOOD PROCESSING STUDY
                PREPARED FOR THE
         U.S. ENVIRONMENTAL
         PROTECTION AGENCY
EFFLUENT GUIDELINES DIVISION
                        BY THE
           EDWARD C. JORDAN CO., INC.
                 PORTLAND, MAINE
           CONTRACT NO. 68-01-4931

                    MARCH 1980

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                       Edward C. Jordan Co., Inc.
                       P.O. Box 7050, Downtown Station   •    Portland, Maine 04112
                       Telephone: 207-775-5401                   TELEX: 94^329
 2983-10
 (SL 2.51)
 March 3. 1980
 Mr- Calvin J. Dysinger
 Effluent Guidelines Division (WH-552)
 U.S. Environmental Protection Agency
 Waterside Mall - East Tower
 401, M. Street, S.W. -
 Washington, DC ,20460

 Dear Cal:

 Subject r  Final Report
          Section 74 Seafood Processing Study
          Contract So. 68-01-5772
           i ,            "   V
 Enclosed please find our final report  entitled "Technology for Seafood
 Processing Waste Treatment and Utilization" which is the Jordan Com-
 pany-1 s written contribution to the Section 74 Seafood Processing Study.
 This document reflects the industry comments which were based on the
 draft final report and submitted to EPA on April 17, 1979.  The draft
 version of the report was prepared under EPA Contract No. 68-01-4931.

 In accordance with Woffc Order No. 10,  Jordan Company personnel will be
 available for consultation, until completion of the Section 74 study,
 If you have any specific questions concerning this document or require
 further assistance, please feel free to contact me.

J Sincerely yours,   -^

 EDWARD C. JORDAN. CO., INC.
 David B. Ertz, P.E,
 Technical Project: Director

 DBE/msh

 Enclosure

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               TECHNOLOGY FOR




          SEAFOOD PROCESSING WASTE




          TREATMENT AND UTILIZATION









                   FOR THE




     SECTION 74 SEAFOOD PROCESSING STUDY
                Prepared For









UNITED STATES ENVIRONMENTAL PROTECTION AGENCY




        EFFLUENT GUIDELINES DIVISION




           WASHINGTON, D.C.  20460
                     By




         EDWARD C. JORDAN CO., INC.




                P.O. BOX 7050




               PORTLAND, MAINE









           CONTRACT NO. 68-01-5772









                 MARCH 1980

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                                   ABSTRACT
Section 74  of the  Clean  Water Act  requires  that the United  States  Environ-
mental Protection Agency  evaluate  and report  to Congress  the  effects of sea-
food processes  which discharge untreated  natural wastes  into  marine waters.
To help meet  that  requirement,  this report identifies and describes  in-plant
waste management techniques  and  end-of-pipe wastewater treatment technologies
which  are applicable  to   the  seafood  industry's  pollution control  efforts.
Also described  are  secondary product and byproduct manufacturing  options  and
solid waste handling  and  disposal  methods  which can help  the  industry better
utilize or more acceptably dispose of its waste materials.

The  seafood  industry consists of many  small-scale, seasonal operations which
intermittently  catch  and  process  various  fish species.   For most  of the  in-
dustry, existing  waste management practices are  relatively simple, resulting
in the wasting  of  a significant portion of the raw material brought to shore.
Removal of  a significant  portion  of this  material will depend on developing
potential markets  for new byproducts.  More complete  resource  utilization is
possible  through  continued  research efforts  in  this  area.   Development of
byproduct  markets   can afford  the  opportunity for  improved   utilization of
proteinaceous materials  and concurrently reduce waste volumes  and associated
environmental control costs.

Some  of   the  larger, year-round  seafood processors,  such as   the  large  tuna
canneries and major fish  meal plants, practice more diversified waste manage-
ment and  environmental control methods.  These include  effective  controls on
water  use,  water  recycling techniques, and  better recovery  and  use  of  raw
materials not  incorporated  as  part of  a  human food  (primary) product line.
Wastes can be  turned into secondary products  suitable for human consumption,
such as  fish sticks,  or  they  can be processed into byproducts such as  pet-
foods, meal commodities, and related proteinaceous or nutrient-rich materials.

Some materials  discarded  as wastes cannot  be  converted  into useful products.
Improved  waste  treatment  and  disposal methods  are  required  to   reduce  the
quantity  of  these  wastes  that enter  the environment.  The seafood processing
industry  can  apply-a number of wastewater  treatment and solids handling tech-
nologies  to reduce waste discharges.  Some  of  the most applicable technologies
are  wastewater screening,  biological  treatment  and  dissolved  air flotation
(DAF) in  addition to, or in  conjunction with,  in-plant modifications to reduce
the  amount of  wastes requiring treatment.   Other, more advanced, technologies
are  available but do not appear widely applicable to the industry.

To  reduce the  quantity  of  wastes  entering the environment,  the  seafood  in-
dustry should  improve its  water  and waste management practices,   expand  its
efforts  in  the  area  of  secondary  product and byproduct  manufacturing,  and
incorporate applicable wastawater  treatment and solids disposal technologies.
All  of these  methods have application within the seafood processing industry.

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                               ACKNOWLEDGEMENTS

This report was prepared  under the direction of David  B.  Ertz,  P.E. ,  Project
Engineer with contributions from Lloyd Fogg,  Kenneth Glidden and  George Murgel.
Production of  the printed  document  was accomplished with the  assistance  of
Connie Michaud, Nancy  Rosengren,  Richard  Boothby,  Patricia Fasulo,  and Robert
Faherty.

The direction  and input  provided by Calvin  J. Dysinger,  EPA  Project  Officer
for this study, is acknowledged.

The Jordan Company wishes to thank the industry members,  trade  associations,
equipment manufacturers and suppliers,  and Sea Grant institutions  which pro-
vided  information during  the  conduction  of  this  study.   Specifically,  the
cooperation and assistance of National Food Processors Association,  especially
Jack L.  Cooper who  coordinated the preparation of industry comments regarding
this  report,   is  acknowledged.   Significant  contributions  were  also  made  by
William  R.  Schnell  of Velsicol  Chemical Corporation;  Peter  M. Perceval  of
CHI-AM  International,  Inc.;  E.  Lee  Johnson of  Food Chemicals  and  Research
Laboratories,  Inc.;  James Bray  of Washington  Sea Grant;  Fredric M. Husby  of
the University  of Alaska; and George Snyder  and O.A.  Clemens of  Dravo  Corpor-
ation.
                                      11

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                               TABLE OF CONTENTS
Chapter	Section/Title	Page No.

               ABSTRACT 	    i
               ACKNOWLEDGEMENTS 	    ii
               TABLE OF CONTENTS 	    iii
               LIST OF TABLES 	    vi
               LIST OF FIGURES 	    vii

  1.            INTRODUCTION 	    1

               I.   BACKGROUND 	    1
               II.   SCOPE OF EFFORT 	    1
               III. GENERAL APPROACH TO SECTION 74 STUDY  	    1
               SUMMARY AND CONCLUSIONS 	    3

               I.    NATURE OF THE INDUSTRY 	    3
               II.  WASTE CONTROL AND TREATMENT  	    4
                    A.   Tuna and Modern Fish Meal Processing    4
                    B.   Other Industry Segments 	    4
               III. SEAFOOD WASTE UTILIZATION AND DISPOSAL ..    8
  3.           WASTE CONTROL TECHNOLOGY AND ASSOCIATED COSTS    11

               I.   GENERAL 	   11
               II.  IN-PLANT MANAGEMENT 	   12
                    A.   Water Management  	   14
                    B.   Waste Management  and Associated By-.
                         products 	   16
                    C.   Current Application of In-plant Con-
                         trol Techniques in the Seafood
                         Industry 	   16
               III. END-OF-PIPE TREATMENT  	   19
                    A.   Screening  	   19
                    B.   Oil Separation 	   20
                         1.   Grease Traps  	   20
                         2.   Oil Skimming  	   20
                    C.   Sedimentation 	   20
                    D.   Biological Treatment 	   25
                         1.   Activated Sludge Processes  ....   26
                         2.   Trickling Filters 	   26
                         3.   Rotating Biological Contactors
                              (RBC)  	   26
                         4.   Lagoon Treatment 	   27
                         5.   Biological Treatment with Macro-
                              organisms 	   27
                         6.   Summary - Biological Treatment    29
                                       111

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Chapter	Section/Title	Page No.

  3. Coat.     III. END-OF-PIPE TREATMENT (CONTINUED)
                    E.   Physical-Chemical Treatment 	    29
                         1.   Flotation 	    29
                              a.   Vacuum Flotation 	    30
                              b.   Dissolved Air Flotation ..    30
                              c.   Dispersed Air Flotation ..    32
                              d.   Electroflotation 	    32
                         2.   Advanced Technology 	    33
                              a.   Reverse Osmosis 	    33
                              b.   Activated Clay 	    33
                              c.   Carbon Adsorption 	    33
                              d.   Chemical Precipitation ...    35
                    F.   Land Treatment 	    35
                    G.   Summary - End-Of-Pipe Treatment ....    36
  4.           SEAFOOD WASTE UTILIZATION AND DISPOSAL 	    39

               I.   BACKGROUND  	    39
                    A.   Solids Generation 	    39
                         1.   In-Plant Solids Generation  	    39
                         2.   End-of-Pipe Treatment	    39
                    B.   Current Disposal Practices  	    40
                         1.   Contiguous United States  	    40
                              a.   Secondary Utilization  ....    41
                              b.   Byproduct Manufacturing  ..    41
                              c.   Land Disposal  	    42
                         2.   Alaska  	    43
                              a.   Non-Remote Areas  	    43
                              b.   Remote Areas 	    44
                    C.   Future Considerations 	    44
               II.  SECONDARY PRODUCT DEVELOPMENT  	    45
                    A.   Separation Of Gross Solids At  Source    45
                    B.   Secondary Products From Finfish
                         Wastes 	    46
                    C.   Secondary Products From Shellfish
                         Wastes 	    47
               III. BYPRODUCT MANUFACTURING 	    47
                    A.   General Ingredients 	    47
                    B.   Gross  Solids  	    47
                         1.   Finfish Wastes 	    47
                         2.   Shellfish Wastes 	    50
                    C.   Screened Solids  	    51
                         1.   Finfish Wastes 	    51
                         2.   Shellfish Wastes 	    51
                    D.   Dissolved Air-Flotation  (DAF)  Sludge    51
                         1.   General  	    51
                         2.   DAF Float Characteristics  	    52
                         3.   DAF Float Handling  	    52
                         4.   DAF Float Utilization  	    53
                                        IV

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Chapter
Section/Title
Page No,
  4. Cont.     III.  BYPRODUCT MANUFACTURING (CONTINUED)
                         5.   DAF Float Disposal 	     54
                              a.   Nitrogen Content 	     54
                              b.   Oil and Grease 	     55
                              c.   Sodium Concentration 	     55
                              d.   Salinity 	     55
                              e.   Odor Potential 	     55
                         6.   Summary 	     55
                    E.   Waste Activated Sludge 	     56
                    F.   Summary - Byproduct Manufacturing ..     57
               IV.  MEAL PRODUCTION FROM SEAFOOD WASTES 	     57
                    A.   Background 	     57
                    B.   Alaskan Meal Production 	     58
                         1.   Anchorage 	     59
                         2.   Cordova 	     59
                         3.   Juneau	     60
                         4.   Ketchikan 	     60
                         5.   Kodiak 	     60
                         6.   Petersburg 	     61
                         7.   Naknek - South Naknek 	     61
                         8.   Dutch Harbor 	     61
                         9.   Kenai Penninsula 	     61
               V.   CHITIN/CHITOSAN PRODUCTION FROM SHRIMP
                    AND CRAB WASTES 	     62
                    A.   Description of Chitin/Chitosan Pro-
                         duction Process 	     62
                    B.   Properties and Applications of
                         Chitin/Chitosan 	     62
                    C.   Current Status of Chitin/Chitosan
                         Production	     65
                         1.   Raw Materials 	     65
                         2.   Cost 	     68
                         3.   Markets 	     68
                    D.   Outlook 	     69
               VI.  ULTIMATE DISPOSAL OF SEAFOOD WASTES 	     69
                    A.   Barging 	     70
                    B.   Landfilling 	     70
                    C.   Other Disposal Methods 	     71


APPENDIX

APPENDIX A -   BIBLIOGRAPHY OF DOMESTIC SOURCES 	     A-l
APPENDIX B -   BIBLIOGRAPHY OF FOREIGN SOURCES 	     B-l
APPENDIX C -   SELECTED FOREIGN ABSTRACTS  	     C-l
APPENDIX D -   GLOSSARY OF TERMS 	     D-l

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                                LIST OF TABLES
Table No.	Title	Page No.

   1.          WASTE REDUCTION AND COSTS RELATED TO APPLICA-
               BLE TECHNOLOGY FOR SPECIFIC SEGMENTS OF THE
               SEAFOOD INDUSTRY  	     6

   2..          COST SAVINGS RESULTING FROM THE IMPLEMENTA-
               TION OF IN-PLANT MEASURES TO REDUCE WATER USE
               AND WASTE LOADS  	     13

   3.     -     UTILIZATION OF FINFISH WASTES  	     17

   4.          UTILIZATION OF SHELLFISH WASTES 	     18

   5.          REPRESENTATIVE COSTS FOR SCREENING SYSTEMS
               APPLICABLE TO SELECTED INDUSTRY SEGMENTS  	     36

   6.          REPRESENTATIVE COSTS FOR BIOLOGICAL SYSTEMS
               DESIGNED FOR SELECTED INDUSTRY SEGMENTS  	     37

   7.          REPRESENTATIVE COSTS FOR DAF SYSTEMS APPLICA-
               BLE TO SELECTED  INDUSTRY SEGMENTS  	     38

   8.          IDENTIFIED CHITIN/CHITOSAN APPLICATIONS  	     66
                                       VI

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                                LIST OF FIGURES
Figure No.	Title	Page No,

   1.          UTILIZATION AND DISPOSAL ANTERNATIVES FOR
               WASTES RESULTING FROM SELECTED LEVELS OF
               WASTE CONTROL TECHNOLOGY 	     9

   2.          SCHEMATIC DIAGRAM OF THAW WATER RECYCLE SYSTEM    15

   3.          PERSPECTIVE VIEW OF HORIZONTAL ROTARY SCREEN
               OR ROTOSTRAINER	    21

   4.          PERSPECTIVE VIEW OF A TANGENTIAL OR STATIC
               SCREEN 	    22

   5.          SCHEMATIC LAYOUT FOR A WASTEWATER SCREENING
               SYSTEM 	    23

   6.          TYPICAL GREASE TRAP CONFIGURATIONS 	    24

   7.          PERSPECTIVE VIEW OF ROTATING BIOLOGICAL CON-
               TACTORS OR BIO-SURF PROCESS 	    28

   8.          SCHEMATIC DIAGRAM OF DISSOLVED AIR FLOTATION
               (DAF) TREATMENT SYSTEM 	    31

   9.          SCHEMATIC DIAGRAM OF A REVERSE OSMOSIS UNIT ..    34

  10.          PROCESS SCHEMATIC OF A CONVENTIONAL FISH MEAL
               PLANT WITH SOLUBLES PRODUCTION 	    49

  11.          PROCESS SCHEMATIC FOR CHITIN PRODUCTION FROM
               SHELLFISH WASTES 	    63

  12.          PROCESS SCHEMATIC FOR CHITOSAN PRODUCTION FROM
               CHITIN 	    64
                                      VII

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INTRODUCTION

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                                   CHAPTER 1

                                 INTRODUCTION
I.   BACKGROUND

On December  27,  1977,  the Clean Water Act  of 1977 (PL 95-217) was adopted to
amend several provisions of the Federal Water Pollution Control Act Amendments
of 1972  (PL 92-500).   Section 74  of  the new Act  requires  the  U.S.  Environ-
mental Protection Agency  (EPA) to conduct a study to determine the effects of
seafood processes which dispose of untreated natural wastes into marine waters.
Investigations  must  address   the  geographical,  hydrological and  biological
characteristics  of  such waters.  In addition, technologies  to facilitate the
use of nutrients  in these wastes or to reduce their discharge into the marine
environment  must be examined.   The findings of these investigations are to be
reported to  Congress.
II.  SCOPE OF EFFORT

As  part of  the  overall  Section 74  study,  a  work program was  developed to
identify and  assess the  applicability of various  technologies  for byproduct
manufacturing,  in-plant waste  control, wastewater  treatment, and solids hand-
ling and disposal within the seafood processing industry.

Developing  costs  associated with achieving  waste reductions through in-house
management  and  end-of-pipe treatment  were also  to be  considered during this
effort.(126)  The work program emphasized the  utilization  of  seafood proces-
sing wastes  for human consumption and the manufacturing of byproducts such as
fish meal,  fish  oil  and  chitin/chitosan.   While fish meal  and  fish oil have
established  markets,  the  widespread  use  of  chitin/chitosan  is  subject  to
economic  and  regulatory   constraints.   For  byproducts  which  have  not been
accepted  for animal  consumption  the  regulatory constraints  were  addressed.
The  economics  relating  to  these  manufactured  byproducts,  as well  as  their
marketability,  are  part of the investigations  undertaken by another contrac-
tor, Development  Planning and Research Associates,  Inc.  (DPRA)  of Manhattan,
Kansas.  To assist  in  the market  feasibility  effort,  background information
was developed  regarding the technical aspects  and  the costs of installing and
operating byproduct facilities.

This report  addresses:  1) the control of  seafood processing waste discharges,
and 2)  the  current and potential uses  of  the materials eliminated from plant
effluents.   Discussions  relating  to  disposal  alternatives and  waste  utili-
zation  within the contiguous states also pertain  to Hawaii,  Puerto Rico, Guam,
and  American Samoa.   Other  study participants  are assessing  water quality
impacts  at  various  geographical  locations and  determining the  market  feasi-
bility  of certain,byproducts manufactured  from  seafood wastes.
III.  GENERAL APPROACH TO TECHNOLOGY ASSESSMENT FOR SECTION 74

This report presents information assembled  for earlier development of effluent
limitations  guidelines  for  the seafood  industry and supplemented  with more

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recent  information collected  and  analyzed  to  specifically fulfill  the  re-
quirements of Section 74.  Continuing with the approach established during the
guidelines work,  the general  characteristics  of the  industry  have been con-
sidered during this effort.  The major areas of interest have been:  1) appli-
cable waste control and treatment technology;  and 2) utilization and disposal
of  seafood wastes  resulting from  the  implementation of  control  technology.
More  specific  information regarding  the generation  and  character of seafood
processing wastes  and the methods  available for its  control  and  utilization
can be  found  in the development documents  (42,  43)  and the draft report pre-
pared  for  the  reassessment of  effluent guidelines  for  the  industry. (126)

Foreign and domestic sources of information were identified through manual and
computerized  literature  searches.   Data which appeared pertinent  to the Sec-
tion  74  study  was  requested; all information  received was reviewed and cate-
gorized for summarization in this report.

Technology deemed  to  be  readily applicable to the seafood processing industry
was  emphasized during the  evaluation process.   In-plant  control  and end-of-
pipe  treatment  costs have  been  updated during  this effort.   Conventional
byproduct  manufacturing  which  includes  the production of meal and oil commod-
ities  has been  addressed for selected  areas of  Alaska  and  the contiguous
United  States.   More innovative  techniques  for  utilizing seafood processing
wastes have also received attention.

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SUMMARY AND CONCLUSIONS

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                                   CHAPTER 2

                            SUMMARY AND CONCLUSIONS
This report addresses  two  of the major topic areas relating to the Section 74
seafood processing study:

1.   waste control  technology and the costs associated  with reducing seafood
     waste discharges; and

2.   utilization and disposal of materials incurred through the application of
    . waste control technology.

These topic areas  are examined to indicate  existing  practices  and character-
istics of  the  seafood industry, as well as potential ways for the industry to
achieve further  reductions  in waste discharges to the marine environment.  In
some cases, technologies  which have not been widely  used by the U.S. seafood
processors in the United States have been evaluated based on their application
in foreign countries or within related food processing industries.
I.  NATURE OF THE INDUSTRY

Because  they  have characteristics which are  fundamentally  different  from the
remainder  of  the industry,  the tuna processing segment and  modern fish meal
plants  (with  solubles) should  be assessed  separately  with  respect  to  waste
control  and  utilization.  Many  of the major tuna processors  and  modern fish
meal  plants  practice  on-site  byproduct  recovery  at  levels of sophistication
which are  significantly higher than much of the rest of the seafood industry.
Through  such  practices,  wastes entering  treatment facilities or marine waters
are  minimized.    Major tuna processors  currently  have in-place,  the highest
level of wastewater treatment employed by the industry.

Seafood  processors  comprising  the  remaining  segments of  the industry are
generally  small, seasonal  operations,  often family-owned.  Most  are labor-
intensive  or  operate  antiquated  processing  equipment and  demonstrate limited
and  unsophisticated waste  management techniques  when  compared to  the tuna
processing industry.

The  significance of the  waste loads which are generated by  the seafood pro-
cessors has been  recognized by EPA during its previous investigations.(29, 75,
118,  145)   The  impact of waste discharges from this  industry  has  been docu-
mented at several sites.(29, 75,  118,  145)  Under  the provisions of Section 74
of the Clean Water Act of 1977,  recent data has been collected and analyzed to
develop  an up-to-date summary  of   the  industry's current practices  and the
potential for improving waste management and  raw material utilization.

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II.  WASTE CONTROL AND TREATMENT

A.   Tuna and Modern Fish Meal Processing

Major tuna  canneries  and modern fish meal facilities exemplify the concept of
total raw  material utilization  for the  seafood  industry.   Extensive efforts
are  made by  tuna  processors to  collect materials  which  cannot be  used for
human consumption  for byproduct  recovery.   Some  canneries  recycle  tuna thaw
water,  which is  the  largest  single  source of  wastewater  in the  plant,  to
significantly reduce the volume of wastewater requiring treatment.

Fish  meal   facilities  have  employed  the recycle approach  for  unloading raw
material from boats.   In  some  cases,  a pneumatic  system has been installed
which only requires a small amount of water for operation.   Unloading water is
usually combined with stickwater and washwaters for  the production of solubles
as  a byproduct.  When  recycling is practiced,  condenser  water  and low-con-
tamination  condensate represent  the  largest  volume  of water  discharged  to
receiving  waters.   Because  these  streams have such low levels  of contamina-
tion, they are discharged  directly (without  treatment) to  receiving waters.

The  installation of thaw water recycle systems at canneries less advanced than
some within the industry and the reduction of water  consumption in other areas
are  future considerations  for additional in-plant management  in tuna proces-
sing  segments.   For end-of-pipe  treatment,  the  optimization  of in-place DAF
systems  is in  order.   Some consideration should  also  be  given  to biological
treatment  systems  as  a treatment alternative.  Wastes  from  the  tuna industry
have been  shown to be treatable by biological systems, as demonstrated by the
Terminal  Island,  California municipal  treatment plant.   Effective  treatment
would be realized  since  the tuna  industry  processes essentially year-round;
however,  land  requirements  of  such  systems  could   be  prohibitive  for  some
canners.

Containing  spills   and  reducing  water   use  during washdown are  pertinent  to
modern  fish  meal  facilities.  Pollutant  levels in the  resulting waste stream
are  not great enough to warrant treatment.

Facilities  which  do  not  now  have  the  capability  to  evaporate  the soluble
streams  (stickwater and  bailwater)  can  provide the  necessary  equipment  to  do
so,  or employ barging for deep sea disposal as an alternative.

B.   Other Industry Segments

Although processing activities  vary among the remaining segments  of the sea-
food industry,  the general approach to  proper waste management  and its inhe-
rent benefits remains the same.  The most effective  means to reduce waste dis-
charges from  this portion of the industry would be for processors to generally
upgrade, where  possible, in-plant  operations  to  control  water  use, minimize
water  contamination,  and  reduce  the  wasting  of raw  materials.    A program
employing  such measures  has a  number  of  direct  and  immediate  advantages:

     o     reduced water consumption, resulting in cost reductions;

     o     reduced  waste loadings,  resulting  in  lower  environmental control
           costs;  and

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     o    improved  potential  for  more  complete  raw  material  utilization,
          including the manufacturing of marketable secondary products and by-
          products.

It is important to recognize that reduced water consumption does not result in
a proportional  reduction in  waste  loadings.  Rather, when  water  is  recycled
and used only where  necessary,  the waste  constituents become  concentrated in
the liquid waste  streams.   The  reduced volume and higher concentrations faci-
litate treatment.

The  economic incentives for more  effective in-plant  waste management  are
matched by a growing concern for improved environmental protection on the part
of the  industry.   Processors in the  segments  of the seafood industry other
than tuna and fish meal, generally have  only screening  (a simple technology)
in-place.  An  updated approach  to  waste  control  emphasizes simple physical-
chemical treatment methods (such as DAF) in conjunction with in-plant measures
for  most industry  segments.   This  suggests  that most  operations  generating
relatively  high wastewater  flows  and  loadings  can upgrade  their  wastewater
treatment practices  to  achieve  additional reductions.  However, the cost of
these improvements require consideration for any operation.

For  plants  which generate  low  waste  flows  from  manual  operations, effective
controls include  in-plant waste management practices followed  by screening.
Examples of  such operations  include hand-filleting bottom  fish,  hand-butch-
ering  salmon,  most  crab processing  activities,  and hand-shucking  clams  and
oysters.  Higher  levels  of  treatment are  available  to these  operations if
necessary.   The only plants  which simply grind and discharge their wastes are
plants in remote areas of Alaska.

For  catfish  processing  areas,  which are usually  located  inland,  simple bio-
logical  wastewater  treatment systems  (e.g.,  aerated  lagoons)  are applicable.
Land for such systems is more available away from coastal areas.  In addition,
some  of the  catfish  processors  have  municipal  wastewater  treatment plants
available which can accept processing wastes.

With  few exceptions,  the  waste management  concepts  and wastewater treatment
technologies discussed herein have already, been proven by model plants within
various  segments  of  the seafood industry.   The  levels  of  technology having
application  to  the  various  industry  segments  reflect present knowledge con-
cerning  their  effectiveness and  associated  costs.   They  also reflect  the
special  nature  of the  seafood  industry,  including  its  processing operations
and  geographical  location.   Moreover,  many of  the  technologies  considered
applicable to the seafood industry have  been applied  successfully  by related
food  industries in  the  United  States and abroad.  In the  United States,  re-
lated  food  industries  generally  utilize  the  technologies  discussed herein
along with  other  more advanced technologies, which  are  not applicable to the
seafood  industry, to achieve  higher levels of wastewater treatment.

Applicable technologies,  associated pollutant reductions and associated costs
are presented in Table 1 for  the various  seafood industry segments.

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                                                        TABLE 1
                               WASTE REDUCTIONS AND COSTS RELATED TO APPLICABLE TECHNOLOGY
                                  FOR SPECIFIC SEGMENTS OF THE SEAFOOD INDUSTRY  (126)
Technology
In-Plant
Modification
Iii-Place
Tuna
Fish Meal
(w/solubles)
Industry
Application
Tuna
Fish Meal
(w/o solubles)
Waste Reduction
Minimize Loadings
for Discharge or
Subsequent Treatment
Cost
Installed
$20,000-$220,000
$270,000-$550,000
Range
Daily
$20 -
$275 -

O&M
$250
$560
Screening
Catfish
Blue Crab
West Coast Crab
Shrimp
Breaded Shrimp
Salmon
Bottom Fish
Clam
Oyster
Sardine
Herring Fillet
Abalone

Tuna

Catfish
Blue Crab
West Coast Crab
Shrimp
Breaded Shrimp
Salmon
Bottom Fish
Clam
Oyster
Sardine
Herring Fillet
Abalone
Catfish
Blue Crab
West Coast Crab
Shrimp
Breaded Shrimp
Salmon
Bottom Fish
Clam
Oyster
Sardine
Herring Fillet
Abalone

Tuna

Catfish
Blue Crab
West Coast Crab
Shrimp
Breaded Shrimp
Salmon
Bottom Fish
Clam
Oyster
Sardine
Herring Fillet
Abalone
                                                           Removal of
                                                           Oversize Solids
                                                           (Generally  larger
                                                            than 0.03-inch)
                                                                                          Contiguous  States
                                                                                    $5,000-$75,000       $5 - $75

                                                                                                 Alaska
                                                                                    $10,000-$220,000      $5 - $240
$48,000-$178,000    $24 - $180

       Contiguous States
$46,000-$160,000    $ 7 - $250
                                                                                                  Alaska
                                                                                    $79,000-$260,000    $33 - $270

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                                                   TABLE  1  (Continued)
Technology	

Grease Trap




Air Flotation
In-Place
Sardine
Tuna
Biological Systems
 Aerated Lagoons    Breaded  Shrimp
 Activated Sludge
 Industry
Application
Catfish
Blue Crab
West Coast Crab
Sardine

Tuna*

Salmon*
Bottom FishT
Sardine*
Herring Fillett

Blue Crabt
West Coast Crab*
Shrimp*
Breaded Shrimp!
Clamt
Oyster*
                    Cattish
                    Tuna
                    Tuna
Waste Reduction
                                                                                             Cost Range
Removal of free
oil and grease for
recovery
Finfish
                                                             BOD  : 50-80%
                                                             TSS: 70-95%
                                                             O&G: 80-95%

                                                           Shellfish
                                                             BOD  : 40-65%
                                                             TSS: 60-75%
                                                             O&G: 70-90%
Installed
Daily O&H
                    BOD :  75-85%
                    TSS: 70-80%
                    O&G: 85-95%

                    BOD :  80-90%
                    BOD;?:  80-90%
                    TSS: 75-85%
                    O&G: 85-95%
       Contiguous States
$1,000-$3,000       $2 - $13
            Alaska
$3,000-$11,000      $10 - $80

$200,000-$800,000   $280-$!,800
                                                                       Remaining Segments
                                                                 $178,000-$600,000   $14-$1,000
                       $110,000-$160,000    $45 - $70
                       $190,000-$2,250,OGO  $80-$890
                       $150,000-$!,000,000  $200-$!,000
""Demonstrated on a full-scale  or  pilot  plant  level.
iKngineering judgment based  on performance  achieved  for  related  industry  segments.

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III.  SEAFOOD WASTE UTILIZATION AND DISPOSAL

Wastes  generated  by  seafood processors,  other  than the  tuna and  fish  meal
segments,  are  proteinaceous,  containing  materials  which  have  some  value.
Seafood  processors  are  not always well-equipped to  produce  valuable products
from  their  waste  materials.   It  is not  always  profitable  to  do  so.   Simple
disposal often  represents  the  cheapest and least cumbersome  way  to deal with
unwanted  raw materials  from  the  processing plants.   The industry has  been
utilizing  rather   convenient,  inexpensive  disposal  options  (such  as  direct
ocean  discharge of  raw wastes)  which have  tended  to  discourage  additional
waste material  utilization while  potentially affecting receiving water quali-
ty.  The general philosophy has  been that you can put  back into the sea sub-
stances that came out of the sea.

The more complex   the practices  for waste material  retention or  capture,  the
more need there is for  alternatives for the  utilization or disposal of these
wastes.  Tuna canneries  have installed lines to produce petfood from portions
of  the  fish  which are  not acceptable for  human  consumption.   In addition,
viscera  and  scraps are  collected  for the production of other byproducts,  such
as meal, oil and solubles, requiring equipment similar to that utilized by the
fish meal segment.

Production of fish meal from whole fish  (menhaden and  anchovies)  generates a
concentrated  waste stream called stickwater.  At some  facilities,  stickwater
is  combined  with  unloading  water to generate solubles  by evaporation.   This
byproduct can be   introduced into the meal drying process  or enhance  quality
or, it  can  be marketed  separately, an approach which has been adopted by some
tuna canners.

Tuna  processors employing physical-chemical  treatment  (DAF)  for  their waste-
waters  are  faced with the disposal of the resulting sludge (float).  Current-
ly,  disposal  is   accomplished by  conventional  means,  such  as  landfilling.
Investigations  are  required  to  establish  the  feasibility  of producing  an
animal  feed additive, fertilizer from float, or disposal at sea.

For the remaining  segments of the  industry,  enlightened waste material util-
ization  will require  improved in-plant  waste  management  to  improve solids
recovery.   Solids   which  can  be  collected  and  potentially  utilized  include
gross solids  (heads, viscera, etc.) from the processing lines, screened solids
from  end-of-pipe  treatment  systems, the  solids  captured by physical-chemical
wastewater treatment  systems (such as DAF),  and the solids  generated  by bio-
logical  wastewater  treatment systems.   Once  collected,  these  solids  have
potential for reuse as foodstuffs, nutrient products, animal  feed, fertilizers
and  other useful  materials, depending on the  species  processed,  processing
steps employed, chemicals  used, and the granting of approval  for selected uses
by  the  Food  and Drug Administration (FDA).  Options for the disposal/utiliza-
tion  of wastes resulting  from the implementations  of  waste management prac-
tices are illustrated in Figure 1.

For most finfish  species,  the production of  fish meal offers a means of waste
material  utilization and  disposal.   Fish meal  plants,  similar to  those  in-
stalled  at  tuna canneries,  are  operated by  independent companies  or  cooper-
ating  seafood processors  located  in major processing centers.  The canning of
petfood  products has  also gained some acceptance as a means  of waste material
utilization by  specific segments of the seafood industry.

                                   8

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                         GROSS SOLIDS
                           CONCENTRATED
                         WASTE STREAMS
WASTE ACTIVATED SLUDGE
OAF
TREATMENT
UNITS
BIOLOGICAL
TREATMENT
UNITS
                                                          SECONDARY
                                                          PRODUCTS
                                                                                           BYPRODUCTS
                                                                                                                             DISPOSAL
                           FISH STICKS. CAKM,ETC
                           SSPARATER BOE
                           FISH PROTEIN SPREAD
                           POTENTIAL HiCM 6HAI* PROTEIN
ANIMAL fOOp.
flS.HHlAL.oi
f IS» f E.6W
                                                                                                                      tANO
                                                                                                                      peep SEA PISPQSAL
                                                   FABRICATED MEAT PRODUCTS
                                                   CLAM JUICE PRODUCTS
                                                   DRY FLAVOR INGREDIENTS
                                                   CONCENTRATED BROTH
                                                  r\
MEAL PRODUCTS
FERTILIZER
AOUACULTURE FEED SUPPLEMENT
ANIMAL FEED
CHITIN/CHITOSAN
PEPTONES FOR MICROBIO. MEDIA
r\
                                                                                             GRIND S DISCHARGE
                                                                                             LAND DISPOSAL
                                                                                             DEEP SEA DISPOSAL
                                                          f VlSM MEAL,0|L, 60LU8LES   -" ^      J tANP DISPOSAL
                                                         f  ANIMAL rejo$, f I*M row ~ [  ,  N..,.,,,.,.,X OEE.P SEA OISPC
                                                                                                                          3£A OISPP5AL
                                                                                  \
                                                         S
                                                            MEAL PRODUCTS. FERTILIZER
                                                            AOUACULTURE FEED SUPPLEMENT
                                                            ANIMAL FEED
                                                            CHITIN/CHITOSAN
ANIMAL Pteu ADDITIVE
(SUBJECT JO FOA *PP«OVAU
                        r~\
                                                                                                                      LAND DISPOSAL
                                                                                                                      DEEP SEA DISPOSAL
          LANDFILL
          AGRICULTURAL SHKSAOIN8
                                                            ANIMAL FEED ADDITIVE
                                                            (SUBJECT TO FDA APPROVAL)
                                                            FERTILIZER
                                                            6QIL AMENDMENT
                                                            ANIMAL FBEO
                                                                                                                      LANDFILL
                                                                                                                      AGRICULTURAL SPREADING
                                 LANDFILL
                                 f OIL ENRICHMENT
                                                                                     SOIL AMENDMENT
                                                                                     ANIMAL FEED
                                                                                             LANDFILL
                                                                                             SOIL ENRICHMENT
                         Figure 1.   Utilization  and  disposal alternatives  for wastes
                         resulting  from selected levels  of  waste control  technology.

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Shellfish wastes  (crab  and  shrimp)  can be converted into  a  meal product, but
one which  has a lower  protein  content  and  poorer market value  than  the  meal
from finfish  plants.  Another  byproduct which can be manufactured from shell-
fish (crab and  shrimp)  wastes  is chitin and  its  derivative,  chitosan.  These
natural polymers have potential for a wide range of applications, but have not
been economically produced  in  quantity  in  the  United States.   A  Japanese
manufacturer currently provides most of the  world's supply  of chitin/chitosan.
The future  may bring greater  attention to  the properties of  these  shellfish
derivatives,  thus  attracting a  greater market.  To be  economically competi-
tive,   chitin/  chitosan  would  have  to  be produced at a large regional  or na
tional plant  which  would  need  to receive adequate volumes  of shellfish wastes
from a large number of processors.

Solids which  are  not converted into byproducts require disposal  either on the
land or  in  the ocean.   Land application requires  the  availability of a suit-
able site.  Techniques  are  available to incorporate seafood processing wastes
into the soil to increase nutrient contents  in support of agricultural activi-
ties.   If  simple disposal  is  the key  objective, suitable landfill  sites can
provide the means when they are available.

Conditions in  most  of  the Alaskan processing areas  preclude  land application
or landfilling of seafood processing wastes.   For this isolated segment of the
industry, alternatives  are  thus  limited  to byproduct manufacturing  or ocean
disposal.

Byproduct alternatives  for  the  Alaskan seafood processors  include  the manu-
facture of  fish meal and associated products at  selected  processing centers.
Meal plants   are  currently   operated  in Seward,  Petersburg  and  Kodiak.   The
market  feasibility  of  establishing  regional  meal  plants  in other  Alaskan
locations  is   currently being  evaluated by  DPRA.   Smaller package-type  meal
plants  may  also  represent  a  feasible alternative  for certain processors.
Other  byproduct alternatives  include  freezing  of  gross  finfish solids for
shipment  to  Seattle  petfood  manufacturers  and  the stabilization  of shells
through  deproteinization. The  stabilized shell material and protein  can then
be transported  to  other locations for  byproduct manufacturing or other forms
of utilization.

Designated  ocean  disposal sites  are located within  5 miles  of most Alaskan
seafood processing  centers.  Barging of wastes to these sites  can usually be
accomplished  at a  reasonable  cost,  thus minimizing the impact  on near-shore
waters.

Progressing to higher levels of waste management will increase the quantity of
residuals requiring  utilization or  disposal.   Byproduct production represents
a  solution  for disposal of  gross and screened  solids  at some locations.   For
DAF sludge  disposal, the tuna processors have employed dewatering  and land-
filling.  However,  long-term solutions  to the disposal requirements  for float
and waste activated sludges must continue to be sought.
                                   10

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WASTE CONTROL TECHNOLOGY
     AND ASSOCIATED COSTS

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                                   CHAPTER 3

                 WASTE CONTROL TECHNOLOGY AND ASSOCIATED COSTS
I.   GENERAL

The character  of the  wastes  generated by  seafood processors  relates  to the
species being processed,  the  volume of production, and the processing methods
utilized.   Generally,  mechanized  operations consume more water  and  result in
higher waste loads  per ton of raw material processed  than manual techniques.
Of  the total volume  generated,  the  major  portion of  the waste  consists  of
gross  solids  such  as heads,  viscera, shells  and carcasses.   The  remainder
comprises smaller pieces suspended in the process wastewaters.  Other types of
waste  products  result from subsequent processing  steps  to  produce  specialty
items.  For  example,   some  shrimp  plants incorporate a breading operation as
part of their  normal  activities;  this results in the presence of bread crumbs
and batter in the process waste streams.

Water  is  used  by seafood processors  for  a  number of operations including the
unloading of boats,  the  transport of  raw materials within the plant, various
processing steps,  and washing and cleanup  operations.  Additional uses,  such
as retorting, do not generally result in the contamination of the water; these
noncontact flows can be discharged without treatment.   Acceptable in-plant ma-
nagement  consists  of isolating  noncontact flows  and implementing  measures
which  can reduce the  process  water use and help control  the amount of wastes
that are  allowed to escape into the floor drains and collection system of the
plant.  When  process  contact  water has been allowed  to  leave the processing
area,  it  is known as wastewater.

Concern for  the environmental effects of wastewaters  discharged to  receiving
waters by municipal and  industrial point sources,  including  the seafood  pro-
cessors,  has led the  United States Congress to provide EPA with the authority
to  issue  guidelines   for the  cleanup  and regulation  of these  discharges.
Federal  regulations,   referred  to as  secondary  treatment and  effluent limi-
tations guidelines,  have  specified  the maximum  amount of  waste materials or
pollutants which can be  discharged  by  municipalities  and  industrial point
sources,  including seafood processing plants.

So  far, much  of the  seafood  industry has done  little in terms of controlling
waste  discharges in  comparison to other food  processing  industries.   Other
food  processors, such as meat  packers, poultry processors, and  fruits and
vegetable plants, have adopted more sophisticated and costly technologies  than
those  implemented by  the  seafood industry.  Although  the characteristics of
these  industries  may  differ from those of  the  seafood industry, the concepts
relating  to waste control and treatment for all are comparable.

The assessments  of waste control and  treatment which have been accomplished to
date have identified  special characteristics of  the seafood industry.  Typical
of  most  segments  of  the industry  are  small  processing plants  which often
operate only  intermittently  during the year.   Many of  the smaller plants are
family-owned.   Manual labor  is  prevalent and waste  management practices are
often  antiquated.  An  exception is the tuna industry, which typically operates
on  a  larger  scale and operates essentially year round.   Most tuna processors
                                   11

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also employ  more sophisticated  waste  treatment technologies  than other seg-
ments  of  the industry.   Modern  fish meal facilities also  represent  a higher
level of sophistication in terms  of waste management.

For  the most  part,   seafood  processors  are  located  in built-up  shorefront
areas.   Some are  actually built  over the water on piles, and still others are
located on seagoing  vessels.   In many instances, processors have limited land
available for  expansion  or  the  construction of wastewater treatment facili-
ties.

Technologies for  reducing the discharge of solid and  liquid wastes from sea-
food processing plants  can  be  segregated  into two  categories.   The  first
category  encompasses  in-plant management techniques  and  modified operating
procedures.   The second  classification  involves equipment  and  appurtenances
which  treat  the wastewater after it has left the processing areas.  These are
referred  to as  "end-of-pipe"  technologies  and generally  represent a  more
elaborate approach to waste control than in-plant modifications.
II.  IN-PLANT MANAGEMENT

In-plant  management techniques  and  modified operating  procedures  constitute
two major  areas:   1)  water management  (i.e., the  reduction of water consump-
tion  through housekeeping methods and/or recycle/reuse);   and   2)  waste man-
agement  (i.e.,  control of  waste materials  allowed to enter  the plant efflu-
ent) .  Both  water  conservation and waste management  can help reduce the cost
of implementing end-of-pipe treatment technologies.  Decreased water usage can
reduce the  total  volume of wastewater which requires treatment, thus minimiz-
ing  the  required  size  of treatment equipment and  the associated capital and
operating  costs.    When  the  flow  to treatment  is  reduced,  the  greater cost
savings  are  realized  in total  capital investment,  with a  lesser  impact  on
use-associated  costs.   Similarly,  by decreasing  the amount of  solids which
enter the waste stream, one reduces the amount of wastes  which must be  removed
by  end-of-pipe  treatment technologies.  Again,  equipment sizes and use-asso-
ciated treatment costs, which includes the handling and disposal of residuals,
can then be  reduced.

Table 2 illustrates the impact of in-plant measures on the costs of installing
and operating end-of-pipe treatment facilities.   Representative seafood indus-
try  segments are  listed in the  table,  and  treatment costs are compared based
on  water  use for  a "model" plant and for a plant  which lacks  sufficient in-
plant  controls.  The model  plants and other plants,  although not named, rep-
resent existing plants  which were characterized during  the study to reassess
the effluent  guidelines for the  seafood industry.(126)  Model plants are those
which are  achieving baseline water use and  waste  load values established for
the particular segment.

The  model plants  generate  less wastewater than  plants which lack in-plant
management  practices,  reflecting the  use of water-saving  techniques  by most
model plants.   Since  operating costs are more directly  impacted by flow, the
cost  savings are  more apparent  for  daily operation and  maintenance (O&M) for
all  selected segments.   Cost comparisons show that  processing  plants  in cer-
tain  segments can achieve pollution control at  a  lower  capital investment by
implementing  in-plant modifications prior  to  installing wastewater treatment


                                   12

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                       TABLE 2

  COST SAVINGS RESULTING FROM THE IMPLEMENTATION OF
1N-PLANT MEASURES TO REDUCE WATER USE AND WASTE LOADS
                       In-Plant Cost
End-Of-Pipe Cost
Cost Savings
Industry Plant Size
Segment (Tons/Day)
Northern 8
Shrimp
Tuna 250

Mechanized 35
Salmon

Mechanized 30
Bottom Fish

Steamed 7
and Canned
Oyster
Type Of
Plant
Model
Other
Model
Other
Model

Other
Model

Other
Model

Other
Total Daily
Flow (MGD)
0.10
0.14
0.67
1.14
0.12

0.17
0.09

0.12
0.12

0.14
Capital
($1,000)
15
0
120
0
45

0
35

0
10

0
O&M
($/Day)
10
0
130
0
40

0
25

0
5

0
Capital
($1,000)
295
300
470
670
275

310
310

340
290

320
O&M
($/Day)
415
480
760
1,170
315

500
380

460
465

540
Capital O&M
($1,000) ($/Day)

55

80 280

185


55


20 70


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facilities.  Higher initial costs can be often justified in terms of operating
cost savings.

Comprehensive water and  waste  management programs have been  shown to produce
economic benefits for seafood processors which can break away from traditional
practices  of  discharging  wastes  directly  to  receiving  waters  with  little
regard to either volume or composition.  In-plant modifications and techniques
associated  with comprehensive  water  and  waste  management  programs  are  de-
scribed below.
A.  Water Management

Reduced water  consumption  is  the principle goal of water management.  Another
objective is to  minimize contact between solids and water,  since this allows
organics and proteins to dissolve in the water.  Simple methods can be used to
reduce consumption and minimize solids-water contact.

Many processors use water to unload and transport raw and/or finished products
within the plant.  In some facilities, hydraulic conveyance of waste materials
is  also typical.   Such practices  could be  modified  by  installing conveyor
belts  or  pneumatic (vacuum)  conveying systems.  Pneumatic  equipment has been
used by plants within various segments of the industry to unload raw material
from boats  and to convey waste materials from separation equpment to storage.
Spring-loaded  hose nozzles which  automatically shutoff when  not in  use  are
commercially available  to help  conserve water.  Faucets  can  be installed at
individual  stations  along manual  butchering  tables so  that water  at an un-
occupied  station can be  turned off.  The  installation  of high-pressure hose
and faucet  nozzles and  the use of  high  pressure/low-volume water supply sys-
tems are  other ways  to reduce water consumption within a processing facility.

Some processing steps produce more wastes than others.   Extremely contaminated
water  from  these  areas  can  be  isolated from the main  waste  stream and sub-
jected to separate recovery operations or treatment processes.

More sophisticated water management methods involve the  recycle and reuse of
water.   Some  canneries  recycle water  which  is used  to unload  boats.   Less
contaminated waste streams can  often be directed  to  receiving  areas or raw
material washing  operations  for reuse without treatment.  Water which is used
to  thaw frozen fish could be  reheated  and  recycled as  shown  in Figure  2.  A
similar approach  can be used for washing sealed cans.

In  some  cases, isolated waste streams can  be  converted  into useful products.
For example, an east coast clam processor  converts water used to wash minced
clam  meats  into  a  marketable  product  comparable  to  clam  juice.(66,  161)
Investigations  have  demonstrated  the  potential of  further  processing this
concentrated material into a dry clam flavor ingredient.(74)

In-plant measures such  as  those mentioned above normally require that produc-
tion managers  and employees  of a given  processing  plant become more aware of
conservation  techniques and  their  impact  on  total  plant  water use.   Most
efforts  (such  as  turning  off faucets,  hoses,  and  processing equipment which
require water  for operation) are simple, direct and inexpensive ways to reduce
overall pollution abatement costs for a particular plant.


                                    14

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THAW
      —\
        I
        I
NS j
	 1
i
1
V *



<



k


\

RETENTION
TANK









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  SUMP
                                               \
                                                                       LEGEND



                                                                       	EXISTING


                                                                               PROPOSED


                                                                               PUMP
                                                        ©
                                                                DRAIN TO WASTEWATER SUMP
             Figure 2.   Schematic diagram of thaw water  recycle  system.

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B.  Waste Management and Associated Byproducts

The  principal  goal  of waste  management  is  to  collect the  relatively large
pieces of  waste,  such  as  fish carcasses, viscera,  shells,  discarded scraps,
etc., before they  enter the waste streams.  A major advantage of this concept
is that it provides greater potential for utilizing or converting waste mater-
ials into marketable secondary products or byproducts.

Simple waste management techniques are available  to  most  seafood processors.
Brooms,  shovels,  and/or squeegees  can be employed as  important tools during
dry  cleanup efforts  to collect scraps which have fallen to the floor.  Solids
which- are  collected  in this manner will not be washed into a drain or require
removal  by end-of-pipe technology.   Another technique  consists of  placing
containers under  conveyor belts  and processing tables to  collect  falling or
discarded  scraps.   Once collected,  certain waste  solids  can be utilized to
manufacture either  secondary products or byproducts  having  some value.  Some
progress has  been made in this  area;  however,  efforts toward  achieving the
concept of total utilization have, for the most part, been more fully explored
by  researchers.  Individual  byproducts and secondary products currently being
manufactured or having  potential for future production from finfish and shell-
fish wastes are identified in Tables 3 and 4, respectively.

The  secondary  products and  byproducts which  can  be manufactured  from waste
solids will  be discussed  in more  detail  in the next chapter of this report,
entitled "Seafood Waste Utilization and Disposal".  That discussion will also
address disposal alternatives for plants which lack the opportunity to utilize
their waste materials.
C.   Current Application of In-Plant Control Measures

In-plant  control measures  to  effectively  manage  waste have  been generally
lacking in  the  seafood industry.  The reluctance  of  processors to adopt com-
prehensive waste management programs can be attributed to two factors:  1) the
maintenance  of  traditional practices  and conceptions which  are  based on the
rationale of  "returning to the  sea what came from the sea;"  and 2) the rela-
tively  unsophisticated end-of-pipe technology  adopted by  the  industry which
does not  emphasize  the need for  reducing incoming waste loads.  For example,
plants  located   in  remote areas  of Alaska  grind  processing wastes  for  dis-
charge.   In  non-remote areas  of Alaska and  in the contiguous United States,
general housekeeping  practices  for  controlling wastewater  generation at its
source are encouraged.

With  the  proper incentives,  all segments  of  the industry  can  identify and
adopt  the appropriate, in-plant water and waste management practices.  Allow-
ing  plants  to  continue grinding wastes for  discharge to  the marine environ-
ment,  as  is  currently performed, does  not  provide  the  required incentives.
The  elimination of flumes  for raw material, finished product  and waste  con-
veyance and replacement by  dry handling methods  is  an  example of a simpler,
but  effective means  of reducing  water use and  solids-water contact.  With the
application  of  higher levels of  treatment technology, the  primary step is to
evaluate  in-plant  activities.   It is  readily apparent that in-plant measures
and  process modification  will  play an important  role in  minimizing the  eco-
nomic  impact  on the industry when  implementing more  sophisticated and costly
end-of-pipe treatment  technology.


                                   16

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                               TABLE 3

                  .  UTILIZATION OF FINFISH WASTES
Commodities Currently Being Produced and Marketed:

     a.   Fish meal
     b.   Fish oil
     c.   Fish solubles
     d.   Fish silage
     e.   Petfood
     f.   Machine separated flesh for use in:

          1.    dips
          2.    snacks
          3.    frankfurters
          4.    fish cakes
          5.    fish sticks
          6.    fish loaves

     g.   Fertilizer
     h.   Fish feeds
     i.   Bait

Byproducts which have been Investigated or Suggested:

     a.   Feeds for use in aquaculture (i.e. the artificial cultivation of
          aquatic animals)
     b.   Recovered protein
     c.   Single-cell protein production (e.g. using fish wastes to grow
          yeast cultures)
     d.   Compost nutrients
     e.   Anti-coagulant drugs
                              17

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                               TABLE 4

                   UTILIZATION OF SHELLFISH WASTES
Commodities Currently Being Produced and Marketed:

     a.   Crab Meal
     b.   Fertilizer (37)
     c.   Construction products, e.g. oyster shells (32)
     d.   Clutch-planting media for maintaining the productivity of
          oyster beds, e.g. oyster shells (32)
     e.   Hog feed, e.g. clam shells and crab shells (32)
     f.   Scouring agent for vegetable processing (95)

Byproducts Which Have Been Investigated or Suggested:

     a.   Chitin (from crab or shrimp shells)
     b.   Chitosan (from crab or shrimp shells)
     c.   Industrial acid neutralizer, e.g.  clam and oyster shells (95)
     d.   Substitute in pressed wood panels (95)
     e.   Texture material for paints (95)
     f.   Abrasives (95)
     g.   Filter for oil well drilling mud (95)
     h.   Component in winter tires  (95)
     i.   Pigmentation ingredient (98)
                              18

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III.  END-OF-PIPE TREATMENT

Even the best  water and waste management  techniques  cannot  completely elimi-
nate wastewater  from  a  processing plant.  Many technologies  are available for
treating this wastewater, ranging from relatively simple separation techniques
to  advanced  biological  and physical-chemical processes.   More  advanced tech-
nologies generally produce cleaner discharges, but at higher costs.  Moreover,
the  removal  of more  pollutants  results  in a greater volume  of residuals re-
quiring disposal.

The  levels  of treatment  employed by  seafood  processors have  generally been
low,  reflecting  the  nature  of  the  industry.   In  certain  areas  of Alaska,
in-place  technology  consists of grinding  the  wastes  then discharging the
solids through an  outfall which is either  submerged  or above the water line.
The  grinding  approach which  was conceived to facilitate  solids  dispersal is
consistent  with EPA  policy  for  designated  Alaskan  areas.   However,  this
approach cannot  be  readily considered a total solution for handling the over-
all waste disposal problem.(26)

In  a  few  areas where  processors  are  discharging  to  receiving waters (usually
inland waters)  with  water  quality considerations, more  complex  treatment is
currently  required by  state-level  environmental control  agencies.   However,
the  technology is   available  for seafood  processors,  in general,  to further
reduce  wastes  which  are discharged  to  the marine  environment.   End-of-pipe
treatment approaches being utilized or currently available to the industry are
described below.
A.  Screening

In general,  screening  is the primary step in removing solids from wastewaters
generated  by the food  industry.   Meat packers  and  poultry processors employ
screening  equipment  prior  to  subjecting process  waters  to higher  levels  of
treatment.   However,  most  seafood processors  use screens to  capture solids
from the wastewater prior to discharging to receiving waters.  Screened solids
are usually  collected  in hoppers, totes, trucks,  etc.,  and in some cases are
used  to manufacture  byproducts.   Available  screening  devices for  gross and
fine solids  removal include the following.

     Coarse  solids removal equipment:

     a.    revolving drums (inclined and horizontal);

     b.    basket screens;

     c.    belt screens;

     d.    inclined troughs;

     e.    bar screens; and

     f.    drilled plates.
                                   19

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     Fine screening equipment (20-mesh equivalent):

     a.   revolving drums (inclined, horizontal, and vertical axes);

     b.   tangential screens (pressure or gravity fed);  and

     c.   vibrating or oscillating screens (linear or circular motion).

As indicated  above,  a  variety of solids recovery equipment with various sizes
of openings  is available  to the processor.   Frequently,  a  coarse screen is
used ahead of and in series with fine screens.  The most common equipment for
gross  solids  removal has been observed to be the revolving drum-type.  Screen
opening sizes are generally %-inch diameter or larger.  These units remove the
larger solids  and reduce loadings to fine screens.   Revolving  drums and tan-
gential screens are  commonly used by the  seafood industry for fine screening
and  are  illustrated  in Figures  3  and 4,  respectively.    Current practices
include the use of fine  screens by most segments of the industry.  Figure 5 is
a  schematic   diagram  of a  typical  screening installation  which  includes  a
collection  sump,   pump(s),  screen(s),  solids conveyance  and  solids  storage
hopper.  An outfall is also required to direct the screened effluent to marine
waters or subsequent treatment.


B.  Oil Separation

Many marine animals contain natural fats (oil and grease) which can find their
way into the process wastewater.  Particularly oily species, such as sardines,
may  contribute so much  fat that  special techniques  for  its  removal  may be
justified.   Grease traps and  oil skimming mechanisms are  used for this pur-
pose.  In  many instances,  the recovered  material  can be  reprocessed into a
salable byproduct.
1.  Grease Traps.  Earlier  investigations  indicated grease traps to be appli-
cable  technology  for selected segments of the industry, including catfish and
crab processors.  Grease traps are basically tanks which allow the fats, which
are  lighter  than  water,  to  rise to  the  surface  where  they can  be removed
either by manual or  by mechanical means.  Figure 6 illustrates typical config-
urations  for a grease  trap which  can reduce the  quantity of  fats  and oils
entering receiving waters where they would float to the surface.
2.  Oil Skimming.  Oil  skimming,  which functions under the same principles as
grease  traps,  has been adopted by  the sardine  canning  industry  for a small
concentrated  waste  stream.   The wastewater  resulting  from  the  precooking
operation is isolated and directed to the skimmer, where  free oil is recovered
for  sale  to a  Tenderer.   Therefore,  a portion  of  the  costs associated with
this equipment is recovered through the sale of a waste material.
C.  Sedimentation

Pollutant  particles  which  are  heavier than water will  tend  to  settle to the
bottom  of  a quiescent tank.  The  level of  technology which takes advantage of


                                   20

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                           HEA080X
                                                                      ROTARY SCREEN
WASTEWATER FEED INLET
                                                                               DOCTOR
                                                                               SLAOE
                                                            SOLIDS FOR COLLECTION
        Figure  3.   Perspective v>^w of a horizontal rotary screen
                  or Rotostrainer (Hycor Corporation).
                                     21

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SURGE FLAP
OVERSIZE
SOLIDS FOR
COLLECTION
                                                             HEAOBOX
                                                             WASTEWATER
                                                             FEED INLET
                                                             STAINLESS
                                                             STEEL SCREEN
      Figure  4.   Perspective  view of  a tangential or  static  screen.


                                   22

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N>
LO
                 RAW WASTEWATER
                                        COLLECTION
                                          SUMP
                                                        SCREEN










PUM
(P

(P

in.
                                                                  SOLIDS
                                                               .5 CONVEYOR
                                                           SCREEN
                                                      SCREENED
                                                      WASTEWATER
                                                      TO OUTFALL OR
                                                      FURTHER TREATMENT
                          SOLIDS
                      STORAGE HOPPER
                           Figure 5.   Schematic layout  for a wastewater  screening system.

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                                REMOVABLE COVER
     INLET PIPE.
                              J ""=»»• OUTLET
                RECTANGULAR CONFIGURATION
                USING A CONCRETE BOX
                               REMOVABLE COVER
     INLET PIPE
n
                                    .OUTLET
                                    -CLAY TILE PIPE
               CIRCULAR CONFIGURATION
               USING CLAY TILE PIPE
                              REMOVABLE COVER

                                  4-CLEANOUT

                                       OUTLET
                 CONVENTIONAL CONFIGURATION
                 FOR SMALLER VOLUMES
Figure 6.   Typical  grease  trap configurations.
                       24

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this principle is called sedimentation, and includes grit chambers, sedimenta-
tion tanks and clarifiers.

Grit chambers have  been found to be applicable to clam and oyster processors.
They are  designed  to  remove heavy, "gritty" materials such as sand, dirt, and
shell  fragments  which  could  erode or damage  wastewater treatment equipment.
When installed,  grit  chambers are commonly placed before screens or any other
treatment equipment.

Sedimentation is not  applicable  for the majority of the seafood industry.  To
accomplish  separation of organic  solids,  wastewater needs to  be  retained in
the  tanks  for long periods of  time.   The putrescible  nature  of  fish wastes
prohibits the use of sedimentation by most of the industry.
D.  Biological Treatment

Biological treatment  systems  are designed to foster the  growth  of microorga-
nisms which are capable of decomposing waste matter.  Most systems require the
removal  of larger  solids and  consist of  a  mixed culture  of  microorganisms
which include protozoans,  bacteria,  yeast and rotifers.  Keeping these organ-
isms propogating  presents a  difficulty for  seafood  processors  which  do not
maintain  a regular  schedule or process  year-round.   When  their activities
cease,  no  wastes are  generated  and  the organisms are  thus  deprived  of their
food source.   Although short-term interruptions may not  significantly impair
the effectiveness of  certain systems, extended shutdown periods  would require
that the organisms be provided with a supplemental energy source, such as fish
food, to maintain acceptable pollutant removals.  Other considerations include
sudden  increases  in  waste loads,  called shock loadings,  which  can  have  an
adverse effect on the organisms  involved.  In addition, cold temperatures slow
down the  activity of  the organisms, thus decreasing the efficiency of biolog-
ical systems.

Although  they have  not  received  widespread  application within  the  seafood
industry,  biological  processes  comprise a common technology for the treatment
of municipal wastewaters and other effluents generated by some segments of the
food processing industry.  The organisms effecting treatment within the system
can be maintained in liquid suspension, or they can attach themselves to fixed
surfaces.  Fixed-growth  systems, which include trickling filters and rotating
biological contactors  (KBC), offer  a greater  resistance to  shock loads than
the  suspended biomass systems,  particularly if multiple stages of treatment
are used.  However, the attached biomass requires exposure to air as an oxygen
source.   To   prevent  freezing during  winter  operation in  northern climates,
trickling  filters and RBC's can  be covered or installed in a building.

Biological systems  can be generally classified according to the type of envi-
ronment  provided  for  the  life   forms.  Aerobic systems promote  the growth of
organisms  which  can exist  in the presence of dissolved oxygen,  whereas an-
aerobic systems are limited to organisms that thrive in the  absence of oxygen.
Various  biological  processes have been adopted by industries and municipali-
ties to reduce organic loads discharged to receiving waters.  Lagoon treatment
which employs either an aerobic  or anaerobic process represents a low-activity
system.  Examples of  high-rate  aerobic systems include the  fixed growth pro-
cesses and activated sludge systems.
                                   25

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Wastewater  which leaves  a high-rate  biological  reactor carries  clumps,  or
floes,  of microorganisms  and  solids with  it.   Sedimentation  techniques,  as
discussed earlier,  are  then required to remove  the  flocculated organisms and
related solids.  A  clarifier,  which can be a circular tank ranging from 50 ft
to  300  ft  in  diameter,  follows  the  biological  reactor  for  this  purpose.
Although areas required for the high-rate biological systems themselves can be
relatively  small,  additional  land is necessary  to  accommodate the clarifiers
and any other ancillary equipment.

Several  alternatives  exist for  both high-r"ate  biological  systems and lagoon
treatment,  each  with inherent advantages and disadvantages.   A brief discus-
sion "of the available options for achieving secondary treatment of wastewaters
is provided below.
1.  Activated Sludge Processes.  Activated  sludge  treatment and its modifica-
tions are  aerobic,  suspended growth processes.   Wastewater is conveyed to an
aeration tank,  into  which air (oxygen)  is  mechanically  introduced to sustain
biological  activity.   When  properly  designed and skillfully  operated,  such
systems can achieve high degrees of treatment, particularly for BOD..  Conven-
tional  systems  retain  the wastewater  for 24 hours or less.  A modification of
the activated  sludge process is extended aeration, in which the wastewater is
retained in  the aeration tank for longer periods  of  time.  Extended aeration
systems  can  better tolerate  shock loadings which are  characteristic of many
food processing operations.   Application of the extended aeration process has
been demonstrated on pilot plant and full-scale levels.(39, 86)  All activated
sludge  systems  generate  biomass which  must be wasted  and then  handled for
ultimate disposal.
2.  Trickling Filters.   Trickling filters  are  basically large circular tanks
filled with  plastic media or rocks.  Wastewater  is  distributed over .the sur-
face of the  filter with  spray nozzles.  As wastewater filters down through the
media, it  is brought into contact with  microorganisms  attached to the media.
The  mass  of  the  microorganisms  increases  with continued wastewater applica-
tion, and  eventually sloughing will occur.   Thus, the  treated wastewater and
clumps of  biomass are directed from the  bottom of the  filter to a sedimenta-
tion  tank  which  allows  phase separation to  occur for  discharge of clarified
effluent.  The  resulting sludge  (biomass)  is generally dewatered further for
ultimate disposal.

In  recent years,  the  trickling  filter  approach has  decreased  in  relative
importance as  a means for achieving secondary  treatment.  However, its appli-
cation  to reduce organic  loadings  prior  to activated  sludge  processes has
gained acceptance.


3.  Rotating Biological  Contactors (RBC).   Another example  of  the fixed bio-
mass  approach  is  rotating  biological contactors.  As  shown in Figure 7, RBC
systems  contain a  series of disks arranged  along a  horizontal axis  and rep-
resents  a  compact  system.   The  disks  are  partially submerged  in the waste-
water.  As  these  disks  rotate, microorganisms  which  attach themselves to the
disks are  alternately submerged  and removed  from the liquid.  Aerobic oxida-
tion  is  effected,  thus  increasing the biomass on the  media.  As the biomass
                                    26

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grows and rotates, the sloughing phenomenon occurs.  Clarification must follow
the contactors  to  obtain an acceptable effluent for discharge.  The separated
biological  solids  are handled  in  much the same manner as  those  removed from
trickling filter  effluents.   The effectiveness  of the RBC process for seafood
processing wastewaters has been investigated for fish and shellfish operations
on a small scale.(3, 70)

4.  Lagoon Treatment.  Wastewater  treatment  lagoons  are usually flat-bottomed
basins enclosed by sloped, earthen dikes.  The depth of the basins varies with
the specific  type of  process selected.   For example,  aerobic  ponds  assume a
liquid depth  of 2  to 5 ft while  anaerobic  lagoons  may be up  to  20  ft deep.
Because they  contain such large volumes of wastewater, lagoons are not highly
sensitive to fluctuations in hydraulic and organic loadings.  As a result, the
systems  can offer  reasonable  long-term performance  in  treating  the inter-
mittent waste loads generally associated with the seafood industry.

Other  food  processing industries  use various modes  of wastewater lagooning,
including aerobic  and anaerobic  processes.   The  oxygen  required to  maintain
aerobic  conditions  can  be  introduced into  the  basins  either  naturally  or
mechanically.   If  air is mechanically forced into the wastewater, the lagoons
can be deeper,  which is an advantage  in cold climates and areas with limited
land availability.

Aeration is not required in anaerobic lagoons.  However,  the organisms which
are used  in an anaerobic system are  less  active  than those available in aer-
obic systems.  Consequently, the wastewater must be retained in the lagoon for
a  longer period of time.  Longer  retention periods require larger land areas.
In addition,  the salt content of  some seafood processing wastewaters  can have
a  harmful  impact  on the  anaerobic  organisms.(115)   Odors   associated  with
anaerobic treatment  can  also pose  a problem.

Indications are  that more interest has been generated regarding lagoon treat-
ment of  seafood wastewaters than  for  other biological alternatives previously
mentioned.  Aerobic  lagoons have been investigated for treating shrimp, crab,
and  clam  processing  wastewaters.(68,  136, 162)   Conventional  anaerobic pro-
cesses have been  studied  for crab  and  shrimp process  waters; however, they
were  not found  to  be  well  suited  to  screened breaded  shrimp  wastewaters.
(113,  135)   The major disadvantage of  both types of  lagoons  is their rela-
tively large land requirement.


5.  Biological Treatment With Macroorganisms.  Life  forms  larger  than micro-
organisms can also  be used  to  remove pollutants from  wastewaters,  and then
harvested for non-human  consumptive  uses.  One  investigator has studied the
use of municipal wastewaters  as a  food source for crustaceans and finfish.(157)
Similar  schemes have  reduced pollutant levels in the  wastewater,  while pro-
ducing harvestable  and marketable products.  Fish grown  in wastewater can be
used for bait,  restocking, petfood or  other non-human consumptive uses.  Other
investigators have used  municipal  wastewater to grow algae, which was then fed
to bivalve mollusks,  lobsters and  finfish.(41, 56, 91,  131, 132)

Additional  studies have  shown  that fish  processing wastes can serve as food
sources for crab and  salmon.  Moreover,  seafood  wastes were  found to be com-
petitive with commercially  available  fish  foods.(133, 157)


                                   27

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CO
              LAYERED MEDIA WITH
              ATTACHED BIOMASS
        WASTEWATER
        LEVEL
        CONCRETE
        TANK
                    CENTRAL SUPPORTING SHAFT
                                 DRIVE MECHANISM FOR
                                 ROTATING DISCS
HOUSING FOR PROTECTION
AGAINST INCLEMENT
WEATHER
                                                                                                           WASTEWATER
                                                                                                           FEED INLET
                              Figure 7.   Perspective view of rotating biological contactors
                                       or Bio-Surf process (Autotrol Corporation).

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6.  Summary - Biological Treatment.   In  general,  activated sludge  treatment
systems  would have  some difficulty  in  effectively treating  the  wastewaters
emanating  from  seafood processing  plants  which operate  intermittently.   Ex-
tended aeration  represents  the most attractive modification for  effluents of
this  nature.   Attached growth  systems,  such as trickling  filters  and RBC's,
would  be  inhibited similarly,  but to a  lesser degree.   Clarification is re-
quired for all of  these high-rate aerobic processes.  Such systems  are  more
applicable to continuously-operated plants, such as the larger  tuna canneries,
which  have  a  consistent supply of  raw material.   Vessels travel  thousands of
miles  year-round to  harvest  fish and  return  them  to port.   This  practice
enables  most  tuna  canneries to  process  year-round at  a normalized  rate of
production.  Nevertheless,  the  limiting  factor  for this processing segment is
the  availability of sufficient land to expand  existing treatment facilities.
Although  high-rate  systems  require smaller reactors,  additional  area  must be
provided for clarification.

Aerated lagoons can reliably handle the intermittent and highly variable waste
loads  which are  characteristic of  the major portion  of the seafood industry.
Studies  have  shown that  finfish and shellfish wastewaters can be adequately
treated  in  aerated  lagoons.  The major disadvantage of  lagoons is their land
requirement,  which  limits  their  application  to most  subcategories.   Limita-
tions  on land availability  are apparently not a  problem for catfish processors
which  are located inland, away from coastal zones.
E.  Physical-Chemical Treatment

Physical-chemical  treatment  technology  employs  nonbiological  processes  to
remove  pollutants  from  wastewater.   Processes  of  this  nature are  usually
applied  after  more basic  treatment,  such as  screening,  has  already  removed
larger solids from the waste stream.  Solids which remain are mostly small and
evenly dispersed  throughout the  liquid.   Certain physical-chemical processes
promote  the  gathering  and isolation of these smaller particles so they can be
removed  from the  wastewater more easily.   For example, chemicals can be added
to  help precipitate  certain  pollutants  from  solution.    Electrical  charge
fields can also help stabilize charged particles to facilitate coagulation and
eventually their removal from solution.
1.  Flotation.   One  of the  most common forms  of  physical-chemical treatment
for  food processing  wastewaters is  flotation, in  which  chemicals and  gas
bubbles  are  introduced into  the wastewater.   In  a  tank,  the  chemicals help
fine solids  and  oil  particles gather into clumps  or  floes.  Tiny gas bubbles
attach themselves  to  these floes, assisting them to  the surface of the water.
The  floating material  is  then mechanically skimmed  away,  leaving  an  inter-
mediate layer of clearer water behind.  Heavier solids settle to the bottom of
the tank and are removed periodically.

Because  flotation  represents  a relatively  simple technology and takes up less
space  than  sedimentation,  it has received considerable  attention  with regard
to treating  wastewaters generated by the seafood industry.   It is also better
suited to  the types  of wastewaters  generated  by  much  of  the  industry.  Red
meat, poultry processing  and rendering industries  have  made  extensive  use of
flotation, usually preceding biological treatment facilities.
                                   29

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The application of  flotation technology to a variety  of  related seafood pro-
cessing effluents has  been discussed by a number of foreign sources.   Specif-
ically,  successful  treatment  of wastewaters has  been achieved  for  Japanese
facilities which  process  cod,  mackerel,  squid,  tuna  and  sardines.(248,  249)
Flotation  has  also  been  described  for  fish  oil  and protein  recovery. (76)
Government reports  for  seven  Swedish processing plants addressed  the physi-
cal-chemical  treatment  of  food processing  effluents, including fish waste-
waters and combined waste streams.(202, 205,  206, 234,  248, 249,  250)

Flotation  methods,  which  are  classified  according to  the technique  used  to
produce the  tiny  gas  bubbles,  include:  a) vacuum flotation;  b)  dissolved air
flotation  (DAF);  c)  dispersed air flotation; and  d) electroflotation.  These
methods are described below.
     a.  Vacuum Flotation

     Vacuum  flotation  has  not received widespread acceptance within  the food
     processing industry or for other conventional applications.

     b.  Dissolved Air Flotation

     As  shown  in Figure  8,  dissolved  air  flotation (DAF) relies  on a pres-
     surized tank,  where air  is  dissolved into the wastewater at conditions
     above  atmospheric  pressure.   This pressure is relieved  in the flotation
     tank,  allowing  tiny air  bubbles  to  form and rise to  the  surface.  This
     effervescence is  analagous to  the bubbling of  a  carbonated  soft drink
     after  it  is  opened.   As the air  bubbles  rise,  they  carry with them many
     of  the pollutant  particles,  oil and grease suspended  in the wastewater.

     As early as 1970, the application of DAF technology to the seafood indus-
     try  was  investigated.   Specific wastewaters  examined   included  those
     generated by  the processing  of salmon, bottomfish,  and sardine.(5,  35)
     Less elaborate  studies  have  addressed the flotation of  herring  crab  and
     shrimp processing effluents.

     DAF technology  is  currently  being used at a number  of tuna canneries in
     California, Puerto  Rico  and  American Samoa. (46,  48)   It  has also been
     investigated on a full-scale  level  for a  shrimp  and oyster cannery in
     Louisiana.(83)

     Screening is employed  prior  to flotation at all in-place  facilities.   A
     variety of  substances  are commercially available for chemically treating
     the wastewater prior to flotation.  Although chemical conditioning limits
     the disposal/utilization  options  for the floated material, the available
     information indicates  that chemical  conditioning is  necessary to provide
     acceptable  performance for  dissolved  air  flotation systems.   Only  one
     facility, a California  tuna  cannery, has elected not to add chemicals to
     enhance pollutant removals from process wastewaters.   However, additional
     equipment  which  is  capable  of reducing pollutant  loadings  to  the  DAF
     system has been provided.
                                   30

-------
LEGEND
         WASTE WATER
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       Figure 8.  Schematic diagram of dissolved air flotation (DAF)  treatment system.

-------
     c.   Dispersed Air Flotation

     Disperse air flotation technology  introduces  air bubbles  into the waste-
     water mechanically  or  by  direct injection  at the bottom of  a  flotation
     tank.  This approach has been  investigated  on a pilot plant  level for a
     number  of   seafood  processing  wastewaters   (shrimp,  tuna  and  salmon).
     Full-scale  applications have been  limited to  a Terminal  Island,  Califor-
     nia,  tuna  cannery  and a  trout  processing  plant  in  Idaho.(46,   77)   In
     Russia,   excellent  performance was  achieved  for  a  flotation cell  with
     mechanically induced air  treating fish processing effluent.(243)
     d.   Electroflotation

     Electroflotation uses  electric current  (electrolysis)  to generate  tiny
     hydrogen and  oxygen bubbles  which  are used  to  float  the  pollutants.
     Electroflotation is  mechanically simpler  and  reportedly offers  several
     other advantages over DAF.   It produces less turbulence, which  can  tend
     to  detach bubbles  from  the  solids.   In addition,  destabilization of  fine
     particles is achieved electrically,  which  reduces the quantity of chemi-
     cals required for  effective  removal.   The  major disadvantage of electro-
     flotation is its excessive power requirement.

     Flotation  induced  by electrolysis  has been established as  a  potential
     pollution control  technology  for the food industry.  Although  some  pri-
     vate testing has been performed on tuna cannery effluents,  seafood plants
     have not yet adopted  this technology on a  full-scale level.   A study has
     been funded by  EPA to  determine the applicability of electroflotation to
     the New England seafood processing industry.

     It   is  important that the economics of this technology  be  considered in
     conjunction  with  its  technical  applicability.   Recent  input from  the
     equipment manufacturers  indicates  the need to combine the  principles of
     electroflotation with dissolved air systems to  achieve hybrid systems for
     economic feasibility.  Specific  information  relative to  the basic design
     criteria and operating parameters (power and chemicals)  is unavailable at
     present.   However, a  significant  advantage  identified  for the  hybrid
     system  is  the   concentration  of  the floated material within  the  unit to
     about twice the normal levels.

     It   is  apparent  that electroflotation has not been demonstrated suffici-
     ently to gain wide acceptance by the  seafood processing industry.   How-
     ever,  some  information  has   been  developed in  Japan for treating  fish
     wastewaters with electroflotation; the information provides an indication
     of  the capabilities of this process.(82)

Flotation  technology has  been employed  for treating  a  variety of  food  and
seafood  processing wastewaters  throughout  the world.   For a given wastewater,
available  information  indicates  that  waste removal rates are  comparable for
the  various  flotation methods.  Efficiencies vary for different  wastewaters,
and the  inherent advantages and disadvantages of each flotation method must be
considered for the specific wastewater to be treated.
                                   32

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2.  Advanced Technology.   There  are  physical-chemical  treatment  processes
which  are  considerably more  sophisticated  than  flotation.   However,  these
advanced systems are  seldom  considered by seafood processors, which generally
employ simpler, less expensive techniques.

Possible  applications  have been identified for  advanced  treatment processes.
For example,  regulatory agencies  in certain states are requiring treatment of
the highly  contaminated water,  called bailwater, used  to  unload  boats filled
with menhaden.   Plants of this  nature are being encouraged  to  evaporate the
bailwater to  produce  fish solubles which can be  sold  as  a byproduct.  If the
waste stream  can be concentrated before evaporation, then the costs of evapo-
ration  can  be reduced.   Some advanced technologies can fill  this  or similar
needs, as described below.

     a.  Reverse Osmosis

     Reverse  osmosis  is one  advanced technology which  can concentrate waste-
     water to produce a smaller volume for utilization, treatment or disposal.
     A  schematic diagram  of  the process can be found in Figure 9.  Wastewater
     and pure water are present on opposite sides of a semipermeable membrane,
     through  which  only  extremely  small  particles  (such  as  water molecules)
     can pass.  High pressure is placed on the wastewater side of the membrane
     forcing  water  molecules through  the membrane into the  pure water side,
     Therefore, a  concentrated solution  remains  on the wastewater side.  The
     water which has been filtered through the membrane is  usually pure enough
     to  reuse within  the  plant for  washdown  or similar  purposes.(1)   If no
     pressure were  applied,  a natural process called osmosis  would cause the
     pure water to  enter the wastewater  side of  the membrane in an effort to
     equalize  concentrations.   The  application  of pressure  reverses  this
     process; hence the name reverse osmosis.
     b.  Activated Clay

     Pollutants  can  be reduced significantly by passing  bailwater  through an
     acid-activated  clay column.(124)   This process  is  much  like  filtering
     water through sand.   Since the spaces between clay particles are smaller
     than  those  between sand  particles,  this method  is  more  effective  than
     using sand.   In addition, activation of the clay makes the adsorption of
     organics possible, thus reducing organic pollutant loadings discharged to
     surface waters.
     c.  Carbon Adsorption

     Carbon  adsorption columns  work much  like acid-activated  clay columns.
     Granular  carbon  is  generally used instead of clay.  The carbon is speci-
     ally  treated  (activated)  to  increase  the  surface  area  of  the  carbon
     granules  and  their  ability to attract and hold  or adsorb pollutant par-
     ticles.
                                   33

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                       34

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     d.  Chemical Precipitation

     Chemical  precipitation  can  remove  colloidal  and suspended  pollutants
     which have escaped other treatment schemes.   Chemicals which are added to
     the wastewater  combine with  colloidal and suspended  matter forming lar-
     ger,  insoluble   particles.   These  heavy particles  then  settle to  the
     bottom of a  tank for easy collection.  The principles of this technology
     are much the  same  as  those  for air flotation,  except for  the  actual
     removal mechanism.

There are  several  other advanced  technologies available for the renovation of
wastewater, including  ion exchange,  filtration,  electrodialysis, and chemical
oxidation.   However,   such  sophisticated methods  appear  unwarranted for  the
treatment  of  seafood  processing  wastewaters.   Further, wastewater treatment
beyond screening has not been encouraged for most processors.

In  some  instances, advanced  wastewater treatment may  be  desired  to produce
renovated water for in-plant reuse.   However,  most processors  generally do not
presently  have to  worry about process water availability.  Any  reuse concept
must meet  the requirements  of  the  Food and Drug Administration prior  to  im-
plementation.
F.  Land Treatment

The natural  filtering  properties  of the soil and associated plant life can be
exploited by pumping or spraying wastewaters onto the land.  This approach for
wastewater  renovation  is viable  when  sufficient and suitable  land  is avail-
able.  Existing  soil  conditions  largely determine the suitability of  a site.
For much  of the  industry, adequate land areas  are  either severely limited or
unavailable.

Three  general  approaches have been developed for applying  wastewater to se-
lected land  areas:   1) irrigation of a cover  crop  or vegetation; 2) allowing
the water to run over  the soil which is covered by vegetation; and 3) allowing
the water to infiltrate the soil.  Seafood processing effluents require pre-
treatment  (a minimum  of  fine screening)  before they can be applied  to the
land.  Overland  flow  and infiltration-percolation alternatives will  generally
require substantial pretreatment to avoid operational problems.

For an irrigation system, wastewater can be distributed over a designated land
area by  spraying or flooding.  Screening and/or  sedimentation  is required to
prevent solids from plugging spray nozzles or clogging the soil.  Ultimately,
undesirable odors and  system failure can result from soil clogging.

Several factors  must  be considered when applying seafood processing effluents
to vegetated land.  A  primary concern is the total dissolved solids content of
the effluent, particularly the sodium concentration.   Large uses of salt water
during plant  operations could prove to be  incompatible  with irrigation tech-
nology.  Evaluations  relative  to  the specific wastewater requiring renovation
and the site under  consideration are recommended.

Climate  is   also important  when  considering irrigation  systems.   Irrigation
systems  located   in cold climates  may  require  storage  facilities,  depending
upon the timing  and length of the processing season.

                                   35

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A final concern  is  the determination of loading rates.  Wastewater character-
istics  dictate  whether  hydraulic  application  rates  or  other  factors  will
control.   With a  proteinaceous wastewater,  such  as  that  found within  the
seafood industry,  nitrogen loadings  must  be considered.   To  prevent ground-
water contamination,  the soil  and plant system must be  able to fully assimi-
late the amount of nitrogen being applied.

There are  two  clara processing  facilities in Maryland which employ spray irri-
gation  for  ultimate  wastewater disposal.   Prior to spraying, the plant efflu-
ent  undergoes  screening  followed by  sedimentation  to  minimize problems asso-
ciated  with nozzle  clogging.   At  one  facility,  filtration has  been contem-
plated as a further safeguard for the irrigation system.   Spray irrigation has
proven  to   be  an effective  disposal method for  these facilities,  which  are
essentially manual  operations  and  generate relatively low  volumes  of waste-
water.
G.  Summary - End-of-Pipe Treatment Technology

With  few  exceptions,  conventional wastewater treatment  technologies  have not
been  demonstrated  on  a  full-scale level within the seafood industry.   Seafood
processors,  in  general,   use  simple  techniques  which  require minimal  land
areas.  The  most basic  and prevalent  end-of-pipe  treatment has  been solids
separation by  screening.   For industry segments which  generate small volumes
of  low contamination wastewater, this approach,  in conjunction  with recom-
mended in-plant  control  measures, should  be sufficient  to  control waste dis-
-uarges.  Table  5  provides estimates of relative capital  and operating costs
for screening wastewaters generated by a few of these segments.

Physical-chemical treatment processes, such as sedimentation and dissolved air
flotation  (DAF),  have been  employed to a  lesser extent.   Biological systems
and land treatment alternatives have not been widely adopted to date.   Limited
land  availability  in coastal  areas  is a major obstacle to implementing such
systems.   Technology  more  sophisticated  than DAF has  generally  not  been re-
quired on a federal, regional or  state level.

                                    TABLE 5
                  REPRESENTATIVE  COSTS FOR SCREENING SYSTEMS
                 APPLICABLE TO SELECTED INDUSTRY SEGMENTS (126)
 Wastewater
   Source
Plant Size    Total Daily    Capital Cost  0 & M Cost
(Tons/Day)   Flow (Gal/Day)    ($1,000)     ($/Day)
Conventional            7
Blue Crab

Alaskan Shrimp*        20

Hand-Butchered         15
Salmon

Hand-Shucked Clam      25

Alaskan Herring        50
Fillet*
                1,850

              436,000
               12,300


               29,000
              150,000
 46

158
 46


 47
100
168
 16


 19
112
•'"Includes building to house equipment and a barge for solids disposal.

                                   36

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It is possible  to  adopt aerated lagoon,  treatment  as  a means to control waste
discharges  from  the catfish  processing  segment, which  generally  has greater
land availability.  Where  sufficient land is available, the  larger  tuna pro-
cessors could employ biological treatment.   Relative costs to achieve second-
ary treatment for these two segments are displayed in Table 6.

Physical-chemical  treatment  processes   are  more  applicable than  biological
treatment  for most of  the seafood  industry.  Physical-chemical  processes can

                                    TABLE 6

                  REPRESENTATIVE COSTS FOR BIOLOGICAL SYSTEMS
                  DESIGNED FOR SELECTED INDUSTRY SEGMENTS (126)
Wastewater .
Source

Farm Raised
Catfish
Tuna
Tuna
Plant Size
(Tons/Day)

15
400
400
Treatment
System

Aerated
Lagoon
Aerated
Lagoon
Activated
Sludge
Total
Daily Flow
(ragd)
0.051
1.07
1.07
Capital Cost*
($1,000)

172
540
1,900
0 & M Cost
($/Day)

90
490
750
"^Assumes sufficient land area is available.
achieve high  degrees  of treatment using relatively small amounts of space.  A
disadvantage  of  the  more advanced systems is the higher costs associated with
equipment,  chemicals,  power, maintenance  and  other operational requirements.
There  is  little practical  application in  the  seafood industry  for  advanced
technology  such  as carbon  adsorption, filtration,  reverse  osmosis,  electro-
dialysis, ion exchange  and chemical oxidation due  to  the  extensive pretreat-
ment  requirements.  In  addition,  the high  level of  sophistication  demands
considerable  operator training and attention.

Flotation schemes  appear  to  have the  greatest potential  for effluent treat-
ment.  The  effectiveness of non-optimized dissolved air flotation systems has
been demonstrated  on  a  full-scale level at  several tuna  canneries throughout
the  United  States  and its  territories.   Improved  removal  efficiencies should
be achievable under  optimal conditions.  Optimization of dissolved air flota-
tion  systems  involves adjusting  the pH of  the wastewater  to the isoelectric
point  of  fish protein  followed by  the addition  of the  chemicals needed for
coagulation  and  floculation to  achieve the maximum removal  of suspended and
colloidal particles.   Minor  pH  adjustments may  be required  prior   to  dis-
charging  the  treated effluents  either to  a subsequent treatment  process or
receiving waters.  For  other segments  of  the  seafood  industry,  the capabili-
ties of optimized  DAF systems have been demonstrated in the United States and
Canada  utilizing federal grants.  Information is  available  for the treatment
of wastewaters resulting  from  the processing of  crab,  shrimp,  tuna,  salmon,


                                   37

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bottomfish, sardine,  herring,  and oyster.   Data generated  in  other countries
supports  the  application  of  flotation technology  to the  seafood  processing
industry.  Table 7 provides cost estimates  for the installation of DAF systems
at plants  within selected  industry  segments.  These  estimates are  based  on
flow information  which  reflects the adoption of  in-plant  measures  applicable
to the specific segment.

                                    TABLE 7

                     REPRESENTATIVE COSTS FOR DAF SYSTEMS
                 APPLICABLE TO SELECTED INDUSTRY SEGMENTS (126)
Wastewater
Source
Southern Non-
Plant Size
(Tons /Day)
10
Total Daily
Flow
(mgd)
0.107
Capital Cost*
($1,000)
230
0 & M Cost*
($/Day)
355
Breaded Shrimp
Mechanized Salmon
Mechanized Bottomfish
Sardine
Herring
Fillet
35
30
70
120
0.119
0.092
0.117
0.359
220
245
200
410
365
360
170
870
*Assumes screens are in-place.
^'"Includes chemical costs for optimization.
Although similar wastewaters are generated by Alaskan operations, the install-
ation  of  DAF equipment has been  found  to be impractical in view  of the geo-
graphical and climatic conditions.  The availability of required chemicals and
skilled labor  for optimized  operation  is  also  restrictive.   Plants  in most
processing areas  are  physically confined or constructed on piles  over water.
The expense  of  providing additional space  on a  wharf and  a building to house
the equipment does not appear warranted.  Therefore, in-plant modifications in
conjunction  with  screens  are  considered applicable for  these  segments  of the
industry.

Other  physical-chemical  processes may be feasible  for  selected  waste streams
which  are  highly contaminated  or represent a potential for  reuse.  Case-by-
case evaluations  are  required to justify the implementation of this treatment
approach.
                                   38

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         SEAFOOD WASTE
UTILIZATION AND DISPOSAL

-------
                                   CHAPTER 4

                    SEAFOOD WASTE UTILIZATION AND DISPOSAL
I.   BACKGROUND

A.   Solids Generation

Waste  management practices  applicable to the  seafood industry  generate two
types  of solids:   wastes  captured  during  actual  processing;  and materials
which  escape into  the plant  effluent for  later  capture by  waste treatment
facilities.   In general, the most economical way to reduce the total amount of
waste  solids  requiring disposal is to capture unused  raw materials in-plant,
and  to process  them  into  marketable secondary products.   Once the  raw ma-
terials  have entered  the  waste stream,  they are generally  more expensive to
recapture.   Furthermore,  the  production  of marketable byproducts  using ma-
terials separated from the waste stream are  more  complex and inherently more
costly.   The potential  markets  for  these  byproducts  are more  limited than
those  for consumable secondary products manufactured in-plant.

Both  types  of  solids  will vary  in  quantity and  character depending  on the
location of  the  facility,  species processed, time  of  year,  and waste manage-
ment  practices.   Historically comprehensive  in-plant water  and waste manage-
ment practices have not been utilized in this industry.  As a result, the need
for  identifying  methods for  recovering  materials  for  subsequent utilization
has been minimal.

1.   In-Plant Solids Generation.  Waste fish solids, processing scraps and meat
fragments which  remain after  processing of a primary  seafood  product can be
collected and processed into  a variety of  secondary  products  and byproducts
such  as  petfood,  fish  meal and animal feed  supplements.   By collecting these
solids at their source, the volume of solids entering the central waste stream
can  be  significantly  reduced.   Relatively   simple  management  practices  are
available to approach total  utilization of  the raw material;  however, these
practices have  not been  widely implemented  in  some segments  of the seafood
industry.  Although methods to recover raw material are relatively simple, the
adoption of  the. total  utilization approach  is subject  to economic considera-
tions, market availability, and governmental regulations.

In some  segments,  water is used to convey raw materials from boats to storage
facilities  inside  the  processing plants.  In-plant  systems  also rely heavily
on hydraulic conveyance.  As a general objective, the industry needs to become
more  aware  of ways  to reduce  water use  through  alternative dry handling sys-
tems.   Attention to  limiting water  use could  result  in better  recovery of
in-plant  solids and  reduced  discharges  of  potentially useful  materials as
waste.

2.   End-of-Pipe Treatment.  Wastewater from most seafood processing operations
is not subjected to high levels  of treatment.   Most common are simple solids
separation  systems,  usually screens,   which  physically  separate larger solids'
from  the  waste  stream.  These separated solids can be collected for byproduct
manufacture,  or  they  can  simply be transported to  a  disposal site.  Because
there  are no chemicals added  to the screened solids, they are more acceptable
for  byproduct  manufacturing than solids  captured using higher levels of tech-

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uology.   The  available   alternatives for  disposal  are  also  more  numerous.
Options include the  manufacture  of animal feeds, aquaculture nutrients, agri-
cultural fertilizers, landfilling and barging for deep sea disposal.

Beyond  screening,  which  is prevalent  in the  seafood industry,  some  plants
employ  sedimentation,  dissolved  air  flotation  (DAT)  and  biological  treatment
systems for  additional reductions  of waste constituents in  the  screened ef-
fluent.  Technologies more sophisticated than DAF have generally not been man-
dated  by  the environmental  regulatory  agencies, thus there  is little  demon-
strated  application  of  full-scale  wastewater  treatment  by  the  industry.
Simple  sedimentation has  been  adopted  by  some  shellfish  (clam  and  oyster)
processors for  the  removal of sand, silt and shell fragments.  Landfilling of
the separated solids is commonly employed.

Dissolved .air flotation  (DAF)  has received some attention for its application
to the  seafood  industry.   It has been used  successfully  by some of the major
tuna processors, and has  seen widespread use by  related  food industries such
as poultry  processing, red  meat packaging and  rendering.    The  solids which
are  skimmed  from the  surface  of  the flotation unit  are than directed  to a
collection vessel.   System operations can be aided by chemical coagulants and
flocculents  at  an optimum  pH.   Chemical additions  are  necessary to  provide
adequate  DAF  performance; however,  their use inhibits the  conversion  of the
resulting sludge  (float)  into  byrproducts.   Float characteristics in relation
to the  requirements  of the Food and Drug Administration for animal feeds will
be discussed later in this section.

DAF sludges, or the  skimmed solids, are water-laden, typically consisting of 5
to 20 percent solids.  The technology is available to dewater this semi-liquid
material  to  approximately  30  percent  solids  with  a coincident  two-thirds
volume  reduction.   The decision  to do so would depend on the adopted disposal
method  and   the  inherent  economics.   For  example,   liquid  DAF float  can be
hauled  to a land application  site  and  sprayed on the ground  or  injected be-
neath  the soil  surface,  whereas  dewatered float is limited to surface spread-
ing.

DAF sludge contains  valuable nutrients, plus oil and grease which require care
when  used in  any  land  application  scheme.   Alum is often  used to aid the
flotation process;  thus  significant concentrations of aluminum may be present
in DAF float.   The  presence of  salt  (and sodium)  must likewise be considered
in terms  of  the toxicity  to cover  vegetation  and effects on the soils at the
selected disposal site.
B.  Current Solids Disposal Practices

The  Alaskan  seafood  industry  differs  in  many ways  from operations  in the
remaider  of  the United States.  Therefore, the discussion relating to current
solids  disposal practices  will segregate Alaskan processors from those in the
contiguous states.


1.  Contiguous  United States.   Among  the  solids disposal methods practiced by
seafood.processors  in the contiguous United States  are:   a)  secondary utili-
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zation; b) byproduct  manufacturing;   and  c) land application (including land-
filling).   These methods are discussed individually below.

     a.  Secondary Utilization.   Waste  materials from  seafood  processing can
     be  converted  into  secondary  products both  to  improve  total  resource
     utilization  and  to reduce  or  offset the cost of  waste  management.   The
     most common  examples  of  secondary products from finfish are  fish sticks
     and fish cakes, which are comprised of deboned or extruded  flesh.

     Fish solids  can  be manually accumulated in totes  or  bins  along the pro-
     duction line,  which is an  effective step in preventing gross solids from
     entering the waste stream.  Collection troughs can  also  be  designed to
     prevent the  solids  from  coming into contact with th; floor.  Other meth-
     ods of collecting the solids include mesh-type conveyors or coarse screens,
     Specific fish  parts can be directed  to  designated  area  for subsequent
     processing  into  secondary  products.   Salmon  roe,  for  example,  can be
     separated,   graded, cured,  boxed  and  marketed  for human consumption.
     Deboned fish flesh can and has been processed into marketable commodities
     such as breaded fish cakes  for human consumption.

     b.  Byproduct Manufacturing.  More prevalent,  however,  is  the production
     of byproducts  such as  animal  food and feed additives.  Tuna and salmon
     operations  have successfully  converted  wastes  into  petfood which can
     realize  a  profit.   In  some  cases,   the  preparation  of  fish wastes as
     petfood  is  accomplished as part of a  line which  includes other primary
     ingredients  such as beef  and  chicken  parts.   Some  seafood  plants  have
     on-site byproduct facilities.   For example, major tuna processors operate
     facilities  to  produce  meal and  oil from  fish  scraps and  cooker water
     generated  during  canning   activities.    Other  processors   collect the
     waste materials and ship them to remote off-site byproduct  plants.

     Finfish  processing wastes  have also  been used  as bait,  particularly
     within the sardine, salmon and halibut processing segments.

     The proteinaceous  wastes from  seafood processors can be converted into a
     number  of  useful byproducts.   For example, the  reduction  process, which
     is employed  by tuna canneries,  yields a protein meal which can be used as
     an animal feed supplement.   In some instances, the required equipment has
     been  installed on-site at  individual  processing plants; however, facil-
     ities are  available in specific geographical areas to serve several food
     processing operations.

     Because of  the intermittent production schedules typical  throughout most
    ' of  the  seafood industry,  on-site  reduction' facilities  have not  been
     widely incorporated at individual processing plants.  To make the fullest
     possible use of  such  reduction  facilities, some  of the  larger tuna can-
     neries  supplement  tuna scrap  processing with anchovy reduction at appro-
     priate times of  the year.

     Unprocessed  wastes  have  been  used to  produce  fish feeds and fertilizer.
     Fresh  or  frozen fish  solids,  including  catfish  offal,  have  been incor-
     porated  into  an acceptable diet  for farm-raised  catfish.(85,  139)  In
     addition,  shrimp wastes  have  been used as a feed supplement for aquacul-
     ture  for pigmentation.(113).  The solids generated during  shrimp and crab


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     processing have significant value where  a  nitrogen-phosphorus  fertilizer
     is required.(38)

     Of the various  byproducts  that can be produced from shellfish wastes,  one
     of the most  interesting  is  chitin  (pronounced "ky'tin") and  its  deriv-
     ative, chitosan.  It  is  a straight  chain polysaccharide polymer  closely
     related to cellulose.  Chitin is the  second  most abundant organic compound
     on earth, yet  its properties  and applications have only recently  gained
     significant attention.

     The technology exists to  isolate chitin  from protein  in shellfish wastes
     and  to produce  chitosan, a  commercially  interesting  derivative.   The
     resultant natural  compound has  been  found  to  have  applications as  a
     coagulant in wastewater  treatment.(14, 15,  16, 18,  19,  20,  22)  Additional
     uses  include additive in  paper making and textile dyeing;  film for mem-
     branes  used  in  electrodialysis (e.g.,  desalination);  thickening  and
     emulsifying agent;  and  a wound  healing  accelerator.    Studies  have also
     shown  that  chitinous  materials  can  be used as animal  feed supplements.
     (18,  22)   The digestability and nutrient  value for  ruminating animals has
     been   established; however,  the  investigators  noted that  additional  in-
     vestigations are necessary to  gain  Food  and Drug Administration approval
     of chitosan as  a food additive.

     These  and  other byproducts will be  discussed more fully in the  Section
     III of this chapter, entitled "Byproduct  Manufacturing."

     c.   Land Disposal.     Secondary  product   and  byproduct   manufacturing
     account  for  only a  fragment  of the total  waste management  practices
     available to the  seafood  industry.   In addition to the  gross solids that
     can be incorporated  into  marketable  products, there are other  processing
     residuals, such  as  DAF float  and biological sludges,  which are  usually
     disposed of on  land.  Disposal is accomplished by applying  the material
     to land to propagate a cover crop or by burial at  a landfill site.

     Among  the factors that  must  be considered  when applying seafood process-
     ing  wastes  to  the  land  are:   1)  nitrogen  content;  2)  oil  and  grease
     content;  3)  sodium  concentrations;   4)  salinity;  and 5) odor  potential.
     Nitrogen content  and odor control  are also  considerations  for landfill
     operations.  The moisture  content of the sludge is an  important  charac-
     teristic when evaluating landfill sites.

     Surface  spreading and  soil   injection  are  two  alternative methods  for
     applying waste sludges  to the land.   Both methods  require  suitable site,
     weather conditions,  soils, drainage  and  other factors,  not  the ieast of
     which is careful management of the land application operation.

     Two  approaches  are  available  for landfilling waste treatment  residuals:
     the  cell  method  and the  trench method.   Selection  of the appropriate
     method is  based on  site  considerations.   Either method can provide the
     environmental control for sludge disposal when properly managed.

The  above  discussion  of solids disposal  practices  -  encompassing secondary
products,  byproducts and  land  disposal - has  offered a  general  perspective of
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the seafood industry.  However, a major segment of this industry is located in
Alaska, where some  of  the alternatives discussed above may not be applicable.
Land disposal for  example,  is not feasible for  most  areas in Alaska.  There-
fore, solids handling practices for Alaskan processors are discussed separate-
ly below.

2.  Alaska.  Seafood processing  plants in Alaska are dispersed  all  along the
Alaskan  coast,  from the  Aleutian Islands  to  the city  of Ketchikan  and the
southeastern panhandle.  Some of these plants  are isolated; others are located
in processing centers  which support several seafood operations.   The process-
ing centers do not necessarily coincide with population centers.   For example,
Anchorage  is  the  most populated  area  in Alaska; but  it supports  just one
salmon  cannery  and a  cold  storage facility.   The  largest seafood processing
center  (in  terms  of the number of plants)  is  in the city of Kodiak on Kodiak
Island, which has approximately three percent of the population of the Anchor-
age area.

Although  the  conditions  encountered  throughout  Alaska  will  vary  with the
specific location, they are significantly different from those occuring in the
contiguous  United  States.  Some  unique  factors  influencing  the handling and
disposal of waste materials  are labor  availability,  weather conditions, ge-
ography, geologic  and soil  conditions,  and relatively  high  costs associated
with construction  and  transportation  activities.  Combinations of two or more
of  these  factors  tend to  limit the  alternatives  available  to  seafood  pro-
cessors for the disposal of waste treatment residues.

A  review  of  the  general soil  characteristics   and  geologic conditions for
selected  processing  areas   indicates  that land disposal  of seafood  solids
should  not  be  adopted  as  an  industry  wide  alternative in Alaska.  Input from
the  municipalities  reinforces this conclusion.   Surface  spreading or subsur-
face  disposal  of  solids  for crop fertilization is  limited  to agricultural
areas,  which are  not prevalent  in Alaska.   Therefore,  it appears  that by-
product  recovery  and barging are the  two  options which  are technically  feas-
ible for Alaskan seafood processors.

In evaluating the  Alaskan seafood processing industry, the U.S.  Environmental
Protection  Agency  (EPA)  has differentiated  between  remote and  non-remote
areas.   Solids  handling  practices,  particularly with  respect  to  secondary
product and byproduct manufacturing, differ substantially for remote areas and
specific non-remote locations.
     a.  Non-Remote Areas.   Under  the original  philosphy,  non-remote  areas
     were  selected  as  those which have significant populations and/or several
     processing  facilities  in a definitive geographical area.  These included
     Anchorage,  Cordova,  Juneau, Ketchikan, Kodiak  and  Petersburg.   In these
     areas,  water  quality  considerations  require  more   rigorous  pollution
     control  efforts.   These  locations  generally offer more Jependable road
     and  ferry transportation, readily available power, and  access  to larger
     numbers  of  workers   demanding  lower  wages.   These  and other  economic
     advantages,  such  as  the  opportunity  for  cooperative  approaches  to waste
     management,  open  some  seafood  waste management  alternatives,  including
     reduction  facilities,  which are not  available  to  more remote processing
     plants.
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     Three Alaskan  areas  -  Kodiak,  Petersburg  and Seward  - have  reduction
     facilities which  convert  fish processing wastes  to useful  byproducts.
     Each facility  has  the  capacity  to accommodate  materials generated  by
     local processors.   Through contractual agreements,  the  largest reduction
     plant,  which is in Kodiak,  is devoted to  serving the 15  processors in the
     immediate area.  Because of  inherent inefficiencies,  this  plant has been
     operating with  subsidies  from the  processors  to  serve  as  a  convenient,
     local waste disposal  facility.   The facilities in  Petersburg  and Seward
     were originally intended to  be economically  self-sufficient in producing
     fish meal  and  oil from whole  fish and processing wastes generated  in
     their respective  geographical area.  However,  neither  facility  has been
     operated at  full  capacity on  an  annual  basis  due to the  limited avail-
     ability of raw material.   This limited availability results from the lack
     of waste  management by area  plants.  Because  the  Seward  and Petersburg
     reduction plants  have excess  capacity,  they will  generally  accept pro-
     cessing wastes transported from outside the immediate area.   In the past,
     both plants  have  received and processed wastes from processors located
     more than  100  miles  away.   However,  this  practice  has been  generally
     discontinued because  the plants  have chosen  to grind and discharge their
     wastes  in view of economic considerations.

     In the absence  of  on-site  or nearby waste processing plants,  the collec-
     tion and transport  of  waste  materials  to  a   plant  which  manufactures
     petfood  represents  an  alternative  waste   solids  handling  procedure.
     Alaskan  salmon canneries,   for  example, have collected,  packaged  and
     frozen salmon  heads  for shipment  to Seattle petfood operations.   These
     salmon processors  are then allowed  to simply grind their remaining waste
     solids  for  discharge  to local receiving waters.    Since they  choose  to
     collect and ship  a portion of their wastes to  Seattle suggests that some
     economic advantage  is realized through  byproduct  manufacturing, despite
     the transportation costs.

     A final disposal option currently available to  Alaskan seafood processors
     is the collection  of  gross and screened  solids for barging to deep water
     dumping  sites.   Every  processing  area  has  a  designated  dumping site,
     usually within a five-mile distance of the processing facility.
     b.  Remote Areas  For  the remote  Alaskan  fish processing  plants,  there
     are generally  only two  viable  waste solids disposal  methods:   grinding
     and discharge  to  local  receiving waters; and barging to deep sea dumping
     sites.  The  vast majority of  processors in these areas have  elected to
     grind wastes for discharge.
C.  Future Considerations

Solids handling  and disposal  practices  which have been adopted by  most seg-
ments of  the seafood  industry,  in some  cases are adequate  but  are  generally
unsophisticated.    With the  exception of  the tuna  and fish meal  processing
segments,  there  has been limited  implementation of  in-plant waste  management
practices  or  secondary or  byproduct  manufacture.    Most  demonstrations  of
improved in-plant water and waste management have resulted from either a gross
pollution  problem  or from readily apparent and  immediate  economic  advantages
for more complete raw material utilization.

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As  the  environmental responsibilities  of various  segments  of the  industry
become  better defined,  it can be  expected  that considerable progress can be
made  toward  reducing waste  discharges  to  receiving waters.   The  most  eco-
nomical  way to achieve  immediate  reductions  in  processing waste discharges is
through  improved in-plant waste materials handling.   In particular,  the  con-
version  from  fluraing  to dry handling  of waste  materials will  yield  improved
segregation of useful raw materials  for  possible  secondary  or byproduct manu-
facturing.   At the  same time, dry handling systems,  recycling, and  general
reductions  in water use by  the processors will  result in effluent  volume and
waste  load  reductions.

The operation of screening  equipment to  supplement in-plant  control  measures
at  Alaskan  processing plants  will  create  a need  for options  in disposal/utili-
zation.   Meanwhile,  in the contiguous United  States, DAF  and biological treat-
ment  systems  have  been  found  to  be applicable to a  number of  industry  seg-
ments.   As  these treatment  facilities  are installed  and placed  on  line,  they
will  produce  increasing volumes  of  solids  requiring some means of disposal.
Among  the alternatives  which are  expected to receive  increased  attention  are:

          secondary product development;
          byproduct manufacturing;
          chitin/chitosan  production; and
          other  disposal methods.

These  topic areas  are addressed in the  remainder of this  chapter.


 II. SECONDARY PRODUCT DEVELOPMENT

To  differentiate between  secondary  products and  fish processing byproducts,
 this  discussion will  focus  on  secondary  products  which are  suitable for human
 consumption.   Byproducts  will include  all  other manufactured products  and
derivatives which are not  directly consumed  by  man;  e.g., fish  meal,  petfood,
bait,  fertilizer,  chitin/chitosan,  etc.

The processing  of  secondary products  requires  separation  of   raw materials
•(i.e.,  gross  solids)  at their  source.   Means of  accomplishing  this necessary
 first  step  will be  discussed,  followed by a review of  some of  the  major  sec-
ondary products  which can  be produced from finfish wastes and shellfish wastes,
 respectively.

A.   Separation of Gross  Solids  at  Source

 Conversion  of waste materials  into secondary products fit  for  human  consump-
 tion generally requires the  collection of leftover fish parts  during produc-
 tion of  the primary product.   The simplest  approach  is manual accumulation of
 gross  solids  in totes or  bins.   Several facilities which hand  butcher salmon
 have adopted  this  method to  prevent gross  solids   from  entering  the waste
 stream.   Conventional bottomfish  is another  industry  segment which could adopt
manual separation of fish  parts for subsequent utilization.

 Dry handling  of  all waste materials is  desirable in terms  of  pollution  con-
 trol.   Belt conveyors are  used throughout the food industry for this  purpose.
 Meal plants operated  by or in conjunction with  tuna  canneries,  employ belt or


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screw conveyor systems  to  transport the tuna wastes  from  the cleaning tables
to the meal  plant,  thereby avoiding the use of water.  This operation facili-
tates handling of  the  waste material during separation  and processing at the
meal plant.

To develop secondary products using gross solids, it is essential that the raw
material be  prevented  from coming into contact with the floor.  Various faci-
lities  have  installed  devices which  prevent waste  solids from  hitting the
floor and  ultimately entering the waste stream.   Coarse screens and mesh-type
conveyors  can  help achieve  this  goal,  as  well as  reducing solids loading to
fine screens or other end-of-pipe treatment equipment.

Although  the equipment available  to collect the raw materials  for secondary
product  development  are relatively uncomplicated,  the  housekeeping and other
practices of the processors which produce secondary products must be carefully
managed.   Great  care  is  required  to  produce  from  once-neglected wastes  a
commodity now aimed at human consumers.

By collecting gross solids as described above, a seafood processor may achieve
three  objectives:   1)  more  complete  utilization  of raw  materials;   2)  the
development of a secondary product which can produce additional income; and 3)
a reduction  of waste  volumes requiring subsequent disposal.  The economics of
secondary  product  development  depend  on  plant  location,  species processed,
availability of  equipment  and market conditions for the secondary product(s).
As the  cost  of  waste disposal increases,  so  does  the incentive for secondary
product manufacturing.

Examples  of  the  secondary products manufactured by finfish and shellfish pro-
cessors are described below.
B.  Secondary Products from Finfish Wastes

After  fish parts have  been collected  in  a specified area,  they  can be sub-
jected to  a  number  of secondary processing  alternatives.   A model example of
such  a product  is   salmon roe.   Conventional  processing  equipment  has been
modified  and handling practices  developed to  facilitate  roe separation from
mechanically  butchered  salmon.   Subsequently,  the  roe  is  graded,  cured and
boxed  for shipment   to  Japan.   In  recent  years,  salmon roe  has become a se-
condary product  which is too valuable to be discarded by canning and freezing
operations.

Other  fish parts can be isolated  and  manufactured into  secondary products.
Finfish processing  plants  are  capable of producing  fish  flesh which has been
deboned.   Flesh  separator  machines  are available which can  recover  37 to 60
percent of minced flesh  from various species.  In comparison, the conventional
filleting  techniques  only  yield a primary product  which  ranges from 25 to 30
percent  flesh.   The  machine  separator squeezes  the  relatively  soft muscle
tissue through a rotating  perforated drum.  Skin and bones mat on the outside
of  the drum and are  scraped off  into a waste  chute.  The  minced  fish muscle
may  be used  in  fabricated foods  such  as pasteurized  spreads, frankfurters,
fish cakes and fish  loaf.
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Implementation of deboning  operations  requires  a considerable capital invest-
ment  and  an established  market.   At  least  one salmon  cannery in  the  Puget
Sound area determined that the capital expenditures were justified in order to
produce a  deboned  salmon  commodity  from materials  which  are discarded  as
wastes by most  facilities.   Although every salmon cannery  cannot  be expected
to  install  a  similar line,  the  economic feasibility  should be  explored  by
individual  plants.    Other   finfish  operations   also  have  the potential  for
generating deboned  or extruded products.   Battering and  breading operations
may follow to generate marketable commodities such as fish cakes.


C.  Secondary Products from Shellfish Wastes

Shellfish, like  finfish,  can be subjected to mechanical flesh separation.   In
Canada, for  example,  flesh separators  have  been used  on lobster  bodies  to
produce salable products.  Fabricated shrimp products can likewise be produced
in this manner.  However, only isolated references to such applications can be
found in the literature.

Secondary products  can  also be recovered from isolated waste streams.  A good
example is the development of a product similar to clam juice from minced clam
washwater.   This process,  which was  recently  investigated  by  a  Sea  Grant
Institution, has been found to be advantageous  both in terms of economics and
water pollution control, achieving a significant reduction in the BOD. load of
plant effluent.(66)   Further processing  of the product  into  a dry flavor in-
gredient  has  also been  demonstrated for the East Coast  surf clam processor.
(74)
III.  BYPRODUCT MANUFACTURING

The  manufacture of  fish  processing  byproducts  includes a  wide  variety  of
products having  applications  other than human consumption.  The general types
of wastes  incorporated into such products are introduced below, followed by a
more  detailed  accounting  of the  processes  and  end-products  involved  with
byproduct manufacturing.


A.  General Ingredients

Seafood  processing wastes can be categorized into  four  general types:  gross
solids  collected  from the production line; screened  solids  captured prior to
effluent  discharge;   dissolved  air flotation  (DAF)  sludge;  and  biological
treatment  sludge.  All of these wastes are characterized by significant pro-
tein  and nutrient  contents.  Some  of the  more  common byproducts which can be
manufactured from these wastes are  described below.
B.  Gross Solids

1.  Finfish Wastes.  Gross solids recovered from finfish processing operations
represent  a  significant  value  in terms  of  total product  utilization.   Tuna
processors  have long  recognized  the economic  advantages  of recovering blood
meats and off-color parts of the fish for incorporation into petfood.  Some of


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the tuna  processors operate  petfood  canning lines in  conjunction  with their
primary processing activities.

Some salmon processors  have  collected the larger solids  and  transported them
off-site to petfood  facilities.   These petfood plants may  receive  waste fish
material from more  than one  processor.  To date, this option has been adopted
by only a limited number of processing plants.

The cost of  equipping,  operating and marketing a petfood line has limited the
number of on-site petfood  operations  at seafood plants.  Generally,  only the
larger  tuna  plants  which  process seafood  year-round have installed on-site
petfood  lines.   One salmon  cannery  has incorporated  waste fish solids into
petfood containing  other ingredients.   But for the most part, non-edible fish
parts which  are retained  by plants  are  transported  off-site  for  subsequent
utilization or  disposal.   The operation of a petfood plant serving a regional
group of primary seafood processors may offer a better economic situation than
single,  on-site operations.   Nonetheless,  small  on-site  petfood  operations
which  handle only  fish wastes  can  reduce  waste volumes  requiring  disposal
while offsetting some of the waste handling costs.

Unprocessed fish scraps from sardine, salmon and halibut processors are often
collected and  sold  as  bait.   From sardine packing tables, for instance, the
heads  and  tails are conveyed to  a chum truck.   The major  use  of these mate-
rials  is  as bait by lobster fishermen,  who purchase the waste.  On  the West
Coast, heads removed from  salmon and  halibut facilities  can  be used for bait
as  well.   This practice  is  also applicable  to  Alaskan processing  areas.
Because  fishing  is  a seasonal activity, demand  for bait  fluctuates.   When it
is  low,  the  fish wastes can be  transported  to  byproduct manufacturing facil-
ities which may generate fish meal and oil using a reduction process.

The reduction process  parallels  rendering in other food industries.  As shown
in  Figure  10,  reduction is basically a cooking process followed by drying and
milling  to  produce  a  dry  fish meal product.  Other  byproducts include sepa-
rated oil and solubles  (the product of stickwater or press water evaporation).
In  some  cases   the  solubles,  which contain a high  level  of dissolved matter,
are recycled to the  drying operation to increase the capture of protein in the
meal.  The protein-rich fish meal is generally used as an animal feed supple-
ment.  Oil which is separated during  the processing  of finfish wastes repre-
sents  another  salable  byproduct.  Markets  exist for both  fish oil and solu-
bles.   Potential uses  included  nutrient  supplements  for mushroom  growing.
Solubles  can also provide  supplemental nitrogen  for  composting agricultural
manures.(53)

As with the operation of on-site petfood plants, the operation of on-site fish
meal  production equipment  is  limited in  an  industry which  does not feature
consistent,  year-round production.   Waste  material supply fluctuations have
hurt  the profitability of  reduction plants,  and only  a  few of  the  larger
processors produce their own fish meal.  Even the regional fish meal .installa-
tions, such  as  those in Petersburg and Seward, Alaska, have failed to operate
at  full  capacity because of raw  material  supply problems.   It is anticipated
however,  that  the  increase  of  bottom fish production in Alaska  and  the con-
tiguous  United  States  will  supplement current  raw material  supplies,  espec-
ially during low activity periods.
                                   48

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                WHOLE FISH
 WHOLE FISH
 AND/OR FISH WASTES
                                      LEGEND

                                      	 SOLIDS

                                      	 LIQUID
                                                  OIL
                                              SEPARATION
                                                  OIL
                                               POLISHING
                                               (OPTIONAL)
                                                  OIL
                                               STORAGE
                                               WASHWATER
                            ,
                                   EVAPORATOR
                                       UNIT
          FINISHED
           MEAL
                                          CONCENTRATED
                                        1  STICKWATER
                                          (SOLU8LES)
                                    SOLUBLES
                                     STORAGE
                      ^N
                      J
            /MEAL STORAGE
            VAND SHIPMENT
D
Figure 10.  Process schematic of a conventional
   fish meal  plant with solubles production.
                     49

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Some of the  supply problems can be avoided by producing fish silage, a liquid
product made by  adding  acid to fish parts and allowing enzymatic digestion to
occur.   Simple  equipment can  be used  to  make small  amounts of  silage  from
intermittent  raw material  supplies.   More expensive  equipment is  needed to
manufacture large  quantities,  but  the required labor  skills  are  minimal  when
compared to  fish meal  production.   Liquefaction caused by naturally occurring
enzymes in the presence of  acid results in a  versatile,  high-quality protein
feedstuff which  will keep  for long periods.   The  silage  process  offers addi-
tional advantages over meal production:  1) it is relatively odor-free, and 2)
it alleviates a  serious problem of liquid waste  disposal.   The University of
Washington, among  others, has  been researching silage production.  In Europe,
silage production was developed in Sweden in 1930; Denmark and Poland now have
well-established industries.(54)

The  stability,  protein content, usefulness  and  economy  of production assoc-
iated  with  the product  are matched by pollution  control  advantages.   At the
present time, silage is fed in liquid  form to pigs and cattle.  It is a bul-
kier protein product  than meal.   Accessible,  nearby markets  are therefore
desirable to minimize the costs of storage and transportation.  However, it is
possible  to  dry  the silage  to accomplish  long-term storage  or transporta-
tion. (54)  In  any  form,  the  stability of silage  is  a distinct  advantage to
seafood processors when compared to other byproducts.
2.  Shellfish Wastes.   Gross  solids  from  crab and  shrimp  operations,  like
those from the finfish plants, are often converted into protein meal products.
Shells  can be  ground  and  dehydrated,  then processed  into a  meal  yielding
protein contents of 30 to 40 percent by weight.  Full-scale production of meal
from crab and shrimp wastes has been accomplished in Alaska and the contiguous
United States.

Among the  problems  encountered in producing shellfish meal are a highly odor-
ous drying process,  a high calcium content  (up to  40 percent by dry weight),
and  lower protein  content  than  fish meal.   The environmental  problems  may
require installation  of expensive pollution control equipment; yet the shell-
fish meal  may be  worth only  about  a one-third  the  wholesale  value  of fish
meal.

A  relatively  new,  but  simple concept was recently introduced  to improve the
economics  of  converting crustacean wastes to marketable byproducts.(112)  The
approach  of  mechanically separating  the protein from the inorganic material
(shells)  to   allow  separate  processing  of  the fractions  was  found  to have
several advantages.   The advantages  identified include:   1) production of a
proteinaceous meal which approaches  the market value  of fish meal; 2) isola-
tion of the shell fraction which either can be utilized  for the manufacture of
chitin/chitosan, or  pulverized to generate  a  material with desirable proper-
ties;  3)  reduction of  the  volume of shell material  subjected  to the drying
operation  which  can  be highly odorous and  require  the installation of costly
air pollution control equipment;  and 4) availability as a recovery method for
isolated  locations and  where dehydration of crustacean wastes is economically
unattractive.
                                    50

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Other shellfish waste byproducts include the following:

          use of crab and shrimp wastes as an agricultural fertilizer, partic-
          ularly where a nitrogen-phosphorus fertilizer is required;

          use of shrimp  protein as a food  supplement  for aquaculture (salmon
          and trout rearing) to achieve desired pigmentation;

          peptone production from enzymatic digestion of shrimp wastes;

          direct animal feed (e.g., clam bellies for swine); and

          production  of  chitin and  chitosan  from crab  and  shrimp  wastes.

Among  the  shellfish byproducts  listed  above,  chitin/chitosan  production and
utilization appears  to  offer the greatest promise for crab and shrimp wastes.
This alternative is  specifically addressed later in this  chapter,  as Section
V, "Chitin/Chitosan Production from Shrimp and Crab Wastes."


C.  Screened Solids

Fish wastes which are not recovered as gross solids enter the processing waste
stream  and  are captured  by end-of-pipe  treatment  facilities.   Among seafood
processors,  screens  are generally  the  first and  most  universally  applied
treatment mechanism.  Solids trapped by the screens can be collected and used
in  the manufacture  of  byproducts,  either alone or  in combination  with gross
solids recovered in-plant.
1.  Finfish Wastes.   Screenings from  finfish  processing  plants can  be pro-
cessed  into  fish meal and  oil  with or without the  addition  of gross solids.
The screenings,  like  the gross solids, are high in protein and nutrient value
and,  can be converted to  byproducts such as animal  feeds,  fish silage, nut-
rients,  fish food  (often in pellet  form),  and  agricultural  fertilizers.  The
screening  process  does  not require  chemical  additives,  thus  the  byproducts
which  can  be generated  from them  approximate  those described  above for the
gross solids.

2.  Shellfish Wastes.  Screens used by the shellfish processors capture  solids
which  can  be  incorporated into most of  the  same  byproducts  that were identi-
fied  earlier for gross  solids.  Again,  the  mechanical  separation of protein-
aceous material  from crustacean shells for separate processing into byproducts
offers  several  advantages.   The  most  interesting byproduct  appears  to  be
chitin  and its  derivative,  chitosan.   In  addition,  peptones have  been ex-
tracted  from screened shellfish wastes to produce a medium for microbiological
growth which can be utilized in laboratory investigations.


D.  Dissolved Air Flotation  (DAF) Sludge

1.   General.  Fewer than ten seafood plants (all tuna) operate full-scale DAF
systems  on a continuous  basis.  However,  DAF  systems  have  been extensively
used  by other  related  food industries, such as  meat,  poultry and rendering,
                                   51

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having  waste  loads  comparable  to  those generated  by the  seafood  industry.
Experiences relative to  handling and  disposing of  the resulting  sludge  in
these particular segments of the food industry will be discussed as they apply
to seafood processors in general.

2.  DAT Float Characteristics.   The  dissolved  air flotation  process  removes
suspended  solids,  oil and  grease from wastewater.   A typical  DAF  unit com-
prises  a  tank,  an  air retention vessel, chemical feed equipment and a surface
skimmer.  Suspended solids, oil and grease which become attached to air bubbles
and float  to  the surface, are then skimmed from the water surface and collec-
ted as  sludge, or "float."

The  volume of  float produced by a DAF  system generally  approaches  1  or 2
percent of  the  total wastewater throughput.  The float is mostly water,  vary-
ing from  5  to 20 percent solids  content  (by weight)  and 0.2 to 3 percent oil
and grease  (by weight).   The composition of the float from a specific DAF unit
will depend on the characteristics of the wastewater being treated, as well as
numerous  operating  parameters of  the  DAF  system.  Among the  operating  para-
meters  of greatest  concern are  the  rate of air introduction  (as  compared to
the rate of solids entering the system) and the types and amounts of chemicals
added to the system to make it operate more efficiently.

The removal of  colloidal constituents  can be aided by adjusting the pH to the
isoelectric point  of fish protein  (pH 4.5  to 5).  The  addition of chemicals
for coagulation  and  flocculation of suspended materials also improves overall
DAF performance.  Coagulant aids include lime in addition  to  trivalent  salts
such as aluminum sulfate (alum), sodium aluminate and ferric chloride.  Other
flotation  aids   such  as  lignosulfonic  acid  (ISA)  have been  investigated  in
various combinations  with anionic and  cationic polyelectrolytes (polymers) to
improve pollutant  removals.   From the information available,  it appears that
chemical additions are needed  to provide acceptable DAF performance.

Chemical  additives such  as  the trivalent salts and polymers remain in the DAF
float that is collected.  Also present is salt from any salt water used in the
seafood processing  operation.  These  substances  limit  the  potential  uses of
the  DAF  float  which, like other solids from  the seafood  industry,  contain
significant levels  of nutrients and proteinaceous material.   The  approval of
these  chemicals  by FDA  is  required to  produce animal  feed supplements from
chemically  coagulated float.   At  present only one  coagulant,  LSA, has  been
approved by FDA  for  use in animal feeds.  Contact with FDA has indicated that
no  additional  applications   have been  submitted  by  seafood processors  for
approval of other coagulants.


3.  DAF Float Handling.    Unprocessed  DAF float is semi-liquid  in  nature, and
would  be   handled  as a  liquid.   However,  this is  not always  convenient  or
desirable.   Although the seafood  industry  has  only  limited  experience  in
handling  DAF  float,  some of the  related  food  industries which use DAF treat-
ment have  found  that further   processing of  the  float is required to make the
material more suitable for disposal or utilization.  Among the processes  which
are used to modify the float are the following:

          thickening  - to further concentrate the sludge, thereby reducing its
          volume;
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          stabilization -  to  reduce putrescible and pathogenic nature  of the
          sludge and make it easier to dewater;
          conditioning - to obtain  further stabilization and further increase
          dewaterability;
          dewatering - to  convert  the sludge into a moist  cake  (more than 20
          percent solids)  which can  be  more easily handled  and  transported;
          and
          drying -  to remove  essentially  all water,  thus  obtaining a  rela-
          tively dry material for utilization or disposal.

Use of any  of  the  sludge treatment methods outlined above would depend  on the
objectives  sought  for disposal  or  utilization of  the end-product.  For ex-
ample, stabilization  is usually required if the sludge is to be landfilled in
an environmentally acceptable  manner.   If  landfill site limitations or  trans-
port  costs  are  a  problem,  dewatering may  be  used to  reduce the  volume  of
material requiring disposal.

Because of the limited number of applications for this  technology, the seafood
industry has  very little  experience  handling the  float.   The most advanced
approach adopted by a tuna cannery consists of centrifugal dewatering followed
by  landfilling.   Surveys  of  meat packers,  poultry processors and  Tenderers
show that DAF float can be successfully dewatered using gravity phase (liquid/
solids)  separation  or centrifugation.  Many of the processors  contacted sub-
ject their  DAF  sludge,  which in some cases contain chemical coagulants, to an
on-site or nearby rendering process.
4.  DAF Float Utilization.  The  trend toward utilization of DAF  float  can be
expected  to  increase as  land disposal sites become more  scarce  and environ-
mental  restrictions  increase.  Despite the presence of  coagulants,  byproduct
development  should  be pursued in  lieu of burying the float.  The use  of al-
ternative chemical coagulants, such as lignosulfonic acid (LSA),  can allow DAF
float  to be  processed into  a salable proteinaceous  byproduct  which  can be
approved  for  animal  feed.  This  process  has been  successfully adopted by at
least  one meat  packer,   the  Sterling  Colorado Beef  Company, in the  United
States.(59)   Another form  of DAF  float  treatment (anaerobic digestion)  can
yield  methane,  a combustible  gas  which  can  help offset  the  energy costs of
pollution  control  operations.(80)   The Coors brewery  uses chemical  treatment
and  DAF to thicken  sludge  from a secondary wastewater  treatment plant.   An
approved  water  treatment  polymer is added to assist in the flotation process.
The  concentrated sludge  from  this operation is  then  dewatered  through evap-
oration  to produce  a material which will be marketed as animal feed, but only
in the State of Colorado because FDA has not approved it for use in interstate
commerce.

As  byproduct  development becomes  more  attractive,  consideration  should be
given  to the  use  of chitosan  as a  coagulation  aid  during DAF  treatment.
Chitosan  has been effectively used as  a coagulant for wastewaters generated by
food  industries  such as vegetable  processing,  fruit  cake  production,  egg
breaking, meat  packing,  poultry processing and seafood processing (the latter
at  an  Atlantic  Coast shrimp  processing  and breading  operation).(15,  16,  18,
20,  22)   This  natural polymer has been found  to  be at least as effective as,
if  not superior to,  synthetic polymers.   Because  chitosan  is a  natural com-
pound,  sludge  byproducts such  as  animal  feeds are more  plausible.   Feeding


                                   53

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studies involving  rats and  chitosan-coagulated byproducts have  indicated no
significant physiological effects.   However,  the Food and Drug Administration
(FDA) has not  approved chitosan as an animal feed ingredient as of this time.

Foreign seafood processors have made more progress than domestic operations in
terms of DAF float handling and byproduct development.(212, 224, 234, 252)  In
the  United  States,  only  limited  research performed  principally by  the  tuna
industry has  been done  in  these areas.   The FDA must  approve any potential
marketable  use  of the DAF  float  due to the  presence  of coagulants; however,
the  seafood industry  in  the  United States has not pursued  such approval for
any type of byproduct.  Consequently, the domestic processors which employ DAF
treatment generally dispose of the float in landfills.


5.  DAF Float Disposal.   Land disposal  has been the principal  form of sludge
disposal in the  United States.(126)  Recently, the application of  sludges on
agricultural land has  gained importance as opposed to burying the material in
landfills.

All types of sludge contain liquid and solid components which will dictate the
physical handling procedures and environmental concerns of land disposal.   For
dewatered DAF  float  from seafood processors, application methods include land
spreading;   for  liquid  float, application methods  include spraying  onto the
ground or injection beneath the soil surface.

Disposal practices which  rely on land application must  take  into account the
ability of  the  soil/plant  system to assimilate the materials  applied to the
land.   The  liquid portion is  dissipated through  percolation,  evaporation and
transpiration.   Suspended matter  is removed by soil particles  which act  as a
filter, and by naturally-occurring bacteria which can decompose simple organic
compounds.   Nutrients  such as  nitrogen and phosphorus may be  removed by the
cover crop  or fixed within the soil structure.

When  using  land application  as a  disposal  method,  the  following  character-
istics  of  DAF sludge  from  seafood processing  operations  must  be considered:
a.)  nitrogen  content; b.)  oil and grease  content;  c.)  sodium concentration;
d.) salinity;  and e.) odor potential.
     a.  Nitrogen Content.   A critical  factor in  applying  DAF float  to  the
     land  is the  ability  of the  soil/plant  system to  assimilate nitrogen.
     Crops will  use  nitrogen for growth; however,  some  species will use more
     than others.

     The soil structure  must be permeable, allowing the nitrogen to reach the
     plant roots.  But  if the soil is too permeable the nitrogen will rapidly
     pass beyond the root  system,  out  of  reach for plant  uptake.  Nitrogen
     should  not  be  allowed  to contaminate  the  groundwater, thus  soils with
     high  water  tables  are  inappropriate.   Assuming  appropriate  soils  are
     available,   sludge   application  rates should  be controlled so  that  the
     nitrogen applied  is not in excess of  the  sytem's  ability to assimilate
     it.
                                   54

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     b.   Oil and Grease.   If oil and  grease  are allowed to concentrate on the
     soil surface or within  a  small subsurface area,  then the soil can become
     impervious.  Oil and grease constituents of DAF float, therefore,  require
     controlled  application  and  careful  incorporation  into  the  soil.   The
     hydrocarbon molecules in oil and grease  will be decomposed by  common soil
     bacteria if the rate of application is controlled.
     c.   Sodium Concentration.   Because  excessive  sodium  concentrations  can
     create soil impermeability problems,  the  rate of sludge application must
     be  within the  capacity of the soil to handle sodium.   Different soils can
     accommodate different levels  of sodium.
     d.  Salinity.    Excessive salt  buildup  can  sterilize  soil  and  inhibit
     microbial  activity  which  is  necessary  for the  decomposition of  waste
     material.  In  addition,  crops  have limited tolerances  to  salt accumula-
     tion, which is  a  consideration with the wastes incurred by  seafood pro-
     cessors.
     e.  Odor Potential.   The  decomposition  of  waste  organic  material  can
     create  odor  and  insect problems  if  a land  application site  is  poorly
     operated.  The potential for such problems is minimized by quickly incor-
     porating the deposited material into the  soil.


6.  Summary.  As  seafood processors  proceed  to meet  their  pollution control
responsiblities,  the  DAF  treatment scheme will  begin to  be utilized by  an
increasing number of plants.  Consequently, an increase in the volume of float
generated will result.  Although only a limited number of processors currently
use DAF technology, this technology has been identified herein as being appro-
priate for much of the industry.  DAF float (i.e., the solids, oil and grease)
removed  from processing effluents  will be utilized, or it  will  require  dis-
posal.

DAF float  generated by the seafood industry in the United States is currently
being  transported  to  landfills  for disposal.   However, as landfill operations
are  subjected to  more  rigorous  evaluation,  an  increasing emphasis  will  be
placed on  DAF float  utilization.   Because the residuals  from seafood waste-
waters are high in nutrients and  protein  content,  potential uses  for these
materials .include  animal  feed   supplements and fertilizers  for  agricultural
activities.

Ultimately,  the generation  of   float  will depend on  the number  of seafood
processors  adopting this technology for water  pollution  control.   What these
processors  do with  the float  will  be more  an  issue of  economics:   simple
disposal will continue to be favored  by the  processors as  long  as  sites  are
available  and the  costs for disposal are  less  than  those for'byproduct manu-
facturing and marketing.
                                   55

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E.  Waste Activated Sludge

The  previous  discussion  of byproduct manufacturing  from seafood  wastes  has
included gross  solids,  screened  solids and DAT  sludge.   The  fourth and final
category of solids which may be incurred by seafood processors adopting waste-
water treatment is waste activated sludge.  Biological treatment systems which
generate this material  rely on the maintenance of a large mass of microorgan-
isms which  are capable  of decomposing organic  wastes.   The  activated sludge
system is widely  used for treating municipal  and  industrial  wastewaters,  but
has only limited applicability to the seafood industry.

High' capital  and operating  costs,  large land area requirements  and the need
for steady operating conditions are among the reasons the seafood industry has
not  adopted biological  systems for treating processing  wastes.   Such systems
can  achieve waste  reductions that are beyond  those obtained  by screening and
DAF  technology.  Most processors  are located in developed coastal areas where
land is  simply  not available for construction of large treatment systems.   In
addition, the fluctuations in processing schedules would generally inhibit the
effectiveness  of most  high-rate  systems.  Lagoons,  which represent  low  ac-
tivity treatment, require even greater land areas.  For these reasons, most of
the  available  information about  the character of waste  activated sludge with
the  biological  treatment  of  fish processing  wastes  has been  gained through
research activities  or  inferred  from information available for treating other
types of wastewater.

Waste  activated sludge  from municipal  and  industrial treatment  systems  has
been finding  increased  use  as a  soil amendment, in  some  cases  supplying  nu-
trients  for  crop-growing.   Such  crops are not  be used  for  human consumption
because a considerable amount of research is required to establish its safety.
Concern  remains for  crop  retention  of  toxic chemicals which  are generally
present in these sludges.

Growing awareness of  the nutrient value of sludge has led to increasing demand
for  this material  by  farmers  and homeowners interested in  enriching- their
field  crops,  gardens or  lawns.   This demand  reflects the fact  that, in some
cases,  the sludge  is given away at no cost; normal market conditions have not
yet  been established.   Some plants charge a fee for  delivering the material;
however, this  fee  is generally intended merely  to offset any special handling
and  transport costs for the delivery service.  The value of the product itself
is not usually  considered.  Sludge utilization  in such cases is viewed simply
as a disposal alternative.

Some efforts  have  been  made to create byproducts from waste activated sludge,
such  as  a  nutrient-balanced  dry fertilizer  product.   There  has  also  been
increasing interest in  the  protein content of  the sludge, which can be pro-
cessed  to  a  single-cell  protein  (SCP)  product and  used  as an  animal feed.

Waste  activated sludge   is  not apt  to be a  common concern  for  seafood pro-
cessors.  Processing  facilities which employ biological treatment will probab-
ly follow  the course established by municipal and other industrial operations
which  have produced  and  will  continue  to produce  the greatest  volumes  of
biological sludges.
                                   56

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F.  Summary - Byproduct Manufacturing

This  section  has introduced  a variety of  concepts and  applications  for by-
product recovery  from  residuals  generated by the seafood industry.  Byproduct
manufacturing offers two  principal advantages to the industry:  1) the recov-
ery  of a  potential revenue-generating  product from  material that was  once
discarded; and  2)  the  reduction of waste loads discharged to effluent streams
with  a  corresponding reduction in pollution  control costs.   Two  byproducts -
meal  and  chitosan  -  appear  to  have the greatest  potential for  meeting the
long-term needs of the  seafood  industry.  These byproducts  are  discussed in
more.depth in the following sections of this chapter.
IV.  MEAL PRODUCTION FROM SEAFOOD WASTES

A.  Background

In general, there is a worldwide shortage of protein.  While this may not seem
evident in  the  United States,  there are  other  countries  and continents which
have  significant  protein deficiencies.   Protein prices  in  the  United States
are  low  compared to those  in  other parts of the world;  European prices,  for
example, are  twice  those established in  the  United  States.   Worldwide short-
ages are aggravated by worldwide population growth.

The  sea  offers  an" abundance of protein,  but only a portion of  that which is
harvested gets  utilized.   To approach total utilization,  fish processors must
rely  on  the production of  secondary  seafood  commodities and byproducts.
Otherwise, much of the protein brought to shore is returned to the environment
as  waste material.   Fish meal is  a widely-accepted  proteinaceous  byproduct
which can substantially increase the total yield of protein currently achieved
by the fish processing industry.

Within the contiguous United States, many of the larger tuna canneries already
operate  on-site meal  production plants.   The  processing  of tuna  scraps  is
supplemented  by anchovy  reduction at specific plants during part of the year.
However,  the seafood industry as a whole has not installed this type of on-
site byproduct  equipment, largely because of intermittent production schedules
and  the  poor profitability  experienced by some meal  producers.   A  number of
the processors  send their waste material  to general rendering facilities which
produce  meal and other  products  (such as  tallow and  oil)  from proteinaceous
wastes  received from various  sources.    It  would  appear  that  the concept of
centralized  fish meal  facilities,  cooperatively handling strictly fish wastes
from  a  number  of  local  processors, may  be  economically  more  attractive than
operation of  on-site equipment at individual plants.

Small fish  meal plants  able to process 250 to 1,000 kilograms of raw material
per  hour are manufactured  and sold as package  units;  however,  none of these
have  been  identified  operating within  the United  States  seafood processing
industry.   The  relative  cost  of  operating  a small-scale meal  plant is high
compared  to  larger  operations, largely due to the economy of scale.   Even the
larger plants located in Alaska have generally act been operated  at an accept-
able  profit  level;  some  actually  lose  money.   Recognizing this,  fish pro-
cessors  have come  to  regard  the operation of  meal plants  as  an alternative
means of waste  disposal, rather than a business venture.  To these processors,
meal  production may  represent a  lower-cost  or less  involved  waste disposal

                                    57

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method  than barging  or landfilling.   The  possibility exists  for  competing
processors  to  cooperatively subsidize  meal  plants in  the  mutual  interest of
keeping waste disposal costs to a minimum.

Obviously, meal production  would be a preferable  disposal  method  in terms of
total  resource utilization.   The  world  market  value  for  protein  tends  to
fluctuate,  but has generally  been increasing.  As this market  improves,  the
economic advantages of  meal production will increase.  Concurrently, the cost
of  other  forms of  disposal may  rise,  creating a greater  incentive for pro-
cessors to  choose  meal  production instead of  ocean disposal or  land disposal
of their wastes.  Since the operation of modern fish meal facilities  is fairly
energy  intensive,  future costs  to meet energy requirements will  also play a
significant role in the economics of meal production.

B.  Alaskan Meal Production

In  Alaska,  three  fish  meal facilities are  currently operating.   Two  typical
fish  meal  installations are  operated by processing  plants  in Petersburg  and
Seward.  Both  include  an evaporator for stickwater,  the waste stream contain-
ing  soluble protein which  is  extracted  after the cooking  process.  Neither
installation has been operating at full capacity on an annual basis because of
raw  material  supply limitations.   The reluctance of other  processors in  the
respective  areas to  separate gross and screenable solids have contributed to
this  situation.  The  third  (and largest) meal plant,  Bio-Dry Incorporated, is
located in  Kodiak, where  it receives  wastes  from about 15 area  processors.
Meal  commodities  are produced  essentially year-round,  while  fish oil is  re-
covered during the processing of finfish wastes.  Stickwater is  discharged to
the harbor without treatment.

The  two smaller operations  (at Petersburg and Seward)  accept  raw  waste mate-
rials  transported  by  local processors,  paying  nothing for  the  wastes  and
charging  nothing  for their acceptance.  The  Kodiak  plant   charges  a  fee  for
going out and  collecting raw wastes from local processors,  much as  a municipal
refuse  collector might  do.   Processors who  instead choose  to  transport their
wastes  to  the Bio-Dry plant  receive  a  credit (to   apply  against processing
fees).  Thus,  the  only exchange  of money is  from the  processors  to the meal
plant; in effect, a service fee for waste disposal.

Because meal production is  one of  the  few alternatives for disposal/utiliza-
tion  of Alaskan  seafood processing  wastes,  special care  has been taken to
identify key seafood  processing centers for further evaluations  regarding the
feasibility of operating  meal plants in these areas.   The rationale for iden-
tifying selected  areas will  be presented to  establish  the  basis  of economic
evaluations to be  conducted by another contractor, as  part of the Section 74
study.

Previous assessments  of the seafood industry,  have shown that,  although con-
ditions vary  from  place  to place,  the Alaskan  industry  as  a  whole  differs
significantly  from that established in the  contiguous United States.  Some of
the  factors  uniquely  influencing the treatment and disposal of seafood wastes
include labor  availability, weather,  geography, geologic and soil conditions,
and  relatively  high  costs  for  construction  and transportation  activities.
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Earlier  assessments regarding  waste  control  within  the seafood  processing
industry differentiated between  remote and non-remote areas  of Alaska, ident-
ifying  non-remote  areas  as  those  having  significant  population  density or
processing  activity.   Designated non-remote  areas  are Anchorage,  Cordova,
Juneau, Ketchikan,  Kodiak  and Petersburg.   It was determined  that fish pro-
cessors in  these areas are capable  of achieving greater  reductions  in waste
discharges  than plants  in  remote  locations.   Not  all plants  in  designated
non-remote areas have installed the appropriate equipment (screens)  to realize
achievable pollutant reductions.

In addition  to  the  designated non-remote areas, there  are  three remote loca-
tions which support substantial fish processing activity:  Naknek-South Naknek
(Bristol Bay);  Dutch Harbor;  and the Kenai Peninsula,  which  includes Kenai,
Soldotna, Ninilchik, Homer and Seward.  Because these have been designated as
remote areas, fish processors simply grind and discharge their wastes to local
receiving waters.

Profiles of  the nine  major processing areas  in Alaska  are presented below.


1.  Anchorage.   Because  it  is Alaska's  largest population  center, Anchorage
has  been  designated as  a non-remote area.  However, the  city has  relatively
little  seafood  processing  activity,  limited  to one large cannery  and a cold
storage plant, mostly handling salmon.  Wastes generated by the cannery repre-
sent  a much  greater volume than  those  produced by cold  storage plant.  The
cannery  wastes   are  ground  and  discharged to a  small stream  called Ship's
Creek.  Waste materials  from the cold storage facility are transported either
to the city landfill or the Seward reduction facility.

Because  Anchorage  is  not a major processing  area, it is not  reasonable to
suggest a  centralized  fish meal  operation there.  There is an existing reduc-
tion plant (150 metric tons per day capacity)  in the Kenai Peninsula at Seward,
over  100  miles  from  Anchorage.   Since  the  reduction  facility  is operating
below  capacity,  transporting the wastes to Seward  represents  a viable alter-
native.  Or,  the Anchorage processor could install its own,  on-site byproduct
manufacturing equipment.   If  screens  were to  be  installed at  the Anchorage
processing  plants,  the accumulated  wastes (gross  and  screened solids) would
require some  form  of byproduct manufacturing or disposal.  A designated ocean
dumping site  is within 5 miles of the city.


2.  Cordova.  There are  four seafood processing  plants  in Cordova  and its
immediate  vicinity.   The  principal   commodities  include  canned  and fresh/
frozen  salmon,  Tanner and Dungeness crab, frozen  herring  in  the  round, and
herring  roe.   Cordova  is  currently  designated as  a  non-remote area.  It is
surrounded  by  mountains  which  make  the  city rather  inaccessible  to other
population centers by ground transportation.  However,  the city is  serviced by
the  state  of Alaska  marine highway  (ferry system) and  commercial airlines.

Because more than  three  processors  are  located  in Cordova and it is a non-
remote  area  (thus  subject to more rigorous waste controls), Cordova is one of
the areas which  should be  evaluated for centralized fish meal production.  The
separation  of finfish solids  and shellfish wastes should be  included in the
                                   59

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analytical process due  to  the different values associated with the respective
meal products.
3.   Juneau.   Juneau  is Alaska's  state  capital and one of  its  larger cities;
therefore,  it  is included  in the list of non-remote  areas.   Like Anchorage,
Juneau does not support an extensive fish processing industry.  Two major pro-
cessing  plants  are  located  in  the  Juneau  area;  principal commodities  are
canned and  fresh/frozen  salmon,  and halibut.  Because the processing schedule
is  normally limited to  the  summer months,  barging of wastes  to  a designated
dumping site during this season would not be a problem.  Juneau is served by a
secondary wastewater  treatment plant which  would  appear  capable of handling
wastewater  from seafood  processors.   An  easily accessible  private landfill
site is available within 5 miles of the local population center.

The number  of processing plants operating in the Juneau area limits the prac-
ticality  a  cooperative waste  reduction  facility there.   Byproducts could be
manufactured individually by the  two processors;  a  foreign manufacturer can
provide meal plants ranging from 250 to 1,000 kilograms per hour for this type
of application.
4.  Ketchikan.  With an estimated 1976 population of over 10,000, Ketchikan is
classified  as  a  non-remote  area.   Three major  seafood processors  operate
within the  city limits and a fourth is located about 3 miles from the popula-
tion center.  Employment statistics show a seasonal fluctuation that coincides
with  the  processing season.  The  main products for this area  are canned and
fresh/frozen salmon, halibut, herring and bottomfish.

Ketchikan's  location  and  relatively  mild weather  allow seafood processing
wastes to be  barged for deep sea disposal essentially year-round.  Local geo-
graphic conditions  limit  the potential for land disposal of wastes.   Because
the  city  has no  municipal wastewater  treatment  system,  this  waste  disposal
alternative  is  also unavailable  to local processors.  Thus,  byproduct manu-
facturing represents one  of the few remaining alternatives to ocean disposal.
The feasibility of a centralized fish meal production facility should be given
detailed consideration for the Ketchikan area.
5.  Kodiak.   Fourteen  seafood  processors were  operating  within the  city of
Kodiak  in 1977,  and  a fifteenth  plant  is  located  just  outside city limits.
Thus  Kodiak  supports  an  extensive  seafood industry; principal  commodities
include  canned  and fresh/frozen salmon,  halibut, King and Tanner crab, shrimp
and herring.   The city's  population  density further justifies its designation
as a non-remote area.

Fish  processing operations  continue  throughout the year  at  Kodiak.   And, as
noted earlier, area processors can have their wastes picked up by or delivered
to  Bio-Dry,  Inc.,  a  local  200-ton-per-day  meal plant.   This plant,  however,
does  not evaporate stickwater to enhance  the meal  quality.   In addition, the
variety  of species processed  in the area  (i.e., both finfish and shellfish)
hinders  the  consistency and quality  of the  final meal product.   Nonetheless,
local processors  have been  sending their wastes to the meal plant since 1973.
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The  Kodiak processor's  have  established  experience utilizing  a  centralized
meal plant as a waste  disposal  option.   The operation of  the  existing faci-
lity, as well  as  its modification to  improve product  quality,  should receive
detailed analysis.
6.  Petersburg.  The  city of  Petersburg is designated as  a  non-remote area.
Four seafood processing facilities are operating or have operated in the city,
producing fresh/frozen and canned salmon, halibut, herring fillets, Tanner and
King crab,  bottomfish  and shrimp.  Herring is also  frozen  whole and stripped
for roe.

In 1974,  one  processor initiated operation of a fish meal plant with a capac-
ity of  100  metric  tons per day.  The reduction plant has received wastes from
local processors,  as well  as  from  seafood  plants operating  in other areas.
Separation  of finfish and  shellfish waste is  an integral part  of the oper-
ation.  The barging  of wastes  from  the  non-local  processors  to the reduction
plant has stopped  because of the cost  incurred  in transport.   The Petersburg
reduction facility does  not operate year-round and has never operated at full
design capacity.


7.  Naknek-South Naknek.   As  many   as   seven  salmon  processing  plants  have
operated  along the  Naknek river,  making this  a  significant  remote  area  in
terms of  fish processing activity.   However, the  salmon  season here averages
only 10 processing days occuring  during a 3-week period.  This extremely short
duration  of waste generation  is not conducive  to supporting  a conventional
fish meal plant.


8.  Dutch Harbor.  In  recent years, the Dutch Harbor area has grown to be the
second  largest seafood processing  port in the  world.   The major commodities
are King  and  Tanner  crab, and  shrimp.   A very small volume of salmon is pro-
cessed in this area.   In view of  the volume and frequency of waste generation,
this processing  center may provide  significant raw material for chitin/chito-
san production at a  future time.   The low value  of shellfish  meal  and the
logistics associated with the Dutch Harbor area are obstacles to the feasibil-
ity of operating a centralized fish meal plant.


9.  Kenai Peninsula.    There  are a number of seafood  processors situated in a
relatively  small  geographical  area  known as the  Kenai  Peninsula.  This land
mass  is  adjacent to  Anchorage, extending  south  into  the  Gulf  of  Alaska.
Processors  are located around  the perimeter of  the  peninsula  in such munici-
palities  as Kenai, Soldotna, Ninilchik,  Homer and Seward.   Principal seafood
commodities  include  canned and  fresh/frozen salmon,  halibut,  King and Tanner
crab, and herring.

The largest and most diversified processor on the Kenai Peninsula is located
at  Seward,  where  operations  include a fish meal plant  which  is  capable  of
processing  150 metric tons of raw materials per day.  The Seward plant handles
wastes  from  its  own  processing activities,  along  with  a small  volume from
another  local processor.   However,  the plant has not operated anywhere near
its  capacity.  Therefore, considerations should be  given to  accepting solids


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generated by  other processors  located  on the peninsula  and  Anchorage plants
during economic evaluations.


V.   CHITIN/CHITOSAN PRODUCTION FROM SHRLMP AND CRAB WASTES

Meal commodities manufactured  from shellfish (shrimp and crab) wastes contain
less  protein  and  have a  poorer  market  value  than those manufactured  from
finfish  wastes.   Because  of  this,  attention must be  given to  alternative
methods of utilizing or disposing of shellfish wastes.   A variety of secondary
products and byproducts have already been described in this report.  Of these
alternatives,  the manufacturing of chitin and"its derivative,  chitosan, appears
to offer a  unique  opportunity for waste utilization which should continue to
be explored.


A.  Description of Chitin/Chitosan Production Process

As  shown in Figure  11,  chitin production requires  deproteination and demin-
eralization of shell material.  Caustic and hydrochloric acid extraction steps
yield  the   residual  polysaccaride,  chitin,  which  is  then washed,  dried  and
ground  into a  white powdery  substance.   Chitin can  then be  converted  into
chitosan through a  deacetylation (hot caustic) process as shown in Figure 12.
The  entire  process  is quite  sophisticated,  and  requires extensive quality
control measures, but  it  produces five marketable  products:   1.)  chitin;  2.)
chitosan; 3.) protein;  4.) calcium chloride; and 5.) sodium acetate.  In lieu
of sodium acetate  separation,  a caustic recovery process  can be incorporated
to reduce chemical costs.

B.  Properties and Applications of Chitin/Chitosan

Chitin  is an  abundant  natural carbohydrate polymer, found not only in shells
but  also  in insect exoskeletons  and,  to  a lesser  extent,  in fungi and other
plants  and  animals.  It  is  similar to other natural  polysaccarides,  such as
cellulose,  pectin,  starch,  and  carrageenan.   However,  most of  these poly-
saccarides  are  chemically  neutral or, in some cases,  acidic.  Chitin differs
from  the rest  because  it  has  the characteristics of a base (cationic), rather
than an acid.

Because they are cationic  and  possess a high electrical charge density, chitin
and  its derivative, chitosan,  exhibit unique properties  in  combination with
other  substances.   For  example,  its high electrical charge density and poten-
tial binding capacity give chitosan the ability to form an ion-exchange resin,
capable  of  recovering toxic  metallic ions  from waste streams.   It can also
help  coagulate  materials  from various types of wastewater, yielding a natural
coagulated  material which may be recycled or utilized more  readily than the
residuals from  other  coagulation processes.   For example  the use of chitosan
to remove suspended solids from food processing wastewaters  results in coagu-
lated  solids   that can  potentially  be  used  as an  animal  feed  supplement.
Chitosan can be made into  specialty films such as food wraps  and ion-selective
membranes for  water and  wastewater treatment systems.   It produces a strong
bind with negatively-charged polymeric products, giving it applications in the
paper-making,   textile-dyeing  and  adhesives  industries  (to  name a  few).   It
promotes the  healing  of wounds in humans, and could also be  used as a natural


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  SHELLFISH WASTES
                                         LEGEND

                                         	 SOLIDS
                                         	 LIQUID
  DEPROTEINATION
         IN
      ALKALI
   PROTEIN
RECOVERY AND
   FINISHING
-[> PROTEIN
          STABILIZED SHELL MATERIAL
        _£_
  DEMORALIZATION
        IN
    DILUTE ACID
                             SALT
                           RECOVERY
                           PROCESS
                           (OPTIONAL)
                    •-£> CALCIUM CHLORIDE
      CHITIN
Figure 11.   Process schematic for chicin production
               from shellfish wastes.
                         63

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   SHELLFISH WASTES
                                          LEGEND
                                          	 SOLIDS
                                          	LIQUID
   OEPROTEINATION
         IN
       ALKALI
   PROTEIN
RECOVERY AND
   FINISHING
-£> PROTEIN
           STABILIZED SHELL MATERIAL
   DEMORALIZATION
         IN
     DILUTE ACID
                              SALT
                            RECOVERY
                            PROCESS
                            (OPTIONAL)
             	£> CALCIUM CHLORIDE
      CHITIN
Figure 12.   Process schematic for chitosan production
                     from chitin.
                          64

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suture material.  Derivatives seem to have application in the selective aggre-
gation of  cancer  cells.   Table 8 lists 76 applications  which were identified
by  a  Brownsville,  Tecas, producer who has since  discontinued operation.(Ill)
C.  Current Status of Chitin/Chitosan Production

Despite  all  these potential  applications,  there is presently only  one manu-
facturer  (small  scale)  of chitosan in the United States.   Previously,  pilot-
scale facilities have produced chitosan and then discontinued their operations
because  of  economic considerations.   None  of these  have practiced the  re-
covery  of byproducts (calcium  chloride  and sodium  acetate).  Other  organiza-
tions have merely conducted research or contemplated full-scale  production of
chitin/chitosan from selected shellfish wastes.  Most of the world's  supply of
chitosan  is produced by a single manufacturer located in Japan.

The  single  United  States  manufacturer  of  chitosan is  located  in  Seattle,
Washington.   Chitosan   is  manufactured on  a  pilot  scale,  having no  large,
readily-identified  market for the material.   An earlier  chitin/chitosan pro-
duction  plant with  a  rated  capacity  of  about 150,000 pounds per year,  was
operated  in  the  Brownsville, Texas,  only  for  a limited time  due  to  economic
considerations.  Velsicol Chemical Corporation of Chicago  is currently seeking
funding  for a pilot scale production plant which would be able to accommodate
the variable  nature of  the raw material,  in this case crab shells, and evalu-
ate  byproduct  technology.   The proposed pilot  facility  requires an initial
capital  investment  of $2 to  $3  million  and would be located  in the  Hampton/
Newport  News,  Virginia  area or on  the  Delmarva  peninsula of Maryland  and
Virginia.  It would require  about  5  million pounds of blue  crab  shell annu-
ally,  to support production  of 10 tons  of chitin  per  month.  Based  on the
findings  of   pilot  plant  investigations  over  a  two-year  period,  full-scale
facility, capable of producing  3 million pounds of chitin/ chitosan annually,
could be  more extensively evaluated.   This facility would  be  supported by an
annual  crab  waste  generation volume  of 60 million  pounds  from  processors in
Virginia, Maryland,  North  Carolina  and  the northern part  of  South  Carolina.

Among  the factors  limiting chitin/chitosan production are  raw  material sup-
plies, raw materials transport,  production complexities,  and market demand for
the finished  product.  Each of these factors are discussed individually below.


1.  Raw Materials.   Chitosan  production  facilities  in the United States, such
as  the  one  which  once  operated in  Brownsville,  Texas,  have had difficulty
receiving a  steady, reliable supply of low-cost  raw material.    Part  of the
problem  is  that  processors  can still  find other  ways  to dispose  of their
wastes.   However, landfills are becoming more reluctant to accept unstabilized
materials, such as  seafood wastes, and meal plants are not realizing a profit
from handling shellfish wastes.   Many local processors are thus  finding them-
selves faced  with alternatives,  at a time when regulatory pressures are build-
ing for more  effective ways of dealing with seafood industry wastes.
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                                   TABLE 8

                 IDENTIFIED CHITIN/CHITOSAN APPLICATIONS (HI)
1.  Superior adhesive for plywood manufacture.   (The bond is stronger than the
    wood even after soaking in water.)
2.  Superior adhesive for laminating paper (water resistant).
3.  Superior adhesive for laminating wood blocks (water resistant).
4.  Superior adhesive for joining paper to regenerated cellulose.
5.  Superior adhesive for joining paper to wood (water resistant).
6.  Superior adhesive for joining paper to cloth (water resistant).
7.  Superior adhesive for joining paper to leather (water resistant).
8.  Superior adhesive for joining paper to glass (water resistant).
9.  Superior adhesive for joining wood to cork (water resistant).
10. Superior adhesive for joining wood to leather (water resistant).
11. Superior adhesive for joining wood to glass (water resistant).
12. Superior adhesive for joining wood to rubber (water resistant).
13. Superior adhesive for joining wood to rayon (water resistant).
14. Superior adhesive for joining wood to canvas (water resistant).
15. Superior adhesive for joining leather to leather (water resistant).
16. Superior adhesive for joining leather to cork (water resistant).
17. Superior adhesive for joining leather to regenerated cellulose  (water
    resistant).
18. Superior adhesive for joining cork to rayon (water resistant).
19. Superior adhesive for joining cork to canvas (water resistant).
20. Superior adhesive for joining rayon to rubber (water resistant).
21. Superior adhesive for joining rayon to cloth (water resistant).
22. Superior adhesive for joining regenerated cellulose films  to other cellu-
    lose films (water resistant).
23. Superior prime coating base for painting with specialty paints.
24. Furniture glue (water resistant).
25. Manufacture of wood veneer paper (water resistant).
26. Laminating safety glass.
27. Imparting increased wet and dry strength in paper manufacturing.
28. Imparting water resistance to finished paper.
29. As surface sizing on paper to impart both oil and water resistant proper-
    ties .
30. Increasing water resistance of cellophane.
31. As an emulsifying agent and thickener in proprietary sizing emulsions.
32. As a thickener in nonemulsion formulations.
33. As a semi-permanent finish on wool to improve-laundering properties and
    aid in retaining shape and greatly reducing shrinkage.
34. As an antistatic coating for synthetic fibers.
35. As a contributer of semi-permanent fullness and stiffness  to cotton fabrics,
    (Also imparts some water resistance.)
36. Improves acidic foot ointments.
37. Improves antacid tablets.
38. Improves contraceptive jellies.
39. Improves antiperspirants.
40. Improves dyeing characteristics of cellulose fibers and films.
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                             TABLE 8 (Continued)
41. As additive to infant food (including livestock)  to enhance growth of the
    essential Lactobacillus-Bifidus, thus enhances weaning earlier with less
    danger of complications.
42. As an additive to tetracycline promoting rapid adsorption of the antibiotic
    by the blood stream and maintaining the tetracycline at a high level.
43. Has similar function to above with other antibiotics.
44. As plastics adhesive.
45. As lubricant and sizing agent in the manufacture  of fiberglass reduces
    abrasion and breakage of fibers during handling and weaving.
46. Increases color capability of fiberglass.
47. Specialty adhesive for plastic to fiberglass laminates.
48. In removing mercury from industrial effluents.
49. In recovering mercury pollutants to useful compounds.
50. In coagulating oily industrial wastes thus permitting recovery and prevent-
    ing pollution.
51. In wound dressings.
52. In biomedical application such as an artificial skin.
53. As special edible food wrappers.
54. In reverse osmosis units.
55. For recovering trace metals from waste, sea and source waters.
56. For definitive water pollution surveying.
57. For imparting radically increased strength to synthetic fibers used in
    various fabrics.
58. In domestic sewage treatment plants in remote locations such as base camps
    for Alaska pipeline, and where conditions of terrain make other processes
    impracticable.
59. As a clarifier in breweries.
60. For improving electrical conductivity of special papers, such as used in
    xerox and other photocopying processes.
61. In brewery waste treatment for recovering animal feed-stuffs.
62. For recovery and re-use of undgested proteins from animal wastes.
63. For recovery and re-use of dissolved protein resulting from shellfish and
    finfish processing.
64. For recovery and re-use of products from cheese whey in big diaries.
65. As an anti-coagulant intravenous substitute for Heparin use (primarily for
    preventing blood clots).
66. For adsorbing D.D.T. and other similar insecticides.
67. As a surgical suture with properties that accelerate wound-healing.
68. For silver recovery in various processes.
69. For recovery of mineral resources of the sea.
70. As an oil-drlling mud additive.
71. For treatment of nuclear power plant wastes.
72. For very rapid determination of nuclear power plant pollution resulting
    from accident.
73. As a substrate for a microbial fermentation to produce a new enzyme "Chito-
    sanase".  Enzyme is used to control infection'in human burns. (WSG)
74. For sensitizing the photo-oxidative destruction of waste organic materials,
    such as phenols in industrial effluents. (WSG)
75. For coating and encapsulating particles. (WSG)
76. As a substrate for controlled release or herbicides (WSG)


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Considering  the  current  shellfish harvests  a  substantial chitosan  industry
could be established in the United States.   Although they are  seasonal,  shrimp
and crab waste supplies  appear plentiful in the Pacific Northwest,  Alaska and
the Chesapeake Bay area.   The Dutch Harbor  area  of Alaska generates  a  huge
amount  of  shellfish wastes.   However,  the remoteness of  this  area prohibits
serious consideration  regarding local chitosan production.  Local  processors
have been  approached by  the Japanese, who  are interested in buying  stabilized
shells  from the  Dutch Harbor area.   Stabilization  can be achieved  through
deproteinization of the  waste  material  (first chemical process  step in chitin
production) with a  weak  alkalai solution.   Not only would shell stabilization
occur,  but high  grade proteinacous  material could  be recovered (90  percent
protein).   The sale of the protein would significantly  improve  the economics
of operating such a facility.  The U.S.  Department of Transportation (DOT) has
published  regulations  for  the  shipboard   transport  of  the  alkali  chemical
required for  this process  as  well as  those pertaining  to hydrochloric  acid
required for demineralization to produce  chitin.    In  view of the  quality
control which must  be  excercised for chitin production,  stabilization appears
to be the  limit for shellfish wastes processing in Alaskan areas.

The availability  of shellfish wastes within a  given region would  have to be
accompanied by a  willingness by local processors to  cooperate  in supplying a
chitin/chitosan manufacturing  plant.  Market values for chitosan vary depend-
ing on the specific application.  But the major volume markets  (such as waste-
water coagulation or papermaking) would require a relatively low selling price
for chitosan.   Low chitosan prices  can only be achieved  by  large-scale  pro-
duction plants receiving  consistent  supplies of raw material  at minimal cost.
Transportation cannot  represent a large portion of the  costs associated  with
operating  a chitin/chitosan plant.
2.  Cost.  To be  economically feasible,  chitosan production would have  to be
large  in scale  and  consistent in quality.   Regional  processing centers  are
thus attractive, receiving wastes from selected areawide processors.   Velsicol
estimates  that  the  production  costs  associated with  a  full-scale  chitosan
plant would be approximately $2.00 per pound of chitosan;  whereas their pilot
facility which incorporates added versatility would  produce chitosan for about
three  to  four  times that  amount.   Investigations  conducted  by a Sea  Grant
Institution  supports the  $2.00 per pound  production  cost.(64)  The  Japanese
company which currently produces most of the world's chitosan sold the product
for about  $3.00 per pound in 1978, plus transportation  costs.

3.  Markets.  Despite  all the  potential  uses of chitosan, a  firm  market  for
this material  has not  yet been  established.   The  technology  exists  for  its
production,  but  additional   research  is needed to ensure adequate  product
performance in many of its applications.   Development of a strong market would
probably  result  from two  achievements:   1)  a  steady  output  of consistently
high quality chitosan; and 2) a full-fledged marketing  (sales)  effort.

The reluctance  of  private industry to enter  the  area  of chitin/chitosan pro-
duction reflects the major capital investment required  to construct a  manufac-
turing plant of  large enough capacity to allow a competitive price structure.
Prices are a  reflection of demand, which many feel  is  not yet great enough to
justify  capital expansion.   One of the uses of chitosan is in the coagulation
of wastewater.  If the  Food and  Drug Administration were  to  approve  chitosan


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as an animal food additive, then it would create immediate demand for chitosan
as a coagulant for proteinaceous food processing wastewaters.   Sludge from the
treatment process could then be used as an animal feed.

The Sea  Grant Program  at the Massachusetts Institute  of Technology recently
reported that  chitosan  production  would be commercially feasible at a produc-
tion rate  of between  1 and 4 million  pounds  per year at a  selling price of
$1.00  to  $2.50 per  pound.(64)   The recommended  scheme  requires  that partic-
ipating local shellfish processors separate their wastes into two parts:   1) a
mechanically separated  protein;  and 2)  shell waste residual.   The shell  waste
residual  would be  sold  to  a  regional or  national-level producer  of  chitin
derivatives.   Several  other researchers  and  industry  representatives  have
expressed skepticism with regard to the economic feasibility of any such  plan.
D.  Outlook

Skepticism  aside,  chitin/chitosan production appears to  offer  an alternative
to  meal production  or  other forms  of shrimp and  crab waste  disposal.   The
potential uses  or  markets for chitosan have  only  recently been seriously re-
searched, but  already  indicate  the broad range of  applications for the mate-
rial.   In the  long run,  chitin/chitosan production will have to be considered
seriously, not only for its own sake, but also for the sake of resource utili-
zation and hence of environmental protection.

The  largest and most  immediate  use of chitosan appears  to  be  for wastewater
coagulation, particularly in cases  where the use of a  natural polymer might
enhance  the  market value of the  coagulated  sludge  (e.g.,  as an animal feed).
Beyond  this, it would  be difficult to speculate which application will emerge
as  the  best potential  market for chitosan,  or  at what price.   Nor  can it be
predicted when or  if this market  will develop.

In  the  immediate  future,  it appears  that  chitosan production  in the United
States  will  need to continue at  pilot  and  demonstration levels, awaiting the
establishment  of  firm market,  predictable  price  structure,  and  consistent
quality  product.   As  these  develop,   chitin/chitosan  production may indeed
emerge  as a long-term  solution to the problem of shellfish waste disposal for
certain  areas  of the country.  Such areas would have to contain enough shrimp
and/or  crab  processors  within an acceptable  distance to  provide a consistent
supply  of raw material in support of large-scale chitosan production.  Not all
processors will  fit into  such a scheme.
VI.  ULTIMATE DISPOSAL OF SEAFOOD WASTES

In  selecting a waste  disposal alternative, a  seafood  processor should first
consider  the manufacture of  secondary products or  byproducts  from this pro-
teinaceous material.  If this  appears unfeasible, then land application should
be  considered, again attempting to take advantage of valuable materials in the
seafood  wastes  for agricultural  purposes.   If  none of the  above courses of
action  can  be  implemented,  then the  processor must  consider  the  ultimate
disposal  of  processing  wastes by some other means.  The two principal altern-"
atives for final disposal are  barging (ocean disposal) and landfilling.
                                   69

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A.  Barging

Alaskan seafood processors have the option of barging their waste materials to
designated  deep sea  disposal  sites  which  are  generally  within 5  miles  of
shore.   Barges  are  generally  operated  by  individual processors;  however,
cooperative  efforts  are also  a realistic option.   In the  contiguous  United
States, most processors have  other disposal alternatives  available,  such as
landfilling  and centralized  byproduct  manufacturing facilities.   The  United
States territories  of Puerto Rico and American Samoa  support  major tuna can-
neries which are accompanied  by  fish meal plants.  At  the byproduct facili-
ties,  stickwater is  not  evaporated to produce  solubles;   instead,  this  con-
centrated waste  stream is  either  barged to  sea  or directed to the respective
wastewater  treatment  system.   Treatment  system  performance is  impacted when
the stickwater is received at the wastewater plant.
B.  Landfilling

The landfilling  (or  burial)  of sludges and other  solid wastes has tradition-
ally  been the most  common and least expensive method  of disposal.   However,
new sites are becoming  difficult  to find,  and there is  mounting  concern for
the environmental  impact of landfill operations.  Regulations  have  been gen-
erated  by state  and  federal  agencies  specifying the  proper  standards  for
selecting and  operating  a landfill site.  For seafood  processors  in the con-
tiguous United States,  this  means greater attention-will have to  be given to
cooperative  approaches  and  to  joint  municipal-industrial  sludge  disposal
sites.   Processors  can  participate  in the operation  of an  existing  sludge
landfill  or  arrange  for the co-disposal of residual  solids  at a conventional
refuse landfill.

The principal  material  to be landfilled by the seafood processing industry is
DAF  sludge   (float)  and,  to  a  lesser  extent,  waste activated sludge.   But
disposal  of  any  type of sludge, including the DAF float, will become increas-
ingly  difficult  as  the  mandated  criteria of  the Resource  Conservation and
Recovery Act (RCRA)  of 1976 are implemented.  RCRA prohibits future open dumps
and requires  upgrading  or closing of existing dumps; regulates the treatment,
storage,  transportation  and  disposal of hazardous wastes to protect the land;
and further  requires reduction of the waste stream through increased resource
recovery  and waste reduction efforts.  While final regulations are still being
formulated,  it is  known that  the  primary  focus  of RCRA  is on the 21 primary
industries which are known  to generate hazardous wastes.  Since  the seafood
processing industry  is  a  secondary industry, little insight  can  be provided
regarding the impact of  RCRA on float disposal.

With  regulations governing landfill operations becoming  more restrictive,  it
is  important  to  consider dewatering the sludges to make  them more amenable to
burial.  Dewatered float and waste activated sludges, are  also easier to trans-
port  to  the disposal  site than liquid material.  Economics  and imposed res-
trictions will dictate  the  need  for installing  dewatering equipment  at the
treatment plant  site.

Co-disposal with other types of refuse  is common for dewatered waste activated
sludge.   But here again,  this treatment  technology  is  not  expected to find
substantial  use  within  the  seafood industry.   The more  common sludge  is ex-
                                   70

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pected  to  result from  use  of DAF  treatment systems.  The  sludge,  or float,
from DAF units  is  a viscous material  that  can  be handled as a  liquid or de-
watered and handled  more  like a solid.  Evaluation  of  alternative dewatering
systems and their  related economics would need to be performed on a case-by-
case  basis.   Dewatered  and  undewatered  DAF sludge has  been   landfilled  by
California tuna  canneries.    In  Puerto Rico the disposal  of  liquid  float and
dewatered float has been accomplished.  Sludge concentration was found to be a
necessary  step  for  this  geographical location mainly  due to  aesthetics and
environmental considerations.   In general,  relatively  few seafood processors
have  installed  DAF  treatment and  even  fewer  have  any  experience  with the
dewatering and disposal of the resulting sludges.

Other food industries which employ DAF treatment units or biological treatment
systems have demonstrated that their sludges can be dewatered and receive safe
disposal .separately  in  conjunction  with  other  municipal  and  industrial
sludges.


C.  Other Disposal Methods

Several characteristics of  the seafood industry have an impact on landfilling
and other  disposal  options.   A significant segment of the industry is located
in  Alaska, where   geographic,  soils  and  climatologic  conditions  eliminate
landfilling as  a viable  disposal  alternative.   The  prevalence  of small pro-
cessing plants  which operate  intermittently prevents  consideration  of high-
technology, high investment  waste  disposal options, such as incineration or
pyrolysis for most of the industry.
                                   71

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APPENDIX

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                                  APPENDIX A
                       BIBLIOGRAPHY OF DOMESTIC SOURCES
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                                        A-l

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15.   Bough,  W.A.,  Chitosan  and  Its  Role in  Food  Processing and  Industrial
     Waste Treatment, presented at  the  Chitin-Chitosan Workshop, Texas A  &  M
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                                        A-2

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28.  Bucove, G.O.,  and G.M. Pigott,  "Pilot Plant Production of  a  Functional
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29.  Caponigro,   Michael  A.,  Benthic  Macrofauna, Sediment  and Water  Quality
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30. .Carroad, P.A.  and R.A.  Tom "Bioconversion  of  Shellfish Chitin  Wastes:
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36.  Collins, J. and R.D. Tenney, "Fishery Waste Effluents:  A  Method to Deter-
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37.  Collins,  J.  and  R.D.  Tenney,  "Fishery Waste  Effluents:   A  Suggested
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38.  Costa,  R.E.,  Jr., "The  Fertilizer Value  of Shrimp  and  Crab  Processing
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39.  Creter, R.  V., and J.  P.  Levandowski, "Simple Waste Treatment for Seafood
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                                        A-3

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44.  Development Document  for Effluent Limitations Guidelines and New Source
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     December  1977.
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84.  Fawler, F.K.,  "Cuts River Pollution - Recycling of Water for Transporting
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85.  Lewis,   W.L. -et  al.,  "A Preliminary Evaluation  of a Fish Diet  Based  on
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     27th Annual Conference  Southeastern Association of_ Game and Fish Commis-
     sioners , 1973.

86.  Lin, S.S. and P.B.  Qias,  "Evaluation of an Extended Aeration Process for
     Skokomish Salmon  Processing Wastewater Treatment", EPA Grant  No.  803911
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87.  Lindsay, G. and N.W. Schmidtke, "Screening Demonstration for  Three  Fish
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88.  Lotan,   R. ,  "Interaction of  Wheat-Germ Agglutinin with  Chitin Oligomers
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89.  Lovell,  R.T.,  "Utilization  of  Solid  Waste  from  Catfish  Processing
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90.  Madhaven, P., and  K.G.R.  Nair,  "Metal-Binding Property of  Chitosan  from
     Prawn  Waste,"  Proceedings   First   International   Conference  on  Chitin/
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91.  Mann, R. , and J.H.  Ryther,  "Growth of Six Species of Bivalve Molluscs  in
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     1977.

92.  Marine  Publications,  College of Marine  Studies,  University  of Delaware,
     1977.

93.  Masri,   M.S.  e_t  al.,  "Insolublizing Enzymes  with Chitosan  and  Chitosan
     Derived Polymers," Proceedings  First International Conference on Chitin/
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     Institute of Technology, Cambridge, MA, MIT Sea Grant Report, MITSG 78-7,
     May 1978.

94.  Masri,   M.S. et  al. ,  "Use of Crosslinked Chitosan in the Finishing Treat-
     ment of Wood Fabric for Laundering-Shrinkage Control," Proceedings of the
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     Muzzarelli  and  E.R.  Pariser,   Massachusetts   Institute  of  Technology,
     Cambridge,  MA, MIT Sea Grant Report, MITSG 78-7, May 1978.
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95.  Marsi, M.S.,  and  V.G.  Randall, "Chitosan  and Chitosan Derivatives  for
     Removal of  Toxic  Metallic Ions from Manufacturing  Plant Waste Streams,"
     Proceedings  o_f  the  First International  Conference  on  Chitin/Chitosan,
     edited by R.A.A.  Muzzarelli  and E.R.  Pariser, Massachusetts Institute of
     Technology,  Cambridge,  MA,  MIT  Sea  Grant Report,  MITSG 78-7,  May 1978.

96.  Mendenhall,  V.,   Utilization  and  Disposal £f Crab  and  Shrimp  Wastes,
     Alaska University Cooperative Extension Service, Marine Advisory Bulletin
     No. 2, NTIS COM-71-01092, March 1971.

97.  Meo, M. et al.,  "Land Treatment of Fish Processing Wastes  on Dredge Spoil
     Sites:  Comparative  Cost Evaluations," Coastal  Zone  Management Journal,
     Vol. 3, No. 3, pp 307-318, 1977.

98.  Meo, M. e_t al.,   Overland Flow in the Louisiana Coastal Zone:  The Poten-
     tial for Land Treatment of Waste Waters on Diked Dredge Disposal Sites in
     South Louisiana,  Louisiana State University,  Baton Rouge,  LA, Report No.
     LSUSG-T-75-04, November 1975.

99.  Meyers, S.P.  and  B.E.  Perkins, "Recovery and  Applications  of Byproducts
     from Louisiana Shellfish Industries," Proceedings 2nd Annual Tropical and
     Subtropical  Fish   Technology  Conference  o_f  the Americas,   October 1977.

100. Meyers,  S.P., and S.C.  Sanu,  "Nucleotides  and Amino Acids  in  Shrimp
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     1974.

101. Meyers,  S.P. et   al.,  "Variability  in Proamate  Analysis   of  Different
     Processed  Shrimp   Meals,"  reprinted  from Feedstuffs, Vol.  45, 'No.  47,
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102. Moody, M.W., Seafood  Plant   Sanitation,  Louisiana State University Co-
     operative Extension Service,  Publication No. 1879, November 1976.

103. Morris,  R.E. and D.G.  Bzdyl, "Physical/Chemical  System   Provides  Cost
     Saving Pretreatment and Byproduct Recovery", Pollution Engineering, March
     1977.

104. Muzzarelli,  R.A.A.,  "Modified  Chitosans  and  Their  Chromatographic  Per-
     formances",   Proceedings   First  International   Conference  on  Chitin/
     Chitosan,  edited   by  R.A.A.   Muzzarelli and E.R.  Pariser,  Massachusetts
     Institute  of Technology,  Cambridge,   MA,   MIT  Sea  Grant  Report,  MITSG
     78-7, May 1978.

105. National  Canners  Association,  "Preproposal:  Utilization   of  Tuna  DAF
     Sludge",  prepared by Tuna Research Foundation,  Terminal Island,  CA, May
     1977.

106. Noguchi,  J. "Studies on the Preparation of Chitin Fibers,"  Proceedings o_f
     the  First  International  Conference  on Chitin/Chitosan edited  by R.A.A.
     Muzzarelli  and  E.R.  Pariser,  Massachusetts  Institute  of  Technology,
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107.  Patashnik,  M.  et al.,   "Smooth,  White Spread  from  Separated Fish  Flesh
     Forms a Base  for Flavored  Dips,  Snack Items," Food Product  Development,
     July/August 1973.

108.  Patton, R.S.  et  al., "Nutritive  Value of Crab Meal for  Young Ruminating
     Calves," Journal of  Dairy  Science,  Vol.  58,  pp.404-409,  March  1975.

109.  Patton, R.S.  and P.T.  Chandler,  "In Vivo  Digestibility Evaluation  of
     Chitinous   Materials,"  Journal of  Dairy Science, Vol.  58, pp.  397-403,
     March 1975.

110.  Peniston,  Q.  P.  and  E.L.  Johnson,  "Method for Treating an Aqueous Medium
     with  Chitosan and  Derivatives  of  Chitin to  Remove  an  Impurity",  U.S.
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111.  Perceval,  P.M., unpublished data,  January 1975.

112.  Perceval,   P.M.  and  W.E. Nelson,  "Improving the Economics of Crustacean
     Waste Disposal" (unpublished), September 1979.

113.  Perkins, B.E. and  S.P.  Meyers,   "Recovery  and Application of  Organic
     Wastes  from  the  Louisiana Shrimp  Canning Industry",   Proceedings Eighth
     National Symposium  on  Food  Processing  Wastes,  EPA-600/2-77-184,  August
     1977.

114.  "Pilot Plant  Could Develop  into  New Industry for Converting  Waste Shells
     into  Chitin  and  Chitosan,"  Pacific Northwest  Sea,  Vol.   6, No.  1,  1973.

115.  Pohland, F.G.  and J.W.  Hudson.  "Aerobic and Anerobic  Microbial Treatment
     Alternatives- for Shellfish Processing Wastewaters in Continuous Culture,"
     presented  at  the Symposium on Novel Approaches  to  Microbial  Utilization
     and  Control  of Waste,   Mexico  City, Mexico,  November 30 -  December  5,
     1975.

116.  Pohland, F.G.,  and  J.W. Hudson,  Wastewater Management  Alternatives for
     the Shellfish Processing Industry,  Georgia Marine Science Center,  Univer-
     sity  System of Georgia,  Skidaway Island, GA, Technical Report Series No.
     78-2  (SCEGIT -77-157),  April 1978.

117.  Process Design Manual  for Land  Treatment o_f  Municipal  Wastewater,  U.S.
     EPA  Environmental Research  Information  Center,  Technology Transfer, EPA
     625/1-77-008, 1977.

118.  Provant,  S.G.,  W.T.  McFall,  and  R.K.  Stewart, Studies on  Industrial
     Effluent and  Its  Effect on Water Quality in St.  Paul  and Kodiak Harbors,
     and  Gibson  Cove,  Environmental  Protection  Agency,  Anchorage,  Alaska,
     Region X,  Alaska Operations Office, 1971, 44 pp.

119.  Public  Law 94-265,   "Fishery Conservation and Management Act  of 1976",
     94th Congress, H.R.  200, April 13,  1976.

120.  Rajulu, G.S.  and N. Gowrl,  "Chitin  from Marine Organisms,"  Proceedings
     First  International  Conference  on  Chitin/Chitosan,  edited  by  R.A.A.
     Muzzarelli  and  E.R.  Pariser,  Massachusetts  Institute  of  Technology,
     Cambridge,  MA, MIT Sea  Grant. MITSG 78-7, May 1978.

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121.  Ramirez,  E.R.,  "Electrocoagulation  Clarifiers Food  Wastewater,"  High-
     lights published by  the  Water Pollution Control Federation, April  1975.

122.  Ramirez,  E.R., "Electrocoagulation of Meat  Processing Wastewater,"  WWEMA
     Industrial  Water and Pollution Conference, Detroit,  Michigan, April  1974.

123.  Ramirez,  E.R., "Direct Comparison in Physiochemical  Treatment of Packing-
     house Wastewater between Dissolved Air and Electroflotation," Proceedings
     £f  the  31st  Purdue  Industrial  Waste  Conference,  Lafayette,  Indiana,
     1976.

124.  Ramirez,  E.R.  and  O.A. Clemens, "Electrocoagulation Techniques  for Run-
     ning Treatment  of  Several Different  Types  of Wastewater," presented  at
     the  49th  Annual  Conference  WPCF  Conference,   Minneapolis,  Minnesota,
     October 1976.

125.  Rao, M.R.  et  al.,  "Pilot Plant Clarification of Menhaden Bail  Water with
     Acid  Activated  Clay,"   First  Internationl  Congress  of Engineering and
     Food, Digest of Papers, Boston, MA, August  9-13,  1976.

126.  "Reassessment of Effluent Limitations Guidelines and  New  Source Perfor-
     mance  Standards  for  the Canned and  Preserved Seafood  Processing  Point
     Source Category",  draft final  report  prepared by  the Edward  C.  Jordan
     Co., Inc.,  December 1979.

127.  Report  on   Pollution  Affecting  Shellfish  Harvesting  in Calveston  Bay,
     Texas, EPA Water Quality Office, March 1971.

128.  "Resources:   Aid  for  U.S.  Fish Processing," Business  Week,   April 17,
     1978.

129.  Rosenau, J.R.,  L.F.  Whitney,  and J.R. Haight, "Economics  of  Starch and
     Animal Feed Production From  Cull Potatoes," Proceedings  Ninth National
     Symposium  on  Food  Processing  Wastes,  EPA  600/2-78-188,  August  1978.

130.  Ryther,  J.H.  et  al. ,  "A Fresh Water Waste  Recycling-Aquaculture System,"
     Florida Scientist,  Vol. 40, No.  2, pp.130-135, 1977.

131.  Ryther,  J.H.,  Marine Polyculture Based upon Natural  Food   Chains  and
     Recycled Wastes  -  Summary,  Woods Hole  Oceanographic  Institution,  Woods
     Hole, MA, July 1975-June 1976.

132.  Ryther,  J.H.,  Preliminary Results with  a Pilot-Plant  Recycling - Marine
     Aquaculture System, Woods Hole Oceanographic Institution, Woods Hole, MA,
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     Wastewater  through Aquatic  and  Terrestrial  Systems, July  15-21,  1975.

133.  Satia,  B.P.,  and  E.L.  Brannon,  "The  Value of  Certain Fish-Processing
     Wastes  and Dogfish  (Squalus  Suckley)  as   Food  for Coho  Salmon (Oncor-
     hynchus Kisutch) Fry," The Progressive Fish-Culturist, Vol. 37, No.  2, pp
     76-80, April  1975.

134.  "Screw  Press  Dewatering  Solves  Costly Waste  Disposal  Problem,"  The
     National Provisioner, November  13, 1976.
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135.  Seligsohn,  M.R.,  "Thrifty Ways Pay Off for Kane-Miller,"  Food  Engineering,
     October 1975.

136.  Shotwell,   J.A.,  "A  Seafood  Solid  Waste  Process",  (unpublished)  1976.

137.  Sludge Treatment  and Disposal,  U.S.  EPA  Technology  Transfer,  EPA  625/
     1-74-006,  October 1974.

138.  Smith, F.J.,  "The Economist  and the  Seafood  Producer," reprinted  from
     American Journal  of Agricultural Economics, Vol.  56, No.  5,  pp 1038-1046,
    .December 1974.

139.  Annual Report  of  the  Warmwater  Fish Cultural Laboratories,  Stuttgart,
     Arkansas,  Kermit  E. Sneed, Director,  1970.

140.  Snider, I.  F.,  "Dissolved Air Flotation Treatment of Seafood Wastes,  "EPA
     Technology Transfer Seminar - Upgrading Seafood  Processing  Facilities  to
     Reduce Pollution," New Orleans, LA,  March 5-6,  1974.

141.  Processing Farm-Raised Catfish, Southern Cooperative Series  Bulletin 193,
     edited by R.T.  Lovell and G.R. Ammerman, October  1974.

142.  Spatz,  D.D.  and  L.  Trauberman, "How  Membranes Separate  Profits  from
     Pollution," Food  Engineering,  October 1975.

143.  Stephens,  N.L.  e_t al.,  "Preparation and Evaluation of  Two Microbiological
     Media  from Shrimp Heads  and Hulls,"  (unpublished)   Department of  Food
     Science, University  of  Georgia, College  of Agricultural  Experiment  Sta-
     tions .

144.  Stuber, D.A.  and  J.T.  Quigley, "Wastewater Treatment in Fish Processing."
     Proceedings £f 16th Conference  on  Great Lakes Resources,  pp.  958-966,
     1973.

145.  Swartz, Richard C.  et al., Benthic Macrofauna,  Sediment and  Water Quality
     Near Seafood Cannery Outfalls in Yaquina Bay,  Oregon,  U.S.  Environmental
     Protection Agency,  Newport, Oregon,  Marine and  Freshwater Ecology Branch,
     Corvallis Environmental Research Laboratory, September 11, 1978.

146.  Szabo, A.J.  et al. , "Dissolved Air Flotation Treatment of  Gulf  Shrimp
     Cannery Wastewater," Proceedings Ninth National Symposium on Food Proces-
     sing Wastes,  EPA  600/2-78-188, August 1978.

147.  Takeda, M. ,  "Use  of Chitin  Powder as  Adsorbent in   Thin-Layer  Chroma-
     tography," Proceedings First International Conference  on  Chitin/Chitosan,
     edited by  R.A.A.  Muzzarelli  and E.R.  Pariser,  Massachasetts Institute  of
     Technology, Cambridge,  MA, MIT  Sea  Grant Report, MITSG  78-7, May 1978.

148.  Tarky, W.  et al. ,  "Protein Hydrolysate from Fish Waste," Journal of Food
     Science, Vol.  38, pp.917-918,  1973.

149.  "Technique Developed  to Purify Fish  Processing  Wastewater,"  Environment
     News, published by EPA  New England Regional Office, Boston,  MA,   August
     1978.
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150.  Toma,  R.B., and S.P.  Meyers,  "Isolation and Chemical Evaluation  of  Pro-
     tein  from  Shrimp  Cannery  Effluent,"  Journal of  Agricultural and  Food
     Chemistry,  Vol.  123,  No.  4,  pp.632-635,  1975.

151.  Umlauf,   J.L.,   Chitin/Chitosan  Shellfish  Waste   Utilization  Program,
     Oceanographic Institute of  Washington.

152.  U.S.D.A., Agricultural  Handbook 60,  Diagnosis and  Improvement  of Saline
     and Akalai  Soils,  1954.

153.  ."Use  Waste  Byproduct  to Recover  Solids from  Processing Wastes,"  Food
     Processing, June 1975.

154.  Veslind, P.A.,  Treatment and Disposal  £f Wastewater Sludges,  Ann Arbor
     Science, 1974.

155.  "Wastewater  Treatment with Air  Flotation," Environmental  Science  and
     Technology, Vol. 7, No. 11,  pp.996-997,  November 1973.

156.  Water  Quality   Investigation  Related  to Seafood  Processing  Wastewater
     Discharges    at   Dutch  Harbor,   Alaska,  October   1975,   October  1976,
     EPA-910-8-77-100.

157.  Welsh,  J.P.,  and  B.Q. Welsh,  "Mariculture  of the  Crab,  Cancer Magister
     (DANA)  Utilizing  Fish and  Crustacean  Wastes  as Food,"  California State
     University at Humboldt, NTIS COM-74-11247/AS.

158.  Wert, F.S., and U.B.  Henderson,  "Feed Fish Effluent and Reel  in Savings,"
     Water and Waste Engineering, June 1978.

159.  Witherow, J.L.,  Waste Treatment for Small  Meat  and Poultry  Plants,  An
     Extension Application,  American Society of Agricultural  Engineers,  June
     1976.

160.  Yaku, F.,  "Chitosan  -  Metal  Complexes  and Their  Function,"  Proceedings
     First  International  Conference on  Chitin/Chitosan,  edited  by  R.A.A.
     Muzzarelli  and  E.R.  Pariser,   Massachusetts  Institute  of  Technology,
     Cambridge,  MA,  MIT Sea Grant Report,  MITSG 78-7,  May 1978.

161.  Zall,  R.R. ,  and  I.J. Cho,  Production  of  Edible  Foods  from  Surf  Clam
     Wastes, presented  at the American  Society of Agricultural Engineers 1976
     Winter Meeting, Chicago, Illinois, December 14-17, 1976,  NTIS PB 267 410
     NS.

162.  Zall, R.R.  "Reclamation and  Treatment  of Clam Wash Water,"  Proceedings
     Seventh  National  Symposium on  Food  Processing  Wastes,  EPA-600/2-76-304,
     December 1976.

163.  Zielnski,  P.B.  and  W.E.   Castro,  Engineering  Considerations  in  the
     Aquaculture  p_f  "Macrobranchium Rosenbergii"  in South  Carolina, American
     Society of Agricultural Engineers,  December  1976.
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                                  APPENDIX B

                        BIBLIOGRAPHY OF FOREIGN SOURCES
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202.  Bloomstrom, G.,  and L.  Eklund, "Technical Investigation of the Operations
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203.  Courtial, W., "Effluent  Purification by the Separation  and  Recovery  of
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204.  "Developing  Countries  Have Role  in  Exploiting Unused  Resources",  World
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206.  Eklund,  L.   and   E.  Swedling,  "Load Measurements  at  Foodia,  Inc.,  at
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207.  Erael'yanova,  E.A. et a^. ,  "Effect of Some Electrolytes on the Coagulation
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214.  Holladay, D.G.,   "An Approach to Effluent Treatment in the Food Industry",
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215.  Kato, T.  and M. Maeda,  "Electroflotation Treatment of Waste  Water  from
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216.  Klopfenstein, D. ,  "B.C.  Plant  for  the Total  Use  of All  Fish,"  Fishing
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217.  Kuji, Y.  et  al.,  "Treatment  of  Waste Water  from Marine Products  Pro-
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218.  Kurosaki, B.,  "Treating Seafood Wastewaters with  Mycelia."  Japan Kokai,
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219.  Leoni, C.  et al.,  "The Depuration  of Waste Waters  from Food  Preserving
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222.  Maeda, M.  et  al., "Treatment  of  Protein  -  Containing Waste Waters  by
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223.  Maeda, M.  et  al. , "Treatment  of  Waste  Water from Marine  Product  Pro-
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224.  Maeda, M.  and T.  Ogawa,  "Treatment of Waste  Water Containing Protein,"
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225.  Maeda, M.,  "The  Treatment of Waste Water by Electrical Flotation Separa-
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226.  Matsuura,  R.  et al.,  "Electrolysis  of Marine Product Processing Waste
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227.  Matsuura,  R.  e_t al. ,  "Marine  Product Process Waste  Treatment."  Japan
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228.  Matsuura, R.  et aj..,  "Treatment  of Waste  Water Discharged  from Seafood
     Processing," Japan Kokai,  50, 267 (1975);  Chemical Abstracts 84,  184623u,
     (1976).
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229. Matsuura, R. et al., "Treatment of Waste Water from Manufacture of Marine
     Products."  Japan  Kokai,   76  41,  257  (1976);   Chemical  Abstracts,  85,
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230. Matsuura, R.  et al.,  "Treating of Waste Water  from Marine  Product Pro-
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231. Matsuura, R.  and K.  Akakie, "Treatment of Waste Waters from Seafood Pro-
     cessing  Plants  by  Electrolysis,"  Japan  Kokai,  75,   120,   160  (1974);
     •Chemical Abstracts, 94, 65080e  (1976).

232. Melvin, A.  and L.  Eklund, "Load Measurements at Abba,  Uddevalla" (unpub-
     lished), The  Swedish National Environment Protecton Board,  February 5-7,
     1974!

233. Mortensen,  B.F.,  "Effluent  Control  in  Food  Processing  Industries",
     Process Biochemistry, Vol. 12, June 1977.

234. Namisa,  M.,  "Recovering  Protein  from Waste Water  Containing Crude Pro-
     tein."  Japan  Kokai,  75,  33,  142  (1975); Chemical  Abstracts,  85, 1006lq
     (1976).

235. Nishida,  E. ,   "Coagulation of  Fishery Waste Water with Organic Coagu-
     lants,"  Nihon Daigaku No Juigakubu Gakujutsu Kenkya Hokoku  (Japan), 34,
     291  (1977); Chemical Abstracts, 87, 106395u (1977).

236. "Norway's Fish Meal Producers Look Forward to Another Good Year", Fishing
     News International, Vol.  16, March 1977.

237. Ohtake,  S.,  "Treatment of Waste Water  from  Marine Paste Products  Pro-
     cessing  Plants  -  Electrolysis  -  Flocculation  Method,"   Japan  Food
     Science, 14,  7, 58 (1975); Chemical Abstracts, 86, 1266l7a -(1977).

238. Onue, Y, and V.M. Riddle,  "Use  of Plastein Reaction in Recovering Protein
     from Fish Waste", Journal Fisheries Research Board of- Canada, Vol. 30 No.
     11, pp.1745-1747, NTIS: COM-74-1089/AS, November 1973.

239. Potter,  D.P.   et  al. , "Fish  By-products - Fish Meal  and Fish Silage",
     Process Biochemistry, Vol.  13,  pp22-25, January  1978.

240. Sand,  G. ,  "Twenty  Countries Try Norse Fish Powder", Fishing News Inter-
     national, Vol. 14, August  1975.

241. Shiflin, S.M.  et aj^. , "Mechanical Cleaning of Waste Waters from Fish Can-
     neries," Rybn Khoz (USSR), 2,  62  (1972); Chemical Abstracts, 76, 131182e
     (1972).

244. Shimoda, Y.  et al. ,  "Analysis  of  Waste  Water Discharged  from a Mackerel
     Processing  Plant,"  Shizuoka Ken  Suisan Shikenjo  Jigyo  Hokuku  (Japan),
     78,  (1974); Chemical Abstracts, 87, 90247J (1977).

243. Shimoda, Y.  e_t a_l. ,  "Analysis  of  Waste  Water  from a Horse Mackerel Pro-
     cessing  Plant,"   Shizuoka Ken  Suisan  Shikenjo  Jigyo Hokoku  (Japan), 80,
     (1974);  Chemical Abstracts, 87,  122357p  (1977).

                                        B-3

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244. Shimoda, Y.  et al.,  "Waste  Water Treatment  after Processing of  Marine
     Products  III;   Waste Water  Treatment  after the  Production of  Salted
     Mackerel," Shizuoka Ken Suisan Shikenjo Jigyo Hokoku (Japan),  61,  (1974);
     Chemical Abstracts, 87, 1064l4z (1977).

245. Shimoda, Y.  et al. ,  "Waste  Water Treatment  After Processing of  Marine
     Products  IV;   Waste  Water  Treatment  After Processing  of  Mackerel,"
     Shizuoka Ken Suisan  Shikenjo Jigyo Hokoku,  (Japan), 61,  (1974)  Chemical
     Abstracts, 87,  1064l4z (1977).

246. Swedling, E. and H. Hedin, "Load Measurements at Salto Industrial Purifi-
     cation Plant"  (unpublished),  The  Swedish National Environment Protection
     Board, May 7, 1974.

247. Swedling, E. and L. Eklund, "Load Measurements at Foodia, Inc. Industrial
     Sewage Plant at Lysekil"  (unpublished), The Swedish National Environment
     Protection Board,  September 24-26, 1974.

248. Swedling, E. et al.,  "Investigation of  the  Operations  at Skame-Delika-
     tesser, Hovicken" (unpublished), The Swedish National Environment Protec-
     tion Board,  January  15, and April 28-29, 1976.

249. Tagawa,  S.  et  al. ,  "Removal of  Constituents from the  Waste Water Dis-
     charged  from 'Kamaboko'  Processing Plants by pH Shifting Method," Suisan
     Daigakko  Kenkuyu  Hokoku  (Japan),  24,  1,374  (1975);  Chemical Abstracts,
     87, 172326y  (1977).

250. Tagawa,  S.  et  al.,  "Removal of Constituents  from Waste  Water Discharged
     from Mackerel  Canning Plants by the pH Shifting Method." Suisan Daigakko
     Kenkuyu Hokoku (Japan), 25, 1, 75  (1976); Chemical Abstracts, 87, 172325x
     (1976).

251. Takagi,  M.  et  al.,  "Comparative Studies on  the  Effects  of Coagulants on
     Activated  Sludges   from  Fish  Meat  Processing  Plants,   I," Aichi  Ken
     Shokuhin  Kogyo   Shikensho  Nempo   (Japan),   14,   93   (1973);  Chemical
     Abstracts, 85,  9915q  (1976).

252. Tanaka,  Y.   et  a_l. ,  "Purification of  Waste  Water  from  Marine  Product
     Processing   Plants,"   Japan  Patent  Diclosure No.  49-84048,   August  13,
     1974.

253. Tashiro,  H., Treatment o_f Wastewater  from Canneries (Shizouka Paper Exp.
     Sta., Shizouka, Japan), PPM, Vol.  6, No. 3, pp 42-49, 1975.

254. Tatterson,  I.  and J.  Wignall, "Alternatives  to  Fish Meal:  Part 1, Fish
     Silage," World Fishing, Vol. 25, p.42,  May 1976.

255. Wada, T.  et al. ,  "Waste  Water Treatment after Processing of Marine Pro-
     ducts III; Waste Water after Processing of Skipjack." Shizuoka Ken Suisan
     Shikenjo Jigyo Kokoku (Japan), 60, (1974), Chemical Abstracts, 87, 90246h
     (1977).

256. Wignall,  J.  and I.  Tatterson,  "Fish Silage", Process  Biochemistry, Vol.
     11, pp.17-19, December 1976.
                                        B-4

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257.  Windsor,  M.   et  al.,  "Developments  in  British  Fish Meal  Technology",
     Fishing News International, August 1975.
                                        B-5

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                                  APPENDIX C

                          SELECTED FOREIGN ABSTRACTS
Akaraa,  A.  and  T.  Terai,  "Treatment of Organic  Wastewater." Japan  Kokai  77
25,451 (1977);
     "Organic waste, water is mixed with CaO, Ca(OH)2, MgO, or Mg(OH)2, and C02
     is blown into  it.   Thus, 10 parts CaO was added to 100 parts waste water
     (COD 3,370, BOD 9,870, total N 676 ppm) from fish washing followed by CO
     blowing and settling.   The  supernatant liquor contained total N 328, COD
    '715, and BOD 2,200 ppm".  (Chemical Abstracts, 87, 28620x, 1977).

Emel'yanova,  E.A.  et al.  "Wastewater of  a Fish  Meal  Feed Plant  as Complex
Poly-disperse System,"  Rybn Khoz (USSR), 8, 73 (1976).
     "Wastewater from washing fish meal cake with hot water contains C1,P, and
     N and has BOD5 8.9 gO/1".  (Chemical Abstracts, 86, 47004, 1977).

Emel'yanova, E.A.,  e_t  al. ,  "Effect of Some Electrolytes on the Coagulation of
Organic Pollutants in Wastewaters."  Rybn Khoz (USSR), 4, 76 (1977).
     "Wastewaters  from  the  fish processing  industry  (fish  flour factories,
     etc.)  contain  very  stable  colloid  dispersions of  fats and  proteins.
     These dispersions  are  broken  down by  addition  of  electrolytes  (HOAc and
     HC1).  The dimensions of the coagulated floes are maximum at pH 4.8 (with
     HOAc). The  filtration  time  of the sediment is minimum at 0.07 ml concen-
     trated HC1  or  0.2  ml glacial HOAc/100 ml effluent.  Al(OH)., did not give
     positive  results.   Polyacrylamide  (1% of 0.5% solution) was  tested  as
     coagulant  without  noticeable  effect.   Colloidial  1.5% solution of SiO.,
     activated with  concentrated H-SO,  after electrolyte treatment, increased
     the  stability  of  the  floes   and  improved  the filtration  rate  of  the
     sludge."   (Chemical Abstracts, 87, 43693s, 1977).

Fujita, T. et al., "Studies on the Utilization of Crab Shell Waste-Chitosan as
a  Coagulating  Agent,"  Nippon  Suisan Kabushiki Kaisha  Chuo Kenkyusho Hokoku
(Japan), 11, 49  (1976).
     "HCHO  was  sprayed on  powdered chitin prepared from  king  crab shell  to
     obtain chitosan  salt  containing H»0 10% and HCHO 18%, which was used for
     coagulation of clay suspension, wastewater from processing of ground fish
     meat,  and  activated  sludge.   In the coagulation  test  of clay suspension
     with 0.1 20 ppm chitosan, the coagulation and settling of clay particles
     were  accelerated  with increasing chitosan salt.   The  chitosan salt also
     had good coagulation  effect for wastewater from ground fish meat proces-
     sing  and  activated  sludge."   ( Chemical  Abstracts, 87,  172265c,  1977).

Fukuda,  et  al. ,  "Coagulation Treatment of Waste Water from the Manufacture of
Marine Products," Mizu Shori Gijutsu (Japan), 18, 5  (1977).
     "Polyacrylate  (300  ppm)  or  800 ppm Al^SO/L added to pollack meat water
     extraction or without pH adjustment, 83 an3 56% of the proteins were pre-
     cipitated,  respectively.   The coagulants were  effective  at  pH 3-6.   The
                                        C-l

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     optimum  pH  to  coagulate the  protein was 4.5-5.0.   The optimum  pH  de-
     creased and the  coagulation was accelerated by increasing the concentra-
     tion of  NaCl  from 0.05 M to  0.5  M.  Sucrose did not  affect  the coagula-
     tion."  (Chemical Abstracts, 87, 106458s 1977).

Kato, T.  and M. Maeda,  "Electroflotation Treatment  of Waste Water from  the
Processing of Marine  Products,"  Mitsubishi Denki Giho  (Japan), 50,  9 (1976).
     "A review with  3 references on the  effectiveness  of  electroflotation in
     the treatment of wastewater from fish processing and equipment installa-
     tion."  (Chemical Abstracts, 86, 110726z, 1977).

Kuji,'Y. e_t al.,  "Treatment of Waste Water from Marine Products  Processing by
Electroflotation" Yosui To Huisui (Japan), 17, 10 (1975).
     "Waste water  from fish  processing  containing proteins,  lipids,  and  ex-
     tractives  was  treated  by  the  electroflotation method  for removal  of
     proteins  on  coagulant  floe  at  the isoelectric  point.  The  treatment
     depended on  type and  sex of  fish and aging of  waste  water."  (Chemical
     Abstracts,  84, 184488d, 1976).

Kurosaki, B.  "Treating  Seafood  Wastewaters  with Mycelia" Japan Kokai 76,  20,
249  (1976).
     "A  seafood  waste water  at  pH  6.0-6.5  and  containing BOD 15,000-200,000
     ppm  is   contacted  in  a  contacting  tank with mycelia  containing mainly
     Pseudomonas for  protein  decomposition and yellow mycelia for hydrocarbon
     decomposition, cultivated in  a mycelia  cultivation tank, to increase the
     pH to 8.0-10.0  and  to decrease the BOD to 5,000-30,000 ppm.   An alkaline
     compound, e.g., CatOH),.,, is added to the mixed solution while it is being
     pumped  to  a  sedimentation  tank to  increase  the pH  to 10.2-10.5. Oils,
     soluble  proteins,  and  mycelia are  deposited  from  the solutionin  the
     sedimentation tank.  A portion of the precipitate deposited is circulated
     to the mycelia  cultivation  tank for  re-use.   Fish oils and  mineral oils
     are  flocculated  rapidly;   soluble  proteins  are  flocculated to  solids.
     Thus,  a seafood waste  water  containing BOD  13,000  ppm was  treated by
     mycelia  cultivation,  alkali  addition  and  H^SO,  neutralization.   The
     capacity was  5-15  kg BOD/m  day, as compared to 0.5-1.0 kg BOD/m  day by
     using conventional  aeration."  (Chemical Abstracts,  84, 18464ly, 1976).

Leoni,  C.  et  al. ,  "The Depuration of Waste Waters from Food-Preserving Facto-
ries; Effect  of Sodium  Chloride Concentration on  the  Depuration Yield of an
Extended  Aeration  Activated  Sludge Plant,"  Ind.  Conserve  (Italy),  51,  30
(1976).
     "Effluents from  the  fish canning industries contain NaCl 11-12 g/1.  The
     concentration should  be  kept under  10 g/1, and, if possible, under 5 g/1
     for biological purification.  An artifical solution contained less than  1
     g/1  of  peptone  and  fish  homogenates, plus  minimum  concentrations  of
     MgSO,, CaCl-,  and K~ HPO,.   This artificial effluent was used to prepare
     tests  solutions  containing 5-100  g NaCl/1.   Analytical determinations
     were  performed  with  the solutions  before  and  after  treatment  in  the
     oxidation chamber.   BOD  and COD values were measured.  These values were
     obtained in  the  effluent before and  after  filtration.   At  5-10 g NaCl/1
                                        C-2

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     the biological  activity  started  to decrease and sludge was  difficult to
     separate.  An excess of NaCl not only inhibits the  biological action, but
     also corrodes."  (Chemical Abstracts, 86, 19450k,  1977).

Maeda, M.  e_t al. ,  "Treatment of Protein-Containing Waste Waters  by Electro-
deposition," Japan Kokai, 75,  141, 582 (1975).
     "During  the  treatment  of  protein-containing waste  waters  by  electro-
     deposition,  the protein-removal  efficiency  is markedly improved when the
     initial  and  final pH  values  of  the  waste waters  are adjusted  from
     slightly acidic to slightly alkaline in relation to the isoelectric point
     of  the  protein, respectively.   The proteins are deposited  on  metal hy-
     droxide  floes  at  the  solute electrode during the  electrolysis.   Thus,  a
     waste  water  (COD  925 ppm,  containing  proteins with isoelectric pH of
     4.25)  discharged  from   a  fish-processing  plant  was  electrolyzed  at  a
     initial  and  final  pH of  3.4  and 5.2,  respectively.    The  COD-removal
     efficiency  was  87%; however,  the efficiency was decreased to  50% if the
     initial and  final pH was 5.2 and 6.11, respectively." (Chemical Abstracts
     84, 111365b,  1976).

Maeda, M.  et al. ,  "Removal  of  Proteins  from Waste Waters by Electrodeposi-
tion,"  Japan Kokai, 75, 141,  855 (1975).
     "Waste waters  containing proteins  are treated by a double electrodeposi-
     tion process,  each at different pH,  using solute electrodes.   The 1st
     electrolysis  is performed at an initial pH such  that at the  end of the
     electrolysis  the  pH  is  similar  to that of the isoelectric  point of the
     protein  in  the  wastewater.  The  2nd  electrolysis  is performed at an
     initial  pH  such that  at  the end of the electrolysis the  pH has reached a
     value  at which the  solubility  of the  metal  hydroxide   floes  formed is
     minimum.   Thus, a  waste water  (COD 1,250 ppm) discharged  from  a  fish
     processing  plant  was  1st  electrolyzed at  an initial pH 5,  using an Al
     electrode  at 20 A/min/1.   The  pH  value at the end  of  electrolysis was
     7.57 and the COD of the  resulting water was decreased to  362 ppm.  The pH
     of the resulting water was readjusted to 6.5 and electrolyzed at the same
     conditions.   The   COD  of  th  resulting  water was  176 ppm."   (Chemical
     Abstracts,  84,  155326u,  1976).

Maeda, M. et  al. ,  "Treatment of Waste Water from Marine Product Processing,"
Japan Kokai,  76,  131, 163  (1976).
     "Waste water from  marine product processing  is treated with acidic clay
     or active clay, and the pollutant adsorbed  clay is  heated at 250 600° and
     reused.   Thus, 2  1  of  a  solution (COD 450  ppm) containing  2,000 ppm
     bonito  extract was agitated  with  5%  granular  active clay  at  15° for 1
     hour and filtered  to  decrease the  COD  to  130 ppm.  The  used active clay
     was heated  at 250° for  30 minutes  and used again.  The  COD decreased to
     178 from 450 ppm."  (Chemical Abstracts, 87, 7296lh, 1977).

Maeda, M. and T.  Ozawa,  "Treatment of Waste Water Containing  Protein,"  Japan
Kokai, 75, 159,  150  (1975).
     "Protein  in waste  water  from fish processing was floated by foaming with
     air at isoelectric point.  For example, waste water (isoelectric point pH
                                        C-3

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     4.9) from fish descaling was bubbled at pH 4.9 with air (air/water = 50).
     The  COD  removal  was  75%,  compared  with  34%  at pH  3.3.  ( Chemical
     Abstracts, 84, 155364e, 1976).

Maeda, M.,   "The Treatment  Waste  Water by Electrical  Flotation Separation,"
Nenrgo Oyobi Nensho, (Japan) 43, 10, 901 (1976).
     "A  review of the  process  for the  treatment of waste water based  on an
     electrode  reaction.   The appropriate and the practical  applications  are
     described  for  waste waters  from  the processing of marine  products,  re-
     covery  of  vegetable  proteins  and paper  pulp  production."  ( Chemical
     Abstracts, 86, 110724x, 1977).

Matsuura, R.  et a 1.,  "Electrolysis  of Marine Product Processing Waste Water"
Japan, Kokai, 76, 36,  764 (1976).
     "The ' waste water  from marine product  processing  is  treated  with a Ca
     compound  and  H«PO,  alkali metal phosphate,  alkali  metal  acid  phosphate,
     or Na tripolyphosphate to precipitate proteins,  peptides, and amino acids
     with  Ca  phosphate and  by electrolysis to  reduce  COD and  BOD.   Thus,  a
     primary-treated waste water  containing  COD  150 and BOD 190 ppm was elec-
     trolyzed  2  minutes  at 0.5 A/dm  and  10 V,  CaCl2 and Na HP04 [7558-79-4]
     were  added,  the  water  was  electrolyzed  8  minutes at p!T6.5,  stirred 30
     minutes,  and then  Na polyacrylate  [9003-04-7]  was added.  The  treated
     water contained COD  67  and BOD 70 ppm, compared to 135 and 170 by simple
     electrolysis.  (Chemical Abstracts, 85, I4588y,  1976).

Matsuura,  R.  et al. ,  "Treatment of Waste Water  Discharged  from Seafood Pro-
cessing" Japan, Kokai. 75, 150, 267 (1975).
     "Waste waters  discharged  from  seafood  processing  are  first oxidized or
     reduced  by d.c.  electrolysis  in  the anodal or cathodal  chambers  of an
     electrolysis  apparatus.   The waters are then treated  by electrophoresis
     and  the  proteins, peptides, and  amino acids  in the  anodal or  cathodal
     solutions  of  the  electrophoresis  chamber  are removed  by passing  the
     solutions  through  an ion  exchange resin column.   The  COD  causing mate-
     rials,  esp. proteins,  peptides,   and  amino  acids  are  thus effectively
     removed.   Thus,  & waste  water (COD 1000 ppm)  discharged  from  a  seafood
     processing  plant  was placed  in  the  cathode chamber of  an electrolysis
     apparatus  separated  by a polyester fiber diaphragm, and electrolyzed at
     an  electrical  potential of 5-10 V  and electrical  current  d. of 2 A/dm .
     The  COD  in the resulting waters was decreased to 250 ppm.  The resulting
     waters were  placed in the cathodal chamber  of  an  electrophoresis device
     and  treated  at  electrical potential of 10 V and electrical current d. of
     2 mA/cra  .   The waters from the 1st electrophoresis  were again placed in
     the  anodal  chamber and treated under similar conditions.   The  final  COD
     of  the   resulting  water after  the 1st and  the 2nd electrophoresis  was
     decreased  to 220  and  170 ppm  respectively"   ( Chemical Abstracts,  84,
     184623u,  1976).
                                        C-4

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Matsuura,  R.  e_t  al. ,  "Treatment  of  Waste Water  from Manufacture  of  Marine
Products", Japan Kokai, 76, 41, 257 (1976).
     "Waste water  from manufacture of marine products is  mixed  with H_PO, to
     adjust to pH  to 2.0-6.0, at which proteins, peptides, and amino acids in
     the waste water exist in the zwitterion state  (isoelectric point).   The-
     Ca(OH)2  or  CaCl^  is added to the  waste  water and the pH is  adjusted to
     6.0-12.0 with  HrPO,  to form Ca phosphates, which adsorb  and precipitate
     the proteins,  peptides,  and  amino acids.  Thus, 1 liter of a waste water
     (COD  850, BOD  2,550 ppm) from marine product manufacture  was mixed with
     H~PO, to adjust its pH to 4.5, and  then polyacrylic acid Na salt 40 ppm
     •was  added.   After  removing  the  resulting  floes  by  flotation,  Ca(OH)2
     slurry was  added and  the pH  was  adjusted  to 6.8 with H^PO,.   The waste
     water was  treated with  polyacrylic  acid Na  salt (20 ppm),  followed by
     floe  removal.   The  treated  waste  water  had COD  82 and  BOD  90  ppm."
     (Chemical Abstracts, 85, I48571n, 1976).

Matsuura,  R.  et  al., "Treatment of Waste Water from Marine Product Processing
for Recycling," Japan Kokai, 76, 66, 158 (1976).
     "A  waste water from marine product processing  is treated  with H,PO, and
     proteins, peptides, and amino acids in the wastewater are subjected to an
     isoelectric  treatment under  acidic  conditions.   CaO or  Ca(OH)2  is then
     added to the  waste  water and the pH of the waste  water is  adjusted to
     6-12  with H,PO,.   The proteins,  peptides,  and amino acids are compounded
     as  Ca salts  of  H.PO,.   The  precipitates  are  removed,  and  the  treated
     water is filtered through an adsorption bed  or  a  filter medium and then
     recycled to  the washing step in the  marine product  processing.  Thus, a
     wastewater  (5  1, COD  838 ppm) was  adjusted to pH  4.5  with H_PO,, sub-
     jected to an isoelectric treatment,  and mixed with aqueous 0.1& Na poly-
     acrylate (200  ml).   The floe was removed,  the treated solution was mixed
     with  200  ppm  Ca(OH)  ,   and  the  pH was  adjusted   6.8  with  20%  H2PO,.
     Aqueous  0.. 1%  Na polyacrylate  (100 ml) was  added  and the precipitate was
     removed.  The  treated  solution was passed through a bed of anthracite and
     sand  to  yield a colorless, transparent, odorless solution for recycling.
     The  COD  contents were 82 and 640  ppm  after  recycling  1  and 30 times,
     respectively"   (Chemical Abstracts, 87,  I40749x, 1977).

Matsuura,  R. and K. Akaike, "Treatment of Waste Waters from Seafood Processing
Plants by  Electrolysis"  Japan Kokai, 75,  120, 160 (1974).
     "Seafood processing waste water is treated by a flocculation or a floccu-
     lation  activated  sludge  process  to  decrease its  COD to  less than  610
     ppm;  the treated wastewater  is  electrolyzed  altering  the  polarity of
     electrodes  and simultaneous  application  of  a.c.;   and  the electrolyzed
     wastewater  is  treated with activated carbon.  Thus,  1  liter of an acti-
     vated sludge  treated  wastewater  (COD   600  ppra)  from  a fish-processing
     plant was electrolyzed by using Ti-cathode and  Pb-anode  plates at elec-
     trode distance 2.0  cm, 10-32 V, 2.5 A/dm , and 5 A.  The polarity of the
     electrodes  was altered  every 2  minutes and  simultaneously a.c.  (0.5 A)
     was   applied.   The  COD  of   electrolyzed  wastewater  decreased  to  less
     than  150 ppm at 0.67 A-hr/1.  The electrolyzed wastewater (COD 150 ppm)
     was  passed  through  a  column  (3 cm diameter x 1.5 m height) containing  1
                                        C-5

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     liter of actvated carbon at 4 I/hour.   The effluent had COD less than  49
     ppm."  (Chemical Abstracts, 94, 65080e, 1976).

Naroisa, M.   "Recovering Protein  from  Waste Water  Containing  Crude Protein,"
Japan Kokai,  75, 33, 142 (1975).
     "Proteins  were  recovered  from wastewater  containing  crude protein  by
     adjusting pH of the waste water to 5-6,  blowing  air in the inlet of the
     pump,  and  adding polyacrylic  salt  at  the outlet of the  pump  during the
     transfer of waste  water containing crude protein from the adjusting tank
     to the stationary  tank.   Thus, waste water (100 kg) (dry matter = 1.43%)
     obtained by  washing mackerel  was  adjusted to  pH 5, and  aerated in the
     presence of  250 ppm  sodium polyacrylate [9003-04-7]  (av.  d.p.  50,000).
     The  recovery  of proteins  was  92.31%.   The  BOD of  the  waste water after
     removal  of  the protein  was 163 ppm.   The  protein  was used as  the raw
     material of feed."  (Chemical Abstracts, 85, 1006lq, 1976).

Nishide,  E.  "Coagulation  of Fishery Waste  Water  with  Organic Coagulants,"
Ninon Daogaku No  Inigakubu Gakinyutsu Kenkyu Hokoku (Japan),  34,  291 (1977).
     "The coagulation of fish wastewater produced in the processing of pollack
     meat   paste,   Na   alginate  [9005-38-3],   Na  (carboxymethyl)  cellulose
     [9004-32-4] and Na polyacrylate  (I)   [9003-04-7]  was  studied  by deter-
     mining residual COD.    I_ was  the  most  effective,  and the  effect was en-
     hanced by  acidifying  the  wastewater  to pH 6.0 with H?SO,.   The protein
     concentration   of   the  wastewater  influenced  coagulation   with  I".
     (Chemical Abstracts, 87,106395u, 1977).

Ohtake, S.   "Treatment  of  Waste Water  from Marine  Paste Products Processing
Plants  Electrolysis-Flocculation  Method,"   Japan  Food  Science,  14,  7,  58
(1975).
     "The  use of electrolysis  in wastewater  treatment  of marine  fish paste
     plant  is discussed.   The use of semipermeable membranes in electrolysis,
     and  various   flocculents,   e.g.   AL-(SO,)»  and  Fed-  is  described."
     (Chemical Abstracts, 86, 1266l7a, 1977).

Shiraoda,  Y. et  al. , "Analysis of Waste  Water  Discharged from a Mackerel Pro-
cessing  Plant",  Shizouka  Ken  Suisan  Shikenjo  Jigvo  Hokoku  (Japan),  78,  80
     "Wastewater  from mackerel  cooking and pressing  was analyzed  for evap-
     oration  residue,  fats,  total  N,  COD,  BOD, NaCl, and pH.   Cooking water
     contained fats  23  and residue 186  kg/ton fish and water 7.3 m /ton fish.
     Water  from pressing was  3.4 m  and  fats 293 kg.  (Chemical Abstracts, 87,
     90247J,  1977).

Shimoda,  Y. et al. ,  "Waste  Water  Treatment  after Processing  of Marine Pro-
ducts.  IV;  Waste Water  Treatment after Processing  of Mackerel" Shizouka Ken
Suisan Shikenjo Jigyo Hokoku  (Japan), 61, (1974).               .,
     "Mackerel processing  wastewater  with BOD less than  4 kg/m  day was.suc-
     cessfully treated  by  activated sludge, but at greater than 4.9 kg/m  day
     the  treatment  was  incomplete.   In  a multistage process wastes having COD
     200-700 approximately  200, and less than 200 ppm were treated for 71. 59,
     and  0% removal.  A combination of  activated sludge and trickling filter
                                        C-6

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     processes gave  the best  COD  removal."   (Chemical  Abstracts,  87,1064l4z
     1977).

Tagawa, S.  e_t al. ,  "Removal  of Constituents from the Waste  Water  Discharged
from "Kamaboko" Processing  Plants  by a pH  Shifting Method,"   Suisan Daigakko
Kenkyu Hokoku, (Japan) 24, 1,  37 (1975).
     "The  wastewater was adjusted  to pH  2 with 3N  HCL and  neutralized  for
     coagulation  of  protein  substances.    By  this  simple  treatment n-hexane
     extractable  matter was  removed greater  than   95  and  suspended  solids
     greater  than 85%.   The  removal efficiency of  COD  was  60-70,  protein N
     70-80, and non-protein N less than 10%.  There was  an approximate linear
     relationship  between  COD  and  total,  protein,  and  non  protein  N."
     (Chemical Abstracts, 87,  172326y, 1977).

Tagawa, S.  e_t al.,  "Removal of Constituents from Waste  Water Discharged from
Mackerel  Canning  Plants by the pH  Shifting  Method," Suisan  Daigakko  Kenkyu
Hokoku (Japan), 25, 1, 75 (1976).
     "Waste water from mackerel  canning  plants was  treated  by adjustment of
     pH.   The waste water  was collected from  cutting,  filling,  and steaming
     processes and a  combined effluent from other sources  in the plant.  The
     removal  efficiencies  were  n-hexane  extractable   matter and  suspended
     solids greater  than  95  and COD 50-60%.  A close relation existed between
     COD  and  N  concentrations  in  the waste  water  before  and  after  the pH
     adjustment.   After treatment  greater  than  90% of the  total N  in  the
     wastewater was  non-protein."   (Chemical  Abstracts, 87,  172325x,  1977).

Takagi, M.  e_t al. ,  "Comparatve Studies on the Effect of  Coagulants on Acti-
vated  Sludges  from  Fish Meat  Processing Plants, I,"  Aichi-Ken Shokuhin Kogyo
Shikensho Nempo (Japan), 14, 93, 1973.
     "The  testing coagulants  included inorganic  and organic  polymers.   The
     dehydration  was  tested .by vacuum filtration.   The inorganic  coagulants
     showed the  lowest water  content in  cake  with  lime  57.4% addition.  The
     water  content was  87-88% if lime  and  Fe    was  added 17.2 and 2.9%, res-
     pectively.   Alum was  the most effective among inorganic coagulants.  The
     addition of  lime decreased the dehydration effect due to increased visco-
     sity of  sludge."   (Chemical Abstracts, 85, 9915q, 1976).

Tanaka, Y. ejt al., "Purification of Waste Water from Marine Product Processing
Plant," Japan Patent Disclosure No. 49-84048 (1974).
     "Waste water from marine product  processing plants is effectively puri-
     fied  by  adding  50  ppm  of  an inorganic  coagulant, adjusting the pH to
     4.5-8.0, adding  5 ppm polyacrylamide-system coagulant, and  then removing
     the  resulting  floes.   Thus,  0.5 kg of an A1_(SO,), solution containing 8
     g  Al^O./lOO  ml was  mixed with 200 kg waste  water  (suspended  substances
     4,82CT,  COD  1,400,  BOD  6450  ppm)  from a  fish  processing  plant.   After
     adjusting the pH to 6.5,  2 kg 0.1% aqueous polyacrylamide (molecular wt.
     8,000,000)  solution  was   added  to the  waste  water  to  form floes, which
     were  removed by flotation.   The waste water  thus  treated had suspended
     substances  337, COD  210, and  BOD 710 ppm".    ( Chemical  Abstracts,  82,
     34855r,  1975).
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Tashiro, H. "Treatment  of  Waste Water from Canneries."   (Shizuoka  Paper Exp.
Stn.,  Shizuoka, Japan),  PPM, 6, 3, 42 (1975).
     "The  composition,  quantity,  and treatment of waste  water  from canneries
     of fish,  peaches,  and oranges are described."   (Chemical  Abstracts,  83,
     65l44h, 1975).

Wada,  T.  e_t al. ,  "Waste  Water Treatment after Processing  of Marine Products
III; Waste  Water after  Processing of Skipjack," Shizouka Ken Suisan Shikenjo
Jigyo Hokoku (Japan), 60 (1974).
     "Steamed skipjack was drained.  The drained wastewater was  33.6% fish wt.
     and contained crude protein  4.75,  crude fats 0.34%  and COD 12,000 ppm."
     "(Chemical Abstracts.  87, 90246h, 1977).
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                                   APPENDIX D

                                GLOSSARY OF TERMS
activated sludge process:  Removes  organic matter  from wastewater by  intro-
ducing air  (oxygen)  into  a  vessel containing biologically  active  microorga-
nisms.

aeration tank:  A chamber for injecting air or oxygen into water.

aerobic organism:  An organism that thrives in the presence of oxygen.

algae (alga):   Simple plants, many  microscopic,  containing chlorophyll.  Most
algae are aquatic  and  may produce a nuisance when conditions are  suitable for
prolific growth.

ammonia stripping:  Ammonia removal.from a liquid, usually by intimate contact
with an ammonia-free gas, such as air.

anaerobic:  Living or active in the absence of free oxygen.

anionic:  Characterized  by an active and  especially  surface-active  anion,  or
negatively changed ion.

aquaculture:  The  cultivation and  harvesting of aquatic  plants  and  animals.

average:  An  arithmetic mean obtained  by adding quantities  and  dividing the
sum by the number of quantities.

bacteria:  The smallest living organisms which comprise, along with fungi, the
decomposer category of the food chain.

bailwater:  Water  used to  facilitate unloading  of  fish  from  fishing  vessel
holds.

batter:  A flowing mixture of flour, milk, cooking oil, eggs, etc. for product
coating.

biochemical oxygen demand (BOD):   Amount  of  oxygen  necessary in the water for
bacteria  to  consume the organic  sewage.   It is  used as  a measure  in telling
how well a sewage treatment plant is working.

biological oxidation:   The process  whereby, through the activity of  living
organisms  in  an  aerobic  environment,  organic  matter is  converted  to  more
biologically stable matter.

biological stabilization:  Reduction in the net energy level or organic matter
as a  result of  the metabolic activity of organisms, so that further biodegra-
dation is very slow.

biological treatment:   Organic  waste treatment  in which  bacteria and/or bio-
chemical action are intensified under controlled conditions.
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biomass:   Mass  or  body of  activated sludge  microorganisms involved  in  the
decomposition of wastes.

blow tank:  Water-filled tank  used  to wash oyster or  clam  meats  by agitating
with air injected at the bottom.

BOD_:  A  measure  of the oxygen consumption by  aerobic organisms  over a 5-day
test period at  20°C.   It is an indirect measure  of  the concentration of bio-
logically  degradable material  present in organic wastes contained  in a waste
stream.

breading:  A  finely ground mixture  containing cereal products,  flavorings and
other  ingredients,  that  is applied  to a product  that has been  moistened,
usually with batter.

brine:   Concentrated salt  solution  which is  used  to  cool or  freeze fish.

BTU:  British thermal unit, the quantity of heat required to raise on pound of
water 1°F.

bulking sludge:   Activated sludge that settles poorly because  of low density
floe.

byproducts:   (As  used  in  this report).   Commodities which  are produced as a
secondary  or incidental product of fish processing, but which are not suitable
for human  consumption (e.g., petfood, fish meal, fertilizer, etc.).

canned fishery product:   Fish,  shellfish, or  other  aquatic  animals  packed
singly or  in  combination with other  items  in  hermetically  sealed,  heat ster-
ilized  cans,  jars,  or  other suitable containers.   Most,  but  not  all canned
fishery products  can. be stored at room temperature for an indefinite period of
time without spoiling.

carbon adsorption:   The separation  of  small  waste  particles  and  molecular
species,  including  color and odor contaminants, by  attachment  to the surface
and  open  pore  structure or  carbon  granules or powder.  The  carbon is "acti-
vated," or made more adsorbent by treatment and processing.

catalyst:  A  chemical  element  or compound which,  although not  directly in-
volved in  a chemical reaction, speeds up that reaction.

cation:   Characterized  by  an active  and especially  surface-active  cation, or
positively changed  ion.

cellulose:   A  polysaccharide,  or complex  carbohydrate,  found  in  plant cell
walls  and naturally occurring  in such fibrous products as  cotton  and kapok;
used as raw material in many manufactured goods including paper.

centrifuge:   A mechanical  device which  subjects material to a centrifugal
force  to  achieve phase  separation  and then  discharges the  separated compo-
nents .

chemical oxygen demand  (COD):   A  measure  of the amount  of  oxygen required to
oxidize organic and oxidizable inorganic compounds in water.
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chemical precipitation:   A waste  treatment process  whereby  substances  dis-
solved in  the  wastewater  stream are rendered insoluble and form a solid phase
that settles out or can be removed by flotation techniques.

chitin:  An  abundant natural  polyssacharide  found in  the shells  of  crusta-
ceans, and in insect exoskeletons, fungi and certain other plants and animals.

chitosan:  A deacetylized  form of chitin, manufactured from  chitin,  and  used
in a  variety of applications ranging from coagulation and ion-exchange waste-
water treatments to adhesives and wound-healing sutures.

clarification:    Process  of   removing  undissolved  materials  from a  liquid.
Specifically,  removal  of  solids either by settling, flotation, or filtration.

clarifier:-  A settling basin for separating settleable solids from wastewater.

coagulant:  A material, which, when added to liquid wastes or water, creates a
reaction  which forms  insoluble  floe  particles  that adsorb  and precipitate
colloidal  and  suspended solids.   The  floe particles can  be  removed  by sedi-
mentation.  Among the most common chemical coagulants used in sewage treatment
are ferric chloride, alum and lime.

coagulation:   The  clumping together of solids to make  them  settle out of the
wastewater  faster.   Coagulation of  solids is brought  about with  the use of
certain chemicals such as lime, alum, or polyelectrolytes.

commimitor (grinder):  A  device for the catching and shredding of heavy solid
matter in the primary stage of waste treatment.

concentration:   The  total  mass (usually in micrograms) of the suspended part-
icles  contained  in a unit volume (usually one cubic meter) at a given temper-
ature  and  pressure;  sometimes, the concentration may be expressed in terms of
total  number of particles in a unit volume (e.g., parts per million); concen-
tration may  also  be called the "loading"  or  the  "level"  of a substance;  con-
centration may also pertain to  the strength of a solution.

condensate:  Liquid residue   resulting  from the  cooling  of  a  gaseous vapor.

contamination:    A  general  term  signifying  the  introduction  into water  of
microorganisms,  chemical, organic,  or  inorganic  wastes,  or  sewage,  which
renders the water unfit for its intended use.

Crustacea:   Mostly  aquatic  animals with  rigid  outer  coverings,  jointed ap-
pendages,  and  gills.  Examples are crayfish,  crabs,  barnacles,  shrimp, water
fleas, and sow bugs.

cyclone:   A  device used to separate dust or mist from a gas stream by centri-
fugal  force.

DAF sludge:  Also  called  float; the semi-liquid skimmings, containing solids,
grease, oil  and other contaminants, collected from the surface of a dissolved
air flotation  unit.
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decomposition:   Reduction of  the net  energy  level  and  change  in  chemical
composition  or organic  matter because  of  actions  of  aerobic or  anaerobic
microorganisms.

denitrification:  The  process involving  the facultative  conversion  by anae-
robic bacteria of nitrates into nitrogen and nitrogen oxides.

deviation, standard normal:   A measure of  dispersion  of  values about  a mean
value; the square  root of.the average of the  squares  of the individual devi-
ations from the mean.

digestion:   Though "aerobic"  digestion  is  used  the term  digestion  commonly
refers  to the anaerobic  breakdown  of  organic matter  in water  solution or
suspension into  simpler  or  more  biologically  stable compounds  or both.  Or-
ganic  matter  may  be  decomposed  to  soluble organic  acids or  alcohols,  and
subsequently  converted  to such gases as methane and carbon dioxide.  Complete
destruction  or organic  solid materials  by bacterial  action alone  is never
accomplished.

dissolved air  flotation  (DAF):  A process involving the compression of air and
liquid,  mixing to  super-saturation, and  releasing  the pressure  to  generate
large  numbers of minute  air  bubbles.  As the bubbles rise  to  the surface of
the water, they carry with them small particles that they contact.

effluent:  Something that flows  out, such  as a liquid  discharged  as a waste;
for example,  the  liquid that  comes  out  of a treatment plant after completion
of the treatment process.

electrodialysis:  A process by which electricity attracts or draws  the mineral
salts through  a selective semi-permeable membrane.

end-of-pipe treatment:    Treatment of wastewater after it  has  entered a sewer
system and is  no longer  subject to recycle within a production process.

enzymatic digestion:   Decomposition  process which is assisted by the presence
of naturally  occurring organic catalysts  called enzymes.

eviscerate:   To remove the viscera,  or entrails from the body cavity.

extruded:  Shaped  by passing  through  a  die or mold such  as  fish  sticks made
from deboned  fish flesh.

facultative aerobe:  An organism that although fundamentally  an anaerobe can
grow in the presence of  free oxygen.

facultative anaerobe:   An organism  that  although  fundamentally  an aerobe can
grow in the absence of free oxygen.

facultative- decomposition:   Decomposition  of  organic  matter by  facultative
microorganisms.

fish fillets:  The  sides of fish that are  either skinned or have the skin on,
cut  lengthwise  from  the  backbone.   Most  types of  fillets are  boneless or
virtually boneless; some may be specified as "boneless fillets."


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fish meal:   A ground,  dried product  made  from  fish  or shellfish  or parts
thereof,  generally  produced by  cooking  raw fish or shellfish  with  steam and
pressing the material to obtain the solids which are then derived.

fish oil:  An oil processed from the body  (body  oil)  or liver (liver oil) of
fish.  Most fish oils are a by-product of the production of fish meal.

fish silage:  Proteinaceous byproduct resulting from the enzmatic digestion of
fish wastes.

fish solubles:   A product  extracted from  the  residual press  liquor (called
"stickwater") after  the  solids  are removed for drying (fish meal) and the oil
extracted by  centrifuging.   This residue is generally condensed to 50 percent
solids and marketed as "condensed fish solubles."

filtration:  The  process  of passing a liquid through  a  porous medium for the
removal of suspended material by a physical straining acton.

float:  (Also called floating sludge)  Solid material resulting from dissolved
air  flotation treatment which remains on  the  surface  of a liquid or is sus-
pended near the surface.

floe:   Something  occurring  in  indefinite  masses or  aggregates.   A  clump of
solids formed in sewage when certain chemicals are added.

flocculation:  The process by which certain chemicals form clumps of solids in
wastewater.

floe skimmings:  The  flocculent  mass formed on a quiescent liquid surface and
removed for use, treatment, or disposal.

flume:  An artificial channel for conveyance of a stream of water.

grease traps:  A  hydraulic  device  which removes grease  from  a waste stream.

grit chamber:  A  hydraulic  device  which removes sand,  grit  and  other large,
heavy particles from a waste stream.

groundwater:  The supply  of freshwater under the earth's  surface in an aqui-
fier or soil that forms the natural reservoir for man's use.

incineration:   (As   used  in this  report)   The process  of burning  sludge to
reduce the volume of material to an inert ash residue.

influent:   A liquid  which  flows  into  a  containing  space or process unit.

in-plant  controls:   Technologies or  management  strategies  which  reduce the
strength  or  volume  of wastes   discharged  to  end-of-pipe  treatment systems.

ion:  A free electron or other charged subatomic particle.

ion exchange:  A  reversible chemical reaction between a solid and a liquid by
means of  which  ions may be  interchanged between the two.  It is in common use
in water  softening and water deionizing.
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isoelectric point:  Point at  which  the net electrical charge  of  particles  is
zero, thus causing  destabilization  which facilitates processes such as coagu-
lation and flocculation.

kg:  Kilogram or 1,000 grams,  metric unit of weight.

kkg:  Kilo-kilogram or 1,000,000 grams, metric unit of weight.

KWH:  Kilowatt-hours, a measure of total electrical energy consumption.

lagoons:    Scientifically constructed  ponds  in  which  sunlight, algae,  and
oxygen interact to restore water to a quality equal to effluent from a second-
ary treatment plant.

land disposal:  (Also called land treatment)  Disposal of wastewater into land
with  crop  raising being  incidental;  the primary purpose is to  cause further
degradation by  assimilation of organics and/or nutrients into the soil struc-
ture or the plants covering the disposal site.

landings, commercial:  Quantities of  fish,  shellfish and other aquatic plants
and  animals  brought ashore and sold.    Landings  of  fish may  be in  terms  of
round  (live)  weight  or dressed weight.  Landings of crustaceans are generally
on  a  live  weight  basis except for shrimp which may be on a heads-on or heads-
off basis.  Mollusks  are generally landed with the shell on but in some cases
only the meats are landed (such as scallops).

live tank:  Metal,  wood or plastic vessel with  circulating seawater for the
purpose of keeping fish or shellfish alive until processed.

m:  Meter, metric unit of length.

mm:  Millimeter = 0.001 meter.

mg/1:  Milligrams  per  liter;  approximately equals parts per  million;  a term
used to indicate concentration of materials in water.

mgd:  Million gallons per day.

microstrainer/microscreen:  A mechanical  filter  consisting of  a cylindrical
surface  of  metal  filter  fabric with  openings  of 20-60  micrometers  in size.

milt:  Reproductive organ (testes) of male fish.

municipal treatment:   A  city or  community-owned waste  treatment plant  for
municipal and, possibly, industrial waste treatment.

nitrate,  nitrite:    Chemical  compounds  that  include the  N0_    (nitrate)  and
NO   (nitrite) ions.   They are composed of nitrogen  and  oxygen,  are nutrients
for  growth  of  algae  and other plant life,  and contribute  to  eutrophication.

nitrification:  The process of oxidizing ammonia by bacteria into nitrites and
nitrates.
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offal:  A term for the waste portion of a fish, including head, tail, viscera,
etc.

organic content:  Synonymous  with volatile solids except for  small  traces  of
some  inorganic  materials  such as calcium carbonate which will lose  weight at
temperatures used in determining volatile solids.

organic matter:  The waste  from homes or industry of plant  or animal origin.

oxidation pond:  A man-made lake or body of water in which wastes are consumed
by bacteria.  It is used most frequently with other waste treatment processes.
An oxidation pond is basically the same as a wastewater lagoon.

pH:  The pH value indicates the relative intensity of acidity or alkalinity of
water,  with the neutral  point at  7.0.   Values  lower  than  7.0  indicate  the
presence of acids; above 7.0 the presence of alkalies.

physical-chemical treatment:  A wastewater treatment process  which  relies  on
physical and chemical reactions, such as coagulation, settling, filtration and
other non-biological processes, to remove pollutants.

polishing:   Final  treatment  stage before  discharge of  effluent to  a  water
course,  carried out in  a shallow, aerobic  lagoon or pond, mainly  to remove
fine  suspended solids  that settle very  slowly.   Some  aerobic  microbiological
activity also occurs.

ponding:   A waste  treatment  technique  involving  the  actual  holdup of  all
wastewaters  in  a  confined space with evaporation  and percolation the primary
mechanisms operating to dispose of the water.

ppm:   Parts per  million, also  referred to as  milligrams  per  liter (mg/1).
This  is  a  unit for  expressing the concentration  of any  substance by weight,
usually as grams of substance per million grams of solution.   Since a liter of
water weighs one  kilogram at a  specific  gravity  of 1.0,  one part per million
is equivalent to one milligram per liter.

press cake:  In the wet  reduction process  for  industrial  fishes,  the  solid
fraction which  results  when cooked fish  (and  fish wastes)  are passed through
the screw presses.

press liquor:  Stickwater resulting from the pressing of fish solids.

primary treatment:  Removes .the material that floats or will settle in waste-
water.  It  is accomplished by using screens  to catch the floating objects and
tanks for the heavy matter to settle in.

process water:  All  water that  comes into direct contact with  the  raw  mate-
rials,  intermediate  products,   final products,  byproducts,   or  contaminated
waters and air.

processed fishery product:   Plants and  animals,   and  products  thereof,  pre-
served  by canning,   freezing,  cooking,  dehydrating, drying,  fermenting,  pas-
teurizing,  adding salt  or  other chemical  substances,  and other- commercial
processes.  Also, changing the form of fish, shellfish or other aquatic plants
and animals  from their original state into a form  in which they are not readily
identifiable,  such as fillets, steaks, or shrimp logs.
                                        D-7

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pyrolysis:    Physical and  chemical  decomposition  of  organic matter  brought
about by heat in the absence of oxygen.

receiving waters:  Rivers,  lakes,  oceans,  or other water courses that receive
treated or untreated wastewaters.

recycle:  The return of a quantity of effluent from a specific unit or process
to  the  feed stream  of  that same  unit.   This would also apply  to  return of
treated plant wastewater for several plant uses.

rendering:   A reduction  process  involving the cooking, pressing and drying of
animal waste materials to produce a dry protein meal.

retort:  Sterilization  of  a food  product  at greater  than  248°F with  steam
under pressure.

reuse:   Water  reuse,  the  subsequent use of water  following an  earlier  use
without restoring it to the original quality.

reverse osmosis:  The physical separation of substances from a water stream by
reversal of the normal  osmotic  process, i.e.,  high pressure,  forcing  water
through a  semi-permeable  membrane  to the pure water side leaving behind more
concentrated waste streams.

roe:  Fish  eggs,  especially when still massed in  the ovarian membrane,  taken
and packaged as a delicacy  for human consumption.

rotating biological contactor(RBC):  A waste treatment device involving closely
spaced  light-weight  disks  which  are rotated through the wastewater allowing
aerobic microflora  to  accumulate on each disk and  thereby achieving a reduc-
tion in the waste content.

rotary screen:    A  revolving cylindrical  screen  for  the  separation  of solids
from a waste stream.

sand filter:   Removes  the  organic wastes  from sewage.   The wastewater  is
trickled over a  bed of sand.  Air  and bacteria decompose the wastes filtering
through the  sand.   The  clean water  flows out  through drains in the bottom of
the bed.   The  sludge accumulating  at the surface must be removed from the bed
periodically.

sanitary landfill:   A  site  for  solid waste disposal during techniques  which
prevent  sector  breeching,  and controls air  pollution nuisances,  fire hazards
and surface or groundwater  pollution.

screen:  (As used  in this  report)   A device with  openings,  generally of uni-
form  size,  used to  retain or  remove suspended or  floating  solids  in flowing
water or wastewater  and to prevent  them  from  entering an intake or passing a
given point in a conduit.   The screening element may consist of parallel bars,
rods, wires, grating,  wire mesh, or perforated plate, and the openings may be
of any shape, although they are usually circular or rectangular.

secondary products:   (as  used  in this report) fish processing products which,
although not  the primary  product,  are  still  suitable for  human consumption
(e.g., fish sticks).

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secondary treatment:  The second step in most waste treatment systems in which
bacteria  consume  the  organic parts  of  the  wastes.   It is  accomplished  by
bringing  the sewage  and bacteria  together  in  trickling  filters  or  in  the
activated sludge process.

sedimentation tanks:  Help  remove solids from wastewater.   The  wastewater  is
pumped to the  tanks where the solids settle  to  the bottom or float on top  as
scum.  The  scum is skimmed off  the  top,  and solids on the  bottom  are pumped
out for subsequent processing or disposal.

settleable matter (solids):  Determined in  the  Imhoff cone test and will show
the quantitative settling characteristics of the waste sample.

settling tank:  Synonymous with "Sedimentation Tank".

sewers:   A  system  of  pipes  that collect and deliver wastewater to treatment
plants or receiving streams.

shock load:   A  quantity  of  wastewater  or pollutant that  greatly exceeds  the
normal discharged  into  a  treatment  system, usually occurring  over a limited
period of time.

shuck:  A process used to remove the shells from oysters and clams.

sludge:   The solid matter  that  settles to the bottom  of sedimentation tanks
and must be handled by digestion or other methods to complete the waste treat-
ment process.

sludge dewatering:  The  process  of removing a portion  of  the water in sludge
by  any method  such  as  draining,  evaporation,  pressing,  vacuum filtration,
centrifuging,  exhausting, passing  between  rollers,  acid flotation,  or dis-
solved-air flotation with or without heat.  It involves reducing from a liquid
to a  spadable  condition rather than merely changing the density of the liquid
(concentration) or  drying (as in a kiln).

solubles:  The  material  which results after processing that was dissolved  or
able  to  pass into solution in the stickwater.   This residue can be incorpor-
ated  into fish meal or sold separately as a byproduct.

species (both singular and plural):  A  natural  population or group of popula-
tions  that  transmit specific characteristics from  parent  to offspring.  They
are  reproductively  isolated  from other  populations  with  which  they might
breed.   Populations  usually  exhibit a  loss  of fertility  when hybridizing.

stickwater:   Water  and entrained organics that originate from the draining or
pressing  of  steam cooked  fish products.

sump:  A  depression or tank that  serves  as  a drain or receptacle for liquids
for salvage  or disposal.

tertiary  waste treatment:   Waste  treatment  systems  used  to  treat secondary
treatment  effluent  and  typically  using  physical-chemical  technologies  to
effect  waste  reduction  of  specific pollutants.   Synonymous  with "Advanced
Waste Treatment."
                                        D-9

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                  Improving the Economics
                             of
                 Crustacean-waste Disposal

               Peter M. Perceval and W.E. Nelson
                  CHI-AM International, Inc.
                    16. E. Southampton Ave.
                   Hampton, Virginia 23669

    The highly valuable segment of the U.S. fishing industry
which processes crustaceans - shrimp, crab, lobster and cray-
fish - has always been plagued with the problem of disposing
of the tremendous quantities of solid wastes it generates.
The problem has become more serious in recent years with the
increase in demand for these species, the development of new
fisheries, and the necessary implementation of water, air and
solid waste pollution control regulations.  Various solutions
have been suggested but few, if any of them, meet the necess-
ary requirements of being environmentally sound, economically
viable and applicable year-round in areas which range in temp-
erature from the highs of the Gulf Coast to the lows of Alaska,
and in locations as different as metropolitan complexes at one
extreme and remote fishing communities at the other.

    The two major inputs to solving the problem have usually
come from either the industry itself or from those institutions
concerned with marine resources.

    Under the circumstances it is quite understandable that
the industry's approach has generally been one of seeking the
least expensive means of getting rid of the troublesome mat-
erials.  In many locations the dehydration plants that have

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-2-
resulted from this approach are now unable to achieve suffi-
cient revenues for their relatively crude product to compen-
sate for rapidly increasing costs - as is the case in the
crab meal industry.  The problems that are now being faced
by these plants, some of which have already gone out of
business, naturally discourage other locations from attempt-
ing this particular solution to the problem.

    The institutional approach has generally been to seek
the highest possible value that could be achieved from crus-
tacean wastes - through the chemical extraction of chitin,
chitosan and by-products.  However, after some forty years
of attempts at commercialization, this solution has yet to
be proven economically viable and the history of repeated
pilot-plant failures discourages many potentially-interested
chemical process industries from further ventures in this
direction.

A Different Approach

    A careful study of the conventional disposal practises
and meal plant operations together with an understanding of
some of the unique properties of chitin suggests that there is
considerable merit in adopting an approach which should gene-
rate more revenue than currently received for crustacean meals;
which benefits from some of the valuable features of the chitin
contained in the wastes; and which lends itself to implemen-
tation by the fishing industry itself - as opposed to requir-
ing manufacturing participation from the chemical process
industry as is the case with chitin and chitosan extraction.

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-3-
    Basically this approach can be divided into two comple-
mentary segments: (a) increasing the profitability of existing
dehydration plants, especially those which handle wastes with
a high proportion of inorganic material such as result from
crab processing, (b) improving crustacean waste processing to
provide an economically viable method for areas where no
such option exists currently.

Problems of Conventional Dehydration

    Three undesirable features of existing crustacean meal
processing suggest the need for change.  First, in almost all
locations which currently practise this means of disposal,
crude dehydration methods are employed which usually involve
direct flame drying of the ground, or frequently unground,
waste materials.  Such drying methods are not conducive to
attainment of highest market values for the resulting products.
Any potential increase in value from pigmentation, such as
is the case with shrimp waste, is considerably reduced by
such crude drying.  Second, in the case of those wastes with
a high inorganic content, such as crab waste,the loss in meal
value due to crude drying is compounded by a very unfavorable
calcium to phosphorous ratio  which markedly restricts levels of
incorporation in feedstuffs.Third, because of the crude dehy-
dration methods that are generally employed, air pollution
problems are almost inevitable.  In order to overcome these
problems considerable additional expense is now being incurred
for major control equipment such as proper scrubbers.  Imple-
mentation of the Clean Air Act Amendments of 1977 requires a
mandatory assessment of "non-compliance penalties" against
nearly every violating source of air pollution after August
7. 1979.

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-4-
    In summary then, avoidance of air pollution penalties,
the requirement for effective disposal techniques and the
necessity for increased by-product revenues all combine to
suggest the need for a change in methods of dehydrating crus-
tacean wastes.

Improved Dehydration Methods

    Various alternative dehydration systems have been avail-
able for some time but few, if any, appear to have been
adopted for drying crustacean wastes probably because of
higher initial cost,  A good example of such an improved
system was announced in NATIONAL FISHERMAN, May, 1979 (1).
This report concerns the availability from within the fish-
meal industry, of an indirect-heat, continous vacuum dryer
which, because of its gentler drying characteristics, should
permit marketing of much more valuable shrimp meal or crab
meal than is the case with the higher temperature direct
heat, flame dryers.  Shrimp meal produced by this process
has brought offers of prices more than double those received
for conventionally dried meal and the process does not result
in air pollution according to the manufacturers (2).  One of
the new units capable of producing .8 tons per hour of dried
crustacean meal at 8-10/6 moisture is quoted as costing appro-
ximately $100,000.

Decalcification

    In the case of meals produced from species of crab, lob-
ster and crayfish, it is generally recognized that if most of

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-5-
the shell fraction could be removed inexpensively a con-
siderably higher price could be attained for the protein
fraction.  A method of such "decalcification" was proposed
by Rutledge of L.S.U. (3) in 1971.

    Rutledge's pioneering work involved decalcifying Blue
Crab and Freshwater Crayfish meals by drying to a moisture
level of 6% or less, grinding through a Wiley mill with a
V1 screen, and sieving through a No. 12 U.S. standard mesh
screen.  Table I from Rutledge's work shows proximate analy-
ses of crab and freshwater crayfish waste before and after
separation.  Table II from the same source, lists separation
processing efficiency.

    Protein content of the meals was almost doubled by such
processing and calcium levels were reduced by as much as
68%.  Rutledge pointed out that, "such processing will tend
to reduce the imbalance between calcium and phosphorus, as
well as increase the protein content" - both of which factors
would raise the value of such crustacean meals.  He concluded
that, "if it is feasible to dry such materials, additional
cost of milling and screening should be nominal."  Figure
III demonstrates what would be the combined value attainable
from such a separation process as described by Rutledge,
assuming that each fraction is worth the price in cents per
pound indicated at the top and side of the table.  It does not
seem unreasonable to expect values in excess of 15 cents per
pound for such an improved meal product with 58.4% protein.
The protein value and amino acid balance approximate those
of fish meal which is currently valued at around $400 per ton.

    Admittedly, an attempt to displace fish meal in some

-------
From James E.Rutledge 1971 (3).
Table  I  Proximate Analyses  of Crab  and Freshwater Crayfish
         Waste  Before  and After  Processing  (a)

Constituent
Moisture
Protein (b)
Fat
Chitin
Ash
Calcium
Phosphorus
Before Pro
Blue Crab
Percen
4.5
24.0
2.0
12.9
56.0
17.0
1.7
cessing
Crayfish
tages
5.7
28.1
4.4
12.5
44.0
18.0
1.2
After Pr
Blue Crab
Perce
8.2
58.4
2.7
2.6
20.5
7.5
1.4
ocessing
Crayfish
ntages
6.4
58.5
6.0
2.1
16.8
5.7
0.9
 (a) Average of  20  analyses     (b) Corrected for chitin
Table II  Processing Efficiency  (a)
Determination
Skeletal material in
waste prior to
processing (b)
Skeletal material in
meal after process-
ing (b)
Processing efficiency
Blue Crab
Crayfish
Percentage
80.2
21.6
73.0
75.4
15.8
79.0
 (a) Average of 20 analyses   (b) Percent of total dry material
Note:  60 to 65 % of total waste material is separated as shell
       in the course of processing.

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                                   1250 POUNDS  SHELL FRACTION = 62.5%
pei
Ib
15
16
17
18
19
20
21
22
23
24
25
1
125
132.5
140
147.5
155
162.5
170
177.5
185
192.5
200
2
137.5
145
152.5
160
167.5
175
182.5
190
197.5
205
212.5
3
150
157.5
165
172.5
180
187.5
195
202.5
210
217.5
225
4
162.5
170
177.5
185
192.5
200
207.5
215
222.5
230
237.5
5
175
182.5
190
197.5
205
212.5
220
227.5
235
242.5
250
6
187.5
195
202.5
210
217.5
225
232.5
240
247.5
255
262.5
7
200
207.5
215
222.5
230
237.5
245
252.5
260
267.5
275
8
212.5
220
227.5
235
242.5
250
257.5
265
272.5
280
287.5
9
225
232.5
240
247.5
255
262.5
270
277.5
285
292.5
300
10
237.5
245
252.5
260
267.5
275
282.5
290
297.5
305
312.5
11
250
257.5
265
272.5
280
287.5
295
302.5
310
317.5
325
12
262.5
270
277.5
285
292.5
300
307.5
315
322.5
330
337.5
13
275
282.5
290
297.5
305
312.5
320
327.5
335
342.5
350
14
287.5
295
302.5
310
317.5
325
332.5
340
347.5
355
362.5
15
300
307.5
315
322.5
330
337.5
345
352.5
360
367.5
375
750 Ibs
IMPROVED
PROTEIN
= 37.5%
                                              Figure  III
                  COMBINED VALUE IN DOLLARS PER TON SEPARATED,  BASED UPON 37.5%
                  IMPROVED PROTEIN FRACTION AND 62.5% SHELL RESIDUAL FRACTION.

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-6-
markets might run into the problem of insufficient quantity
of the improved crustacean meal to meet the high-volume re-
quirements of major pet food producers.  Never-the-less there
are some other lower volume markets, such as aquaculture,
wherein the supply and demand factors should be in better
balance, and the special properties of a marine-source protein
are in great demand.

Processing in Isolated Locations

    In certain isolated locations where even an improved dehy-
dration plant might be considered a doubtful economic pro-
position, either because of fuel costs or added transportation-
to-market costs for the products, utilization of either a
Paoli or Baader type meat-bone separator has been found to
be highly effective for extracting the proteinaceous portion
of crustacean wastes which could then be block frozen for
distant markets (4).  It has been demonstrated (5) that a
Paoli machine can obtain 32% of the total weight of moist,ground blue
crab waste as a protein fraction with an analysis of 56.72%
protein and 16.93% ash (dry basis).  If the market justifies
it the shell fraction resulting from such a separation system
would be considerably cheaper to dry after most of the adven-
titious protein has been removed.  Furthermore the particle
size would already have been reduced during the grinding which,
with most species of waste, is required prior to separation
by this type of machine.

    In summary there is a considerable body of evidence to
demonstrate that crustacean wastes could be better processed
in a variety of methods any one of which should result in a

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-7-
pricing structure for the resultant protein product that
approximates that of fish meal.

The Residual Shell Fraction

    The shell fraction that would result from perfect mech-
anical separation consists of the cuticle with its associated
chitin, calcium, and bound proteins.  Much is already known
about crustacean cuticles partly as a result of the research
that has been done in connection with chitin and chitosan ex-
traction, and also from another body of the literature which
is involved with the cuticle for purely scientific reasons.

    In arriving at some minimum attainable values for this
shell fraction the approach taken was to consider:  (a) its
basic structure; (b) those properties of chitin itself which
have suggested market potential; (c) chitin manufacturing
procedures.  In the isolation and purification of chitin,
accompanying calcium and proteins are dissolved away by dilute
acid and alkali respectively.  What is left is the chitin
which is insoluble in dilute acids, and cold alkalis of any
concentration (16).  It has been noted frequently that when
demineralization precedes deproteination a considerable portion
of the bound protein is removed along with the calcium (11).

    All of these factors are then considered in the context of
possible market areas wherein a pollution application might
benefit from utilization of the dried shell fraction, at its
original grind size, or further pulverized.

    Referring again to Figure III, for example, it is obvious

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-8-
that a price of even 10 cents per pound for the shell fraction
radically affects the economics of a dehydration plant if one
can attain 15 cents per pound for the protein fraction.  In
fact the combined revenue per ton of meal separated almost
doubles, increasing from approximately $120 under the present
drying and marketing system to $237.50 in the new concept.
Such added revenue potential for existing meal plants should
improve the economics sufficiently to justify installation
of needed air pollution control equipment.  It should also
justify establishment of newer, and more efficient, environ-
mentally acceptable plants at locations which currently have
no disposal method.

The Cuticle

    B.S. Welinder (6) reported that crab cuticle (Cancer
pagurus) consists of three layers: a combined epi - and
exocuticle, an endocuticle, and a membranous layer (Figure
IV).  The weight distribution between the layers showed that
the dominating layer is the endocuticle.  Chitin distribution
was as follows:

      Epicuticle/Exocuticle	 9%
      Endocuticle	84%
      Membranous layer	 1%

Lockwood (7), and others have established the fact that the
membranous layer of crustacean cuticle is uncalcified.  It
has also been determined that the protein associated with this
layer is arthropodin - not the tanned protein, sclerotin (8 and
9).  Thus the protein in this layer is more readily solubilized

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                                FIGURE IV
                    Decalcified Cancer pagurus cuticle
                        From B.S.Welinder 1975 (4)
Combined epicuticle/exocuticle   17'(
percentage of weight of cuticle
         Endocuticle
percentage of weight of cuticle
76.0
       Membranous layer
percentage of weight of cuticle   6.4
                                  	100

33.9* Chi tin 66.1* Lipop
73*
Chi tin
73.9* Chitin
*- Jf0* 10
rotein
27*
Protein
f~26* Pro.
                               FIGURE IV a

             Solubility of layers of previously decalcified Cancer cuticle
              (Numbers in brackets represent weight loss expressed as
               percentage of the protein present in the various layers)

Combined epicuticle/exocuticle
Endocuticle
Membranous layer
100* HCOOH
36.1* (58.1*)
28.2* (104.4*)
30.9* (118.0*)
1M CH^COOH
21.7* (34.9*)
15.7* (58.1*)
20.1* (76.9*)
   Note:  Numbers exceeding 100 indicate some "chitin was brought into solution,

-------
-9-
or caused to dissociate from the chitin without having to
resort to harsh chemical treatment.  While the middle layer
(endocuticle) is heavily impregnated with calcium salts, the
protein associated with the chitin is also arthropodin.  The
outer layer (combined epi- and exocuticle) is also calcified
but seems to contain the tanned protein, sclerotin, in asso-
ciation with its chitin.  According to Neville (10) and
others,the epicuticle itself is non-chitinous.  Thus the 9%
of total chitin that Welinder (6) reports in the combined
epi- and exocuticle must lie on one side of this layer - the
exocuticle.   In summary then, the crab cuticle usually
contains:

    (a)  no chitin in its outermost layer
    (b)  no calcium in its innermost layer
    (c)  approximately 90% of its total chitin
         in the middle and innermost layers

Recent work by Perceval (11) has confirmed that, as might be
expected, the cuticle of blue crab (Callinectes sapidus) is
layered in much the same manner as in the species (Cancer
pagurus) studied by Welinder.  Therefore it seems reasonable
to expect that chitin distribution between the three layers
will also be somewhat similar.

    Whether or not the arthropodin of the membranous layer
and endocuticle is as easy to solubilize in water, or after
heat treatment, as has been suggested by Kent (12) remains to
be determined.  However, Welinder (6) states that much, if not
all, of this protein is soluble is acid (see also Figure IVa).
Moreover the techniques of chitin extraction prove that cuti-
cular proteins are solubilized by weak alkali solutions,

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-10-

and the associated calcium is solubilized by dilute acid.

The Effect of Pulverization

    If the dried cuticle (shell fraction) is now pulverized
and the resulting material is used as a liquid-phase adsorbent
it seems highly probable that certain inherent properties will
become available.  The vastly increased surface area should
encourage some adsorption, the presence of the proteins might
be expected to bring about some chelation of heavy metals (13),
and the calcium would reduce the acidity of a low pH effluent
solution.  Furthermore, as solubilization and dissociation of
the calcium in the upper layers and the arthropodin of the
middle and innermost layers, continues in an acidic effluent
a maximum of 90% of the total available chitin could become
available for chelation and/or ion exchange.

Powdered Shell Compared to Chitin and Chitosan

    Many, if not all, of these assumptions are borne out by
work that was performed recently at the National Taiwan Uni-
versity (14).  At that institution Tsu-Chang Hung and Sharon
Li-Ming Han tested commercially extracted chitin and chitosan
against powders they prepared from shellfish-shell as adsorbents
for heavy metal ions from aqueous solutions.  They found that
the adsorbent capacity and selectivity for metal ions on shrimp-
shell powder was almost the same as for extracted chitin and
chitosan.  They also found that there was no significant differ-
ence between powders prepared from the shells of different
species of shrimp and crabs.  The degree of metal ion adsorption
varied with pH value and was also a function of time.  Significantly,

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-11-
they report that at pH 3, after one hour of stirring, the
degree of adsorption on the powder was higher than either
chitin or chitosan for mercuric ions, cuperic ions, zinc ions,
lead ions and cadmium ions.  Another interesting finding was
that the powder itself, the same material subjected to acid-
treatment with 13.5% HC1, the powder alkali-treated with 5%
NaOH, the powder with combined acid and alkali treatments as
above, and the commercially extracted chitin and chitosan
all adsorbed in excess of 85% mercuric ions regardless of
changing pH and with only a slight difference in effectiveness.
The Taiwanese scientists experimented with a species of crab
(Portunidae tribercultatus) which comes from the same over-all
family as the blue crab (Callinectes sapidus).  Assuming the
adsorbent capacity and selectivity of powdered shrimp and crab
shell from waste products of the United States fisheries appro-
ximates the levels obtained in the Taiwan experiments, suggests
a potential marketability in such industrial effluent situations
as mining and metallurgy, paints and dyes, pesticides, electrical
and electronic, and battery manufacture.

    This potential has already been the subject of preliminary
investigation by one of the major U.S. companies involved in
water pollution control.  Initial testing performed at Virginia
Polytechnic Institute and State University (15) also has pro-
duced encouraging results in adsorption of lead.

Other Areas with Utilization Potential

    The preferential affinity of chitin for Chromium (VI) at
pH 2.5 discussed by Muzzarelli (16) also suggests the wisdom
of testing the material in other industrial settings such as
electro-plating.

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-12-
    The affinity of chitin for actinide series elements such
as Uranium and Plutonium reported by Muzzarelli (16) and
Silver (17) respectively, offers another fertile field
for testing the powdered shell fraction on nuclear industry
effluent streams which, in many instances, are acidic.  In a
neutral or alkaline nuclear industry effluent situation the
know affinity of calcium for strontium might also prove
beneficial.

    Richards and Cutkomp (18) discussed the correlation between
possession of a chitinous cuticle and sensitivity to DDT.
Lord (19)  reported on the sorption of DDT and its analogues,
and there have been other publications on the general subject
of an affinity between chitinous cuticle and chlorinated hy-
drocarbons.  A very recent paper by Hiraizuma, Takashi and
Nishimura (20) examines adsorption of Polychlorinated Biphenyl
onto sea bed sediment, marine plankton and other adsorbing agents,
Those authors found that dehydrated zooplankton adsorbed PCB
with nearly the same concentration factor as Amberlite XAD-4
and considerably more than aged granular activated carbon.
They state that the effect of organic content upon the magni-
tude of the concentration factor cannot be denied.  Copepods
possessing chitinous exoskeleton are the dominant grouping in
most samples of zooplankton and it is interesting to speculate
whether possession of a chitinous cuticle might not be the main,
or at least a major contributor to the results obtained in the
Japanese work.  A preliminary investigation of this possibility
is also getting underway and the results might help define
yet another promising market potential for powdered crustacean
shell.

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-13-

Benefiting from Nature's Processes

    Subramanian (21) and Martin (22) discuss the role of chitin
contained in moulted exoskeletons as a means of transport of
metals to the world's oceans and their sediments.  One might
reasonably expect that adsorption of the metals they examined,
and others, would be enhanced on powdered crustacean shell due
to the fact that the moulted exoskeletons often contain less
chitin than the cuticle possesses at other stages in the crus-
tacean life cycle (23).

    Puquegnat, Fowler, and Small (24) reported that the maxi-
mum Zn requirements for marine organisms is 2.7^g Zn/g wet
weight.  They thus attributed the higher stable-zinc concen-
trations of Euphausia pacifica to adsorption-exchange, since
14 times as much was found in just-moulted exoskeletons as in
the muscle tissue of the same individuals.  Fowler, Small,
and Dean (25) reported that Zn uptake by dead and living
euphausids was statistically similar and thus, neither directly
nor indirectly related to metabolism; the largest Zn fraction
was always associated with the exoskeleton.

    Martin (22) lists concentration factors for the zooplankton
samples he analyzed as:

    Element                            Concentration Factor
    Pb                                    197,000
    Fe                                     14,400
    Cd                                      6,000
    Zn                                      5,100
    Co                                      3,200
    Ni                                      2,500
    Mn                                      1,650
    Cu                                      1,630

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-14-

Biodeterioration

    An important point that is made by Subramanian and Martin
(21 and 22), and discussed in a different context by Berkeley
(26) and others has to do with the biodeterioration of chitin -
and therefore crustacean shell.  In some pollution control
applications that have been proposed for pulverized shell it
is obvious that prolonged immersion in the presence of chitin-
olytic microorganisms will result in complete degradation of
the particles whereupon the entrapped pollutant would again
be released to the environment.  Hood and Meyers (27) found,
as would be expected, that the rate of decomposition of cuticle
increased as particle size decreased.  They suggest that the
protein content of the untreated chitin (cuticle) may provide
an attractant, allowing the substrate to be more rapidly
colonized and degraded after 4 days of the in situ studies
they conducted.  Essentially all of the substrate had been
degraded by the end of the 23rd day.  While this biodeterior-
ation factor must be considered in many applications for chitin -
and therefore powdered shell fraction - it should not prove
to be an insuperable problem because the content of some of the
effluent streams under consideration would make it rather
unlikely that microbial activity would be high.  Particle size
and duration of its exposure to the sources of biodeterioration
can be controlled to allow sufficient time for maximum removal
of pollutant and minimum degradation by microorganisms.

Possible Pricing Structure for Pulverized Shell Fraction

    If powdered crustacean shell fraction, produced in some
manner as suggested herein, could approximate the cost-effect-
iveness of activated carbon as an adsorbent, or that of Amberlite

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-15-
XAD-4 with its affinity for chlorinated pesticides (28), the
price to the user would be somewhere around 40 cents per pound
in the former case and 80 cents per pound in the latter.  How-
ever both of the materials used for this comparison are usually
capable of being regenerated - a cost-saving feature which is
also possible for chitin but might prove impractical for the
powdered shell.  It would seem therefore that once-through
situations would be the best targets for decontamination
applications with the proposed new product.  Even in this
setting, with a necessarily lowered market price, it is not
unlikely that worthwhile markets will develop which could
consume all the powdered shell that might be produced from
current and future crustacean wastes in the United States
especially when the product is perfected as to particle size
and quality control.  The optimum markets and pricing struc-
tures remain to be determined, but, referring to Figure III
it can readily be seen how a given value for the shell fraction
significantly affects the overall economics of crustacean waste
disposal in this scheme of operation.

A Minimum-Investment Process

    Simplicity of the separation process, the prospect of
some profitability for the crustacean-processing industry,
and the interest already generated all suggest that this type
of disposal technique may one day become the method of choice
for this industry.  Other obvious separation techniques should
no doubt be considered.  However, some of these more sophis-
ticated methods may result in elevating production costs to
the point where the shell fraction might not compete with

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-16-
possible alternative materials or processes.  The problem that
has to be solved is waste disposal in an extremely valuable
segment of the fishery industry - in some instances located
at great distance from major urban centers.  The solution
should be one that requires minimum investment in production
equipment and systems necessary to maintain quality control
of the ultimate products.

    Finally, other possible market areas will likely occur
to those familiar with the unique properties of chitin - some
potentially more valuable than discussed here, and some less -
however the suggestions herein are not intended to be all-
inclusive.  The purpose of this paper is to point out that
there appears to be a viable alternative disposal scheme for
the crustacean industry and that it will likely be one that
is well-worth exploring.  In fact it is the subject of con-
siderable work that is either ongoing or was performed many
years ago.

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Literature cited
(1)   NATIONAL FISHERMAN, May 1979. pg 52.

(2)   Wilson, Donald G., Steel-Pro Inc., P.O. Box 669, Rock-
      land, Maine 04841.  Private communication.

(3)   Rutledge, J.E., J. AGR. FOOD CHEM.,  19 (2), 236-7 (1971).

(4)   Simpson, K.L., In PROCEEDINGS OF THE FIRST INTERNATIONAL
      CONFERENCE ON CHITIN AND CHITOSAN, Boston, Massachusetts
      (1977), R.A.A. Muzzarelli and E.R. Pariser, Eds. MITSG
      78-7, pp 253-62.

(5)   Perceval, P.M., (1976) Unpublished.

(6)   Welinder, B.S., COMP. BIOCHEM. PHYSIOL. 52A, 659-63 (1975).

(7)   Lockwood, A.P.M., ASPECTS OF THE PHYSIOLOGY OF CRUSTACEA,
      W.H. Freeman and Company, San Francisco (1967).

(8)   Richards, A.G., THE INTEGUMENT OF ARTHROPODS, University
      of Minnesota Press, Minneapolis (1951).

(9)   Welinder, B.S., COMP. BIOCHEM. PHYSIOL.,  47A, 779-87 (1974).

(10)  Neville, A.C., BIOLOGY OF THE ARTHROPOD CUTICLE, Springer-
      Verlag, New York (1975).

(11)  Perceval, P.M., (1979) Unpublished.

(12)  Kent, P.W., In COMPARATIVE BIOCHEMISTRY VOL. VII, M. Florkin
      and H.S. Mason, Eds. Academic Press, New York (1964).

(13)  McGRAW-HILL ENCYCLOPEDIA OF SCIENCE  AND TECHNOLOGY, Vol. 3,
      p 20, McGraw-Hill Book Company, New York (1977).

(14)  Hung, Tsu-Chang & Han, Sharon Li-Ming, ACTA OCEANOGRAPHICA
      TAIWANICA, No. 7, 56-63 (1977).

(15)  Wightman, J.P., Virginia Polytechnic Institute and State
      University, Blacksburg, Va. (1979).  Private Communication.

(16)  Muzzarelli, R.A.A., NATURAL CHELATING POLYMERS, Pergamon
      Press, Oxford (1973).

(17)  Silver, G.L., U.S. Patent No. 4,120,933 (1978).

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Literature cited (cont.)


(18)  Richards, G.A., Cutkomp, L.K., BIOL. BULL., Woods Hole, 90,
      97-107 (1946).

(19)  Lord, K.A., BIOCHEM.  J.,  43, 72-8 (1948).

(20)  "Hiraizumi, Y., Takahashi,  M., Nishimura, H. ENVIRONMENTAL
      SCIENCE AND TECHNOLOGY 13 (5), 580-3 (1979).

(21)  Subraraanian,  V., In PROCEEDINGS OF THE FIRST INTERNATIONAL
      CONFERENCE ON CHITIN AND CHITOSAN, Boston, Massachusetts (1977),
      R.A.A. Muzzarelli and E.R. Pariser, Eds., MITSG 78-7, pp
      288-94.

(22)  Martin, J.H., LIMNOL. OCEANOGR. 15, 756-71 (1970).

(23)  Brine, C.J.,  in PROCEEDINGS OF THE FIRST INTERNATIONAL
      CONFERENCE ON CHITIN AND CHITOSAN, Boston, Massachusetts,
      (1977), R.A.A. Muzzarelli and E.R. Pariser, Eds., MITSG
      78-7, pp 509-16.

(24)  Pequegnat, J.E., Fowler, S.W., Small, K.F., J. FISH. RES.
      BD. CAN. 26,  145-50 (1969).

(25)  Fowler, S.W., Small, L.F., Dean, J.M., In PROC. SECOND
      NAT. RADIOECOL. SYMP. (1969), D.J. Nelson and F.C. Evans,
      Eds. pp 399-411. USAEC Publ. Conf. 670503. TID-4500.

(26)  Berkeley, R.C.W., CHITIN,  CHITOSAN AND THEIR DEGRADATIVE
      ENZYMES, In press.

(27)  Hood, M.A., Myers, S.P., In PROCEEDINGS OF THE FIRST
      INTERNATIONAL CONFERENCE ON CHITIN AND CHITOSAN, Boston,
      Massachusetts (1977), R.A.A. Muzzarelli and E.R. Pariser,
      Eds., MITSG 78-7, pp 563-9.

(28)  Kennedy, D.C., ENVIRONMENTAL SCIENCE AND TECHNOLOGY
      7 (2), 138-41 (1973).

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                            Processors Association              Aflrleultural and
               1133 Twentieth Street N.W., Washington, D.C. 20036
               Telephone 202/331-5900                               Senior Vice President
                                                               202/331-5967
                                                               Jack L. Cooper
                                                               Director,
                                                               Environmental Affairs
                                     •April 17,  1979            202/331-5969
                                                               Raymond F. Altevogt, Ph.D.
                                                               Assistant Director,
                                                               Agricultural Affairs
Mr. Calvin J.  Dysinger                                       202/331-5968
Effluent Guidelines Division  (WH-552)
U.  S. Environmental Prot ection Agency
401 M Street,  S.  W.
Washington, D. C.  20460

Regarding:  Comments on the February 1979 report titled Technology for
            Seafood Procesaing Waste Treatment and Utilization,  Section 74
            Seafood Processing Study,  prepared for EPA by the E. C. Jordan
            Company,  Portland, Maine,  under contract No. 68-01-4931.

Dear Mr. Dysinger:

        The National Food Processors Association,  formerly the National Canners
Association, is a nonprofit trade association with approximately 650 members
who pack about 90 percent of the total United States production of  canned food for
human consumption.  The seafood processing members of our Association
appreciate this opportunity to comment on the above report.

        The only comments submitted at this time are our specific comments
on  individual parts of the report.  Our  overall  general comments  on the scope
of the report,  assumptions made, and other factors will be provided to you as
soon as they can be prepared,  and reviewed by the industry and counsel.

        The attached specific comments are presented by page, paragraph, and
sentence  number.

                                     Sincerely,


                                     Jack L. Cooper

enclosure

cc:  Effluent Guidelines Subcommittee for Seafoods
     Brian Leamy
     Vince Evich
     Dave Ballands
     Tony Nizetich

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                                                              April 17,  1979

                        SPECIFIC COMMENTS
                                 by the
             NATIONAL FOOD PROCESSOGS ASSOCIATION
                          on the Report titled
          TECHNOLOGY FOR SEAFOOD PROCESSING WASTE
                   TREATMENT AND UTILIZATION
                                 dated
                           FEBRUARY 1979
                            Prepared by the
            E. C. JORDAN COMPANY, PORTLAND, MAINE
                                 for the
            U. S. ENVIRONMENTAL PROTECTION AGENCY
                  under EPA Contract No. 68-01-4931

       Our comments are presented by page, paragraph, and sentence number:

       ii,  1,  1,  The last word of the first sentence  should be "waters" instead.
of the term "wastes. "

       ii,  2,  2,  This sentence should be rewritten to read as follows:

       For most of the industry,  existing waste management practices are in
       compliance with EPA's nationally promulgated effluent guidelines and
       additional more stringent requirements  necessary to achieve locally
       derived water quality standards.

       The industry does not regard its existing waste management practices as
"poor"; nor does the industry regard its existing waste management practices as
resulting in the wasting of significant portions of the raw material brought to shore,
The  industry currently-utilizes as much"material from the incoming raw fish or
shellfish as is possible.  Since there are no existing markets for unutilized parts
of the incoming raw material,  these residuals must be handled as waste.

       ii,  2,  3,  We disagree with the  statement that improved handling  of the
waste materials can result in more complete utilization,  the  production of salable
by-products,  or reduced waste volumes and reduced associated environmental
control costs.  Just because you  are able to handle a waste better is no assurance
that  more of that material can be utilized or that it can be sold for a reasonable
return of or on the investment.  Improved handling is also no guarantee that the
volume of waste generated or the costs associated with its disposal can be reduced.
Accordingly,  this sentence should be deleted.

       ii,  3,  We recommend that this  paragraph be rewritten to read as follows:

       Large year-round seafood processors,  such as large  tuna canneries
       and major fish meal plants,,  practice waste management and environ-
       mental control methods, which  include effective controls on water use,
       water  recycling techniques, and recovery and use of raw materials not

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                                  - 2 -

       incorporated as part of a human food product line, such as for the
       production of pet food and meat by-products.  Portions of the incoming
       raw material which cannot be converted into human food  or by-products,
       must be disposed of as waste.

       iii, 2, 2,   We disagree with the statement that improved waste treatment
and disposal methods are required to  reduce the impact of these wastes on the
environment.  This is a generalized statement implying that the disposal of seafood
processing wastes adversely impact the environment and thus must be removed
from the environment at all locations.  This implication is improper particularly
since the focus of the Section 74 Seafood Processing Study is to assess and deter-
mine the effects of seafood waste discharges into marine waters.  The contractor
has prejudged the conclusion of the  report that seafood processing wastes adversely
impact marine waters.  We strong disagree with this  implication and recommend
that  this sentence be deleted.  In fact,  in at least one  area,  Terminal Island,
California, a recent study by the Institute for Marine  and  Coastal Studies  of the
Allan Hancock  Foundation,  Los Angeles,  California, has concluded that controlled
discharges of cannery waste may be beneficial to marine life by providing nutrients
for the food web.  We understand that the complete report is at the printers and
will  be submitted to EPA  soon.

       We recommend that thia paragraph  be rewritten to read as follows:

       The most applicable technology for  seafood processing plants located
       in remote parts of Alaska is grinding followed by direct discharge.
       For seasonal seafood processing plants  in the  contiguous states the
       most applicable technology  is screening.  For the tuna and fish meal
       processing plants,  the highest level of treatment that should  be required
       is dissolved air flotation.  Other, more advanced technologies are avail-
       able but are not applicable to the industry.   Where the achievement of
       locally  derived water quality standards require treatment beyond the
       levels indicated above, seafood processing plants could investigate a
       number of more complex wastewater treatments.  Where more complex
       alternatives are being considered, seafood processing plants should
       examine in-plant modifications for opportunities to reduce the quantities
       and volumes of wastes generated.

       iii, 3, 1,   This  paragraph begins with the statement "To reduce its environ-
mental impact, the seafood industry should ..."  Again, the contractor has
concluded that  there is  an adverse  environmental impact due to the discharge of
seafood, processing wastes  into  marine waters.   If this sentence is to be left  in,
we recommend that it be rewritten to  read as follows:

       At those specific sites where adverse impacts due to the discharge  of
       seafood processing waste need to be mitigated, affected, seafood proc-
       essing plants should investigate improvements to their water and waste
       management practices,  which may  include efforts in the area of by-
     •  product manufacturing,  and wastewater treatment and solids  disposal
       technologies.

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                                  - 3 -

       1, 1, 1,  The scope of effort states that the contractor was to identify
and evaluate certain technologies.  We concur that the report does indeed identify
many technologies;  however, we disagree that the report "evaluates" any of them.
Accordingly, we recommend that the words "and evaluate" between the words
"identify" and "technologies" be  stricken from this sentence.

       The major purpose of the Section 74 Seafood Processing Study was to
evaluate the effects of seafood processes which discharge into marine waters.
Consequently, the scope of effort on page 1 should include an evaluation of the
technologies necessary for the proper disposal of seafood processing wastes into
marine waters.  However,  the report is  completely void of any such evaluation.

       2, 1, 1,  In the scope of effort, the contractor  states that costs were to be
developed for programs to achieve waste reductions through in-house management
and end-of-pipe treatment techniques.  While  some costs are shown, no source
or reference is  cited for many of them.   For example,  see Tables 5, 6,  and 7.
Without specific reference citations as to how these costs were developed, it is
impossible to comment on their validity.

       2, 1, 2,  The report does emphasize the utilization of seafood processing
wastes for human  consumption;   however, little or no discussion is presented on
the problems of obtaining FDA approval for the marketing of by-products made
from seafood processing wastes  for human or animal  consumption.   Problems in
obtaining FDA approval should be investigated and included in the report. Also,
this  sentence lumps demonstrated technologies  such as the production of fish meal
and fish  oil with speculative and  unestablished markets for new human consumption
and chitin/chitosan products.  Throughout the report,  reference to  the production
of new products  for human consumption and other theoretically producable products
such as chitin/chitosan should be clearly identified and presented as possible
alternatives that may be available sometime in the future but that they are not
presently available.  A reader of the paragraph as written could conclude that
the production of by-products for human consumption and chitin/chitosan are just
as available as by-products such as fish meal and fish oil.   This  simply  is not
true and should not be implied in the report.

       While the seafood processing industry looks forward to the development
of new by-products from seafood wastes,  we  caution the contractor to keep  in
mind the following economic and regulatory facts:  (1) fish and shell meal plants
not processing a primary fish meal product such as menhaden are net loss opera-
tions;  (2) the chitin/chitosan plant in Brownsville, Texas,  went  into financial
backruptcy;  (3)  uses of protein by-products derived from seafood wastes, i.e.
DAF sludges, by the use of polymers and chemicals will be  stringently regulated
by the U. S.  Food and Drug Administration; and (4) neither chitosan nor any
other polymeric agent currently  used in DAF  systems has FDA approval.

       Considering the economic and regulatory constraints on the use of chitcsan
and any by-products recovered with its aid, caution is  urged in promoting chitosan
as a solution to seafood waste disposal.   This concern has apparently been recog-
nized by the economic contractor (DPRA)  who concludes that chitosan is  not
economically feasible  under present conditions.

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                                  - 4 -

       If the contractor is predisposed to urge recovery of protein materials
from seafood wastes  to serve as feed, and food supplies, we fail to see why the
contractor has failed to recognize  the nutritional value of feeding these materials
to marine organisms.

       2, 1, 3,  The statement is  made that an economic study is being "undertaken
by another contractor. " The other contractor should be identified.

       2, 2,  The report does not  address  technologies for discharging or
dispersing seafood processing wastes to marine waters.  We strongly recommend
that the report be revised to address the various methods for returning seafood
processing wastes to the marine environment.  The contractor should not rule
out this low-cost, environmentally acceptable,  disposal alternative.

       2, 2, 1,  The report does not, but should, address disposal alternatives
and potential uses of  wastes in Puerto Rico, Hawaii, Guam, and American Samoa.
The contractor should either include these  areas in the report or explain why they
were omitted.

       2, 3, 3,  As we noted at 2,  2, "the  major areas of interest," should
have  included an assessment of technologies to ". . . facilitate the use of the
nutrients in these wastes ..." when discharged". .  .  into the  marine environment. "
(See Section 74 of the Clean Water  Act. )

       4, 1, 1,  This sentence should be rewritten to read as follows:

       This report addresses three of the major topic areas relating to the
       Section 74 Seafood Processing Study:

       1.  Return of  seafood, processing wastes  to the marine environment;

       2.  Waste control technology  and the coats associated, with reducing
            seafood waste discharges;  and

       3.  Utilization and disposal of materials  accumulated through the
            application of waste control technologies.

       4, 3, 1,  The statement is  made that the tuna processing segment and modern
fish meal plants  (with solubles) should be assed  separately from the rest of the
seafood processing-industry with respect to waste control and utilization because
they "best demonstrate the  philosophy of total utilization of raw materials. "   We
concur that  the tuna processing industry has installed the  highest level of waste-
water treatment  employed by the seafood processing industry and that they do
indeed utilize  as  much of the raw material  as possible.  However, the contractor's
emphasis should  be placed not on the philosophy of total utilization but on the
differences  between the tuna processing industry and the other  subcategories,
such as length  of season,  volume of raw product processed, plant size, ability
to hire professional environmental staff,  potential of waste materials for manu-
facture of by-products, proximity  of processing plants to  by-product (reduction)

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                                 - 5 -

plants,  processing equipment employed,  and degree of treatment required on
a case-by-case basis in order to protect receiving water quality.  In other words,
we concur that the tuna and fish meal processing industries should be assessed
separately from the rest of the seafood processing industry but we do not agree
that  it should be based upon a philosophy of total utilization;  rather, it should be
based upon the fundamentally different characteristics of the industries.  We
recommend the report be rewritten to differentiate  clearly between these two
vastly different segments of the seafood processing industry.

        5, 2, We recommend that this paragraph be rewritten as follows:
      /
       Seafood processors comprising the remaining  segments of the industry
       are generally small,  seasonal operations, often family owned,  which
       have  complied with the existing EPA  effluent guidelines.

        We strongly disagree with the statement that most of these plants operate
antiquated processing equipment and demonstrate limited  and unsophisticated
waste management techniques.  The equipment is not antiquated.  If a new plant
were to be constructed  today,  equipment similar to that currently employed
would be installed.  We strongly believe that the waste management techniques
currently employed are adequate to prevent  degradation of marine wasters at
most locations.

        5, 3,  We recommend that this paragraph be deleted from  the report.  The
first sentence states  that the significance of waste loads generated by the seafood
processors has been  recognized by EPA during its previous investigations; however,
the "significance" is  not identified,  nor are  the previous investigations referenced
which have been "recognized"  by EPA.  The second sentence states that the impact
of waste discharges from this  industry has been documented at several sites;
however,  no references are  cited and the word "impact" is  not explained.  Waste
discharges can have both beneficial and adverse impacts.   References should be
provided showing both types  of impact.  The third sentence  of this paragraph
could remain.

        6, 1, 5, The applicability of this sentence to the report is questioned.
The  barometric condenser water and condensate are not wastewaters,  do not
require treatment, and are discharged directly to the receiving wasters.  It  is
not comingled with processing wastewaters.  The statement is made that unloading
water is usually combined with "another concentrated waste stream. "  This other
concentrated waste stream should be identified.

        6, 1, 3, The sentence beginning with the words  "fish meal" should begin
a new paragraph.

       6, 2, 1, The term "at less progressive canneries"  should be deleted,

        6, 2, 3, The seafood processing  industry disagrees with the statement
that  biological treatment systems should be  considered.  Just because the tuna
industry processes essentially the year around is no basis to imply that biological
treatment is an appropriate treatment alternative.   In our view a Federal require-
ment for application of  biological treatment  for any segment of the seafood processing
industry would result in "treatment for treatment's sake. "

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                                  - 6 -

       6, 3, 1,   The term "minor improvements,  such as ..." should be
deleted.  The sentence would then read: Containing spills and reducing water
use during washdown are pertinent to modern fish meal facilities.

       6, 3, 3,   The sentence beginning with the word facilities should begin a
new paragraph.   Also, the period at the end of this sentence should be changed
to a semicolon and we recommend that the following be added:  however, the
feasibility of installing solubles plants must be evaluated on a plant-by-plant
basis.

       7, 1,  This paragraph  should be rewritten.  The contractor should
recognize the discharge  of seafood processing wastes into the marine environment
as a waste disposal alternative.  Instead, the paragraph implies that all seafood
processors  should undertake extensive in-plant modification programs to  control
waster use and minimize contact of processing water with the raw material and
wastes.  Such in-plant modifications  should only be considered where local
water quality conditions  indicate that complex wastewater treatment technologies
may be required. We disagree with the implication of this  paragraph that improved
in-plant operations to control water use will result in reduced waste loadings and
also provide improved potential for more complete raw material utilization.  The
manufacturing of secondary products for human consumption and by-products for
animal feed, and other purposes such as  production of chitin/chitosan are business
ventures in  themselves.   Just because a seafood processor upgrades in-plant
operations,  does a "better" job of controlling water use,  and handles  the raw
material and resulting wastes  in a "better" manner does not mean that acceptable
markets can be found for by-products made from these wastes.  We recommend
that this paragraph be rewritten in the following manner:

       Processing activities vary among the remaining segments of the seafood
       processing industry.   Those segments able to  utilize grinding  or
       screening need not concern themselves with capital  intensive in-plant
       changes to reduce-the quantities  of waste generated or the amounts of
       water used.  However, for those plants where more complex treatment
       may be required,  individual plants should investigate in-plant modifi-
       cations to control water use and  minimize water contact with the raw
       material and wastes.  Reduced water consumption could result in a
       reduction in the size of the wastewater treatment system ultimately
       constructed or in the size of barges needed.  It is important to recognize
       that  reduced water consumption usually does not result in reduced waste
       loadings.   Rather,  when water is recycled and used only where necessary,
       the waste materials become concentrated in the liquid waste streams.

       7, 2, 1,   We concur that there is a concern for environmental protection
on the part of the seafood processing industry.  However, we do not agree that
there  is a growing concern for improved environmental protection.  On the contrary,
the seafood  processing industry believes that the environment is generally adequately
protected by the  wastewater treatment technologies current in place.  Consequently,
we do not agree  that there are current economic incentives for more effective
in-plant waste management on the part of the industry.

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                                 - 7 -

       7, Z,  Z,  This sentence should be rewritten as follows:

       Seasonal food processors generally have only screening technology
       in place.  This technology is adequate at most locations in order to
       protect receiving water quality.

       The phrase  "with the exception of the major tuna processors and modern
fish meal plants, " should be deleted from this sentence because it is redundant.
This part of the  report refers only to "other industry  segments. "

       7, Z,  3,  This sentence should be deleted.  We do not agree that physical-
chemical treatment methods (such as DAF) should be  considered  or emphasized
for seasonal  seafood processing plants.

       8, 1,  1,  We disagree with the statement that most seasonal seafood
processing plants can economically afford to upgrade  their wastewater practices.
The contractor has assumed that seasonal seafood processing plants in the contiguous
states will be able to install, maintain, and operate the complex wastewater treat-
ment system, dissolved air flotation and remain in business.  We disagree.  The
imposition of controls requiring technology greater than screening will result in
widespread plant closures and industry dislocations.  Even the EPA Economic
Impact Documents predict that many plant closures would result from the applica-
tion of this technology (see Tables VI-7 and VI-8 of EPA  Economic  Impact
Documents Nos. 230/2-74-025 and 230/2-75-047, respectively).

       8, 2,  1,  The manual operations discussed in this sentence should be
identified.  Are  they hand-filleting of bottom fish, butchering of salmon, or crab
picking?

       8, 2,  2,  The word "can" is  inappropriate. This  sentence should be
modified to read as follows:

       Some plants may be able to afford higher levels of treatment where
       necessary to achieve locally derived water quality standards.

       8, 2,  3,  The catfish sentence  should begin a  new paragraph.

       8, 3,  1,  We disagree that all of the waste management concepts and
treatment technologies discussed  in this report have  been proven by model plants.
Many of the technologies may have been tried by pilot plants but they certainly
have not been proven or demonstrated to be widely applicable to the entire industry.
Particularly, technologies such as biological treatment and reverse osmosis have
not been proven applicable to the seafood processing  industry.  This sentence
should be rewritten to read as  follows:

       Some of  the waste management concepts and wastewater treatment
       technologies discussed herein have already been tried by model
       plants within various segments  of the seafood industry.

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                                  - 8 -

       8, 3, 2,  We concur that many of the technologies  considered in this
report have been applied successfully by other food industries; however, this
does not mean that these technologies should be considered applicable to the
seafood processing industry.

       8, 3, 3,  The contractor states that the levels of technology included in
the report are "proposed" for the various industry segments.  We were not
aware that this report was intended to propose levels of technology.

       8, 3, 4,  We disagree that the levels of technology "proposed" by the
contractor reflect the special nature  of the seafood processing industry.  This
sentence contradicts  the sentence at 8, 3, 2, which states that the technologies
considered applicable have been applied successfully by "related food industry
in the United States and abroad. "  We concur that the contractor has applied
technologies utilized  by other food industries to the seafood processing industry;
however, the technologies applied by other food industries do  not "reflect the
special nature of the  seafood industry," particularly its processing operations
and most importantly,  its  geographic location.  If the contractor did take into
consideration the geographical location, the report would  contain a discussion
of means of dispersing seafood  processing wastes into marine waters.

       8, 3, 3,  The industry disagrees that the contractor has adequately
examined the effectiveness and  associated costs of the "proposed" technologies.
In order  to do this, the contractor would have to examine  the costs of achieving
particular pollutant reductions against the economic  impact that such costs would
have on processing plants, and  the contractor would  have  to examine the effect
of pollutant  reduction discharges on receiving wasters.  The contractor has taken
neither of these steps.

       9 and 10,  Table 1,  No references are provided for the sources of the
costs presented.  Accordingly,  we cannot comment on their validity;  however,
the biological systems for tuna  apparently do not include the additional cost of
DAF construction,  operation and maintenance.  DAF would probably be required
for efficient operation.

       11, 1, 1,  We question the statement that wastes generated by seafood
processors  have  "some value. "  Those residuals that are  already utilized to
manufacture by-product are not wastes.  The residuals that remain after by-
product manufacture  are wastes and have "no value. "

       11, 1, 5,  The contractor has concluded that  existing wastewater treatment
techniques  will not be allowed in the future.  Also,  the contractor has concluded
that the discharge of  seafood processing wastes adversely impact water quality.
Both of these conclusions are improper as well as incorrect.  Accordingly, this
sentence should be  deleted from the report.

       11, 2, 1,  The word "sophisticated" should be replaced with the word
"complex. "

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                                 - 9 -

       Pages 11  through 15 discuss seafood waste utilization and disposal
techniques.  We recommend that this  section be divided into two sections as
was done in the section on Waste Control and Treatment,  pages 5 through 10.
The first section would be on Tuna and Modern Fish Meal Processing plants,
and the second section would be on Other Industry Segments.  The rationale  for
this recommendation is that the seafood waste utilization and disposal alternatives
are different for  these two segments of the industry.

       11, 3, 2,   The word "modern"  should be replaced with the word "some. "

       11, 3, 3,   We disagree with the statement that the addition of solubles to
fish meal improves the quality of the product.  Also, the words "as with the tuna
canners1 approach," should be deleted, because the addition of solubles to fish
meal  is not unique to the tuna processing industry.

       IE, 1, 3,   This  sentence should be revised to read as follows:

       Investigations are required to  establish the feasibility of producing
       an animal feed additive, fertilizer from float, or disposal at sea.

       12, 2, 1,   We recommend that this  sentence be revised to read as follows:

       For the remaining  segments of the industry,  where waste utilization
       is desirable, improved in-plant waste management may be necessary.

We disagree  with the tone of this sentence which implies that existing waste
management  techniques are not "enlightened. "

      ' 12, 2, 2,   The words "and utilized" should be deleted from this  sentence.
Just because you are able to collect the solids does not mean that you will be able
to utilize them.  Also,  the words "and the solids generated by biological waste-
water treatment systems" should be deleted.  There is no current nationally
approved method by which these solids can be utilized for the production of any
by-product use,

       12, 2, 3,   This  sentence should be rewritten as follows:

       Once  collected,  these  solids have potential for reuse as animal feed,
       fertilizers, and other  useful materials, depending on the species
       processed,  processing steps employed, chemicals used, and the
       granting of approval for such use by the Food and Drug Administration^-

       14, 1, 1,   The phrase "a more interesting" should be replaced with the
word  "another. "

       14, 1, 2,   We recommend that the  first part of this sentence be  revised to
read as follows:  "These natural polymers have potential for a wide range of
applications, "

       15, 1, 1,   The other study participants  should be identified.

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                                - 10 -

       15, 1, 3,   We recommend that the first part of this sentence be revised
to read as follows: Other theoretical by-product alternatives which have yet to
be demonstrated feasible include ...

       15, 2, 2,   We recommend that a period be placed at the end of  the word
"accomplish" and  the remainder of the sentence deleted.  Most food processors do
not consider barging costs to be "reasonable"  and they do not believe that their
current discharges adversely impact near-shore waters.

       15, 3, 2,   We recommend that this sentence be revised to read as follows:

       By-product production may be a solution for disposal of gross and
       screened solids at some locations.

The contractor has utilized the term "by-product recovery. "  By-products are
produced, wastes  are recovered.  Generally,  by-product production results  in
a negative cash flow and therefore is not an "attractive solution. "

       17, 1, 1,   The word "contaminated" should be replaced by the words
"process contact."

       17, 2, 1,   This  sentence should be revised to read as follows:

       Concern for the environmental effects of wastewaters discharged to
       receiving waters by municipal and industrial point sources  has  led the
       United States Congress to provide EPA with the authority to issue
       guidelines  for the cleanup and regulation of the discharges.

       The  contractor has erroneously charged the nation's seafood processing
industry with being the reason for enactment of the 1972 amendments to the Water
Pollution Control Act.  This statement may reflect the attitude of the contractor
toward the industry; however, the House passed version of the 1972 amendments
exempted seafood  processing wastes from the  definition of "pollutant"
(see Committee Print,  Serial Number 92-1,  Legislative History of the Water
Pollution Control Act Amendments  of 1972, Volume I, January,  1973,  page 1068).

       17, 2, 2,   We recommend that this sentence be revised to read as follows:

       Federal regulations,  referred to.as secondary treatment and effluent
       limitations guidelines, have  specified the maximum amount of waste
       materials for pollutants which can be discharged by municipalities and
       industrial point sources,

       17, 2, 1,   We recommend that this sentence be revised to read as follows:

       The  seafood processing industry has made a considerable effort and
       has generally achieved compliance with applicable federal and local
       waster pollution control  requirements.

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                                  - 11 -

It is inappropriate to compare wastewater treatment techniques employed in other
food processing industries to seasonal seafood processing plants.  While it is a
fact that other food processing industries do employ more complex wastewater
treatment methods  than seasonal seafood processors do, there are valid reasons
for the implementation of different technologies.  For instance, most other food
processing industries are operated year round, discharge into inland waters,
have greater economic stability, are usually larger in size, and have control  over
their raw material  supply.  If the contractor wishes to compare the wastewater
treatment techniques of the seafood processing industry with other food processing
industries, the inherent differences between the two  industries should be clearly
noted.

       17, 3, 2, We recommend that this sentence be rewritten as follows:

       While the Agency has  required other food processors such as meat
       packers  and poultry processors to adopt more complex and costly
       technology than those  implemented by the seafood processing industry,
       there are valid reasons for the different technologies.  Among these
       differences  are year-round operations,  point of discharge  (ocean vs.
       inland waters), economic capability, plant size, and control over raw
       material supply.

       17, 4, 4, The term "often antiquated" should be deleted and replaced  with
the following: "Adequate to comply with existing federal and state requirements. "

       17, 4, 5, The remaining sentences of this paragraph should be  deleted
or placed in a separate section discussing the tuna and fish meal processing
industries.

       18, 1, 3, The words  "or no" should be  inserted between the words "limited1
and "land. "

       18, 2, 1, This sentence should be revised to read as follows:

       Technologies for reducing the discharge of solid and liquid waste
       from  seafood processing plants can be segregated into  two  categories.

       18, 3, 3, While the statement is  correct, the contractor should emphasize
that decreased water usage is only useful in the design stage of the consideration
of wastewater treatment alternatives.  Once the treatment facility has been
constructed there may not  be any tangible results of water conservation practices,, -
For example, the operation and maintenance costs for dissolved air flotation of
tuna processing waste is about 80% for the suspended solids loading and 20% for
water.  Consequently, even if the amount of water were to be  cut  in half, little
savings in the operation and maintenance costs  would be achieved.

       19, 1, 1, The words  "foreign matter  or pollutant" should be replaced  with
the words "volumes of wastes. "

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                                  - 12 -

       19, 2, 3,  This sentence  states that the "model" plant represents  "existing
plants. "  After having made an extensive analysis of information contained in the
development document, we question the contrator's statement.   The sentence provides
no source for its reference to  these existing plants.  We are of the view that the
contractor has erred and that these "existing plants" do not in fact exist.

       19, 3, 1,  This sentence  should be revised to read as follows:

       The model plants  generate less wastewater than other plants which
       have not installed equivalent in-plant management practices, reflecting
       the use of intensive water saving techniques of most model plants.

The  contractor has improperly concluded that plants using more water than the
model plants have "poor" in-plant management practices.

       19, 4, 1,  This sentence  should be deleted.  Where are the references to
show that comprehensive water and waste management programs can produce
"economic benefits" particularly for plants which already have adequate waste
disposal facilities in place to  protect receiving waters.  Also, what are the
"traditional practices" that seafood processors must break away from?

       21, 2, 1,  The word "principal" should be deleted from this sentence.

       21, 2, 3,  The word "simple"  should be deleted from this sentence.

       21, 4, 1,  The word "pollutants" should be replaced with the word "wastes. "

       21, 4, 2,  The words "extremely contaminated" should be replaced with
the words "heavily leaded. "

       22, 1, 1,  The words "more sophisticated" should be replaced with the
word "other. "

       22, 1, 2,  The word "contaminated" should be replaced with the word
"concentrated. "

       24, 1, 5,  The contractor should identify the specific solid wastes that are
believed to be utilizable and the "valuable commodities" that can be made from
these wastes should also  be identified.

       24, 3, 1,  We recommend that this sentence be rewritten as follows:

       Based on existing wastewater treatment requirements, currently
       employed in-plant control measures are effective in managing seafood
       processing wastes.

The  contractor has erroneously concluded that existing in-plant control measures
in seafood  processing plants are  "lacking. "

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                                  - 13 -

       24, 3, 2,  We recommend that this statement be revised to read as follows:

       The seafood processing industry is reluctant to adopt complex waste
       management techniques for two reasons:  (1) the maintenance of traditional
       practices and conceptions  which are based upon the rationale of "returning
       to the sea what came from the sea;"  and (2) the end-of-pipe  technology
       currently required by state and federal governments is adequate to protect
       receiving waters at most locations.

Consequently, there is no  need for the seafood processing industry to emphasize
complex procedures or technologies for reducing raw waste loads.

       27, 2, 1,  The contractor  is implying that EPA should increase the level
of control imposed on seafood processing plants  and that no segment of the industry
will have any problem with compliance. We disagree strongly with the tone of this
sentence and recommend that it be deleted.  The contractor has made  no economic
impact analysis to  determine if in fact all segments of the industry can adopt more
effective in-plant water and waste management practices,

       27, 2, 2, Again,  the contractor has  prejudged the report and has  concluded
that discharges  to the marine environment should be eliminated.  We recommend  .
that this sentence also be deleted  from the report.

       27, 2, 2,  We recommend that this sentence be rewritten as follows:

       Once a plant determines that in-plant modifications are necessary,
       the elimination of flumes for raw material,  finished product, and
       waste conveyance can be installed where  economically justified.

       27, 2, 4,  This, sentence is repetitive and can be deleted.

       27, 2, 5,  We recommend that this sentence be rewritten as follows:

       In-plant  measures  and process  modifications can play an important
       role in minimizing economic impacts on plants which decide  to implement
       costly end-of-pipe  treatment technology.

       28, 2, 1,  We recommend that this sentence be rewritten as follows:

       The levels of treatment employed by  seafood processors are  adequate
       to comply with existing federal and state  requirements.

       28, 2, 2,  We recommend that the word "sophisticated" be replaced with
the word "complex. "

       28, 2, 3, We recommend the following new sentence be added at the end
of the sentence ending in the words "marine  environment! "

       However, the  application of such technology is unnecessary in most
       cases for the protection of receiving  waters.

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                                 - 14 -

       28, 2, 4,  We recommend that this sentence be rewritten as follows:

       End-of-pipe treatment approaches available to the seafood processing
       industry are described in the Development Documents.  The only
       information presented here is  new information that was not discussed
       in the Development Documents.

We do not believe that there is a need to repeat in this report information that is
already available  in the Development Documents.  Only that information that is
new or updated should be presented here.

       28,  As noted previously, the contractor has made no reference to techniques
for disposing of seafood processing wastes  in the marine environment.  Such
techniques should be discussed at this point  in the report.

       36, 2, 1,  We recommend that this sentence be rewritten as follows:

       Biological processes do not comprise a common technology for the
       treatment  of effluents generated by the seafood processing industry;
       however, these processes are common for treatment of municipal
       wastewaters and effluents by some other segments of the food processing
       industry.

       38, 1, 5,  We question the  statement that the extended aeration process has
been demonstrated on seafood processing wastes.  Rather, we are of the view
that it has been attempted on pilot  plants  but not full scale levels.

       39, 1, 8,  We recommend that the word "demonstrated" be replaced with
the word "attempted. "

       42, 3, 5,  We disagree with the implication that just because tuna canneries
are continuously operated that biological  treatment systems are applicable for them.

       42, 3, 6,  This sentence should be deleted.  The fact that vessels travel
thousands of miles has no effect on this report.

       43, 2,  A section should be added to  the discussion of physical-chemical
treatment techniques on operator training requirements.  How many people are
required, what should be their qualifications, and how much should they be  paid?
The contractor notes at 57, 2, 2,  that skilled labor is restrictive  in Alaska.
Why isn't it also restrictive to seasonal processing plants in the contiguous states?

       47, 2, 3,  We recommend that this sentence be revised to  read as follows:

       A full scale application has been limited to a trout processing plant
       in Idaho.

The unit at Treminal Island, California, has not been operated at  full-scale.

       47, 2, 4,  We recommend that this sentence be revised to  read as follows:

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                                  - 1 5 -

       In Russia,  a flotation cell with mechanically induced air has been
       treating fish processing effluent.

       48, 1, 2,   We recommend that this sentence be revised to read as follows:

       Some private testing has been performed on tuna cannery effluents.

       48, 2, 2,   We recommend that the words "need to combine" be replaced
with the words "possibility of combining. "

       48, 2, 4,   We recommend that this sentence be revised to read as follows:

       However, an advantage noted for the hybrid system is the possible
       concentration of the floated material within the unit to a higher than
       normal level.

       48, 3, 1,   We recommend that this sentence be revised to read as follows:

       It  is apparent that  electroflotation has not been demonstrated
       sufficiently to gain acceptance  by the seafood processing industry.

       48, 4, 2,   We recommend that the word "pollutant" be  replaced with
the word "waste. "

       49, 2, 2,   We recommend that this sentence be rewritten as follows:

       However, these advanced, systems are seldom applicable to
       seafood processing.

       49, 3, 5,   We recommend that the word "can" be replaced with the word
"may. "

       52, 2, 3  and 4,  We recommend that these two sentences be deleted.

       52, 2, We recommended that the following sentence be added at the end
of this paragraph:

       Several of  the noted methods have been tried by the tuna industry
       and have not been proven feasible.

       53, 2, 1, In item 3,  we recommend that the words "seep" and "into" be
deleted.

       53, 3, 3,   We recommend that the word "would" be replaced by the
word "can".

       54, 3, 3,   We recommend that this sentence be revised to read as follows:

       The most basic and prevalent end-of-pipe treatments have been
       grinding  with direct discharge  and solid separation by screening.

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                                 -16-

       55, Table 5, references for the data shown in this table should be provided.

       56, Table 6, references for the data in this table should be provided.

       56, 2, 2,  We recommend that this sentence be rewritten as follows:

       The usefulness of dissolved air flotation systems  for removal of
       suspended solids and oil and grease has been demonstrated on a full-
       scale level at several tuna canneries within the United States and its
       territories.

       56, 2, 3,  We recommend that this sentence be deleted and replaced with
the following sentence:

       However, attainment of higher removal efficiencies has been proved
       economically unsound.

       56, 3, 4,  The term "optimized DAF systems"  should be defined.  Also,
we recommend that this sentence be revised to read  as follows:

       For the other segments of the seafood processing industry, the
       capabilities of optimized  DAF systems have been demonstrated in
       limited tests conducted in the United States and Canada utilizing
       federal grants.

       57, 3,  A new sentence is recommended to be added between the words
"industry" and "Table 7" to read as follows:

       However, practical and economically feasible application of this
       technology to commercial processors in the United States  has not
       been demonstrated for most species listed.

       57, Table 7, references  should be provided for the data in this table.
Also, the industry  representative from the Maine Sardine Council suggests that
the plant size for sardine and herring fillet plants be increased to 60 and 120
tons  per day,  respectively;  the  total daily flow for these plants should be increased
to 0. 1 and 0. 2 million gallons per day, respectively, and the capital and O&M costs
for each of these should be increased by at least 50%.  Also,  the American Shrimp
Canners Association reports that "there is a discrepancy in the Southern, non-
breaded  shrimp category. The plant size and total daily flow do not conform to  the
experience and studies  made by ASCA for DAF systems operations." Accordingly,
the projected costs are in error.  For additional information contact Mr.  A. J.
Szabo (318/232-5182) or see the  following report:  Dissolved Air Flotation Treat-
ment of Gulf Shrimp Cannery Wastewater, June 1978, EPA Project No. SS03338-01-1«

       59, 1, 1,  The words "are allowed to':  should be deleted.

       59, 1, 3,  The words "then allowed to escape into" should be, replaced with
the word "entered.  "

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                                 -  17 -

       59, 1, 5,  The words "the more" should be deleted.

       59, 2, 2,  This sentence should be rewritten as follows:

       Historically, comprehensive in-plant water and waste management
       practices have not been needed generally in this industry.

       60, 1, 3,  This sentence should be rewritten as follows:

       Relatively simple management practices are available to approach
       recovery  of the raw material;  however, these practices  are not
       widely employed  by the industry due to economic considerations,
       market limitations, and regulatory constraints.

It is generally  "simple"  to recover raw material; however, utilization of
recovered materials is not "simple" as implied by the contractor.

       60, 3, 1,  The word "sophisticated" should be replaced with the word
"complex. "

       60, 3, 2,  The beginning of this sentence should be revised to read as follows:

       Most common are grinding and direct discharge, or simple  solids
       separation systems .  .  .

       60, 3, 4,  The word "manufacturing" should be  substituted for the word
"manufacture. "

       61, 1, 1,  The word "pollutant" should be replaced with the word "waste. "

       62, 1, 1,  The word "care" should be replaced with the word "caution. "

       62, 2, 2 and 3,  The contractor should include a discussion of the likely
impact of EPA's  Solid Waste Disposal Criteria (February 6, 1978 Federal Register),
and EPA's proposed Hazardous Substances Regulations (December 18, 1978
Federal Register) on the disposal of DAF sludges containing "salt" and "significant
concentrations of aluminum."  Will disposal sites continue to be available for
deposit of these wastes?

       62, 3,  Throughout Section B,  the contractor in discussing the current
secondary and by-product production methods  suggests that the industry  does not
look for innovative  ways  to produce and market waste materials.  On the contrary,
the  industry has tried  a number of techniques which have not proven feasible.
The  contractor has reported on two of these attempts at 68,  3 and 74, 3,  2.   Yet,
these trial methods which have failed continue to appear in the report as  methods
which are practical and the industry is criticized for not implementing them.

       We recommend that the by-product    production and utilization methods
presented in Section B be discussed in the following categories:

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                                  - 18 -

       1.  Successful commercial ventures;

       2.  Attempted commercial ventures;

       3.  Pilot projects;  and

       4.  Theoretical  considerations.

Such categorization is essential to full understanding and discussion of by-product
production and marketing.

       63, 2, 6,   The words "can also be" should be substituted with the words
"hold the possibility of  being. "

       65, 2, 5,   It is a fact, not an "indication" that additional investigations
are necessary to gain FDA approval for the use of chitosan as a food (or feed)
additive.  The contractor should provide in the  report a thorough analysis of the
requirements and costs for obtaining FDA clearance.

       65, 3, 2,   The word "readily"  should be deleted.

       67, 1, 4,   The words "less than  one tenth"  should be replaced with the
words "approximately 3% of. "

       67, 2, 1,   The word "than" should be replaced with the word "from.  "

       68, 2, 3,   This  sentence  should be deleted.  Water  quality considerations
were  not part of the Administrator's procedures for designating these non-remote
areas.  The Clean Water Act does not currently provide for consideration of water
quality factors in the establishment of effluent guidelines.   The purpose of the
Section 74 Seafood Study was for EPA  to prepare a report for Congress' considera-
tion so it could consider -whether or not to amend the law to allow water quality
factors to be considered in the determination of effluent limitations for seafood
processing plants.

       68, 2, 4,   The words "people demanding lower wages" should be substituted
with the word "workers. "

       68, 3, 1,   This  sentence  should be revised to read as follows:

       Two non-remote areas  --Kodiak and Petersburg --  have reduction
       facilities which  convert fish processing wastes to by-products.

Seward is not a remote area.

       68, 3, 3,   The following new sentence should be inserted after the words
"immediate area":

       It was constructed to serve as  a waste disposal facility for the
       processors and  is subsidized as  such by the processors.

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                                  -  19 -

       68, 3, 4,  This sentence should be revised to read as follows:

       The facility in Petersburg was intended to be economically self-
       sufficient in producing fish meal and oil from whole fish and
       processing wastes generated in its geographical area.

       69, 1,  The remainder of this paragraph after the words "geographical area"
should be revised to read as follows:

       However, the facility has not  been operated at full capacity on an
       annual basis  due to the limited availability of raw materials.  This
       limited availability does not result from the  waste management
       practices of the area plants.  It results from the lack of a continuous
       processing season.  Because  the Petersburg reduction plant has excess
       capacity,  it will generally accept  processing wastes transported from
       outside the immediate area.   This plant has  received and processed
       wastes from processors located more than 100 miles away on a trial
       basis, but this did not prove economically feasible and has been
       discontinued.

       69, 2, 2,  The remainder of this paragraph after  the word "procedure"
should be revised to read as follows:

       Alaskan salmon canneries,  on a trial basis,  have collected, packaged,
       and frozen salmon heads for shipment to Seattle pet food operations.
       This practice did not prove economically feasible and it has been
       discontinued.

       69, 2, 3 and 4,  These sentences  should be deleted.

       70, 2,  This  paragraph should be  revised to  read  as follows:

       Solids handling and disposal practices which have been adopted by
       most  segments of the seafood processing  industry are practical but
       unsophisticated.  With the exception of the tuna and fish meal processing
       segments, there has been limited implementation of in-plant waste
       management practices or secondary by-product manufacturing.  Most
       changes in-plant water and waste management have resulted from either
       a serious pollution problem or normal economic advantages derived
       from more complete raw material utilization.

       70, 3, 1,  This sentence should be deleted.  The contractor has  improperly
concluded that the existing wastewater practices  employed by the  seafood processing
industry are  inadequate in order to protect receiving waters.

       70, 3, 2,  The words "The most economical" should be replaced by the
words  "If necessary. "

       70, 3, 4,  The words "readily yield" should  be replaced by the words
"result in. "

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                                  - 20 -

       71, 1, 1,   The words "create the need" should be replaced by the words
"create a need. "  The word "identifying" should be deleted;  and the words
"options for" should be replaced by the words "options in. "

       71, 1, 2,   The words "a number of" should be replaced by the word "some. "

       71, 1, item 4, the term "ultimate disposal methods" should be replaced by
the term "other disposal methods. "

       72, 2, 4,   The word "readily" should be deleted.

       72, 3, 3,   This sentence  should be deleted because the production of meal is
not a "secondary product"  intended for human consumption.

       73, 3,1,   In item 2,  the word "can" should be substituted by the word "may. "

       74, 2, 3,   The words "37 to 60%" should be deleted.

       74, 2, 4,   This sentence  should be deleted.  Conventional filleting  techniques
do not yield secondary products. They yield primary product.

       74, 2, 7,   The word "can" should be substituted by the word "may. "

       74, 3, 2 and 3,  These  sentences should be deleted or at  least modified to
accurately reflect that this facility is no longer producing this product because of
economics.

       74, 3, 4,   The word "bottom fish"  should be replaced by  the words "only
fin fish. "

       74, 3, 5,   The word "can" should be replaced with the word "may. "

       76, 2, 2,   The word "scraps" should be replaced  by the words "blood
meats"  and the words "less appealing" should be replaced by the words "off-color, "

       76, 3, A new sentence should be added at the end of this  paragraph as follows:

       This has proved feasible  in only a limited number of non-Alaskan plants,

       80, 1, The contractor  should discuss  the additional costs involved in handling,
shipping,  and storing the liquid fish silage in comparison to dried meal.  Also,
what are the  economics of  drying silage compared to the  normal  fish meal process?
What benefits would result from drying fish silage?   Why not make fish meal in
the first place?

       81, 1, In the first  item,  the contractor should  identify the aquaculture
operations and should identify which species would be utilized to  achieve the
desired pigmentation.

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                                  - 21 -

       83, 1, 2,  The beginning of this sentence should be modified to read as
follows:  "Suspended solids,  oil and grease which are attached to . .  . "

       83, 2, 2,  We believe the 20% figure to be in error;  shouldn't  this figure
be 10% as shown on page 61.

       83, 3, 1,  We recommend that this sentence be revised to read as follows:

       The removal of colloidal constituents at times can be aided by adjusting
       the pH to the isoelectric point of fish protein (pH 4. 5 to 5. 0); however,
       pH adjustment to this low level requires that the equipment be designed
       for resistence to acid corrosion.  Also, the pH must be readjusted to
       between 6. 0 and 9. 0 prior to discharge to receiving water.

       84, 1, The following  qualifier should be added at the end of the last sentence
of this paragraph: "float;  however, FDA has not approved any such chemicals for
food or feed use as of the date  of this report. "  The contractor should explore
with FDA if any companies have submitted petitions for food or feed additive
tolerances for any of the chemicals used in DAF treatment.   The results of this
exploration should be included  in this report.

       85, 3, 4,  The meat packer should be identified with a reference.

       85, 3, 5,  A reference  should also be provided for the production of methane
from the DAF float.

       86, 1, 1,  A reference should be  provided for the Colorado brewery which
utilizes chemical treatment and DAF to  thicken sludge from a secondary waste -
water treatment plant.

       86, 1, 2,  The following qualifier should be added at the end of this sentence:

       "; but only in the State of Colorado because FDA has not approved it
       for use in interstate commerce. "

The  contractor has left the reader with the impression that the marketing of such
a product is a very simple procedure.  As stated previously in these  comments,
the contractor should provide a full discussion of the problems involved in obtaining
FDA clearance for the production and marketing of such materials.

       86, 3, 1,  We recommend that this sentence be deleted.  The  contractor
provides no references for his conclusion on foreign seafood processors.

       86, 3, 2,  We recommend that this sentence be revised to read as follows:

       In the United States,  continuous research is being conducted by the
       tuna canners on the use of DAF float; however,  at the present time,
       there are no approved markets for DAF float.   Consequently,  the
       domestic processors which employ DAF treatment generally dispose
       of it in land fills.

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                                 - 22 -

       86, 4, 1,  References should be provided.

       87, 1, 2,  The word "might" should be inserted between the words "methods"
and "include",  at both places  in this sentence.

       88, 1, 3,  The words  "is no greater than the total plant uptake" should be
substituted by the words "is not in excess of the system's ability to assimilate it. "

       89, 2, 1,  This sentence should be deleted.  The contractor has improperly
concluded that  seafood processing plants must install dissolved air flotation
facilities to comply with future wastewater treatment requirements.

       89, 2, 2,  The words "by EPA" should be  inserted between the words
"identified" and "as."

       89, 2, 3,  The word "hopefully" should be deleted.

       90, 1, This paragraph should be deleted as the potential worldwide protein
shortage has no impact on wastewater treatment requirements for seafood processing
plants.  The entire paragraph is based on conclusions of the contractor without any
reference to the volumes of food needed to solve the world's protein shortage or
how much of this need seafood processing wastes  could help alleviate,  if they could
miraculously be converted from a waste to  a food.

       90, 1, 3,  If the contractor wishes  to discuss overseas operations,  references
should be provided and the geographic, climatic,  size of plant,  length of season,
government assistance programs, and other differences between the U. S.  and the
others should be included in the discussion.

       92, 2,  This paragraph is repetitive of previous  information and should
be deleted.

       92, 2, 2,  Does the "approved water treatment polymer" have approval
from FDA as a food or feed additive?

       93, 2, 3,  The word "much" should be replaced by the word "some" and
a period should be added after the word "environment".    The  term "as waste
material" should be deleted.

       94, 2, 4,  A comma should be added after the word  "waste disposal" and
the term "high-prof it"  should be deleted.

       114, 1,  4,  The words "some  of" should be inserted between the word
"At" and the word "the. " Also, the words "highly contaminated"  should be deleted.

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APPENDIX H

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           National Food Processo*  Association              Economics and SIall3llc,
           1133 Twentieth Slrool M.W., Wachinci'.on. D.G. ?003!i              l> Lav.-rencc Van Meir
           Telephone 202/331-5900                                Director
                                                            202/331-5997
                                              April 16,  1979
Sammy K.  Ng
Office  of Analysis  and  Evaluation (WH-586)
U.S. Environmental  Protection Agency
401 M Street,  S.W.
Washington,  D.C.  20460
 Regarding:   Comments on the March 1979 Draft Report titled Market ing Fcas ibili _ty
             Study of Seafood Waste Reduction in Alaska, prepared for EPA by
             the Development Planning and Research Associates, Inc., Manhattan,
             Kansas.

I pear Mr.  Ng:

      The  National Food Processors Association, formerly the National Canners
 Association, is a nonprofit trade association representing approximately 650
 companies who pack about 90 percent of the total United States production of
 canned foods for human consumption.  The seafood processing members of NFPA
 are pleased to have an opportunity to provide comments on the above draft
 contractor report to EPA on the Section 74 Seafood Study.  Our comments are
 provided on an individual page, paragraph and sentence number basis.

      Page 1-5, 3, 1,  The statement is made that crab and shrimp meal are
 "low value."  What  is meant by the term "low value"?  What is the  value  in
 relation to salmon meal?

      Page 1-5, 3, 3,  The statement is made that "if all of  the wastes
 available were processed as presented  in Chapter II, Alaska  could  account
 for nearly  10 percent of the U.S.  production."  The part of  the statement
 "all of  the waste available" should be explained,  Are these  the wastes  found
 in Petersburg, Seward and Kodiak;  or  are they all  of the wastes that may be
 available in Alaska?

      Page 1-5,  1, 5,  It is  implied  that the  low capacity  of utilization of
 reduction plants, other  than at  Kodiak,  is  due  to  seafood  processing  plants  not
 collecting  their wastes  for the  reduction  plants.   If  it were economically
 feasible to collect these  wastes for  processing, would not the  seafood  processing
 plants already  be doing  it?. This study  has  left out  this  most  important point,
 i.e.,  it is not economically feasible to collect wastes  from other plants
 to  process.  Unfortunately,  the  contractor has  not included a consideration
 of  such  costs in its analyses.   Another reason for the low percentage utilization
 is  that  the reduction plants are large in relation to the available recoverable
 wastes.   This will  always  be a problem at  most Alaskan points,   In order to
 handle peak seasonal flows, the  plant will have substantial excess capacity
 for the  balance of the year.

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Comments on Marketing Feasibility                           Page 2.
Study  of Seafood Waste Reduction in
Alaska.
      Page  1-10,  2,  1,   The  report does  not analyze  the supply and demand
 factors  underlying  price  elasticity of  demand  for fish and shellfish by-
 products.   The revenue  estimates for  the model meal  plants in Alaska are
 based on assumed prices of  $360 per ton for  salmon  meal and $100 per ton
 shellfish  meal,  the actual  prices at  Seattle in  September of 1978
 (Page I-15, 3).   However, fish and shellfish meal was only available in
 extremely  limited quantities  when  these prices were obtained.   Is it
 reasonable to expect this price  to hold if production of meal  in Alaska
 jumps to 13.4 million tons  of salmon  meal and  31.8  million tons of  shellfish
 meal?  What would be the  economic  effect on  the  NPV of  the plants if the
 price were to drop  considerably?

      Page  1-13, 3,1, Although historical data  on prices  for Alaskan fish
lineal and oil are not available in  published  form,  good  factual  data on
 price and  volume could  have been obtained  from Pacific  Northwest  fish  meal
 dealers or from Bio-Dry in  Kodiak.

      Page  1-15, 1,1, Reference is  made to  "...  a regression  technique
 analysis utilizing  supply and demand  factors show that  current prices  are
 fairly representative of normal  conditions;  ,..",No information is  given
 on the variables and source of data  used  in_ the analysis.  At  a minimum
 the regression equation and identification of the variables  along with
 "t" values should be included in the  text.

      Page 1-15, 3,  Table,  A market analysis should be conducted  to determine
 an estimate of  the price elasticity of demand for meal and oil products.
 To what price levels would these products  fall if production in Alaska were
 to be increased by 50%?  100%?  200%?

       Page  1-15, 4,  1,  What part of potential production of shellfish meal
 would the  entire livestock industry of Alaska (or Washington)   use?   Does
 Alaska  have available  sufficient quantities of other feeds (corn, barley)
 to utilize significant quantities of shell  meal?  What percent of  the feed
 requirements  can fish  meal comprise?

       Page II-l,  2,  2,  The justification for  use of limited and secondary
 data was,  "improbable  total  cooperation of  all  processors," and the need
  to  collect data over several years to  arrive  at  complete and accurate data.
 However,  no attempt was  made  to contact the processors or their associations
  for available data we  would  have  cooperated fully  to assist the contractor
  had we been contacted.  We believe that most  of the data sought  is already
  public knowledge and that  the contractor  should be familiar with the  sources
  (See "Draft Report Industry  Structure  and Pricing  Patterns in Alaskan Seafood
  Industry" EPA Contract No. 68-01-4630, October 1978).

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 Comments  on Marketing Feasibility                                 Page 3.
 Study of  Seafood Waste Reduction in
 Alaska
      Page II-2,  Table at bottom of page,   The recoverable  waste  as  percent
 of live weight is statdd at 35 percent and 20 percent respectively  for  canned
 salmon and fresh and frozen salmon.   Industry experience is  a recoverable
 waste of 20-25 percent for canned salmon and 12-13 percent for fresh and
 frozen salmon.  Just on the basis of this overestimation of  waste,  assumed
 production of salmon meal appears to be overestimated by about 60 percent.
 Due to the price of salmon meal relative to shellfish meal,  the  use of  more
 realistic output of salmon meal for the model plants would result in a  much
 lower revenue for the model plants.

      A factor that further reduces recoverable waste relative to total waste
 is the physical removal of water clinging to seafood waste.   The water  is
 physically removed to decrease fuel cost in the reduction process.   However,
 in the water removal process fish material is lost.

I'.     Similarly for shrimp, recoverable waste falls significantly short  of
 total waste due to loss of body fluids and fine particulate material too
 fine for  screening.

      Page II-6, 2, 3,  The study points out  that  in  1976  the  three existing
 plants at Petersburg, Seward and Kodiak had  a combined  production of less
 than 20 percent of the pro forma estimates for these plants.  In view of this
 fact,  is  it not unrealistic to base  the analysis  on  the pro  forma data?

      Page 11-10,  1,  3,  The projection of 300 thousand  tons  of  potential
 fish meal production in Alaska by the year 2000 is absolute  speculation and of
 no meaning  to this study.

      Page 11-14,  Table  II-7,  In an earlier  comment  it  was  pointed  out that
  the  assumed yield of recoverable waste  for  salmon was almost 60 percent above
  industry experience.   The total  revenues  in  Table II-7  reflect  this  upward
  bias  in assumed yield of waste.   For example,  if  industry experience is used
  as  a basis  for recoverable waste,  the total  revenue  for Kitchikan would be
  $245,000 (471 tons  of meal and 189  tons  of oil).   Revenues  for  the  other
  locations are also  overstated.

       Page 11-14,  Table II-7,  The revenue projected from crab  waste should
  be decreased to account for the 80 pounds of oil  that must  be added per
  ton of crab meal necessary to reduce the dust sufficiently  to permit handling,
  shipping and use of crab meal.

       Page II-14,  Table II-7,  In order to obtain seafood wastes of the
  magnitude shown in Table 7 for Bristol Bay, it would be necessary  to collect
  wastes from a triangular area 50 miles at the base and approximately 75 miles
  at the sides.  It does not appear that the cost of collecting and transporting
  this waste to Bristol Bay is included in the cost of operating the  reduction
  plant at Bristol Bay.

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 Comments on Marketing Feasibility        \                  Page 4.
 Study of Seafood Waste Reduction in
 Alaska

      Page III-4, 1,3,  The sizes of plants provided by the B.C.  Jordan Company
 should be provided in the footnote or in an Appendix.

      Page III-4, 5,1,  Because of errors in the estimation of recoverable
 wastes available in Chapter II, these revenues appear to be overstated by
 60 percent or more (See our comment about Page II-2, table at bottom of page).

      Page III-5,  Table III-l,  The utilization of capacity for the existing
 plant at Seward is given as 13 percent.  The actual experience of this plant
 has been a utilization rate of 5-6 percent of capacity.  The inability of
 the plant to operate at a higher rate of utilization is due to the unavailability
 of an adequate supply of raw waste.

      Page III-6, Table III-2,  As stated earlier,  these revenues are grossly
 overstated due to overestimation of recoverable waste available.

||     Page III-7, 4,  1,  The investment costs provided by  the E.G. Jordan
 Company should be provided in an Appendix.

      Page III-7, 6,  2,  The study admits that at some locations, a "floater"
 type of reduction plant would have  to be used due  to lack of available land.
 The  study does not  identify these sites but assumes  for all plants a  land
 cost equal  to 10 percent of total investment.  Applying this methodology to
 those  sites  that would have to  resortto floaters results  in an  overstatement
 of Net Product  Value (which means if net product value is  negative it would
 be negative  by  a larger amount  if more  realistic data were used).

      A floater  type reduction plant is  a  capital investment  —i.e.  a  case
 of substituting capital  for land.   Generally,  the  initial cost  is  greater.
 Secondly, maintenance costs are encountered  in  connection with  the floating
  platform that would not  be incurred in the case with a  land  based  operation.
 Finally,  the cost  of land  is  considered recoverable and  therefore  has  a
  significant impact on the  NPV computed by  the formula  used in Chapter IV.

       Page 111-10,  5,  The  total investment cost  for the  reduction  plants
  should be compared to the  investment represented by the processing plant.
  Even a general magnitude,  i.e., percentage less  than,  same as,  or  percentage
  greater than would suffice.

       Page III'-ll, Table III-5, Has the energy required to remove process
  water been considered?  This greatly understates the energy required per
  ton of meal processed.  For example, the data available would imply that
  the plant at Dutch Harbor was expected tooperate at 100 percent efficiency.
  Since drying equipment is considered to be operating optimally at 66 percent
  of efficiency, it is likely that fuel costs (at 50c a gallon) would be two
  to three times greater than assumed in this study.

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Comments on Marketing Feasibility                             Page 5.
Study of Seafood Waste Reduction in
Alaska
     Page  111-12, 2,  The waste material being sent to  the reduction
 facility is  considered "to have a  zero value  (neither a  cost nor a credit
 to  the model waste  reduction  plant),  We believe  that this assumption is
 invalid.   Expenses  are  incurred in collecting (screening) and storing
 the waste  and  in  transporting it  to reduction plants.   These costs should
 be  estimated and  utilized in  the  analysis.   While the collection and storage
 costs may  cancel  out  when comparing waste  reduction and barging disposal
 alternatives,  the costs should be included in order to  place in perspective
 the TOTAL  cost for  waste disposal that must  be incurred by affected seafood
 processing plants.  Transportation costs will not cancel  out and should
 be  included.

      Page  111-13, Table III-6,  The labor  requirement for the existing
 plant at Seward is  stated as  one  skilled employee and two unskilled
• employees  per  shift.   The actual  operation of  this plant  employs  three
 skilled employees and two semiskilled  employees  per shift in addition
 to plant management input.  This  underestimation of labor requirements  at
 the existing Seward plant suggests  that  labor  requirements; and  therefore,.
 labor costs for all the model plant  sizes  in Table II1-5  are wrong.  Since
 labor costs for the model plants  .are  seriously understated,  the  entire
 analysis of Net Product Values  is in  serious error.

      Page 111-15, 5,   This  paragraph  infers, that E.G. Jordan  has  reviewed
 weather and operating conditions  at  various processing  sites  and  has  concluded
 that there is  only  a potential  problem at  Dutch  Harbor  for the  "relatively
 small barges that could be  towed by power  skiffs."  Have  they gathered  port-
 by-port evidence to support this conclusion?  If B.C.  Jordan does not  have
 data to support these statements, then they  should withdraw their conclusions
 regarding such barging alternatives.   Moreover,  because barging operations
 may have  to be carried out several times a day,  data  on tidal fluctuations
 is necessary to evaluate this alternative.

      Page III-17, Item  1,  The distances between plants at the Bristol  Bay
 "location" would preclude operating a barge on a cooperative basis.   Consequently
 costs for barging  from Bristol Bay (Table III-8) likely are significantly
 understated.

      Page 111-17,  Item 2,  We are unaware of any company that is willing  to
 build a 25  ton barge capable of  containing  and  dumping seafood wastes for
 $30,000.  The  contractor should  cite a source for  this information.

      Page 111-17,  Item 3,  Used  seine skiffs might be  available for $16,000.
 New,  they cost considerably  more.

      Page 111-17,  Item 4,  It  is assumed  that one skilled and one unskilled
 plant  employee would be required for  two  hours  per barging trip with an
 estimated total  labor  cost of  $70.00  per  trip.   First, it is not  probable

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 Comments on Marketing Feasibility         '                   Page 6.
 Study of Seafood Waste Reduction in
 Alaska
 that.plant employees could-be utilized to operate the barges.  Barge operators
 belong to a different union than cannery employees.  Accordingly, the costs
 of operators is greatly underestimated.  Additionally, ocean barging of
 waste can be life-risking during certain weather conditions.  Second, we
 do not believe that any employees could be found who will be willing to
 operate such barges even in good weather conditions for this sum.

      Page 111-17,  Table at bottom of page,  The algebraic signs in table
 are  reversed.

      Page 111-18, 3,  The calculation of costs for Dutch Harbor  is based on
 an erroneous assumption that a tug boat and crew can be hired on a daily basis
 as needed.  It is unrealistic to assume that a tug and crew will be idly
 standing by for a call when needed.  More  realistically, the tug and crew
 would have to be retained on an annual base fee.  Consequently,  actual costs
11 likely will be significantly greater than  assigned to this operation.

      Page 111-19,  Table III-8,  Because of the various points made on the
 preceding pages on barging analysis, these costs are grossly understated
 in our view.

      Page IV-2, 3, 2,  This paragraph  states that  there are  only two options
 available for  the disposal of. screened solid waste; however, a  third
 alternative which is  the central  focus of  the Section 74 Seafood Study,
 should be included.   This  option  is discharge of  the  solid  waste directly
 to receiving waters with minimal  treatement.  The  major policy  question  that
 should be under  consideration  is  not whether the  industry will  barge  or  go
  to reduction  plants  if forced  to  turn  from present procedures  to one  of  these,
 '/.but  rather, what  are  the  consequences  and  benefits of  forcing  the  industry
  to depart  from present practices.  Either  barging  or  reduction will add
  considerably  to  the  cost  of  processing fish in Alaska.  The data on
 Dutch  Harbor  shows  that revenue  from a reduction plant would not even cover
  the  direct  costs  let al'one any yield on investment.   If more realistic data
 were used for recoverable wastes  and costs,  all model  reduction plants
  exhibit  the same situation i.e.,  they  can only  operate  a  continuing deficit
  on operating costs.

       Page IV-3,  5,  2,  It may be true  that screening and collection costs
  will cancel themselves out for either  fish meal reduction processes or
  barging; however, trasportation costs  would not be cancelled.    There would
  be  an extra cost of transportation from the seafood processing  plant to the
  reduction facility.  This cost should be  factored into Item 3 on this page.
  Item 3 should have a new  litle Screening, Collection and Transportation
  Costs.

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Comments on Marketing Feasibility                               Page 7.
Study of Seafood Waste Reduction in
Alaska
     Page IV-5, 5,  A company that has costs sunk in capital equipment will
tend to use that capital as long as it can cover variable costs and recover
anything towards the fixed costs.  However, it is entirely a different
situation to force the company to use the facility at an output which would
greatly increase its total loss,  A more realistic analysis of the existing
plants would be their NPV'-s at different levels of output within the existing
plant.  Adjusting the revenue and labor cost for the data given indicates  the
existing plant at Seward would have an annual revenue of $140,000 less than
direct costs.  The more processed the greater the loss under this situation.

     Page IV-6, Table IV-1,  An  equity cost of 15 percent is used for  the
base case analysis.  It is naive to believe that equity costs are 157., given
the nature  of  the investment, the existing investment climate, and interest
rates between  10 and 14%.   At best, that would provide debt coverage of
only 2  to 3 times,  Such coverage would not be acceptable.


     Page IV-7, Table IV-2, This  table presents  sensitivity  analyses  for
6 variables that will impact  the Net  Present Value  of  the model plants.
However,  the  sensitivity analyses  ignores  several  important  variations to
 the assumptio.ns underlying the  "base  case," namely,

                1.  A decrease in the  price of .fish  and  shellfish  meals as
                    output  increase.

                2.  A  reduction  in raw wastes  to  be  processed because the
                    present study has  grossly  overestimated  recoverable raw
                    waste quantities.

                3.   An increase in costs  due to various under estimates of
                    costs.

                4.   A cost of equity greater than 15 percent particularly in
                    view of industry experience and inherent risks in Alaska.

      Page VI-1,  Wherever possible, the specific variances noted in
  Chapter VI should be incorporated into the other chapters at the appropriate
  point either as an explanatory sentence or a footnote.  It is unfortunate
  but true that many reviewers and users of technical reports do not read
  past the text and often overlook the "Limits of the Analysis"

      We appreciate this opportunity  to submit these comments on behalf  of
  our seafood processing members.
                                      Sincerely,

                                     ^^fc**/T-*^»t<.
                                      Lawrence W.  Van Meir
  cc:  Cal  Dysinger, EPA
      Dave Jordening, DPRA
      Effluent Guidelines Subcommittee for Seafoods

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