United States Environmental Protection Agency
         Office of Wastewater Management
         Washington, DC 20460
Fish Hold Effluent and Fish Hold
Cleaning Wastewater Discharge
                             EPA-800-R-11-005
                             November 2011

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Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges	CONTENTS


                                  CONTENTS

                                                                           Page

EXECUTIVE SUMMARY	m

SECTION 1 INTRODUCTION	1

SECTION 2 FISHING VESSEL TYPES, FISHERIES, GEOGRAPHIC DISTRIBUTION, AND FISH
      HOLD DISCHARGE PRACTICES	3
      2.1    Lobster/Crabber	3
      2.2    Scallop Dredge	4
      2.3    Fish Tender	4
      2.4    Gillnetter	5
      2.5    Longliner	5
      2.6    Purse Seiner	6
      2.7    Trawler	6
      2.8    Trailer	6

SECTION 3 WATER QUALITY CHARACTERISTICS OF FISH HOLD EFFLUENT AND FISH HOLD
      CLEANING WASTEWATER	8

SECTION 4 VOLUMES AND RATES OF DISCHARGE OF FISH HOLD EFFLUENT AND FISH HOLD
      CLEANING WASTEWATER	10

SECTIONS WASTE DISPOSAL PRACTICES FOR FISH HOLD EFFLUENT	12

SECTION 6 ESTIMATED COST OF FISH HOLD EFFLUENT AND FISH HOLD CLEANING
      WASTEWATER WASTE TREATMENT AND DISPOSAL	14

SECTION 7 REFERENCES	15

Attachment A: Summaries of Information Gathered In Telephone Conversations

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Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges	CONTENTS


                                  LIST OF TABLES


Table 1. Fish Hold Storage and Discharge Practices	11

Table 2. 2007 Fish Hold Effluent Treatment and Disposal Costs	14
The EPA technical contacts for this document are Robin Danesi (202) 564-1846 and Ryan Albert
(202)564-0763.
                                          11

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Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges                  Executive Summary
	EXECUTIVE SUMMARY

       Commercial fishermen store the fish and shellfish they catch in some form of chilled
condition on board their fishing vessels, to keep their catch fresh until delivery to an onshore
seafood processor. Most seafood is either dead when brought onboard or is killed shortly
thereafter, before being stored in a refrigerated seawater holding tank, with the exception of
certain shellfish (e.g., crab, lobster), which must be kept alive. The two most common methods
of cooling seawater are by mechanical refrigeration or by adding ice (or ice slurry or ice chips).
In general, refrigerated seawater (RSW) systems are used aboard purse seiners, tenders and some
trawlers, while ice is used aboard gillnetters, longliners, trailers and some trawlers. Other vessels
(e.g., large shrimping vessels in the Gulf of Mexico) use dry freezers to preserve their catches,
while lobster and crab boats have seawater flow-through tanks used to keep their catch alive.

       Fish hold  effluent includes RSW, ice and melted ice that remains in the fish hold after the
catch has been off-loaded at the seafood processor. The water that is drained as the ice melts
during the fishing expedition is also considered to be fish hold effluent. Common practice aboard
commercial fishing vessels is to discharge the fish hold effluent overboard immediately
following off-loading of the catch at the onshore seafood processor. Following evacuation of the
catch, the fish hold may be cleaned; any fish hold cleaning wastewaters are also discharged
overboard. The fish hold effluent and fish hold cleaning wastewater are discharged in the water
body adjacent to the vessel, with only a few exceptions. At least one port was identified that
captures fish hold effluent along with dock and pier runoff and transports it into the municipal
sewer system.

       The water quality characteristics offish hold effluent reflect contributions from various
sources:  vessel and fish hold materials and coatings, ambient water, potable/service water, and
the seafood product itself. EPA collected fish hold  effluent discharge samples  from 31
commercial fishing vessels, and fish hold cleaning discharge samples from 9 vessels for their
Study of Discharges Incidental to Normal Operation  of Commercial Fishing Vessels and Other Non-
Recreational Vessels Less Than 79 Feet (USEPA, 2010). Elevated concentrations of certain total
and dissolved metals, as well as many of other pollutants, were measured in fish hold effluent
and fish hold cleaning wastewater. Elevated metals concentrations were found for total iron,
dissolved and total copper, total arsenic, dissolved zinc and selenium. BOD, TSS, turbidity, and
nutrient parameters (NH3-N, TKN, and TP) were found at elevated concentrations that were
often higher than those typically found in domestic sewage.

       The volume offish hold effluent discharged by  a fishing vessel depends on the size of the
vessel, the number offish holds and their volumes, the  method used for keeping the catch fresh
(RSW, ice, etc.) and the frequency at which  the catch is off-loaded. These discharges are not
continuous, but occur periodically when the fishing vessel is in operation during the fishing
season. Fish hold cleaning wastewater discharges also occur on a periodic basis; however, the
volumes are considerably smaller.

       To date there has been little regulation offish hold effluent discharges. Discharges
"incidental to the normal operation of a vessel" were excluded from the National Pollutant
Discharge Elimination System (NPDES; 40  CFR 122.3).  That exclusion did not apply when the
                                            in

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Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges                   Executive Summary
discharges were due to operation of the vessel "in a capacity other than as a means of
transportation .  . . such as when used as ... a seafood processing facility." Of five states with
significant commercial fishing industries surveyed, only one (Virginia) was found to have a
NPDES permit  for fishing vessel operations.

       Although the most common practice for commercial fishing vessels is to discharge their
fish hold effluent and fish hold cleaning wastewater overboard after unloading their catch in port,
transfer of these effluents ashore for treatment and disposal may be a practical alternative for
managing these wastes. This practice was encountered in two locations: San Francisco,
California and Sitka, Alaska. Using average fish hold effluent BOD and TSS concentrations and
average rates for industrial users of municipal wastewater treatment plants (WWTPs), the cost
for sewage treatment and disposal offish hold effluent was estimated to be $5.02 71,000 gallons.
                                            IV

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Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges	Section 1 - Introduction


                                                                         SECTION 1
	INTRODUCTION

       This document addresses fish hold effluent and fish hold cleaning wastewater, two
common discharges from commercial fishing vessels. Commercial fishing vessels are vessels
that commercially engage in the catching, taking, or harvesting offish and shellfish or an activity
that can reasonably be expected to result in the catching, taking, or harvesting offish and
shellfish. Commercial fishing vessels include any vessels harvesting fish, crab, lobster, shrimp,
or other aquatic organisms for commercial sale.

       Commercial fishermen store the fish they catch in some form of chilled condition on
board their fishing vessels, to keep their catch fresh until delivery to a seafood processor. Most
seafood is either dead when brought onboard or is killed shortly thereafter, before being stored in
a refrigerated seawater holding tank, with the exception of certain shellfish (e.g., crab, lobster),
which must be kept alive. The two most common methods of cooling seawater are by mechanical
refrigeration or by adding ice (or ice slurry or ice chips). In general, refrigerated seawater (RSW)
systems are used aboard purse seiners, tenders and some trawlers, while ice is used aboard
gillnetters, longliners, trailers and some other trawlers. Other vessels (e.g., large shrimping
vessels in the Gulf of Mexico) use dry freezers to preserve their catches, while lobster and crab
boats have seawater flow-through tanks used to keep their catch alive.

       Commercial fishing vessels may employ various methods of collection including nets,
trawls, traps, or hook-and-line to capture the target species. The major classes of fishing vessels
are differentiated by fisheries, geographic distribution, and how the fish are stored onboard ships.
Fish hold effluent and fish hold cleaning wastewater discharge practices vary according to these
differences. The type offish usually determines both the method of onboard storage and the
process by which catch is removed from fish holds when the vessel returns to port, as discussed
in the following section of this document.

       For vessels with refrigerated seawater tanks, the catch is typically extracted from fish
holds by pumping the fish and the accompanying RSW out of the hold, often with the use of
additional ambient water called bail water. The RSW and bail water is often captured and
recirculated back to the hold and pumped multiple times, until all fish have been removed from
the fish hold. Any excess RSW or bail water that is not required to assist in fish extraction is
pumped overboard pierside. Vessels that use chipped or slurry ice generally remove the seafood
and then discharge the spent ice overboard pierside. Occasionally, vessels that store their catch in
ice slurry also use vacuum filtration systems (e.g., some shrimping boats in the Gulf of Mexico).

       Tanks used to keep lobster and crab catch alive, pump surrounding water into the tank
continuously to maintain the highest water quality possible. The flow rate through these systems
results in a constant discharge offish hold effluent. Because the majority of the seafood product
remains alive, there is little biological decay or degradation in the tank. Furthermore, because
these tanks have reasonably rapid flushing times and a continuous discharge, there is a little
accumulation of pollutants.

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Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges                Section 1 - Introduction


       Fish hold effluent includes RSW, ice and melted ice that remains in the fish hold after the
catch has been off-loaded. The water that is drained as the ice melts during the fishing expedition
is also considered to be fish hold effluent. Standard practice for disposal offish hold effluent
aboard commercial fishing vessels is to discharge the fish hold effluent overboard immediately
following off-loading at the seafood processor.

       Fish holds are also often cleaned or disinfected by vessel crews between catches. All fish
holds are evacuated (i.e., completely emptied) for cleaning. To rinse the fish hold tank, vessel
crews use either municipal water from the pier or dock or they pump water from the surrounding
ambient water. Cleaning may simply involve rinsing the tanks with this water, or crews
sometimes  add detergents or disinfectants. Crews also often use scrub brushes to clean the walls
and floor of the fish hold to maximize the removal  of organic material. Fish hold cleaning
wastewater is a combination of residual fish hold water and ambient or municipal water and
often contains soaps or detergents.

       The fish hold water, bail water (including bail water that is transferred with the catch to
the docks of most off-loading facilities), melted ice and/or fish hold cleaning wastewaters are
typically discharged in the adjacent water body, with only a few exceptions.  Two ports (San
Francisco, California and Sitka, Alaska) were identified that had methods of capturing fish hold
effluent for treatment and disposal. San Francisco's Pier 45 conveys the fish hold effluent along
with dock and pier runoff into the municipal sewer system.  Some fish processing facilities, such
as the Sitka Seafood Processors Co-op, may collect the fish hold effluent and treat it. However,
most ports  and processing facilities are not equipped to capture the high volume of water
contained in fish holds. Overboard fish hold effluent and fish hold cleaning wastewater
discharges  are not currently regulated by EPA in the current VGP.

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges         Section 2 - Fishing Vessel Types,
	Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

                                                                       SECTION 2
             FISHING VESSEL TYPES, FISHERIES, GEOGRAPHIC
    DISTRIBUTION, AND FISH HOLD DISCHARGE PRACTICES

       Commercial fishing vessels may employ various methods of collection including nets,
trawls, traps, or hook-and-line to capture the target species. This section describes the major
classes of fishing vessels, including how they vary according to different fisheries and
geographic distribution. It also discusses how the fish are stored aboard ship, and how fish hold
discharge practices vary according to these differences.

       Approximately 70,000 commercial fishing vessels operate in US waters, representing the
largest category of vessels in the Report to Congress: Study of Discharges Incidental to Normal
Operation of Commercial Fishing Vessels and Other Non-Recreational Vessels Less Than 79 Feet
(USEPA, 2010). The majority of commercial fishing vessels are relatively small compared to
other nonrecreational vessels such as barges or utility vessels, with 56 percent of commercial
fishing vessels in the 26- to 50-foot range (USEPA, 2010).

       In any geographic region,  commercial fishing is a highly diverse industry. Based on
personal communication with a representative of United Fishermen of Alaska, Alaska has
approximately 10,000 active fishing vessels ranging in size from 7 feet to 635 feet and including
skiffs, gillnetters, purse seiners, trawlers, crabbing vessels, tenders,  and trailers (see Attachment
A). Of these vessels, many are equipped to fish several different species throughout the year by
modifying their gear type. Gear type modification mainly involves changing deck equipment and
other machinery. Almost all purse seiners, tenders, and crabbing vessels have RSW systems,
while hook and line and set-net vessels use ice tanks. A vessel with an installed RSW system
would not use the tanks as ice tanks even if their gear type changed.

2.1    LOBSTER/CRABBER

       Lobster and crab (Dungeness, King,  Tanner, and Blue) boats target their catch using
twine or wire-meshed steel pots (traps). Baited pots are left to "soak" for up to several days
before retrieval. Lobster pot vessels are typically found in southern  California and in the New
England coastal states from Maine to Rhode Island. In southern California, the spiny lobster is
the primary target species, while in New England the American lobster is the primary target.
Lobster and crab boats vary in shape  size and range from aluminum skiffs with outboard motors
that fish the inside waters, to seagoing vessels 100 or more feet in length that fish the Bering Sea
and the Gulf of Alaska for king crab (USEPA, 2010). During the 2010 Study of vessel
discharges, EPA observed lobster boats with flow-through tanks that pump ambient sea water
into the lobster tanks, and then discharged directly overboard. Flow-through tanks are used to
keep lobsters alive until the lobster boat reaches the seafood processing facility.

       Crab boats that fish the in-shore waters along the East Coast and Gulf Coast range in size
from approximately 24 feet to 40  feet. The Chesapeake Bay, North Carolina  and Louisiana
coasts support the largest blue crab fisheries (SCDNR, 2010). Commercial fishing methods for
blue crabs include crab pots and trot lines. Blue crabs are placed in a ventilated container (e.g.,
bushel basket) with a moist cloth  covering the top, rather than in water which can suffocate blue

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges        Section 2 - Fishing Vessel Types,
	Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

 crabs when oxygen levels drop. Since blue crabs are placed in ventilated containers rather than a
 tank of water, no effluents are discharged from these fishing vessels.

       Vessels catching Dungeness, king and snow crabs are typically between 50 feet and 150
 feet in length and are larger than crab boats used along the East Coast and Gulf Coast for
 catching blue crabs. Dungeness crabs exist in commercial quantities from Alaska to south of San
 Francisco,  California. Along the Pacific coast, Dungeness crabs live in the intertidal zone out to a
 depth of 170 meters. Dungeness crabs are  stored alive in holds on boats that are filled with re-
 circulating sea water and are delivered every few days to seafood processing  plants. Once the
 catch is off-loaded at the processing plants, any remaining seawater in the tanks is discharged
 overboard pierside. King and Snow crabs are found in the waters off the Alaskan coast such as
 the Bering Sea. Like Dungeness crabs, King and Snow crabs are stored alive  in holds on boats
 that are filled with re-circulating sea water until they can be delivered to the seafood processing
 plant. Water in the tanks is discharged overboard as the catch is off-loaded at the processing
 plant.

 2.2    SCALLOP DREDGE

       A scallop dredge or oyster dredge,  is a dredge which is towed along the bottom of the sea
 by a fishing boat to collect scallops, oysters, clams, crabs, and in some cases, sea cucumbers.
 Dredge boats used to collect clams, oysters, and crabs in near-shore estuarine waters range from
 24 feet to 50 feet long. Offshore dredge  boats used to collect sea scallops can be as large as 190
 feet long (USEPA, 2010). The largest wild scallop fishery is the Atlantic sea scallop
 (Placopecten magellanicus) fishery found off the shores of the northeastern United States and
 eastern Canada; however, scallops are harvested along all United States coastal areas as far north
 as Alaska.  Some scallop dredging boasts process and freeze scallops at sea, while others have
 RSW holding tanks that off-load fresh scallops at a shore-side processing facility. Fish hold
 effluent and fish hold cleaning wastewater is discharged overboard at the pier.

 2.3    FISH TENDER

       A fish tender vessel supports fishing vessels by providing supplies, fish products or other
 materials, and additional refrigerating space; storing the catch; and transporting the catch from
 the fishing vessels to the fish processing facility. During specific fishing seasons, fish tenders can
 also be fitted into a crabbing vessel. Fish tenders range in size from 50 to  130 feet in length. In
 southeast Alaska, fish tenders are typically used to transfer chum salmon (Oncorhynchus ketct)
 from offshore fishing boats to the shore-side fish processing facility. Fish tenders are often large
 vessels with large fish holds filled with RSW. In Alaska, fish and RSW are pumped into the
 seafood processing facility where fish are collected into tanks for further processing and a
 portion of the RSW is returned to the vessel to continue the fish removal process. The remaining
 portion of the RSW is discharged to ambient water pierside. Ultimately, all the RSW from the
 vessel is discharged in this manner along with any  fish hold cleaning wastewater.

       Due to the large size of these tender vessels, the fish hold cleaning process lasts much
 longer than for other vessels. The tanks  are generally rinsed and then filled with water and a mild
 detergent. The solution  is then allowed to circulate in the tank system for several hours before
 the fish hold cleaning wastewater is discharged  pierside.

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges        Section 2 - Fishing Vessel Types,
	Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

2.4    GlLLNETTER

       Gillnetters catch a variety offish, such as salmon and herring, by setting curtain-like nets
perpendicular to the direction in which the fish are traveling as they migrate along the coast
toward their natal streams. Gill netting is performed in nearly all coastal waters of the United
States, including the Great Lakes (MDNRE, 2010). Nets can be set in place, such as at or near
the mouths of rivers, or allowed to drift freely in deep water. Gillnet vessels are usually 30 to 40
feet long and are easily recognized by the drum on either the bow or the stern on which the net is
rolled (ADFG, 2008). Fish caught by gillnetters are dead when pulled aboard. Gillnetters
typically gut the fish on-board, and then place the gutted fish in a hold filled with wet ice. In
southeast Alaska, the wet ice is discharged overboard at the pier after the fish have been
unloaded at the seafood processor. Any wastewater generated by fish hold cleaning is also
discharged overboard at the pier.

2.5    LONGLINER

       Longliners catch fish (primarily halibut, black cod,  swordfish, tuna and shark) via a
longline that is either laid on the bottom or suspended in the water column. Long line fishing is
conducted in nearly all coastal areas of the United States (NJDA, 2010; NMFA, 2010). Each
longline can be up to a mile in length and have thousands of baited hooks.  A longline vessel
typically sets several lines for a 24 hour "soak." Fish brought aboard long-line boats are either
cleaned immediately or placed in ice in the vessels' hold until they reach the seafood processing
plant. Based on personal communication with Alaskan Longline Fishermen's Association,
almost all longliners do some amount offish processing immediately after the fish are caught.
This can includes gutting, bleeding, heading or cleaning the fish before stowing them into their
fish holds (see Attachment A).

       Longliners are typically 50 to 100 feet in length (USEPA, 2010). The vast majority of
longliners have fish hold tanks that are filled with clean ice prior to fishing. As the tanks are
filled with fish and the ice melts, any water is automatically pumped out of these tanks via the
bilge pump. In southeast Alaska, the remaining ice from the fish hold is discharged overboard,
usually pierside at the seafood processor. The tanks stay relatively clean due to the use of ice.
Based on personal communication with Alaskan Longline Fishermen's Association, some
longliners clean their fish holds between each off-load (see Attachment A) while others add fresh
ice to the tanks before leaving on another fishing trip and clean their fish holds periodically. The
tanks are pressure washed with water; dish soap, biodegradable detergents, or a very mild bleach
solution is added when needed.  The wastewater from pressure washing is discharged directly
overboard.

       Based on personal communication with Western Fishboat Owners Association, some
longliners that fish for tuna in the Pacific Ocean use dry blast freezing systems (see Attachment
A). These dry blast vessels are similar to the trailers in the  Gulf Coast used to catch shrimp in
that they have no fish hold discharges but do occasionally need to be cleaned between seasons.
The fish are caught and immediately frozen whole, with no processing on board the vessels. The
reason for this is that tuna tend to be very clean fish and the tuna industry prefers that all
processing to be done at the processing plant closest to where the fish is ultimately consumed.
The cleaning of the fish hold aboard these vessels is similar to defrosting a refrigerator, and any

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges        Section 2 - Fishing Vessel Types,
	Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

water or condensation is discharged overboard. The tuna season generally lasts from June to late
October, but there is some amount of fishing occurring in American Samoa during other parts of
the year.

2.6    PURSE SEINER

       Purse seiners catch fish that school close to the surface, such as salmon, herring, and
sardines, by encircling them with a long net and drawing (pursing) the bottom closed to capture
the fish. Purse seiners are used in Alaska primarily for salmon, while in New England and along
the Gulf Coast, purse seiners are used to capture species such as menhaden (Smith, 1991). Purse
seiner vessels in Alaska are limited to a maximum length of 58 feet (ADFG, 2010) to control the
salmon harvest, while purse seine vessels in New England targeting menhaden generally range
from 140 to 170 feet in length (Smith, 1991). Fish caught on purse seiners are normally placed in
a RSW fish hold and are off-loaded at the seafood processing facility. Refrigerated sea water is
pumped to the seafood processing facility along with the fish during off-loading. A portion  of the
water is returned to the vessel to assist in additional fish off-loading, while the remaining water
is discharged pierside.  Ultimately,  all of the fish hold effluent is discharged once the fish have
been off-loaded. Fish holds aboard  purse seiners are cleaned by filling the tanks with water  and a
mild detergent and allowing it to circulate for some time before the water is discharged pierside.

2.7    TRAWLER

       Trawlers, also called draggers, typically catch large quantities of mid-water species, such
as pollock or pink shrimp, and bottom-fish, such as flounder, by towing a large, cone-shaped net.
Trawlers are common in the New England fishery for bottom fish, and in the Gulf of Mexico for
shrimp. Trawlers also operate along the Pacific Coast from California to Alaska, targeting
sablefish and longspine and shortspine thornyheads (Sebastolobus altivelis and Sebastolobus
alascanus). Dover sole is generally captured using deep water trawls while rockfish is caught
with midwater and bottom trawls (Gilden, 1999). Alaskan  trawlers target mackerel and Pacific
cod in the Bearing Sea. Trawlers range in size from small shrimp trawlers to large, 600-foot
ocean Pollock and Pacific Cod trawlers that possess onboard processing facilities (USEPA,
2010). Trawlers can either store fish in ice-filled hold tanks, or RSW tanks, or process, package
and freeze the fish on board. As an  example, a 160-foot trawler available for purchase in the
northeastern United States has four RSW tanks with a 250-ton capacity and a freezer hold that
can accommodate 400,000 Ibs of squid in bags; 218,000 Ibs. of mackerel (8,400 cases); or
292,000 Ibs. of herring (8,400 cases). Trawlers that preserve fish using wet ice or RSW discharge
the ice/water overboard when the catch is off-loaded at the seafood processing facility. Any fish
hold cleaning wastewater would also be discharged at the pier. Those that process,  package and
freeze fish on board do not have a wastewater  discharge from the fish-hold. These vessels would,
however, discharge wash-down waters from decks and fish processing areas.

2.8    TROLLER

       Troll vessels catch fish such as salmon and tuna by "trolling" bait or lures on lines
through feeding concentrations offish. Commercial troll fishing is conducted in Alaska primarily
for salmon, while commercial troll  fishing in the northeastern United States targets species  such
as tuna and mahi-mahi. Trolling vessels vary in size and configuration, ranging from small,

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges         Section 2 - Fishing Vessel Types,
	Fisheries, Geographic Distribution, and Fish Hold Discharge Practices

hand-trolling skiffs to large, ocean-going power trolling vessels of 50 feet or more in length.
Troll fish are gutted after being caught and placed in a fish hold containing wet ice. In Alaska,
the majority of the wet ice and fish hold cleaning effluent is discharged overboard after the catch
is off-loaded.

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges             Section 3 - Water Quality
	Characteristics of Fish Hold Effluent and Fish Hold Cleaning Wastewater

                                                                       SECTION 3
          WATER QUALITY CHARACTERISTICS OF FISH HOLD
         EFFLUENT AND FISH HOLD CLEANING WASTEWATER

       The water quality characteristics offish hold effluent and fish hold cleaning wastewater
reflect contributions from various sources: vessel and fish hold materials and coatings, ambient
water, potable/service water, and the seafood product itself (USEPA, 2010). If the seafood is not
frozen, but preserved in RSW or ice slurry, small quantities of organic material from the catch
(e.g.,  lipids, protein) will be released as the fish degrade, thereby increasing the concentration of
these  constituents in the discharge. Furthermore, different volumes of blood, mucus, and other
matter can drain from the seafood into the hold, depending on how the fish is cleaned  on deck.
For example, salmon, when caught via gillnets on gillnetting vessels, are cut at the gills and bled
and then placed into the fish hold with RSW or ice before being  cleaned (USEPA, 2010). This
results in their internal organs and some blood leaking into the water. In contrast, salmon caught
on trailers are cleaned while the fishing vessel is still at sea and the internal organs are discarded
into the surrounding waters. Hence,  on the salmon trailers, the organs and most of the residual
blood are not in contact with RSW or ice and consequently, lower quantities of these materials
are discharged when the vessel  empties and cleans its hold at dock.

       EPA collected fish hold effluent samples from 31 commercial fishing vessels,  and fish
hold cleaning wastewater samples from 9 vessels for their study  of vessel discharges (USEP A,
2010). EPA generally collected single grab samples from these vessels while the vessels were
dockside. These samples were usually collected while the effluent was being discharged, but
they were occasionally collected directly from the fish hold. The samples were analyzed for both
total and dissolved metals, classical  pollutants (biochemical oxygen demand, oil and grease,
sulfide, total suspended solids and other physical-chemical parameters) pathogens, and nutrients.
EPA also analyzed the fish hold cleaning wastewater samples and three fish hold effluent
samples for nonylphenols (USEPA,  2010).

       Section 3.4 of EPA's Report to Congress on the Study of Discharges Incidental to
Normal Operation of Commercial Fishing Vessels and Other Non-recreational Vessels Less than
79 Feet (USEPA, 2010) summarizes the specific analytes detected in fish hold and fish hold
cleaning effluent water. EPA's interpretation of the likely risks posed by these analytes to human
health and the environment, relative to pollutant loadings, background ambient and source water
contaminant levels and characteristics, and other relevant information useful for this assessment,
is presented in Chapter 5 of the report to Congress and summarized below.

       Elevated concentrations of certain total and dissolved metals, as well as many  other
pollutants, were measured in fish hold and fish hold cleaning effluent. Elevated concentrations
were found for total iron, dissolved and total copper, total arsenic, dissolved zinc and  selenium.
Concentrations of total and dissolved metals in fish hold cleaning effluent were generally similar
to, but lower than, those measured in fish  hold effluent samples.

       Several classical pollutants found in fish hold effluent and fish hold cleaning wastewater
may have the potential to pose risk. BOD  was found at elevated  concentrations in all samples
and, in many instances, was found at higher concentrations than  those in typical raw domestic

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges              Section 3 - Water Quality
	Characteristics of Fish Hold Effluent and Fish Hold Cleaning Wastewater

sewage. Concentrations of COD and TOC correlated with BOD concentrations and were
similarly elevated in all samples. The high BOD likely contributed to the pervasively low
dissolved oxygen levels. Total suspended solids (TSS) and turbidity in fish hold effluent and fish
hold cleaning wastewater were also similar to levels found in typical raw domestic sewage.
Sulfide concentrations were elevated, particularly in samples from a New England ground
fishery trawler. Nutrient parameters, particularly NH3-N, TKN, and TP, were all measured at
concentrations comparable to typical raw domestic sewage. High pathogen concentrations were
found in a few fish hold effluent and fish hold cleaning wastewater samples; however, the source
of pathogens was likely contaminated ambient background water used to clean the decks aboard
these vessels (USEPA, 2010).

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges        Section 4 - Volumes and Rates of
	Discharge of Fish Hold Effluent and Fish Hold Cleaning Wastewater

                                                                       SECTION 4
         VOLUMES AND RATES OF DISCHARGE OF FISH HOLD
         EFFLUENT AND FISH HOLD CLEANING WASTEWATER

       The volume offish hold effluent generated by a fishing vessel depends on the size of the
vessel, the number offish holds and their volumes, the method used for keeping the product
fresh (RSW, ice, etc.) and the frequency at which the catch is off-loaded. The discharge offish
hold water is not continuous, but occurs periodically when the fishing vessel is in operation
during the fishing season. Fish hold cleaning wastewater discharges also occur on a periodic
basis; however, the volumes are considerably smaller.

       Vessels such as small salmon trailers or longliners that frequent Alaska waters have
approximately 1,500 gallons offish hold storage. EPA estimated this volume is occupied by
approximately 50 percent fish and 35 to 40 percent ice when the vessel off-loads at the seafood
processing facility (USEPA, 2010).  The ice, which is thrown overboard daily after the fish are
unloaded, would result in a fish hold discharge of between 500 and 600 gallons per day (gpd) for
these types of vessels on days they are actually fishing (fish hold volumes, fish hold effluent
discharges, and fish hold cleaning wastewater discharges are  summarized in Table 1).

       EPA estimated that mid-size fishing vessels, such as gill netters, and purse seiners found
in Alaska, and shrimp boats in the Gulf of Mexico, have fish hold volumes of between 3,000 and
5,000 gallons.  Assuming these vessels have between 35 and 40 percent of ice/water slurry in the
fish hold tanks, they likely discharge between 1,000 and 2,000 gallons offish hold water every
two to three days when they are fishing. Larger fishing vessels such as offshore trawlers found
off the coast of New England and tenders found in Alaska can have RSW holding tanks or ice
hold tanks with capacities as large as 15,000 gallons. These tanks, which contain 30 to 40
percent RSW or ice after the seafood is unloaded, result in a fish hold discharge of between
4,500 and 6,000 gallons. These vessels are expected to unload their catch and discharge fish hold
effluent every three to five days when  operating during the fishing season.

       Fish hold tanks are cleaned after the catch has been off-loaded at the seafood processing
facility. Therefore, the frequency offish hold cleaning depends on the type and amount offish
being caught. For example, offshore trawlers  in New England might clean the fish hold tank
every three to five days when they return to the fish processing facility. Small fishing vessels
such as salmon trailers and longliners in Alaska, off-load the catch daily and also clean the fish
hold tanks daily. Fish tenders and purse seiners with RSW tanks might clean their tanks every
few days when they return to the fish processing facility.

       On small fishing boats such as  trailers and longliners, and mid-size fishing boats such as
gill netters, fish holds are typically cleaned using a garden hose at a flow rate of approximately
10 to  12 gpm (USEPA, 2010). Fish hold cleaning is completed in 15 minutes or less, resulting in
a discharge of between 150 and 200 gallons each day the vessel is fishing. Larger vessels such as
offshore trawlers found in New England and large tenders in Alaska also use a garden hose to
wash down the fish hold tanks; however, cleaning these tanks takes longer, approximately 30
minutes. EPA estimated the volume offish hold cleaning wastewater discharged for these vessels
                                          10

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges        Section 4 - Volumes and Rates of
	Discharge of Fish Hold Effluent and Fish Hold Cleaning Wastewater

ranges between 300 and 400 gallons per cleaning, which are expected to occur every three to five
days during fishing season (USEPA, 2010).

                    Table 1. Fish Hold Storage and Discharge Practices

Vessel Size

Small: salmon
trailers and
longliners
Mid-size: gill
netters, purse
seiners and shrimp
boats
Larger: offshore
trawlers and fishing
tenders

Fish Hold
Storage Volume
(gal.)

1,500


3,000-5,000



up to 15,000


Frequency of
Fish Hold
Discharge and
Fish Hold
Cleaning
Wastewater
Discharge
Daily when
fishing

Every 2-3 days
when fishing


Every 3-5 days
when fishing


Fish Hold
Discharge
Volume
(gal.)

500 - 600


1,000-2,000



4,500-6,000


Fish Hold
Cleaning
Wastewater
Discharge
Volume
(gal.)
150-200


150-200



300 - 400


     Source: USEPA, 2010
                                            11

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Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges      Section 5 - Waste Disposal Practices
                                                                       for Fish Hold Effluent
                                                                        SECTION 5
  WASTE DISPOSAL PRACTICES FOR FISH HOLD EFFLUENT

       To date there has been little federal regulation offish hold effluent discharges (see
Section 6 of EPA 2010 for an analysis of how incidental discharges are currently subject to
regulation under US Federal Law or a binding international obligation of the United States). As
documented in the previous sections, it is a common practice for commercial fishing vessels to
discharge their fish hold effluent and fish hold cleaning wastewater overboard after unloading
their catch. Transfer of these  effluents ashore for treatment and disposal may be a practical
alternative for managing these wastes. This practice was encountered in two locations:  San
Francisco, California and Sitka, Alaska.

       Based on personal communication with the San Francisco Port Authority, the city
recently finished re-engineering the pier deck of Pier 45 at Fisherman's Warf to capture all off-
loaded water, ice and fish waste (see  Attachment A).  The Port had been named in a lawsuit in
which one of their 15 tenant fish processors was sued for violating their storm water permit for
allowing fish processing wastewater to drain into the bay. As a property owner, the Port was
responsible for their tenant's  compliance. In response, the Port of San Francisco installed a
system that captures all fish processing waste as well as fish hold effluent. Funded by a $1.6
million grant from the  Clean  Water State Revolving Fund, the project included installation of a
pumpout manifold that allows herring boats moored along the west apron of the Pier 45 fish
processing facility to discharge fish hold effluent and fish waste to the city sewer system. The
project also included installation of a new stormwater collection  system along the west apron of
Pier 45 to direct polluted stormwater runoff from this area back to the city's sewer system
(SFPORT, 2009). The new pier deck system screens larger solids, which are collected and
composted, and routes the separated wastewater to the municipal sewer system. Similar
collection  systems have been used by seafood processing plants for some time.

       Based on personal communication with the Sitka Seafood Producers Co-op in Sitka,
Alaska, the facility accepts "dirty" fish hold ice from fishing vessels (see Attachment A). This
facility is permitted through the NPDES program to collect seafood processing wastewater, grind
any solids (fish parts) using a macerator, and discharge the wastewater through their dockside
outfall. The processing facility began voluntarily collecting dirty ice in the fall of 2009 from
some fishing vessels, since the processor had the means to manage it onsite. As at other ports, the
ice is usually shoveled overboard, but if the ice appears to be very bloody or contain significant
fish guts and slime, the Sitka Co-op facility asks that the ice be shoveled into totes (the same
totes used to off-load fish) and taken  into the facility.  There the ice is melted, and the melt water
is then combined with  the seafood processing wastewater. The Sitka Co-op operates a fleet  of
about 120 hook and line vessels and four gillnetters, the majority of which use only ice tanks.
RSW tanks are primarily used by purse seiners, which are not members of the co-op. The four
gillnetters  and a half dozen of the hook and line vessels use RSW tanks or a mixture of ice and
ambient seawater. These vessels have no means of pumping their fish hold effluent into the
facility, so these vessels discharge their fish hold effluent directly overboard per their usual
practice.
                                           12

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges      Section 5- Waste Disposal Practices
	for Fish Hold Effluent

       As the San Francisco Port and Sitka Co-op examples illustrate, different methods and
facilities are required to convey ice and RSW ashore for treatment and disposal. Based on
personal communication with West Coast Seafood, in regions such as the Pacific Northwest, fish
processors are generally located in secluded or rural areas where the local sewer or WWTPs may
not have the capacity to handle large volumes offish hold effluent (see Attachment A). In larger
metropolitan areas (such as San Francisco) this would not be a limitation.
                                            13

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 Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges       Section 6 -Estimated Cost of Fish
	Hold Effluent and Fish Hold Cleaning Wastewater Waste Treatment and Disposal

                                                                     SECTION 6
       ESTIMATED COST OF FISH HOLD EFFLUENT AND FISH
  HOLD CLEANING WASTEWATER WASTE TREATMENT AND
	DISPOSAL

       The cost of treating and disposing fish hold effluent and fish hold cleaning wastewater at
a publically owned treatment works was estimated using average 2007 rates for industrial users
(NACWA, 2008), as shown below in Table 2. Average concentrations for BOD (840 mg/L) and
TSS (210 mg/L) measured in fish hold effluent samples (USEPA, 2010) were used to determine
surcharges for these constituents. Based on these concentrations and average rates for industrial
users of WWTPs, the total cost for sewage treatment and disposal offish hold effluent is
estimated to be $5.02 71,000 gallons.

             Table 2. 2007 Fish Hold Effluent Treatment and Disposal Costs
Rate component
Volume charge
BOD surcharge
BOD charge
TSS surcharge
TSS charge
Total charge
2007 Average
$2.76 71,000 gallons
0.2625 /pound
$1.84 71,000 gallons
0.2421 /pound
$0.42 A, 000 gallons
$5. 02 /1, 000 gallons
                    Source: NACWA, 2008

       As noted above, the feasibility of onshore treatment and disposal offish hold effluent and
fish hold cleaning wastewater depends upon the nature of the effluent (i.e., RSW or ice), the
method of conveyance from ship to shore (e.g., pumping, fish totes), and the availability of a
facility to accept, convey and treat the waste. In some cases, capital expenditure may be
necessary to construct or upgrade the facilities to allow them to accept fish hold wastewater.
Costs of construction/upgrading would be highly specific to an individual site, and no general
estimates of such capital expenditures are available. For example, the investment of $1.6 million
for improvements made at Pier 45, which allow herring boats to discharge fish hold effluent to
the City of San Francisco sewer system, is likely to be a high estimate for such a system, because
that project also included the installation of a new stormwater collection system. On the other
hand, at some seafood processing facilities the capability to accept fish hold effluent may already
exist.
                                         14

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Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharges                 Section 7- References


                                                                       SECTION 7
	REFERENCES

ADGF. 2010. Frequently Asked Questions. Alaska Department of Fish and Game, Division of
       Commercial Fisheries, Accessed October 10, 2010.
       (http ://www. cf.adfg. state. ak.us/geninfo/about/faq/cf_faq.php)

ADFG. 2008. What Kind of Fishing Boat is That? Alaska Division of Fish and Game, Division
       of Commercial Fisheries. Juneau, AK 2008.

MDNRE. 2010. Commercial Trapnets in Central Lake Huron. Michigan Department of Natural
       Resources and Environment. Accessed October 6, 2010.
       (http://www.michigan.gov/dnr/0,1607,7-153-10364_52259_10951_11244-69487--
       ,00.html).

NACWA. 2008.  Highlighting Challenges in Utility Financing and Management; 2008 NACWA
       Financial Survey Summary. National Association of Clean Water Agencies. Washington,
       DC.

NMFA. 2010. California-based swordfish pelagic longline fishery. National Marine Fisheries
       Service, Southwest Regional Office. Accessed October 10, 2010.
       (http ://www. swr. noaa.gov/fmd/ob server/wcllprog02. htm).

NJDA. 2010. New Jersey Fishing and Aquaculture: Harvesting the Garden  State's Waters. New
       Jersey Department of Agriculture, Jersey Seafood. Accessed  October 6, 2010.
       (http://www.state.nj.us/seafood/seafoodreport.pdf).

Gilden, J., editor. 1999. Oregon's changing coastal fishing communities.  Oregon State
       University, Corvallis, Oregon, ORESU-0-99-001.

SFPORT. 2009. Pier 45 Drainage Improvements Project. Port of San Francisco.
       (http://recoverysf.Org/intranet/RecoverySF/files/2009/03/pier45drainageimprovementsl.p
       df).

Smith, J.W.1991. The Atlantic and Gulf Menhaden Purse Seine Fisheries: Origins, Harvesting
       Technologies, Biostatical Monitoring, Recent Trends in Fishery Statistics, and
       Forecasting. Marine Fisheries Review,  1991.

SCDNR. 2010. Sea Science, Blue Crabs. South Carolina Department of Natural Resources.
       Accessed October 6, 2010 (http://www.dnr.sc.gov/marine/pub/seascience/bluecrab.html).

USEPA.  2010. Report to Congress: Study of discharges incidental to normal operation of
       commercial fishing vessels and other non-recreational vessels less than 79 feet. Office of
       Water, United States Environmental Protection Agency, Washington, D.C. EPA 833-R-
       10-005.
                                           15

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Attachment A: Summaries of Information Gathered in Telephone Conversations
                               ATTACHMENT A:





  SUMMARIES OF INFORMATION GATHERED IN TELEPHONE CONVERSATIONS
                                      A-l

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   Attachment A: Summaries of Information Gathered in Telephone Conversations
           TELEPHONE CALL RECORD

        Outgoing Call	
Company Name: Sitka Seafood Co-op
Name:  Kathleen Wu
                                               Project No.: 0256.03.001.004
                                               Project Name: Vessels - Technical Support
Date: Aug, 122010
Time: 6pm
Contact Name:  Craig Shoemaker

Phone No.: 907-747-5811
                                  DISTRIBUTION

                                  Page _1_ of	1_
GENERAL SUBJECT : Information on the Fishing Industry
                        TOPICS DISCUSSED AND ACTION TAKEN

  Craig Shoemaker is a plant manager at the Sitka Seafood Producers Co-op in Sitka, Alaska. I
  told Mr. Shoemaker that I had spoken with Linda Behnken earlier and that she mentioned the
  Co-op was now accepting "dirty" fish hold ice from boats. He confirmed this practice and said
  that their facility is permitted through the NPDES program to collect their seafood processing
  wastewater, send it through their primary grinder,  and discharge it through their dockside outfall.
  The processing facility "felt obligated" to accept dirty ice from some fishing vessels since the
  processor had the means to manage it onsite. The facility began this voluntary process of
  collecting dirty ice in the fall of 2009.

  If the ice appears to be relatively clean upon inspection, the facility does not bother with
  collecting the ice and asks the vessel operators to shovel it overboard per their usual practices.
  Most of the Co-op's vessels process their catch immediately after bringing it onboard and before
  anything enters the hold tanks, so the ice remains very clean. However, the cleanliness of the
  tanks can depend on the fish species. For example, some bottom fish species can excrete  slime
  after processing, which influences the amount of cleaning required later.

  99% of the fish processed at this facility is salmon. Last year the facility processed 500,000 Ibs
  of halibut, 1.3 million Ibs of black cod, and 300,000 Ibs of rockfish. Salmon and black cod are
  sold as whole fish  so require little processing  at the facility itself.

  I asked if the Co-op accepts only dirty ice or also dirty refrigerated seawater from in fish  holds.
  Mr. Shoemaker stated that the Co-op only has the  ability to take ice from boats  using the  same
  totes that are used  to offload fish. The ice is collected, melted, and then sent to a sump. The
  vessels with refrigerated seawater have no way of pumping their fish hold wastewater into the
  facility. However,  the Co-op operates a fleet of about 120 hook and line vessels and 4 gillnetters
  and the majority of these vessels only use ice  tanks. Refrigerated seawater tanks are primarily
  used by purse seiners, which are not members of the co-op. All 4 of the gillnetters and about 5%
  of the hook and line vessels use refrigerated seawater tanks or a mixture of ice and ambient
  seawater.  All the fish hold wastewater from these vessels is  discharged directly overboard per
  their usual practice.
                                             A-2

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 Attachment A: Summaries of Information Gathered in Telephone Conversations
Fish hold cleaning is also performed after each offload on these vessels. Any wastewater
generated from this activity is also discharged directly overboard. Most vessel operators use
bleach, joy dish soap, or any FDA-approved food grade cleaners.

The only other facility that also offers a similar dirty ice service for their vessels is Alaska
Glacier Seafood in Juneau, Alaska.
                                            A-3

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   Attachment A: Summaries of Information Gathered in Telephone Conversations
           TELEPHONE CALL RECORD

        Outgoing Call	
Company Name: Alaskan Longline Fishermen's Association
Name:  Kathleen Wu
                                               Project No.: 0256.03.001.004
                                               Project Name: Vessels - Technical Support
Date: Aug, 112010
Time: 2pm
Contact Name:  Linda Behnken

Phone No.: 907-747-0695
                                  DISTRIBUTION

                                  Page _1_ of	1_
GENERAL SUBJECT : Information on the Alaskan Fishing Industry
                        TOPICS DISCUSSED AND ACTION TAKEN
         Linda Behnken is a representative of the Alaskan Longline Fishermen's Association and
  an avid fisherman owning her own longliner vessel and fishing when she can along Alaska's
  coast. Her expertise is in longliner vessels.

         These longliner vessels range from 14 ft skiffs to 70 ft vessels. The majority of the
  longliners however range from 40 ft to 60 ft. The longliners mainly fish for salmon, halibut,
  rockfish, black cod, and a few other species that belong to multi-species fisheries, such as skates.
  Although the sizes of the vessels are not really species dependent, Black cod fishing longliners
  tend to be larger ranging from 40 ft to 70 ft, because their target species are concentrated in
  deeper waters and require the fisherman to travel further out from shore. Almost all longliners do
  some amount offish processing immediately after the fish are caught. This includes gutting,
  bleeding, heading and clean the fish before stowing them into their tanks.

         The vast majority of longliners are ice boats. These ice boats have fish hold tanks that are
  filled with clean ice prior to fishing. As the tanks are filled with fish and the ice melts, any water
  is pumped out of these tanks via the bilge pump automatically. When the boats return to the
  seafood processing facility, the catch is offloaded and any ice is shoveled  out of the tanks
  directly overboard.

         The remaining longliners have refrigerated seawater (RSW) holding tanks. Ms. Behnken
  estimates longliners with RSW tanks make up about less than 10% of all longliners in Alaska.
  She added that it is very different than purse seiners, the majority of which have RSW tank
  systems. These vessels also discharge their fish hold wastewater directly overboard after
  offloading their catch to a shore side seafood processor.

         Ms. Behnken also confirmed that longliners almost always clean their tanks between each
  offload. Most use pressure  hoses with water to keep their tanks clean, but  some add mild
  detergents when needed. The soaps that are most commonly used are dish soap, biodegradable
  detergents, or a very mild bleach solution.  She said that the fishermen are  very careful to not use
                                             A-4

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Attachment A: Summaries of Information Gathered in Telephone Conversations


any detergents that could affect the food grade of the fish. In other words, only soaps they felt
comfortable using in a kitchen or for cleaning dishes.

       When asked about any exceptions to managing fish hold discharges, Ms. Behnken noted
that the Sitka Seafood Co-op has just started a new policy of collecting visibly "dirty" ice from
fish hold tanks. Most of the time the ice is allowed to be shoveled overboard, but if the ice
appears to be very bloody or contain significant fish guts and slime, the facility asks that the ice
be shoveled into totes (the same totes the fish  were offloaded in) and taken into the facility. She
was not sure how the facility then manages the ice, but speculated that they probably first
allowed the ice to melt and then sent everything through the facility's macerator prior to
discharged via their outfall. She also stated that this new activity was likely a result of trying to
keep their dock and shore clean and free of birds.
                                           A-5

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Attachment A: Summaries of Information Gathered in Telephone Conversations
*ERG
TELEPHONE CALL RECORD
Outgoing Call
Company Name: United Fishermen of Alaska
Name: Kathleen Wu
Project No.: 0256.03.001.004
Project Name: Vessels - Technical Support
Date: Aug, 122010
Time: 7pm
Contact Name: Mark Vinsel
Phone No.: 907-586-2820

DISTRIBUTION
Page 1 of 1

GENERAL SUBJECT : Information on the Fishing Industry
                      TOPICS DISCUSSED AND ACTION TAKEN

Mark Vinsel is the Executive Director of United Fishermen of Alaska, an umbrella organization
that represents 38 smaller fishing vessel associations in Alaska, such as District Fishermen
United, Alaskan Longline Fishermen's Associations, Alaska Trailers Association, etc. Thus their
members operate the entire range of fishing vessels and fish in all the fisheries.

As discussed in the 2009 comments provided on fishing safety (Attachment 1), there are about
10,000 permitted and active vessels in Alaska. 9,828 vessels ranged in size from 7 feet to 635
feet and included skiffs, gillnetters, purse seiners, trawlers, crabbing vessels, tenders, and
trailers. Of these vessels, many are equipped to fish several different species through out the year
by modifying their gear type. Gear type modification mainly involves changing on desk
equipment and other machinery. The following are some statistics included in the report.

Vessel Size Distribution
1.  2,009 vessels (20%) are 20ft or less;
2.  2,363 vessels (24%) are between 21ft and 29ft;
3.  4,096 vessels (42%) are between 30ft and 49ft;
4.  863 vessels (9%) are between 50ft and 79ft; and
5.  497 vessels (5%) are over 79ft.

Age of Vessels Distribution
1.      634 vessels are over 50 years old, built before 1959, (two are over 100 years old);
2.      463 vessels are 40 to 50 years old, built in 1959 - 1968;
3.      2,070 are 30 to 40 years old, built in 1969 - 1978;
4.      3,626 are 20 to 30 years old, built in 1979 - 1988;
5.      2,265 are 10 to 20 years old, built in 1989 - 1998;
6.      646 are less than ten years old; and
7.      4,395 (45%) are of 5 net tons or less and not currently required to be documented vessels.

Gear Types Distribution
                                          A-6

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Attachment A: Summaries of Information Gathered in Telephone Conversations
1.      54% operate one gear type;
2.      24% operate two gear types;
3.      11% operate three gear types;
4.      4% operate four gear types;
5.      2% operate 5 or more gear types;
6.      Two vessels are registered under 11 different gear types; and
7.      The remaining vessels did not specify gear type.

Mr. Vensel stated that larger vessels generally operate more gear types and have more deck
space to switch out equipment as needed.

Mr. Vinsel said that he was unsure about the distribution of vessels that have refrigerated
seawater (RSW) tanks or use ice tanks, but generalizations can be made. For example, almost all
purse seiners, tenders, and crabbing vessels have RSW systems, while hook and line and set-net
vessels use ice tanks. A vessel with an installed RSW system would not use the tanks as ice tanks
even if their gear type changed.

Mr. Vinsel stated that as far as he is aware, all vessels discharge their RSW tanks and ice tanks
directly overboard after offloading their catch. This includes any wastewater from tank cleaning
as well. I told him that the Sitka Co-op was actually accepting "dirty" ice from some of their
vessels. He said that he has never heard of this, but was not surprised to learn of voluntary
practices from more progressive communities. When I asked him which other communities he
would also consider progressive in Alaska, he stated that Cordova is considered more
progressive, but doubted they would have voluntary environmental practices similar to Sitka
because it is not a cruise ship community.

Mr. Vinsel also provided the following website http://www.cfec.state.ak.us/plook/, which has
additional Alaska vessel information and statistics. His instructions were to select the "Yearly
CSV" tab, select "Vessels" under File Type, and then select the year of interest. He said that this
method provides the most complete data sets.

Mr. Vinsel also offered some additional contacts, but they were all already on my contacts list.
                                           A-7

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Attachment A: Summaries of Information Gathered in Telephone Conversations
                           UNITED  FISHERMEN  OF ALASKA
                                                                    211 Fourth Street. Suile 110
                                                                    Juneau. Alaska 99801-1172
                                                                         (907) 586-2820
                                                                       (907) 463-2545 Fax
                                                                     E-Mail ulaOula-flsh.org
                                                                        www uta-ltsh org
                                     July 29, 2008
 Docket number USCG-2003-16158
 Attn: Rear Admiral Brian M. Salerno,
 Assistant Commandant for Marine Safety. Security and Stewardship
 U.S. Coast Guard
 By Fax: 202-493-2251
     United Fishermen of Alaska Comments on Advance Notice of Proposed
                Rulemaking for Commercial Fishing Vessel Safety
 A. Background on United Fishermen of Alaska
 United Fishermen of Alaska (UFA) is an umbrella association representing 37 commercial fishing
 organizations from fisheries throughout Alaska and its offshore waters. UFA passed a resolution
 in 2007 (attached), supporting the Commercial Fishing Industry Vessel Safety Advisory
 Committee, and the Commercial Fishing Vessel Safety Act of 1988 by which the committee was
 established, and encouraging member organizations to:
 1.       Strongly urge all members and fishermen to ensure that the required Coast Guard safety
 gear is onboard, is properly maintained, and crew are all instructed in its proper usage, where
 applicable.
 2.       Participate in the Coast Guard dockside exam program and maintain a current decal,
 where applicable.
 3.       Ensure that all crew participate  in regular hands-on emergency drills conducted by a
 certified drill instructor who is preferably a member of the crew, where applicable.
 4.       Ensure that new crewmembers be given a safety orientation addressing what to do in the
 event of emergencies and proper use of appropriate safety and survival equipment prior to getting
 underway.
 5.       Ensure that safety programs be regularly reviewed.

 The enactment by Congress of the Commercial Vessel Safety Act of 1988 and the work of the
 Commercial Fishing Industry Vessel Safety Advisory Committee has continued to improve the
 fishing industry safety record. The effectiveness of the safety measures and the committee have
 been remarkable — with nearly a fourfold drop in fishing fatalities since the measures went into
 effect  in 1992 (from statistics from Alaska Marine Safety Education Association).
                                           A-8

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Attachment A: Summaries of Information Gathered in Telephone Conversations
 B. Commercial Fishing Industry Vessel Safety Advisory Committee
 UFA supports the work of the Commercial Fishing Industry Vessel Safety Advisory Committee
 (CFIVSAC) and maintains regular communications with its current chairman. Jerry Dzugan. We
 reiterate the direction of the committee in stressing that for meaningful improvements in
 commercial fishing safety, regulators need to look more deeply into the topic than is indicated in
 the advance notice of proposed rulemaking.  The separation of fishing vessels into categories based
 solely on vessel length is not a meaningful way to address  fishing safety, and ignores the fact that
 there are hundreds of different fisheries conducted in our nation's waters, and each is unique.  We
 strongly advise that attention be applied to assessing risk by fishery, then working with  fishermen
 in fisheries that are shown to present a higher than normal  risk to fishermen. To continue forward
 without consideration for different fisheries is a scattershot approach that brings undue costs and
 burden to regulators and to fishermen, and is not a cost effective problem solving methodology for
 further improvements in fishing safety. We recommend that you first identify the problem areas of
 fisheries that show high levels of fatalities.  The Center for Disease Control National Institutes for
 Occupational Safety and Health (CDC-NIOSH) is in the process of long term studies on fisheries
 that will inform the Coast Guard in this direction.
 C. Risk by Fisheries in Alaska
 The Alaska Commercial Fishery Entry Commission regulates permits for Alaska state waters
 fisheries. A listing of fishery codes online at Intoi^iv •  . j-,.  -i ,   „  -  i>     .  ,        i-m
 shows 24 categories of fish species codes, 22 regulatory area codes, and  17 gear types altogether
 making for 325 different fisheries.

 In the timing of the current Advance Notice comment deadline, we were unable to obtain thorough
 data on safety and fatalities in Alaska's fisheries, but we were provided general data on salmon
 fisheries. From records of Alaska fishing fatalities provided by the Center for Disease Control
 National Institutes for Occupational Safety and Health, there were 34 fatalities incurred in Alaska
 salmon fisheries from 2000 - 2007.  To get an idea of the relative safety  of the different types of
 salmon fisheries, we have  estimated round numbers for crew to see how  the fatalities compare to
 total participants.  The results of this very preliminary assessment illustrate that there are
 significant differences in risks based on fishery. We encourage that this  kind of assessment take
 place to identify problems in fishing vessel safety, so that appropriate solutions can be targeted
 without undue costs in fisheries that do not share the risks that a particular solution addresses.

  Alaska Salmon Fatalities per total estimated participants, by gear type, 2000-2007
   Gear Type   Fatalities   Number of permitholders     Est. Crew    Total est. participants   Fatalities/participants
   Drift Gillnet     17              3911               5800             9711               0.175%
    SctGillnet     8              4505               4000             8505               0.094%
        Troll     4              3239               3200             6439               0.062%
        Seine     2              1422               5000             6422               0.031%

        Total     31             13077             18000           31077              0.100%

  Notes: Does not include 2 salmon tender fatalities and one salmon processor fatality
  Drift Gillnet estimated crew of 2 for Bristol Bay (4000) plus 1 for other areas (1800)
  Set Gillnet estimated crew of one per site.
  Troll crew estimated 1 per vessel
  Seine estimated crew of 5 for SE (2000) plus 3 for other areas (3000)
                                                 A-9

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Attachment A: Summaries of Information Gathered in Telephone Conversations
 D. Fishing Vessels in Alaska
 A listing of commercial fishing vessels registered in Alaska is available online at
 http://www.cfec.statc.ak.us/publook/other.isp. This listing provides valuable insight into the wide
 range of Alaska fishing vessels and raises doubts on the applicability of concepts contained in the
 advance notice of proposed rulemaking. We appreciate the intention of different safety
 requirements for different size vessels, but a seven tier categorization by vessel length, as shown in
 Table 4 in the Advance Notice falls short of meaningful differentiation of the safety needs in
 different fisheries. Differentiation using vessel size would cause some vessels within a fishery
 facing the same risks to have different regulations than another vessel. This seems appropriate in
 equipment common to all vessels such as the need for fire extinguishers - but other times it is not.
 More in depth risk assessment may indicate that stability regulations should be designed based on
 fishery more than vessel length, or a combination of the these and other factors.

 The lengths of commercial fishing  vessels registered in Alaska shows a wide range that may not be
 the  common perception:
  -9828 Commercial fishing vessels were registered in Alaska in 2007, ranging in length from 7 feet
 to 635 feet.
 -Over two thousand Alaska commercial  fishing vessels are of 20 feet or less in length.
 -Over two thousand are from 21 to 29 feet.
 -4,404 are from 30 to 49 feet
 -863 are from  50 to 79 feet
 -497 vessels are over 79 feet
                        AK State Registered Fishing Vessels 2007 - by Length
                              Over 79 feet. 497, 5%

                    50 lo 79 feel, 863,9%
              30 to 49 feet. 40<». 42%
                                                    20 fee! or less, 2009. 20'
                                                         21 to 29 fact. 2363. 24%
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Attachment A: Summaries of Information Gathered in Telephone Conversations
 E. Age of Alaska Fishing Vessels
 The wide range of age of fishing vessels in Alaska in an indication that the application of ABS
 classification is not feasible, even with a long phase in period:

 -634 vessels are over 50 years old. built before 1959, (two are over 100 years old).
 -463 are 40 to 50 years old, built in 1959-1968
 -2,070 are 30 to 40 years old, built in 1969 - 1978
 -3626 are 20 to 30 years old, built in 1979-1988
 -2265 are 10 to 20 years old, built in 1989 - 1998
 -646 are less than ten years old.
  - 4395 (45%) are of 5  net tons or less and not currently required to be documented vessels.
                            Alaska Registered Fishing Vessels 2007 - by Age
                              Age not listed in registration,
                                   124, 1%
                          50 years or older, 634.6%

                     40 to 50 years old. 463, 5%
Less than 10 years old, 646, 7%
            30 to 40 years old, 2070. 21%
                                                                  10 to 20 years old, 2265, 23%
                                             20 to 30 years old, 3626, 37%
 F. Stability Assessments and changes in deck gear
 It is also not easy to categorize fishing vessels by gear type. It is common practice for fishermen to
 fish in different fisheries with the same gear type, often changing deck gear multiple times through
 a fishing year.
 Understanding the concepts of stability assessment is vital to fishermen as they change deck gear,
 but a requirement for documentation of calculations for every combination of gear on board a
 vessel will become burdensome and unworkable for many fishermen.
                                                A-ll

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Attachment A: Summaries of Information Gathered in Telephone Conversations
 F. Stability Assessments and changes in deck gear  (continued)
 Of 9828 vessels, 4031 (41%) are registered to fish more than one gear type.
 215 vessels are registered to fish 5 or more gear types.
 Two vessels are registered to fish 11 different gear types.
                   AK Fishing Vessels 2007 - Number of Fishery Gear Type Endorsements
                      5 or more gear r>pes, 215,2%
                       4 (sear types. 393, 4°/,
Number not shown in
registration, 524,5%
                3 gear types, 1043, [19
          2geartjpes, 2380. 24%
                                                         1 gear type. 5273, 54%
 G. Fish Safe Website
 We appreciate the creation of the Fish Safe Website at www.fishsafe.info , and monitor it at least
 monthly and relay items of importance to Alaska fishermen to our email list of approximately 1500
 individuals. We have heard anecdotally that staff at U.S. Coast Guard headquarters for fishing
 vessel safety has been reduced and ask that you ensure that adequate staff resources to maintain
 and grow the site to retain its usefulness are intact.
 In particular in researching this topic, we found that a link for certified dockside examiners in
 Alaska was broken. This was reported to staff, and we were provided with a list of certified
 dockside examiners within the Coast Guard, but this does not include private individuals  that have
 also been certified. We  ask that the Fish Safe website include a comprehensive list of all certified
 examiners, and also include an up-to-date calendar showing all scheduled locations of courtesy
 dockside exams.
 H. Voluntary vs. Mandatory Dockside Safety Exams
 UFA encourages all skippers to participate in voluntary dockside exams, but this is not always
 feasible without undue costs. Although courtesy free dockside exams were conducted in more than
 65 Alaska ports, this does not cover all vessel home ports, and traveling to a port solely for a
 dockside exam would prove an economic hardship to many vessel owners.
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  Attachment A: Summaries of Information Gathered in Telephone Conversations
H. Voluntary vs. Mandatory Dockside Safety Exams (continued)
Rather than mandating dockside exams, we suggest instead more meaningful incentives for
participation.  The best incentive would be a reasonable expectation that the dockside exam would
prevent routine boardings without reasonable cause. According to Coast Guard News, April 29,
2008, "Fishermen operating vessels with recently-issued decals benefit by being less likely to have
to suspend fishing operations to accommodate an at-sea Coast Guard or Alaska State Trooper law
enforcement boarding."
Alaska fishermen commonly report this to not be the case, and many report being boarded more
than once in a fishing season even with a current decal displayed. The Coast Guard should have a
database that shows when courtesy exams were conducted rather than asking the vessel captain the
date.  Boardings of vessels while transiting or fishing interferes with fishermen's livelihoods, and
is unnecessary on vessels that have already undergone a recent dockside exam. Standard operating
procedures should instruct Coast Guard personnel to not delay or interfere with fishing vessels on
the water displaying recent safety exam decals without reasonable cause.
I. Voluntary vs. Mandatory Stability Training
While offering stability training during "offseasons" may make this more convenient for many, it
brings up the problem of providing training where fishermen live. Over 25 percent of Alaska
permitted fishermen live outside Alaska, some in every state of the U.S. We suggest that training
be available online, yet still this would not remove our concern that making these trainings
mandatory would present a logistical difficulty and cost to many who do not  have internet access
or live in areas not served with Stability Training classes.  The CF1VSAC recommended that
stability training for vessels over 30ft to be vessel specific. This would be extremely expensive for
operators and vessels that only have one or two fishermen located in remote rural communities.
J. Mandatory Safety Equipment & Survival Craft
The listing above of the length of fishing vessels in Alaska illustrates the impracticality of
imposing requirements on all vessels for survival craft and embarkation stations, as very small
vessels have no room for carrying a survival craft and no need for a designated embarkation
station.

It is also important to note that purse seine fisheries are conducted with a skiff that tows the seine
net from, and back to the primary vessel. In purse seine fisheries the seine skiff should not need to
duplicate the safety equipment that is carried on board the seine vessel.

Embarkation stations are impractical on vessels less than 79 to 100 ft range. Vessels smaller than
this size are well known to the individuals onboard the vessel. Designating an embarkation station
and providing lighting and boarding ladder on only one side of the boat may hamper the ability to
use the safety equipment if the vessel is listing to that side. If all the training and drills are done
specific to it being done in only one way and place, in the case of an emergency the individual
might not be able to react as quickly as needed.
K. "Safety Regulations" currently in place that do not address safety
Regulations that dictate what a fisherman may do with fish once caught, such as the prohibition of
filleting on board, have nothing to do with safety and should be eliminated.
                                                 A-13

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     Attachment A: Summaries of Information Gathered in Telephone Conversations
 L. Documentation - Trip Departure Report
 Fishing is often an exploratory venture and fishermen need to be able to seek fish, which may or
 may not be found where expected. The requirement of filing a departure report with a vessel's
 owners before leaving on a fishing trip is an unnecessary burden and should be left to the
 discretion of the owner of the vessel. Most vessels under 79 ft in Alaska are owner-operated,
 which raises the question of who will these owners file a departure report with.  Many fishermen
 plan to leave but then wait for a day or two or anchor up and wait for the weather to clear before
 fishing. Although recordkeeping of safety activities may be required for enforcement purposes, we
 do not  see a clear safety benefit to the filing of trip reports.
 M. Other Comments
 Commercial fishing is a challenging occupation, with high operating overhead and no guarantee of
 income. Any regulations in the name of safety that cost fishermen money or usurp fishing time
 have a negative effect on fishing income and the ability to provide optimal safety equipment. All
 fishermen understand the dangers of fishing and the need for preventative vessel maintenance and
 working safety equipment, and appreciate a common sense approach that allows economically
 viable fishing.

 Although we understand that federal fisheries policy is not within the jurisdiction of the Coast
 Guard, it plays a huge role in fishing safety. We point out that there have been no crew deaths in
 the Alaska Bering Sea crab fishery since major regulatory changes were implemented beginning in
 2005. The high number of casualties that occurred in this fishery prior to these changes is
 referenced in the Advance Notice as a prime motivator for stability training - but that is not the
 only solution:
      "In 1999, due to the high number of deaths in the Alaska/Bering Sea crab fisheries, the Coast Guard and the
      Alaska Department of Fish and Game began a program to analyze crab-vessel loading when stability
      instructions are provided on board the vessel prior to departure. Despite having stability information on board,
      overloading still occurred in some instances. Factors contributing to this, as confirmed in casualty
      investigations, are that the calculations often were not understood by operating personnel and stability
      information was often not updated after changes were made to the vessel, which invalidated the instructions
      provided..."

• The Coast Guard should not discount the fact that major fishing safety improvements may occur in
 regulatory areas outside of Coast Guard jurisdiction. UFA supports the regional fishery
 management council process that allows a forum for fishermen to work collectively to solve
 problems,  through which changes in the Bering Sea Crab fishery were implemented.
 N. Timing of Advance Notice and Comment Period
 Many Alaska fishermen fish in all months of the year, but virtually all of Alaska's fishermen make
 the most of warmer summer months and the timing of salmon runs to fish throughout the summer.
 The timing of your request for comment in spring and early summer, and the comment deadline of
 July 29 will prevent many Alaska fishermen from providing comment on the Advance Notice of
 Proposed Rulemaking.

 We have been notified by Coast Guard and fishing vessel safety contacts that the comment period
 is to be extended though December 2008, and we support this extension. The extension of the
 comment period will allow fishermen to provide comment, and will allow UFA's member
 organizations to discuss this important topic for further comment.
                                                   A-14

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          Attachment A: Summaries of Information Gathered in Telephone Conversations
    O. Recognition of Exemplary Service by U.S. Coast Guard in Alaska Fishing Safety
    In closing, we appreciate the attention by the Coast Guard to fishing vessel safety, and especially
    the exemplary work of the many Coast Guard personnel who make continued noble efforts in
    responding to emergencies that arise in Alaska's fisheries.

    Thank you for consideration of these comments.


    Sincerely.
    Joe Childers                                                    Mark Vinsel
    President                                                       Executive Director
                                               MEMlERIffiGANJZAIIONS
              Alaska Crab Coalition * Alaska Independent Tendermesrs Association • Alaska Longiine Fishermen's Association
 Alaska Scallop Association • Alaska Trotters Association - Alaska Whitefish Trawlers Association • Armstrong Kela • At-sea Processors Association
      Bristol Bay Reserve • Bristol Bay Regional Seafood Development Association • Cape Barnabas Inc. * Concerned Area "fVT Fishermen
 Cook Inlet Aquaculture Association * Cordova District Fishermen United * Crab Group of independent Harvesters • Douglas Island Pink and Churn
   Fishing Vessel Owners Association ° Groundftsh Forum • Kenal Peninsula Fishermen's Association ° Kodiak Regional Aquacuiture Association
       North Pacific Fisheries Association • Northern Southeast Regional Aquaculture Association - Petersburg Vessel Owners Association
Prince William Sound Aquaculture Corporation * Purse Seine Vessel Ovwier Association * Seafood Producers Cooperative * Sitka Herring Association
     Southeast Alaska Fisherman's Alliance • Southeast Alaska Regional Dive Fisheries Association * Southeast Alaska Seiners Association
   Southern Southeast Regional Aquaculture Association * United Catcher Boats • United Cook Inlet Drift Association • United Salmon Association
           United Southeast Alaska Gillnetters • Vaidez Fisheries Development Association • Western Gulf of Alaska Fishermen
                                                                 A-15

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      Attachment A: Summaries of Information Gathered in Telephone Conversations
           TELEPHONE CALL RECORD

        Outgoing Call	
Company Name: West Coast Seafood
Name: Kathleen Wu
                                               Project No.: 0256.03.001.004
                                               Project Name: Vessels - Technical Support
Date: Aug, 202010
Time: 2pm
Contact Name:  Rod Moore

Phone No.: 503-227-5076
                                  DISTRIBUTION

                                  Page _1_ of _1
GENERAL SUBJECT : Information on the Fishing Industry
                        TOPICS DISCUSSED AND ACTION TAKEN

            Rod Moore is a representative of West Coast Seafood, a trade association that
      represents 12 seafood processors located in Washington, Oregon, and California. The
      seafood facilities process several species of tuna, 12 species of ground fish, crabs,
      salmon, sardines, whiting, and swordfish year round.

            Mr. Moore was unsure of the type of vessels or the lengths of the fishing boats but
      offered the following generalization based on his knowledge of the fishing industry.
      Almost all crabbing vessels use live tanks that circulate seawater to keep the crabs alive.
      Tuna, ground fish and swordfish are generally flash frozen onboard or kept in ice tanks.
      Sardines, however, are fished most frequently on vessels with RSW systems or ice slurry
      tanks.

            Mr. Moore is unaware of any seafood processors, whether they are part of his
      association or not, that collect fish hold effluent or used ice from these vessels. He
      confirmed that all fishing vessels discharges their fish hold effluent immediately
      overboard following offloading at the seafood processor. Any fish hold cleaning
      discharges are managed the same way. He is unaware of any other management processes
      for fishing vessels or seafood processors. He stated that the processors he represents are
      generally located in secluded or  rural areas where the local sewage or POTW systems
      would not have the capacity to handle that volume of waste. I mentioned that San
      Francisco Bay may have a fish hold offloading site where vessels can discharge their fish
      hold effluent directly into the San Francisco sewage system. Mr. Moore stated that he is
      unaware of this service offered by the Bay, but he is also unfamiliar with the processors
      in that area. However, if it would not surprise him if San Francisco's sewer system had
      the capacity to manage fish hold effluent from several vessels a day.
                                            A-16

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       Attachment A: Summaries of Information Gathered in Telephone Conversations
    GLEC
Great Lakes Environmental Center
            TELEPHONE CALL RECORD

        Outgoing Call	
 Company Name: San Francisco Port Authority
 Name: Michelle Moore
                                                Project Name: Vessels - Technical Support
Date:  Aug, 132010
Time: l:30pm
Contact Name:  John Mundy

Phone No.: 415-274-0256
                                  DISTRIBUTION

                                  Page  1  °f _JL_
 GENERAL SUBJECT : Information on new Pier 45 system for capture of all water and ice discharged with catch	

                         TOPICS DISCUSSED AND ACTION TAKEN

      The Port Authority in the City of San Francisco re-engineered the pier and put in a pump
      system that captures all water and waste that had previously washed into the bay.  There
      are 15 seafood processors on Pier 45 and their operations have had sewer service in place
      for some time. After being screened for solids, which are sent to be composted, the
      wastewater from these processors is routed to the city sewer.  Water discharged onto the
      Pier deck from fish holds, etc. used to wash back into the bay. This water is now
      captured by the new design. The seafood processors have permits and if they were to get
      sued for allowing gurry (the W coast term for bail water?) to go into the bay, they could
      get sued, and their landlord, the City of SF, would get sued as well.  Three pump-out
      manifolds were installed for pumping out fish gurry. He said the worst offenders have
      been the herring operations because they just want the roe so they don't care about the
      condition of the fish.

      John is retiring today. If we have additional questions, we should contact Jay Ach (415-
      274-0562).
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      Attachment A: Summaries of Information Gathered in Telephone Conversations
           TELEPHONE CALL RECORD

        Outgoing Call	
Company Name: Western Fishboat Owners Association
Name:  Kathleen Wu
                                               Project No.: 0256.03.001.004
                                               Project Name: Vessels - Technical Support
Date: Aug, 11 2010
Time: 4pm
Contact Name:  Wayne Heikkila

Phone No.: 530-229-1097
                                  DISTRIBUTION

                                  Page _1_ of	1_
GENERAL SUBJECT : Information on the Fishing Industry
                        TOPICS DISCUSSED AND ACTION TAKEN
             Wayne Heikkila is a representative of the Western Fishboat Owners Association.
      He mainly works with trailers and hook-and-line vessels (longliners) that fish in the
      Pacific Ocean and offload along the US West Coast. These vessels primarily fish for
      Albacore tuna, salmon, and a variety of crabs throughout the year.

             About 50% of vessels use dry blast freezing systems. These systems have no fish
      hold discharges but do occasionally need to be cleaned between seasons. Mr. Heikkila
      stated that the cleaning is similar to defrosting a refrigerator and any water or
      condensation is discharged overboard. These dry blast vessels are similar to the trailers in
      the Gulf Coast used to catch  shrimp, but used exclusively in the Pacific for tuna. The tuna
      season generally lasts from June to late October, but there is some amount of fishing
      occurring as far as American Samoa during other parts of the year. The fish are caught
      and frozen whole immediately with no processing on board the vessels. The reason for
      this is that tuna tend to be very clean fish and are delivered whole because the industry
      prefers that all the processing to be done at the processing plant closest to where the fish
      is ultimately consumed. The  only processing ever performed on board is limited to gill
      bleeding the tuna.

             About 40% of the vessels use refrigerated seawater/recirculated sea water/brine
      systems. The majority of these vessels are used for crabbing. The remaining 10% of
      vessels use ice tank systems  and are used primarily for salmon. All fish hold tanks on
      these vessels discharge their  effluent directly overboard following the offload of their
      catch. This includes any fish hold tank cleaning activities as well.

      Mr. Heikkila also provided the following contacts for information gathering purposes:

             Moore, Mr. Rod
             Executive Director, West Coast Seafood
             Processors Association
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Attachment A: Summaries of Information Gathered in Telephone Conversations
      1618SWFirstSt, Ste318
      Portland, OR 97201
      Telephone: 503-227-5076
      Fax: 503-227-0237
      Email: seafood@integra.net

      Marchand, Jr., Mr. Pierre
      Processor
      President, Jessie's Ilwaco Fish
      Company
      PO Box 800
      Ilwaco, WA 98624-0800
      Telephone: 360-642-3773
      Fax: 360-642-3362
      Email: pierrem@ilwacofish.com

      Pleschner-Steele, Ms. Diane
      Executive Director, California Wetfish
      Producers Association
      PO Box 1951
      Buellton, CA 93427
      Telephone: 805-693-5430
      Fax: 805-686-9312
      Email: dplesch@earthlink.net

      Alverson, Mr. Robert
      Fishing Vessel Owner's Association
      4005 - 20th Ave W, Room 232
      Seattle, WA 98199-1290
      Telephone: 206-283-7735
      Fax: 206-283-3341
      Email: robertalverson@msn.com

      Fricke, Mr. Douglas
      WA Trailer Assoc
      Boat Seafoods
      PO Box 306
      Hoquiam, WA 98550
      Telephone: 360-580-3027
      Fax:360-538-0466
      Email: dfricke@techline.com
                                    A-19

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